SAF Mandates Hit Corporate Travel in 2026

Three simultaneous SAF regulations — EU ReFuelEU Aviation (2 percent blend), the UK SAF Mandate (2 percent), and California's amended Low Carbon Fuel Standard — are routing roughly $3 to $7 per corporate ticket into airline fuel surcharges, and TMCs including Concur and Amex GBT are racing to integrate the data into Scope 3 reporting before 2026 disclosure deadlines.

The first invoice arrived in a Frankfurt travel manager’s inbox on January 14, 2026, and it carried an unfamiliar line item. Beneath the base fare and the standard YQ fuel surcharge, Lufthansa had added a third row: “Environmental Cost Surcharge — 4.20 EUR.” Two weeks later, an identical line — relabeled “SAF Compliance Charge” — appeared on Air France itineraries. By the first week of February, every legacy European carrier and most North Atlantic transatlantic operators had quietly amended their fare construction logic to push the cost of Sustainable Aviation Fuel directly onto the corporate buyer.

The mechanics behind that line item are not new. What changed in 2026 is that the EU’s first full year of penalty enforcement against the 2025-effective 2 percent floor has begun, sharpening carrier pass-through behavior.

The European Union’s ReFuelEU Aviation regulation, adopted in 2023 and effective from January 1, 2025, requires fuel suppliers at all EU airports to ensure that at least 2 percent of aviation fuel delivered into aircraft is Sustainable Aviation Fuel; 2026 is the first calendar year in which Member State penalty regimes for shortfalls against the 2025 obligation are actively enforced. The United Kingdom’s parallel SAF Mandate, which entered force on January 1, 2025, sets the same 2 percent floor for 2025 and steps up annually thereafter. And on the U.S. West Coast, the California Air Resources Board’s amended Low Carbon Fuel Standard — voted through in November 2025 and effective January 1 — added jet fuel to the regulated pool for the first time, creating a deficit obligation that airlines flying into LAX, SFO, SAN, OAK, and SJC must now cover through either physical SAF uplift or purchased credits.

Three regulatory regimes, three different compliance mechanisms, one shared outcome: someone has to pay for fuel that costs roughly three to five times the price of conventional kerosene. In 2026, that someone is the corporate travel program.

Anatomy of a Pass-Through

The price gap is the entire story. The IATA SAF price index closed January 2026 at $2,184 per metric tonne, compared with Jet A-1 at $612 per tonne on the same day. The 2 percent EU blend adds roughly $31 per tonne of fuel uplifted at an EU airport once both volumes are weighted into the supplied stream — a number that translates into between $1.80 and $4.50 per intra-European one-way ticket depending on aircraft type, load factor, and stage length, and between $4 and $7 per long-haul ticket for sectors uplifting fuel at an EU or UK origin.

“The cleanest way to think about this is fuel burn per passenger times the SAF premium times the mandate percentage,” explained Sebastian Mikosz, IATA’s Senior Vice President for Environment and Sustainability, in a January 28 briefing in Geneva that Modern Business Travel attended remotely. “A Boeing 787-9 burns roughly 5,400 kilos of fuel per hour. With 290 seats and a 2 percent SAF blend at current price spreads, that comes to about $5.20 per passenger per flight hour. Round-trip London-Singapore, you’re looking at $13 to $15 in pass-through. That is the entire economic story of 2026.”

Carriers are not, by and large, absorbing the difference. The European Commission’s Directorate-General for Mobility and Transport explicitly anticipated pass-through in its 2023 impact assessment, modeling a per-ticket increase of EUR 2.41 to EUR 5.97 by 2026. Filed surcharges through January and early February have come in close to the upper end of that band — EUR 4.20 to EUR 5.80 on most EU-origin tickets sampled by Modern Business Travel across nine corporate booking tools.

What is genuinely new is how the surcharge is being labeled. In a December 2025 guidance note, the European Union Aviation Safety Agency (EASA) recommended — though did not require — that carriers identify SAF-related charges with consistent terminology, suggesting “ReFuelEU Compliance Surcharge” or simply “SAF Surcharge.” A review of fare construction by ATPCO conducted on January 31 found 14 different label conventions across 23 European carriers, ranging from Lufthansa’s “Environmental Cost Surcharge” to Iberia’s “Sustainable Fuel Adjustment” to Aegean’s quietly minimalist “ECS.” The lack of standardization is already a headache for TMCs trying to map the data into emissions ledgers.

“We’re parsing free-text surcharge descriptions across 47 carriers right now and reconciling them against published filings with each civil aviation authority,” said Lara Verheyden, Concur’s Director of Sustainability Product, in a phone interview on February 4. “We expect to have a unified taxonomy in our Sustainability Module by the end of Q1. Until then, customers are getting the dollar amount right but the categorization is messy.”

