ReFuelEU aviation requires ongoing operational monitoring. Discover how FL3XX helps aircraft operators manage fuel uplift, data and reporting.
ReFuelEU aviation may come with an annual reporting deadline, but compliance is built one flight at a time.
Aircraft operators in scope need accurate planned-fuel data, reliable records of what was actually uplifted, supporting evidence when circumstances affect local fuelling, and a clear view of how they are performing across the Union Airports they use. All of that information eventually has to come together in a verified annual submission.
For many operators, that's where the difficulty starts. The information needed for ReFuelEU rarely sits neatly in one place. It may be spread across flight plans, operational records, fuel receipts, invoices, SAF documentation, and spreadsheets owned by different teams.
Martina Becher, sustainable aviation consultant at ETS & More, has seen those challenges first-hand.
“Unlike EU ETS, ReFuelEU requires coordination and action from various departments and must be applied on each and every flight departing from a Union Airport. It cannot be ‘corrected’ retroactively if the regulation hasn’t been applied correctly throughout the year.”
That makes ReFuelEU much more than a reporting task for the sustainability or compliance team. Dispatch, flight crews, operations and management all have a part to play - and operators need to know how they are tracking before the year is over.
ReFuelEU aviation is intended to increase the use of sustainable aviation fuels and reduce avoidable fuel tankering in European aviation.
For aircraft operators in scope, one of the main requirements is to uplift at least 90% of their annual aviation fuel requirement at each applicable Union airport.
The key word is annual. The 90% threshold is assessed across the reporting period at each airport, rather than flight by flight. A lower uplift on one departure does not automatically mean an operator has failed to comply. But every departure contributes to the final position at that airport.
For crews and operational teams, that can require a change in thinking. Local fuel uplift has to become part of the wider compliance picture, while safety and operational requirements still come first.
Martina says this has been one of the biggest adjustments for operators.
The regulation, she explains, has “a major impact on the freedom of the pilots to decide how much fuel to take or not.”
Getting crews on board is therefore essential.
“This is absolutely key as without their support, it is impossible to apply this regulation correctly.”
Preparing the final ReFuelEU report is only the last stage of the process.
The underlying information is created throughout the operation. Planned fuel may come from an operational flight plan. Actual uplift may be entered after a flight, supplied by a fuel provider or reconciled later against an invoice. Weather, diversions, airport conditions, fuel availability, and safety considerations can all affect what happens on a particular departure.
SAF brings its own documentation requirements, with information such as quantities, batch details, sustainability characteristics and supporting records potentially needed later in the reporting and verification process.
Martina says the fragmentation of this data has been one of the biggest practical problems.
“In most cases, the required data and information for reporting is stored in different software systems. This must be extracted and consolidated at the end of the year, which for the initial year was not possible for all operators.”
If that process is managed mainly through spreadsheets, gaps can remain hidden for months. Planned and actual fuel figures may not match. An explanation for an unusual uplift can be separated from the flight it relates to. A missing field may only be noticed when somebody starts preparing the annual report.
By then, finding out what happened can be much harder than recording it correctly at the time.
For many operators, ReFuelEU still means Excel - a process Martina is more than familiar with:
“The biggest effort was to extract the safety fuel figures from flight plans and then merge them with the ops software to insert it into the final report.”
That's before dealing with supporting evidence for flights where the expected local uplift did not happen, or checking the final dataset for inconsistencies.
Those tasks may be manageable for a small number of flights. As the reporting population grows, however, so does the amount of manual work - and the opportunity for errors.
For smaller operators, there may simply not be a dedicated team available to spend weeks reconciling fuel data. In this case, software can at least take much of the administrative burden away.
“If a software can be used that already provides the data that must be added into the final report in the correct reporting format, it will help any operator, but definitely smaller ones as they don't have the resources to handle this topic.”
As well as this, ReFuelEU has a deadline of 31st March every year: the same as for EU/CH/UK ETS and CORSIA compliance. Having three regulations with the same annual deadline puts many operators, who will have to comply with all three, under a lot of pressure if they're still relying on spreadsheets. Martina continues:
"Therefore, a software solution, where the preparation of the report is partly automated and already delivering high quality data, can add a lot of value."
FL3XX takes a different approach from building a separate compliance spreadsheet alongside the operation.
Relevant fuel information can be maintained with the flight itself, in the same system operators are already using to plan, operate and complete their flights.
Planned fuel, actual uplift and supporting fuel information can all be associated with the relevant flight. FL3XX’s flight-planning integrations make this process much faster. With ForeFlight, for example, planned fuel data can be brought into FL3XX at the press of a button rather than entered manually for every flight - a significant time saver when ReFuelEU data needs to be captured across an entire calendar year.
It sounds like a small change, but it removes a lot of the work that otherwise appears later.
Instead of taking a value from a flight plan, copying another from an operations system and then trying to match both with a fuel receipt months afterwards, the records simply stay connected to the flight.
Operational context can be kept there too. If weather, holding, airport conditions, safety requirements, or another legitimate reason affected fuelling, the explanation can be recorded while the flight is still fresh in people’s minds.
Because the uplift requirement is calculated across the year, operators also need an airport-level view.
FL3XX shows how the operator’s fuel-uplift position is developing across the applicable Union Airports it uses, with status indicators making it easier to see where attention may be required.
Martina highlights the value of being able to see that quickly.
“Through the coloring scheme, it's very clear at first glance which airports require attention and which airports are fine.”
That's particularly useful for airports an operator visits frequently.
A single quick turnaround with little or no local uplift may not be a concern if the cumulative position at that airport is healthy. At another airport, the same operational decision may deserve a closer look.
Having that visibility during the year gives teams a chance to investigate what is happening. Sometimes the issue is operational. Sometimes it's simply missing or incomplete data.
