Brazil sets the rules for its SAF market ahead of 2027 mandate

SAF

Brazil has established the regulatory framework for its domestic aviation decarbonization mandate ahead of its January 2027 start. Decree No. 13,094, signed on August 12, 2026, introduces a national SAF certificate, Book & Claim transactions and links with CORSIA, creating the foundations of a broader sustainable aviation fuel market.

Brazil’s new framework regulates the Programa Nacional de Combustível Sustentável de Aviação (ProBioQAV), created by the Fuel of the Future Law adopted on October 8, 2024. The August 2026 decree defines how sustainable aviation fuel will be certified, traded and accounted for as airlines begin complying with mandatory greenhouse gas emission reductions on domestic operations.

A 1% emissions target starts in 2027

Brazil’s ProBioQAV does not impose a conventional Sustainable Aviation Fuel blending mandate. From January 1, 2027, covered air operators must reduce greenhouse gas emissions from domestic operations by 1% compared with a baseline assuming that those operations were performed entirely with fossil aviation fuel. The target remains at 1% in 2028, rises to 2% in 2029 and then increases by one percentage point per year until reaching 10% from 2037.

Brazil’s emissions-based approach means that the physical volume of SAF required will depend on the lifecycle carbon intensity of the fuel used. A Sustainable Aviation Fuel pathway delivering a larger lifecycle reduction can contribute more toward the same regulatory target than one with a higher carbon intensity. The Agência Nacional do Petróleo, Gás Natural e Biocombustíveis (ANP) will establish emissions values using lifecycle methodologies aligned with Brazil’s RenovaBio system or with methodologies used under the International Civil Aviation Organization’s Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA).

Brazil’s National Energy Policy Council, or CNPE, will monitor SAF supply, market conditions, environmental effectiveness, economic efficiency and the impact of the mandate on air transport. The August 2026 decree also allows the regulatory target to be adjusted if conditions affecting the public interest justify a temporary change.

Brazil puts Book & Claim at the center of SAF compliance

Brazil’s August 2026 decree formally introduces Book & Claim, allowing the physical SAF and its environmental attribute to be sold to different buyers. The mechanism is designed to separate the environmental benefit of certified SAF from the physical movement of the fuel through the aviation supply chain.

The Book & Claim model could be particularly relevant in Brazil, where long distances between production facilities and airports can make physical SAF distribution costly. An airline operating at an airport without a local SAF supply could ultimately acquire the certified environmental attribute generated by Sustainable Aviation Fuel supplied elsewhere, rather than requiring the same fuel molecules to be transported to every airport where the airline operates.

Brazil will support that system through the Certificado de Sustentabilidade do Combustível Sustentável de Aviação (CS-SAF). Every quantity of Sustainable Aviation Fuel commercialized in Brazil for use on domestic or international flights must be linked to a CS-SAF, which records information including the fuel volume and mass, production pathway, carbon intensity and traceability of the associated sustainability attributes.

The CS-SAF will be recorded through electronic platforms operated by entities authorized by the ANP. Brazil’s decree requires those platforms to record issuance, transfers and the final retirement of certificates, while also providing interoperability with internationally recognized certification and registry systems, including systems associated with CORSIA. Authorized registrars may also provide an electronic marketplace for trading CS-SAF certificates.

Air operators using CS-SAF certificates to meet their annual ProBioQAV obligations must permanently retire the corresponding certificates. For each compliance year, the required amount must be retired by January 31 of the following year, preventing the same certificate from being reused for another regulatory obligation.

A certification system designed to connect with CORSIA

Brazil’s ProBioQAV framework is being designed to connect the domestic Sustainable Aviation Fuel market with international aviation decarbonization systems rather than operating as a closed national mechanism. The ANP must establish a Brazilian SAF certification program, but domestic producers will also be allowed to certify fuel according to ICAO CORSIA criteria. SAF certified in Brazil under CORSIA methodologies will automatically be considered eligible under the national certification framework.

Imported SAF entering Brazil will have to meet CORSIA sustainability certification requirements. Foreign SAF sustainability certificates may also contribute toward Brazilian obligations under specific conditions, including reciprocity between countries and interoperability between the relevant certificate registries.

Brazil’s regulatory design also addresses the risk of double counting. ProBioQAV must operate in coordination with RenovaBio and the Brazilian Emissions Trading System so that a single emissions reduction cannot simultaneously support multiple environmental claims or regulatory obligations. The decree specifically prevents the environmental attribute attached to the same SAF from being counted repeatedly across different schemes.