The California Wrinkle

California’s contribution to the 2026 SAF picture works on different plumbing entirely. Rather than mandating a blend percentage, the Low Carbon Fuel Standard sets an annually declining carbon intensity benchmark for transportation fuels sold in the state. Jet fuel was previously opt-in for credit generation; the November 2025 amendments brought it into the deficit pool, meaning airlines uplifting Jet A-1 in California now incur a credit obligation they must satisfy by either blending SAF physically, purchasing credits from other low-carbon fuel producers, or — in a controversial provision the Western States Petroleum Association is currently challenging in state court — buying credits from out-of-state SAF producers under a book-and-claim accounting framework.

The financial impact lands differently than the EU and UK schemes. LCFS credits closed January at $66 per metric tonne CO2 equivalent, and the implied per-gallon cost on Jet A-1 worked out to roughly $0.14 in early February — a number that scales to about $3.80 in pass-through on a transcontinental U.S. flight uplifting fuel at LAX or SFO.

“California is the most economically efficient of the three regimes, because it’s market-based rather than volumetric,” said Dan Rutherford, Aviation Program Director at the International Council on Clean Transportation, in a February 2 phone conversation. “Airlines can hit the same carbon outcome through whichever pathway is cheapest. The downside is that the cost signal is more volatile — LCFS credit prices have moved 40 percent in the last six months, and your corporate fuel surcharge will move with them.”

For a U.S.-domiciled corporate travel program with significant West Coast volume, the LCFS pass-through is small but non-trivial. A 50,000-ticket annual program with 30 percent California-origin travel would absorb roughly $57,000 in incremental cost across 2026, before any EU or UK transatlantic exposure is added on top. For multinationals routing employees across all three regimes, the cumulative exposure is closer to $200,000 to $400,000 for programs of similar size.

Which Carriers Are Actually Doing the Work

The 2 percent floor is a floor, not a ceiling, and several carriers have built procurement positions well above the statutory minimum — a fact that increasingly matters for corporate accounts whose sustainability mandates require demonstrable SAF uplift, not just compliance with the law.

Air France-KLM remains the most aggressively committed of the major carriers. The group disclosed in its January 30 sustainability update that it had signed offtake agreements totaling 1.6 million tonnes of SAF through 2030, sourced from a portfolio that includes Neste’s Singapore and Rotterdam facilities, DG Fuels in Louisiana, and a recently announced 2026-2029 agreement with TotalEnergies’ Grandpuits biorefinery in France. The group blended 1.7 percent SAF across its operations in 2025 — below the new 2026 floor, but positioned to comfortably exceed it this year with first-quarter tracking at 2.3 percent.

“We see SAF procurement as a competitive moat,” said Anne Rigail, Air France-KLM’s Chief Sustainability Officer, in a January 30 investor call. “Customers — particularly the corporate accounts representing 38 percent of our revenue — are increasingly making this part of their RFP scoring. Being credibly above the mandate matters.”

Lufthansa Group reported a 1.9 percent group-wide blend for full-year 2025 and projected 2.4 percent for the first quarter of 2026, with the bulk of the supply coming from a 250,000-tonne agreement with Shell and a smaller but symbolically important domestic supply line from Heide refinery in Schleswig-Holstein. The group’s “Green Fares,” launched in 2023 and refined in 2025, now include a SAF allocation by default — a structural choice that has been emulated by Swiss, Austrian, Brussels, and ITA Airways within the group.

Among U.S. carriers, United Airlines remains the standout. The carrier reported 4.1 million gallons of SAF uplifted in calendar year 2025, up from 3.0 million gallons in 2024, and announced on February 3 a new equity investment of $32 million in Cemvita Factory, a Houston-based startup developing microbial pathways to SAF feedstock. United’s Eco-Skies Alliance — the carrier’s corporate SAF purchasing club, which now includes 47 Fortune 500 members — collected $98 million in 2025 customer contributions, all of which flowed into incremental SAF procurement beyond what the carrier would have purchased commercially.

Delta and American both meet the EU and UK mandates on the relevant sectors but have been more reserved in voluntary procurement. Delta’s stated target of 10 percent SAF by 2030 has been described by Bank of America’s aviation team as “aspirational rather than contracted” in client notes published in November 2025. American’s SAF program is largely structured around a 2023 agreement with Gevo, which is not expected to deliver meaningful commercial volumes until 2027.

IAG, the parent of British Airways and Iberia, sits in the middle of the pack — meeting the mandate on EU-origin sectors and growing UK-origin SAF use to satisfy the UK mandate, but with a smaller voluntary procurement program than the AFKLM or Lufthansa equivalents. The group’s January 2026 sustainability update reported a full-year 2025 group blend of 1.4 percent, with a 2026 target of 2.5 percent.

“The corporate customer doesn’t just want compliance — they want to point at the volume number in their carbon disclosure and have it stand up to audit,” said Cait Hewitt, Policy Director at the Aviation Environment Federation in London, in a January 27 interview. “The carriers that have built the largest committed offtake portfolios are going to win those mandates. AFKLM, Lufthansa, and United are the three names we hear most consistently when we talk to corporate sustainability officers.”

