SAF Mandates by Country: A Developer's Comparison

10 min read · Oct 22, 2026 · By Alex

In essence, SAF mandates are government rules that require a minimum share of sustainable aviation fuel in the fuel supplied or used in a country or region. However, they are not all the same tool. Some place the obligation on fuel suppliers. Others place it on airlines. A third group raises money through a levy instead. For a developer, the difference decides who signs your offtake. Overall, this guide compares the SAF mandates that matter for a Southeast Asia project, from Brussels to Seoul.

In short

Most important, a mandate, an incentive and a levy are three different tools with different revenue effects.
After all, the obliged party and the penalty matter more than the headline percentage.
By comparison, the EU’s ReFuelEU Aviation is the reference case. It combines a supplier obligation, rising shares and a fine written into the regulation.
In addition, Singapore uses a levy on passengers rather than a supplier duty. As a result, the state becomes the buyer of record.
Moreover, Japan and South Korea have drafted supplier obligations for FY2030 and 2027. Neither had published a penalty level when I checked.
Therefore, the table below carries a date. I last opened every row on 3 November 2026.

SAF mandates: mandate, incentive or levy

Mandate: a legal minimum share. As a result, it creates volume demand, and the buyer is whoever must comply.
Incentive: a subsidy, credit or tax measure. Unlike a mandate, it narrows the price gap but creates no duty to buy.
Levy: a charge on tickets, cargo or fuel. In effect, it creates a pool of money rather than a duty on a supplier.

According to IATA, a mandate should arrive only where market conditions, capacity, infrastructure and supportive policy are in place. Otherwise, the scheme risks supply constraints and cost burdens on airlines and consumers. Moreover, IATA estimates that SAF could deliver up to 65 % of the emissions cut aviation needs by 2050. At the same time, SAF remains a small share of global jet fuel today.

For a project, the three tools produce three cash flows. A mandate produces a compliance buyer with a deadline. An incentive produces a subsidy that usually expires. A levy produces a central purchaser holding other people’s money. Consequently, I read the design before I read the percentage. Above all, I want to know who can be sued for not taking the fuel.

SAF mandates comparison table

Last checked: 3 November 2026. I opened each row at the source named under the table. Consequently, the table shows status as well as target.

Jurisdiction	Tool	Obliged party	Target and year	Penalty and status
European Union	Mandate (ReFuelEU Aviation)	Fuel suppliers; airlines for uplift and reporting	2 % in 2025, 6 % in 2030, 20 % in 2035, 34 % in 2040, 42 % in 2045, 70 % in 2050, plus a synthetic fuel sub-target rising to 35 % in 2050	Fine of at least twice the price gap on the missing volume; in force since 1 January 2025
United Kingdom	Mandate with tradable certificates and a buy-out	Fuel suppliers owning and supplying 15.9 TJ or more of aviation turbine fuel a year	2 % in 2025, 10 % in 2030, 22 % in 2040, held at 22 % after that	Buy-out price, civil penalties and certificate revocation; in force since 1 January 2025
Singapore	Levy funding central procurement	Passengers, cargo shippers and general aviation, collected by carriers as a separate fare line	1 % SAF uplift target from 2027, then 3 % to 5 % by 2030 depending on global supply	No supplier penalty; the levy is the instrument. Passengers from 2027, cargo from 2028

SAF mandates in Asia: Japan, Korea, Indonesia and Thailand

Jurisdiction	Tool	Obliged party	Target and year	Penalty and status
Japan	Supply obligation (proposal)	Jet fuel suppliers at seven airports, including Narita and Haneda	1 % of supply volume in FY2030, 3 % in FY2031, 5 % in FY2032 to FY2034, international routes only	Proposal of 23 July 2026; no penalty level published
South Korea	Blending mandate	Fuel suppliers and airlines on international departures	1 % in 2027, 3 % to 5 % in 2030, 7 % to 10 % in 2035, international departures	Penalties provided but initially deferred; up to 20 % of a year’s duty may move to the next three years
Indonesia	Blending mandate	Fuel business entities in the distribution chain	1 % in 2027 and 2028, 5 % in 2029 and 2030, initially at two major airports	Penalty not published in the decree I read; rollout conditional on feedstock, funding and infrastructure
Thailand	Fuel specification plus phased blend	Fuel suppliers at production and sales points	1 % in 2026, 1 % to 2 % in 2027 to 2029, 3 % to 5 % in 2030 to 2032, 5 % to 8 % from 2033	No penalty yet; the first phase runs on voluntary commitments signed as memorandums of understanding

Two rows deserve a warning. In Japan, the obligation is still a proposal from METI and MLIT. Therefore, a lender should treat FY2030 as a plan and not as law. In Thailand, the standards took effect on 1 January 2026. Nevertheless, the government described SAF use as voluntary at first, so the percentage exists without an enforceable duty. By contrast, the EU and UK rows are live obligations with a price for missing them.

SAF mandates in the European Union: the shares

ReFuelEU Aviation, Regulation (EU) 2023/2405, applies from 1 January 2025 to fuel suppliers at Union airports. In practice, the shares sit in Annex I rather than in a national plan. The minimum share of SAF is 2 % from 2025, 6 % from 2030, 20 % from 2035, 34 % from 2040, 42 % from 2045 and 70 % from 2050.

Moreover, a sub-target for synthetic aviation fuels runs inside those numbers. It starts at an average of 1.2 % over 2030 and 2031 and reaches 35 % in 2050. Consequently, SAF mandates in Europe are not one market. They are a bio-based market now and a synthetic market later. For a HEFA plant in Asia, that split defines the window in which its molecule is scarce.

