Viewpoint: A Call to Action For SAF Users In Business Aviation

The Greenhouse Gas Protocol has released its Action and Market Instruments Phase I white paper alongside a formal Request for Information, initiating a multiyear process to determine how sustainable aviation fuel book-and-claim transactions may be recognized within corporate greenhouse gas accounting frameworks. The GHGP, which underpins widely adopted standards including the Science Based Targets initiative and California's climate disclosure rules, has not issued a major update to its corporate accounting guidance in over a decade — the same period during which SAF emerged as a commercially available product. The RFI submission window closes May 31, and a Phase II paper with a full draft standard for public comment is anticipated in 2027. The outcome of this process will directly determine whether and how SAF purchases can be credited toward corporate emissions reduction goals.

For corporate flight departments and business aviation operators, the stakes are substantial and immediate. Nearly all large public companies — 94 percent of Russell 1000 constituents and 99 percent of S&P 500 companies — now report on sustainability, and close to 11,000 organizations globally carry formal near-term or net-zero climate commitments. Flight departments operating under Part 91, 91K, or 135 certificates are increasingly integrated into those commitments and are being asked to quantify and reduce their scope of emissions. The current ambiguity around SAF book-and-claim — a mechanism allowing operators to purchase SAF credits even when the physical fuel is not delivered to their specific location — has made it difficult for operators to make confident procurement decisions or for sustainability teams to communicate verified emissions reductions to investors, regulators, and boards. Without recognized accounting rules, the value proposition of SAF investment remains difficult to defend internally.

The complexity of aviation emissions accounting is compounded by the structural realities of how business aviation operates. Unlike commercial airline fleets with centralized fueling and straightforward corporate ownership, business aviation involves fractional programs, charter operators, flight management companies, fuel resellers, and individual corporate flight departments — each with distinct relationships to the fuel supply chain and different levels of decision-making authority over sustainability choices. The GHGP's forthcoming guidance must account for these layered structures if it is to be practically applicable. Organizations like 4AIR have indicated they will submit formal responses, but the call for individual operator and fuel provider input reflects a recognition that first-hand, experience-based perspectives carry distinct weight in shaping technical accounting standards.

The broader aviation industry context reinforces why this moment matters. SAF currently represents a fraction of total jet fuel consumption globally, constrained by limited production capacity and unresolved questions about how its environmental benefits translate into recognized credits under major reporting frameworks. The commercial aviation sector, through CORSIA (Carbon Offsetting and Reduction Scheme for International Aviation), has its own parallel accounting mechanisms, but business aviation largely falls outside CORSIA's scope and depends on voluntary corporate frameworks — principally the GHGP — to validate its sustainability actions. If the forthcoming GHGP standard produces robust, aviation-aware guidance on book-and-claim, it could meaningfully accelerate SAF demand by giving operators a defensible, auditable method for claiming emissions reductions, directly stimulating investment in SAF production infrastructure.

The window for the aviation industry to influence how these rules are written is narrow and closing. The Phase I RFI represents the earliest and often most impactful stage of a standards development process — the moment when foundational assumptions are established before positions harden in technical drafting. Operators, fuel suppliers, and corporate aviation sustainability professionals who engage now, with concrete data on how book-and-claim transactions actually function in practice, have a genuine opportunity to ensure the resulting standard reflects operational reality rather than theoretical models developed without aviation-specific input. The alternative — a framework that fails to accommodate aviation's structural complexity — could leave the industry with accounting rules that discourage rather than reward SAF adoption at the moment when decarbonization pressure is at its highest.