SAF mandate ambitions stall as policy design, competitive disadvantage and MRV complexity deter smaller nations

A commentary by AirAsia's Yap Mun Ching, published on 2 September 2026, argues that sustainable aviation fuel adoption is falling well short of international targets, with real-world uptake tracking closer to the International Civil Aviation Organization's pessimistic scenario of a 15% contribution to required emissions reductions by 2050, rather than its optimistic projection of 55%.

The commentary states that meaningful SAF uptake has so far been concentrated in the United States and Europe, both driven by aggressive public policy, while several countries that announced SAF mandates elsewhere have retreated from or delayed them. Japan cut its target from a 10% SAF blend by 2030 to just 1%. Singapore, which opened what it described as the world's largest SAF refinery in 2023 and announced a levy from 2026, has pushed implementation back by one year. Brazil has set a 1% SAF emissions reduction mandate from 2027 but lacks sufficient domestic production capacity and must rely on international sourcing.

The commentary identifies three categories of structural obstacles for smaller nations: the technical expertise required to design a mandate, the competitive disadvantage a mandate creates for domestic carriers and airports, and the multiplying complexity of monitoring, reporting and verification (MRV) regimes. On the second point, it estimates a Southeast Asian hub airport with a 1% SAF mandate could see long-haul carriers reroute to a neighbouring non-mandated hub, citing a cost difference of between US$30 and US$40 per passenger. On the third, it notes EU-based carriers meet three MRV requirements — CORSIA, ReFuelEU and EU ETS — to operate across 27 countries, whereas an intra-regional Southeast Asian airline could face at least seven distinct MRV regimes if five of the region's 11 nations introduce standalone mandates. It also notes that SAF batch verification for CORSIA eligibility currently takes six to eight months per batch.

Singapore's SAF levy development, managed by the designated entity SAFCo, required multiple consultants to design accounting systems, emissions standards, certification guidelines and MRV procedures. ICAO's Third Conference on Aviation and Alternative Fuels (CAAF/3), held in November 2023, adopted biofuel blending targets that the commentary says would need to be aligned with the existing CORSIA framework.

The commentary frames Japan's, Singapore's and Brazil's retreats not as isolated policy reversals but as symptoms of a shared structural problem: designing a SAF mandate from scratch demands expertise spanning aviation operations, fuel production and climate accounting that smaller countries without existing climate legislation frameworks do not readily have.

It also argues that any single country's mandate creates an uneven playing field on shared routes, since carriers based there absorb costs that competitors from non-mandated countries avoid — a particular risk for export-led and tourism-dependent economies where higher aviation costs feed through to broader trade and travel flows.

The pattern described here — ambitious targets announced, then diluted or delayed once implementation costs and technical burdens become clear — shows how climate mandates in aviation behave differently from unilateral rules in most other transport sectors: because routes are shared and competitive, a mandate's cost lands unevenly unless matched by peer jurisdictions.

The commentary's own numbers illustrate the mechanism: a per-passenger cost gap of US$30 to US$40 is large enough to redirect long-haul connections toward a neighbouring hub, and a jump from three MRV regimes across a 27-country bloc to seven-plus regimes across a handful of Southeast Asian mandates shows how fragmentation, not the mandate itself, drives compliance cost. This is why the commentary points to regional coordination — common mandate design, quantum, timelines and mutually recognised certification — as a way to blunt both the competitive-disadvantage and MRV problems at once, while conceding that ICAO-level global alignment would be more comprehensive but slower.

What happens next depends on whether ASEAN or a similar bloc actually converges on shared mandate terms before more members follow Japan, Singapore and Brazil into unilateral, and diluted, commitments — and on whether CAAF/3's blending targets get reconciled with CORSIA in a way that gives smaller markets a common reference point rather than a fresh set of rules to build alone.