Two design details matter for a plant outside Europe. First, Article 5 requires an airline to uplift at least 90 % of the fuel it needs at a Union airport. That rule limits tankering. Second, Article 15 lets a supplier meet the shares as a weighted average across the airports it serves until the end of 2034. In other words, the mechanism moves volume around, not obligation.

SAF mandates in the European Union: the penalty

The penalty is the part I read most closely. Under Article 12, a member state must fine a supplier that misses the minimum share. The floor is twice the gap between the average annual price of conventional fuel and SAF, multiplied by the volume that does not comply. For an airline that fails the refuelling duty, the fine is at least twice the average fuel price per tonne times the fuel it did not tank.

As a result, the EU fine is a formula, not a fixed fee. It also scales with the price gap that the project is trying to earn. Therefore, a high SAF premium raises both the value of the contract and the cost of missing it. That symmetry is what makes the EU scheme credible to a lender.

However, the text also leaves room. Member states set the rules and notify them to the Commission, and Article 15 provides averaging. Nevertheless, the obligation itself has no opt-out for a supplier that cannot source fuel. In practice, SAF mandates of this kind convert a policy target into a procurement problem for a named company.

Which party SAF mandates oblige decides who signs the offtake

When the duty sits on fuel suppliers, as in the EU, the UK, Japan and Korea, your first counterparty is a supplier, a refiner or a trader. The airline sits behind that contract. If the duty sits on airlines, the airline is the natural buyer. When the tool is a levy, as in Singapore, the buyer may instead be a government-backed purchaser. See ReFuelEU Offtake.

In practice, this changes the credit you underwrite. A supplier obligation gives you a corporate offtaker with a deadline and a fine. Such a buyer usually wants a short contract with a price review. By contrast, a levy gives you a pool funded by passengers. That pool is steadier in volume, but exposed to traffic and to political decisions about the charge.

In addition, the obliged party decides where the fuel must physically arrive. A supplier duty ties the fuel to the airports that supplier serves. Consequently, a Southeast Asia plant needs a blending point and a logistics chain inside that market. A levy can accept attributes separately from the molecules, which is why Singapore’s design and the book and claim debate belong in the same conversation.

Finally, SAF mandates differ in how they treat imports. The EU requires sustainability proof under its own rules. CORSIA runs a separate certification chain. As a result, the same batch of fuel may qualify for one buyer and not for another, and the offtake has to name the scheme it relies on.

Reading the SAF mandate table as a lender

Is the target legally binding, or announced? A proposal with no ordinance is a scenario, not a market.
Who pays the penalty, and is it big enough to matter? A fine below the price gap is a licence to miss the target.
Does the scheme accept fuel made abroad, and under which certification? The EU and CORSIA apply different tests.
Is there a sub-target your molecule can serve? Synthetic quotas create a premium that bio-based SAF cannot capture.
Can the rule change before your debt matures? The UK fixed 22 % for 2040, and the EU built in reviews.
Is demand averaged or site-specific? A weighted average across airports gives the buyer room that one airport does not.

For the investor view of the last question, read SAF Policy Risk. Meanwhile, for the regional picture, read Southeast Asia SAF.

After all, a table of SAF mandates is a map of duties, not of credit. Two countries can print the same percentage. Yet one will produce a bankable contract and the other a press release. The difference is usually the penalty, the clarity of the obliged party, and whether the scheme survived its first review.

How SAF mandates change the revenue line

Firstly, a mandate fixes a minimum volume, not a price. The EU text sets shares and fines. It does not guarantee a margin, so a developer still negotiates the number above the compliance cost. Secondly, a mandate moves the negotiation to the penalty. A buyer facing a fine of twice the price gap has a rational reason to pay a premium up to that point.

Thirdly, a levy changes the shape of demand. In Singapore, the charge appears as a separate fare line and goes into a statutory fund. A central company then aggregates levy demand with voluntary demand and buys SAF and its environmental attributes. As a result, a producer sells to a pooled buyer whose budget comes from passengers, not from an airline balance sheet.

Finally, the calendar matters more than the headline. A 2 % share in 2027 on a market of a few million tonnes is a small volume. By contrast, a 5 % share in 2030 is a different business. Therefore, I model the ramp year by year, contract by contract, and I check whether the plant start date lands before or after the step change.

Sources

Sources

Regulation (EU) 2023/2405 (ReFuelEU Aviation), Articles 3, 4, 5, 9, 12 and 15 and Annex I, EUR-Lex, OJ L 2023/2405, 31 October 2023.
Department for Transport, The SAF Mandate: an essential guide, 19 December 2024, and the SAF Mandate collection, last updated 13 July 2026.
Civil Aviation Authority of Singapore, Airline domain sustainability initiatives, last updated 20 October 2026, and the media release of 3 September 2026 on the SAF Levy, read in the corpus.
Codo Advisory, Starting at One Percent: How Japan Rewrote the Numbers on SAF, 2026, reporting the METI and MLIT proposal of 23 July 2026.
ESG Today, South Korea Mandates Use of Sustainable Aviation Fuel on Flights Beginning 2027, 2025.
USDA Foreign Agricultural Service, Biofuels Annual, Indonesia, report ID2026-0033, 14 August 2026, for ESDM Decree 113/2026.
The Nation, Thailand mandates 1 % SAF blend for jet fuel from January 1, 2026, 5 January 2026.