09. October 2026

Measures intended to make air travel more climate-friendly are becoming an existential threat to European business aviation. Two regulatory frameworks—the EU ETS and ReFuelEU Aviation—are hitting our industry with full force, while failing to achieve their actual goals.

Under the EU Emissions Trading System (EU ETS), operators must monitor and report their CO₂ emissions and surrender allowances. Starting in 2026, the previous system of free allocation will be completely phased out: in the future, allowances must be obtained entirely through auctions. Beginning in 2025, the Non-CO₂ Aviation Effects Tracking System (NEATS) will add yet another bureaucratic monster to the mix, collecting flight, fuel, and weather data and causing a significant increase in administrative burdens.

In July 2026, the European Commission presented its proposal to revise the EU ETS. The GBAA analysis identifies three serious consequences for essential air transport:

First, significantly more operators will be covered by the ETS in the future: The exemption for 243 flights per year is to be eliminated, and the current 10,000-metric-ton threshold will be lowered to a uniform 1,000 metric tons—regardless of whether the flights are for commercial or private use. Numerous smaller operators would be affected for the first time.

Second, the ETS is set to be expanded to include flights to third countries starting in 2029. While this applies to airlines only for outbound flights within a 5,000-km radius of Frankfurt, all arrivals and departures are to be covered for business aviation. This is clear discrimination against our industry—confirmed by the deliberate introduction of new terms such as “business flight” and “business aircraft” in place of the previous definition of “commercial air transport.”

Third, on-demand air transport is to be excluded from SAF subsidies: Our industry will derive virtually no benefit from the 20 million ETS allowances planned through 2030 to offset the additional costs of SAF—and we are also denied access to the flexible “Book & Claim” allocation system.

We strongly reject the Commission’s assertion that demand-responsive air transport has thus far been largely exempt from the ETS: Our operators have long been complying with all monitoring, reporting, and allowance obligations.

At the national level, the draft Market Ramp-Up Act for SAF provides for a penalty of 1,332 euros per metric ton not fueled (§29d)—and once again fails to distinguish between scheduled and on-demand air transport. This ignores operational realities: last-minute mission changes, safety reserves calculated exclusively based on flight criteria, a lack of SAF infrastructure at most of the regional airports we use, multi-segment daily rotations, and additional fuel consumption due to weather and ATC conditions. For small operators, the required proof of refueling entails a disproportionate bureaucratic burden—while offering little climate benefit, since refueling is rare in on-demand service anyway and mid-flight refueling can actually increase fuel consumption.

The GBAA’s demands are clear:

First: do not introduce the penalty levy in its current form. Second: establish a clear regulatory distinction between scheduled and non-scheduled air transport in the ETS, ReFuelEU, and national law. Third: ensure equal access to SAF subsidies, including Book & Claim. Fourth: implement practical exemptions that respect operational realities and flight safety rather than jeopardizing them.

The EU ETS, ReFuelEU Aviation, and non-CO₂ MRV collectively have a cumulative impact on costs and administration—with a force that threatens the very existence of parts of the on-demand aviation sector. Anyone serious about climate protection in aviation must treat our industry with nuance. Anything else is symbolic politics at the expense of an industry that has long been doing more for sustainable mobility than it is given credit for.