Buying SAF certificates is the easy part. Reporting them is where companies get stuck, because the rules sit in four places at once: the certification scheme, the GHG Protocol, SBTi and, for larger companies, the CSRD. None of them has the full picture on its own, and the GHG Protocol is still rewriting its rules on market instruments.
This article puts the SAF scope 3 reporting rules in the order you need them, from category to claim wording.
The short answer. Report the gross emissions of your flights as usual, and disclose the SAF-supported reduction separately next to them, capped at your own flight footprint and backed by a retirement statement in your name. Do not net it. Word the external claim as financing SAF, not as carbon neutral flying.
Which Scope 3 categories
SAF certificates relate only to aviation. RSB defines the corporate end-user as a company that claims a Scope 3 reduction for business travel (Category 6) or cargo (Categories 4 and 9) in its Book & Claim Manual (version 4.2, effective since 3 December 2025). Its June 2026 guidance adds that freight is commonly reported in Category 4 for inbound and Category 9 for outbound logistics.
Activity | Scope 3 category | SAF certificate applies to |
|---|---|---|
Employee flights | Category 6, business travel | Your share of passenger flight emissions |
Inbound air freight you pay for | Category 4, upstream transportation | Air cargo emissions in your supply chain |
Outbound air freight | Category 9, downstream transportation | Air cargo emissions to your customers |
Office energy, cars, rail | Other categories | Not eligible |
A certificate from aviation cannot be used for other transport modes or sectors. RSB is explicit that units are claimed within their sector only.
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The RSB rules that matter
Three RSB rules decide whether your claim holds up.
1. The claim is capped at your own footprint. RSB states that corporate end-users cannot claim retired SAF units “that exceed their total air travel and air freight footprint in that reporting year”. Calculate your flight footprint first; it is the ceiling. SBTi V2 has the same logic in its volume matching criterion.
2. The claim is exclusive. Each RSB Book & Claim Unit, one tonne of neat certified SAF, carries one Scope 1 claim and up to two Scope 3 claims. The airline that burns the fuel takes the Scope 1 claim; two Scope 3 claims can exist when, for example, a freight forwarder and its shipper, or a travel agency and its corporate client, share the chain. The registry tracks who holds which claim, so no tonne is claimed twice in the same scope.
3. The reduction is reported separately. RSB asks all actors, corporate end-users included, to “disclose B&C-supported emissions reductions separately and do not use them to adjust the GHG inventory”. RSB notes that this guidance is a practical example rather than a normative standard, but it matches where the GHG Protocol stands.
The GHG Protocol’s standard development plan of 29 July 2026 says market-based approaches, which it lists as including SAF and book and claim, are “not included in or allowed under” the current Scope 3 Standard. A consolidated draft is expected for consultation in Q2 2027 and the revised standard in Q4 2028. Until then, the separate disclosure is the safe route.
Avoiding double counting with your airline
Double counting is the first thing an auditor looks for, and it can happen in three places.
Between you and the airline. The airline uses the physical SAF and may report it in Scope 1, under the EU emissions trading system or under CORSIA. Your Scope 3 claim comes from the separate Scope 3 attribute. Under ReFuelEU Aviation, airlines must also declare that they have not reported identical SAF batches under more than one greenhouse gas scheme. Ask your supplier which claim the airline holds and confirm that your certificate is the Scope 3 claim.
Between you and another company. If you buy through a travel agency or freight forwarder, check whether it also claims a Scope 3 reduction on the same units. RSB allows up to two Scope 3 claims, so the split must be explicit.
Between registries. Certificates are issued in registries such as the SAFc Registry, which separates a Scope 1 certificate for the air transport provider from a Scope 3 certificate for aviation customers, the RSB Book & Claim Registry, ISCC’s Credit Transfer System and the SAF Registry run by CADO. Buy certificates that sit in one registry with a unique serial number, and ask how the supplier prevents the same batch from appearing in another. Our comparison of 5 partners to source SAF certificates from in 2027 lists which registry each route uses, as far as providers publish it.