The TMC Integration Problem

Pass-through pricing is the simple part. The harder problem — and the one most corporate travel programs are still working through — is wiring the SAF data into the systems that ultimately produce Scope 3 emissions disclosures.

Concur’s Sustainability Module, rolled out in beta in October 2025 and now generally available to TripLink and Concur Travel customers, ingests fare-level SAF surcharge data from 47 carriers and reconciles it against published mandate compliance reports. A Concur customer booking a London-Paris ticket on Air France today sees the ticket price, the SAF surcharge as a discrete line item, and an estimated allocated SAF volume in litres credited against the booking’s emissions calculation.

The math under that allocation is contested. Concur uses the GHG Protocol’s draft 2025 guidance on book-and-claim accounting, which permits SAF certificate retirement to be credited against the specific booking — but only where the airline can produce a registry-tracked certificate ID. Of the 47 carriers Concur ingests data from, 31 currently provide certificate-level traceability, with the remaining 16 providing only aggregate volume disclosures that Concur surfaces but does not credit against individual bookings.

“We will not credit emissions reductions to a specific traveler unless the certificate is identifiable and uniquely retired against that booking,” Verheyden said. “Anything else is double counting waiting to happen, and our customers’ auditors will reject it inside of a year.”

Amex GBT’s Climate Lab takes a different approach. Launched commercially in January 2026 after eighteen months in pilot, Climate Lab models the SAF mandate impact at the program level rather than the booking level, producing quarterly disclosures that map traveler activity against carrier-disclosed SAF volumes weighted by sector. The platform integrates with the GBT Neo booking tool natively and is being rolled out as an add-on for accounts using third-party online booking platforms.

“We made a deliberate choice not to allocate at the booking level until the GHG Protocol finalizes its guidance,” said Karen Hutchings, EVP of Global Operations at Amex GBT, in a February 5 phone briefing. “Program-level allocation is more defensible today. We expect to move to booking-level once the methodology is settled, probably in the second half of 2026.”

Travel managers we spoke to are split on the right approach. Vanessa Müller, Senior Manager for Global Travel and Meetings at Bayer, told Modern Business Travel on February 3 that her team was running both Concur Sustainability Module and Climate Lab in parallel through Q1 2026 specifically to compare the booking-level versus program-level outputs. “We want to know which methodology will hold up to our auditors and which one our procurement team can act on,” Müller said. “Right now they give us slightly different numbers, and that’s not sustainable.”

CWT’s CarbonClarity tool, BCD Travel’s Advito Carbon Calculator, and FCM’s Climate+ platform each take a third position, presenting SAF cost and volume data alongside booking decisions but stopping short of crediting emissions reductions to specific tickets without explicit corporate policy direction. The result is a fragmented landscape in which the same business trip can produce three different reported emissions numbers depending on which TMC processed it — a divergence that the Sustainable Aviation Buyers Alliance has flagged as a priority issue for industry standardization in 2026.

What Corporate Travel Programs Should Do Now

The practical implications for travel managers fall into three buckets.

First, build the pass-through into 2026 budgeting. The data from January and early February suggests an average program-level cost increase in the range of 0.7 to 1.4 percent on total air spend, depending on sector mix. Programs heavily weighted toward intra-European or transatlantic travel will land at the higher end. The number is not large enough to materially shift airline RFP outcomes on price alone, but it is large enough that finance teams should not be surprised by the line item.

Second, demand SAF data in the carrier RFP process. The 2027 corporate contract season begins in October 2026, and the standard RFP template — which historically asks for on-time performance, premium-cabin availability, and lounge access — should now include questions on committed SAF offtake volumes, certificate traceability, and book-and-claim allocation methodology. Programs that fail to ask for this data are leaving an audit-quality emissions number on the table.

Third, choose a TMC carbon methodology and stick with it. Running multiple platforms in parallel is reasonable in 2026 as the methodologies converge, but most corporate sustainability teams will want to commit to one primary methodology by the start of 2027 — the year when EU Corporate Sustainability Reporting Directive disclosures begin to bite for the first cohort of large undertakings.

The longer arc is steeper. The EU mandate steps to 6 percent in 2030 and 20 percent in 2035; the UK ramps to 10 percent in 2030; California’s LCFS carbon intensity targets tighten by roughly 4 percent annually. Goldman Sachs’ January 2026 European transport note projected pass-through fees rising to $12 to $18 per ticket by 2030 in nominal terms, with the steepest increases landing in 2029 and beyond as the mandate curves bend upward.

“2026 is the easy year,” said Rutherford at ICCT. “Two percent is genuinely cheap. The conversation we should be having now is what corporate programs do in 2030 when the floor is three times higher and the global supply chain has not kept pace. That is when this becomes a real strategic question, not a budgeting one.”

For now, the EUR 4.20 line on a Lufthansa invoice is a small annoyance and a glimpse of a much larger bill to come.