Either way, it's better you find out sooner rather than later.
An airport-level result is useful, but it only tells part of the story. FL3XX also allows operators to review the flights contributing to that result.
This matters because an unusual percentage does not automatically point to poor operational practice. A record may be incomplete, a flight may have diverted, or local fuel may not have been available. Weather or other safety considerations may also have changed the original plan.
Being able to move from the airport result to the flights behind it makes it much easier to understand whether there is a genuine operational issue, a legitimate exception or simply a data-quality problem.
For compliance teams, it also provides a much clearer path to the supporting evidence if the result later needs to be explained to a verifier.
This is one of the areas where Martina sees the clearest benefit from FL3XX.
“As FL3XX does this automatically, the manual merging and sorting process is no longer required, which massively helps!”
There will still be review work to do. Operators remain responsible for checking their data, resolving exceptions, and making sure the information submitted is complete and accurate. The difference is that they are no longer starting from a collection of unrelated datasets.
Much of the information has already been gathered during the operation, which also makes it easier to spot missing or inconsistent records while there is still time to investigate them properly.
SAF reporting can add another collection of documents and data points to the process.
Depending on the reporting circumstances, operators may need information covering the supplier, fuel quantity, batch number, eligible-fuel category, feedstock, lifecycle emissions, and how the fuel has been treated under applicable schemes.
FL3XX provides a structured place to maintain relevant SAF information and supporting records. This can include fuel quantity and batch data, feedstock and lifecycle-emissions information, claimed or unclaimed quantities, comments, and attachments.
This is mainly about keeping the evidence organised and accessible.
FL3XX does not determine whether a particular fuel is eligible or replace the role of the verifier. The aircraft operator and its appointed verifier remain responsible for validating the evidence and making sure claims are treated correctly.
When the reporting period closes, operators still have to bring together their covered flights, planned fuel requirements, actual uplift, and supporting information in the required structure.
FL3XX helps prepare that data from the operational records built up during the year.
Operators can review the relevant airport and flight totals and prepare structured information for the EASA-aligned reporting process, rather than rebuilding the entire reporting population from scratch.
The data then goes through the operator’s own reconciliation and review process before being provided to the appointed independent verifier and ultimately submitted through the relevant regulatory channel.
FL3XX isn't a one-click compliance button. What it does is remove much of the repetitive work that makes getting to the verification stage unnecessarily difficult.
The FL3XX ReFuelEU functionality grew out of a collaboration between FL3XX, ETS & More, and FAI.
Work began in July 2025, with FL3XX and ETS & More collaborating on ReFuelEU as well as EU, Swiss and UK ETS, CORSIA, and non-CO₂ requirements.
FAI then tested new functionality from the operator side and provided feedback on how it worked in day-to-day operations.
That practical involvement was important. Regulations describe what has to be achieved, but they cannot always show where the friction will appear inside an operator’s daily workflow.
When we asked Martina what working directly with an operator revealed that would have been difficult to understand from the regulation alone, her answer was very simple:
“The real, daily and operational difficulties.”
Those difficulties have shaped the way ReFuelEU is handled in FL3XX.
The focus on local uplift can also create the wrong impression if it's discussed without operational context.
ReFuelEU is intended to reduce avoidable tankering. It does not override an operator’s fuel policy, a crew’s safety responsibilities, or other operational requirements.
There will always be flights where carrying additional fuel is the right decision. Weather, congestion, diversions, fuel availability, and airport conditions are just some of the reasons why.
Good ReFuelEU monitoring should not put pressure on crews to avoid carrying fuel they need. It should make it easier for the operator to understand what happened and keep the evidence that explains it.
Martina recommends putting the foundations in place early:
For Martina, the first months are especially important.
“Closely check that the regulation is applied correctly for the first months as it takes time until people digest the rules.”
Her advice for operators based outside the EU is equally straightforward:
“Implement a software solution that's providing you with a ReFuelEU report, as this will help to stay on top of this complex regulation and keep compliance as simple as possible.”
The hardest part of ReFuelEU isn't calculating a percentage at the end of the year; it's making sure the underlying information is complete, accurate, and easy to trace back to the operation that created it.
FL3XX helps operators keep that work closer to the flight itself: planned fuel alongside actual uplift, airport-level monitoring alongside the flights behind it, and supporting evidence alongside the operational decisions it relates to.
That gives compliance teams fewer spreadsheets to reconcile, and gives operational teams earlier visibility when something needs attention.
For a regulation that cannot sensibly be managed only once a year, that makes a considerable difference.
Contact us to see how FL3XX can simplify your ReFuelEU monitoring and reporting workflow.
Aircraft operators in scope are generally required to uplift at least 90% of their annual aviation fuel requirement at each applicable Union airport.
The percentage is calculated across the reporting period at each airport, rather than against every individual flight.
Every departure contributes to the operator’s annual position.
Regular monitoring makes it easier to spot missing data, unusual uplift patterns or airports that may require closer attention while the underlying flights and supporting information are still easy to investigate.
No. Safety and applicable operational requirements still come first.
There may be legitimate reasons for carrying additional fuel or uplifting less locally than planned. Operators need to keep the appropriate operational context and supporting evidence when those circumstances arise.
Flight management software can keep planned fuel, actual uplift and supporting information connected to the relevant flights, while giving operators an airport-level view of how their position is developing.
It can also reduce the amount of manual consolidation needed when preparing data for verification and annual reporting.
No. FL3XX supports the capture, monitoring, review and preparation of information relevant to ReFuelEU aviation. Operators remain responsible for determining their regulatory scope, maintaining the appropriate methodology, checking the accuracy and completeness of their data, appointing an independent verifier and completing the required submission.
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