Brazil ANAC seeks SAF monitoring rules input before 2027 deadline

Brazil's civil aviation regulator has opened a public consultation on the monitoring and compliance rules for its mandatory sustainable aviation fuel program, with less than four months before the first binding emissions reduction targets take effect and key market architecture questions still unresolved.

The National Civil Aviation Agency (ANAC) launched Public Consultation No. 12/2026 on Sept. 3, inviting submissions on a proposed resolution establishing monitoring, reporting and verification procedures for the National Sustainable Aviation Fuel Programme, known as ProBioQAV.

The consultation remains open until Oct. 1, 2026, after which ANAC will analyze contributions before the proposal goes to the agency's Board of Directors for deliberation.

The ProBioQAV program, established under the Fuel of the Future Law and regulated by Decree No. 13,094 of 2026 signed on Aug. 12, requires airlines operating domestic flights in Brazil to reduce aviation greenhouse gas emissions by 1% in 2027 through SAF use, with targets increasing progressively in subsequent years.

The first mandatory targets are effective from Jan. 1, 2027, creating a narrow implementation window for an industry still awaiting final rules on certification, feedstock eligibility, pricing and financing.

Regulatory framework and unresolved questions

The proposed resolution covers the procedures and methodologies air operators must follow for monitoring and reporting emissions and reductions attributable to SAF use on domestic flights, the mechanisms for proving compliance with targets set under Law No. 14,993 of 2024, verification processes for declared information, use of the Sustainable Aviation Fuel Certificate (CS-SAF), alternative compliance pathways, and ANAC inspection procedures.

The proposal was developed through technical analyses and discussions within the SAF Connection initiative, a forum coordinated by ANAC and the National Agency of Petroleum, Natural Gas and Biofuels (ANP) that brings together representatives from the aviation sector, the fuel industry, sector associations, academic institutions and public bodies.

ANAC will hold a forum on Sept. 11 to present the proposed regulations and detail the agency's responsibilities within ProBioQAV, the monitoring mechanisms and the CO₂ target compliance framework.

Despite the regulatory progress, significant market questions remain unresolved with the mandate less than five months away.

A key issue under scrutiny is how Brazil's domestic certification system will interact with the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), whose mandatory phase also begins in 2027.

The decree allows producers to certify SAF either through the national system to be developed by ANP or under CORSIA-approved schemes, and CORSIA-certified SAF will automatically qualify under the Brazilian system.

However, the regulation does not establish whether Brazilian CS-SAF certificates will similarly support CORSIA Eligible Fuel claims, creating potential uncertainty for airlines with both domestic and international compliance obligations.

Brazil's pool of CORSIA-certified feedstocks remains limited.

Bunge supplies certified SAF-grade soybeans, while ADM's soybean processing unit in Rondonópolis, Mato Grosso, is also listed as certified.

State-controlled oil company Petrobras has commercially produced co-processed SAF using technical corn oil and Bunge's certified soybean oil.

Traceability remains a challenge for other potential feedstocks, particularly used cooking oil, where collection is fragmented, and Brazil currently restricts UCO imports, though the government has been reviewing the issue.

Book-and-claim and cost concerns

The decree's inclusion of a book-and-claim structure has introduced a new pricing dynamic that market participants are still assessing.

Under the framework, CS-SAF certificates can be traded independently from the physical fuel until retirement, meaning the purchaser of the physical SAF cannot claim the associated emissions reduction once the certificate is separated.

The structure could streamline compliance logistics, given that Brazil's mandate is based on annual emissions reductions rather than requiring each airline to physically blend a fixed SAF percentage, potentially allowing physical SAF to be supplied where logistics are most efficient while airlines acquire certificates separately.