Brazil will allow a limited part of the annual ProBioQAV target to be met through alternative mechanisms, including lower-carbon aviation fuels (LCAF), RenovaBio CBIO credits, eligible foreign SAF certificates and verified emissions reduction or removal certificates under Brazil’s carbon market. Alternative mechanisms may cover up to 15% of the annual target in 2027 and 2028, 10% in 2029 and 5% from 2030 onward. The percentages apply to the emissions-reduction obligation, not to the physical share of aviation fuel consumed.

Brazil has the feedstock — but supply still has to scale

Brazil’s Sustainable Aviation Fuel regulation arrives as the country positions its agricultural, biofuel and refining industries for a potentially much larger aviation fuel market. The International Air Transport Association (IATA) estimated in June 2026 that Brazil could have around 180 million tonnes of biomass feedstock potential by 2050, theoretically capable of supporting approximately 60 million tonnes of SAF production.

IATA estimates that sustainably sourced sugar-based ethanol, virgin oils and waste oils in Brazil could provide around 18 million tonnes of feedstock by 2030, equivalent to approximately 12 million tonnes of SAF production potential. Around 15 SAF projects were already under development in Brazil in June 2026 and could provide about 2 million tonnes of capacity if all are completed. IATA nevertheless stresses that Brazilian Sustainable Aviation Fuel production remains at an early stage and will require investment in conversion technology, infrastructure, logistics and financing to reach scale.

Brazil’s Empresa de Pesquisa Energética (EPE) also shows how strongly future demand could vary according to the carbon intensity of available SAF pathways. EPE estimates that Brazilian Sustainable Aviation Fuel demand could reach between 3.2 billion and 9.1 billion litres in 2037, with around 18% associated with ProBioQAV and 82% with CORSIA in the scenarios examined.

The EPE projection highlights a broader issue for Brazil’s Sustainable Aviation Fuel industry. The domestic ProBioQAV mandate can create an initial regulated market, but international aviation obligations under CORSIA could ultimately generate a much larger share of demand for Sustainable Aviation Fuel produced or supplied through Brazil.

The market architecture is set, but the rules are not finished

Brazil’s August 2026 decree establishes the architecture of ProBioQAV, but several operational rules still have to be completed before the first mandate begins in January 2027. The ANP and the Agência Nacional de Aviação Civil (ANAC) have until December 18, 2026 to publish the complementary regulations required to implement the program.

The ANP will regulate areas including SAF certification, traceability and environmental certificate issuance, while ANAC will establish compliance methodologies and supervise whether airlines meet their emissions-reduction targets. Brazil will also continue monitoring Sustainable Aviation Fuel availability, prices, market concentration and the economic effects of the mandate on aviation.

Brazil’s ProBioQAV mandate therefore begins with a relatively modest 1% emissions-reduction target in 2027, but the regulatory infrastructure being built around it is considerably broader. Book & Claim, CS-SAF certificates, electronic registries and CORSIA interoperability could determine how one of Latin America’s largest aviation markets develops SAF production, trading and compliance over the next decade.


Sources: Brazilian Government — Decree No. 13,094/2026 regulating ProBioQAV, August 12, 2026 Official decree · Brazilian Government — Fuel of the Future Law No. 14,993/2024 Official law · IATA — Brazil’s Opportunity to Be a SAF Powerhouse, June 8, 2026 IATA · EPE — SAF and green diesel outlook for Brazil, 2025 EPE report

When does Brazil’s ProBioQAV aviation mandate start?

Brazil’s ProBioQAV mandatory emissions-reduction target starts on January 1, 2027, with a 1% reduction requirement for covered domestic aviation operations.

Does Brazil require airlines to blend 1% SAF in 2027?

No. Brazil requires a 1% reduction in greenhouse gas emissions, not a fixed 1% physical SAF blend. The amount of SAF needed depends on the lifecycle carbon intensity of the fuel.

What is a CS-SAF certificate?

The CS-SAF is Brazil’s sustainability certificate for SAF. It separates the verified environmental attribute from the physical fuel and records information needed for traceability and emissions accounting.

How will Book & Claim work under ProBioQAV?

Brazil’s Book & Claim system allows the physical SAF and its certified environmental attribute to be purchased separately. The model can allow airlines to claim verified SAF reductions without requiring the same physical fuel to be delivered to every airport where they operate.

When will Brazil finalize the remaining SAF regulations?

Brazil’s ANP and ANAC have until December 18, 2026 to issue the complementary regulations needed to put the ProBioQAV framework into operation.

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