SBTi’s Corporate Net-Zero Standard V2.0 turns these checks into criteria: unique attribution, double counting prevention through serialisation, temporal alignment within 12 months of the underlying activity, and retirement through transparent registries, which Category A companies must have assured. V2.0 is usable from 1 February 2027 and mandatory for new submissions from 1 February 2028.
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What must be on your retirement statement
The retirement statement is the evidence for the claim. Before you report, check that it shows:
your company as the beneficiary of the Scope 3 claim, and the claim type (Scope 3, not Scope 1)
the quantity of neat SAF in tonnes and the emissions reduction in tCO2e
the fuel pathway, the feedstock and the life cycle emissions value used
the certification scheme (RSB or ISCC) and the registry, with a unique serial number
the period in which the fuel was delivered, matching your reporting year
the retirement date
Life cycle values decide the reduction. For used-cooking-oil HEFA, ICAO’s default value is 13.9 gCO2e/MJ against a fossil baseline of 89, about 84% lower (as of November 2025). If the statement uses a different value, ask why. The values per pathway are in the best SAF certificates to buy in 2027.
Tip from Bernard de Wit, Co-founder of Regreener: “Keep three numbers apart in every report: gross flight emissions, the SAF-supported reduction and the carbon credits you financed. As soon as one is subtracted from another, the figure can no longer be traced back. File the retirement statement next to your flight data and the calculation that links the two, so the tonnes can be followed from booking to registry serial number.”
How to show it in your report
A clear disclosure has three lines that never get added together.
Line | Example (hypothetical) | Evidence |
|---|---|---|
Gross Scope 3 Category 6 emissions | 800 tCO2e | Flight data and emission factors |
SAF-supported reduction, reported separately | 80 tCO2e (24 t of neat SAF, HEFA from used cooking oil) | Retirement statement, registry serial number |
Carbon credits for residual emissions, reported separately | 720 tCO2e retired | Registry retirements of the credits |
For CSRD reporters, ESRS E1 refers to the GHG Protocol for Scope 3 and does not mention SAF certificates. Until there is guidance, keep gross Category 6 unchanged and describe the SAF purchase as a decarbonisation action with its reduction. The CSRD now covers companies with more than 1,000 employees and more than €450 million turnover, with revised ESRS from financial year 2027 (European Commission, July 2026). Our comparison of SAF certificates vs carbon credits shows how the two instruments sit side by side.
Claims you can and cannot make
Reporting is one audience; marketing is another, and the rules there are stricter.
In November 2025, 21 airlines committed to the European Commission to stop claiming that a specific flight’s emissions could be neutralised, offset or directly reduced through consumer contributions to alternative aviation fuels. In March 2024 the Amsterdam District Court found that KLM’s “Fly Responsibly” advertising painted an overly rosy picture of measures such as SAF. Since 27 September 2026, the EU Empowering Consumers Directive bans product claims of neutral or reduced climate impact based on offsetting; the Commission has not yet said how this applies to SAF certificates. We explain the rules in our guides to carbon neutral claims under EmpCo and the EU Green Claims Directive.
Holds up | Avoid |
|---|---|
“In 2026 we financed 24 tonnes of SAF, an estimated 80 tCO2e reduction in aviation emissions, retired in registry Y.” | “Our business travel is carbon neutral.” |
“We report a SAF-supported reduction of 80 tCO2e next to our business travel emissions.” | “SAF cut our Scope 3 emissions by 10%.” |
“We support the production of lower-carbon aviation fuel.” | “We fly sustainably.” |
For B2B communication, factual wording with numbers and a registry reference is the safest choice. Our article on contribution claims gives examples for carbon credits that follow the same logic.
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Plan the SAF purchase so the retirement statement lands in the right reporting year, sized from the same footprint as your carbon credits.
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Get the purchase right, and the report follows
Most reporting problems start at the purchase: a certificate without a Scope 3 claim type, a delivery period outside the reporting year, or a volume larger than the flight footprint. Regreener sources SAF certificates supplier-agnostically from recognised certification schemes and registries, checks the retirement statement against these rules, and sizes SAF and carbon credits from the same footprint. For the purchase steps, see how to buy SAF certificates, and for the volume, how many SAF certificates do I need. For the budget, see SAF certificate prices in 2026. Before your next report, talk to a SAF specialist.
