Brazil's ANAC Launches Public Consultation on SAF Regulations Following Issuance of Decree No. 13,094
Why It MattersThe rules push Brazilian air operators toward a book-and-claim SAF compliance system, tying mandatory emissions cuts to tradable certificates rather than physical fuel delivery.
Brazil's National Civil Aviation Authority (ANAC) has opened a public consultation on draft regulations for Sustainable Aviation Fuel (SAF), following the publication of Decree No. 13,094 on August 12, 2026. The consultation remains open until October 1, 2026.
The decree regulates ProBioQAV and sets operational rules for the production, certification, trading, and oversight of SAF, alongside mandatory greenhouse gas emissions reduction targets imposed by the Fuel of the Future Law (Law No. 14,993/2024) on air operators running domestic flights. Under the draft resolution, the rules apply to any operator emitting 10,000 tonnes of CO₂ or more in a year and certified under Brazilian Civil Aviation Regulation (RBAC); such operators must submit an Emissions Monitoring Plan to ANAC by October 31 of the relevant year and file an annual Emissions Report.
To meet the mandatory annual targets — starting at 1% from January 1, 2027, and rising to 10% by January 1, 2037 — operators must retire SAF Sustainability Certificates (CS-SAF), a book-entry instrument tied to the volume or mass of SAF sold domestically and tradable separately from the physical fuel under a book-and-claim model. All SAF sold in Brazil for domestic and international flights must be linked to a CS-SAF valid for 18 months, and imported SAF must meet CORSIA certification requirements.
The decree bars the issuance of CBIOs for SAF production to prevent double-counting, though operators may still use CBIOs as an alternative compliance mechanism within limits: combined alternative mechanisms may not exceed 5% of the annual target, with transitional caps of up to 15% in 2027 and 2028 and up to 10% in 2029. ANAC will oversee compliance, operators must complete CS-SAF retirement by January 31 of the following year, and ANAC and the National Petroleum Agency (ANP) must issue complementary regulations, including the National SAF Certification Program, by December 18, 2026.
