Summary of engagement
Through a rigorous assessment of Air New Zealand’s Scope 3 Sustainable Aviation Fuel Certificate (SAFc) Programme, Toitū Envirocare confirmed that the airline’s SAFc emissions reductions meet the integrity requirements of our Climate Impact Programme. This gives clients confidence to incorporate SAFc into their decarbonisation strategies while supporting the scale-up of SAF as a critical solution for reducing aviation emissions. Outside of the work with Air New Zealand, we also established New Zealand’s first high-integrity framework for SAF certificate accounting, further strengthening Toitū’s position as a leader in shaping credible climate action and market practice.
Client quote
"Emerging approaches like SAFc need to be both technically robust and practical for organisations to use. We greatly appreciated Toitū's collaborative approach and their genuine commitment to working through a complex and evolving area to reach an outcome that organisations can use with confidence."
Laura Luther, Sustainability Lead - Decarbonisation, Air New Zealand
Client overview
Air New Zealand knows aviation is critical to New Zealand. As an island nation, our economy, communities and international connections rely on air travel. At the same time, reducing aviation emissions is one of the industry's greatest challenges.
Sustainable Aviation Fuel (SAF) is the aviation sector’s most significant opportunity to reduce emissions — capable of decarbonising existing fleets today without waiting for new aircraft technology. Yet with global supply of SAF accounting for less than 1% of jet fuel, scaling SAF is one of the industry’s defining challenges.
The SAF market is nascent, but Air New Zealand is acting now to help scale SAF and enable a lower emissions future. Air New Zealand has developed a Scope 3 SAF certificate (SAFc) programme, enabling organisations to address their air travel emissions while contributing to the additional cost of SAF over fossil jet fuel, and helping support additional investment in SAF.
Air New Zealand has worked with Toitū to ensure that customers can confidently use emissions reductions from Air New Zealand’s Scope 3 SAFc Programme in Toitū's Climate Impact Programme.
Challenge
Aviation faces a fundamental decarbonisation challenge. Sustainable Aviation Fuel (SAF) is expected to be the sector’s most significant decarbonisation lever through to 2050, however global supply is currently less than 1% of total jet fuel. This mismatch between ambition and availability is driven by the significant cost premium to fossil jet fuel and demand uncertainty. Ultimately, scaling SAF will depend on collective action across airlines, aviation customers, industry and governments to give confidence to producers and investors to bring additional supply online.
Emerging market-based models, such as book-and-claim, have been developed to help overcome some of these constraints. These decouple the environmental attributes of SAF from physical fuel delivery, enabling corporates globally to address emissions associated with business air travel and air transport. However, the absence of consistent, widely recognised accounting frameworks creates complexity and uncertainty.
Air New Zealand and Toitū recognise the importance of trusted frameworks and mechanisms to enable organisations to participate in this emerging space. Organisations looking to purchase Scope 3 SAFc want confidence that the emissions reductions can be used to support their decarbonisation and reporting objectives.
Objective
Toitū’s objective was to independently assess whether Air New Zealand's Scope 3 SAFc Programme met the integrity expectations of our Climate Impact Programme, giving our clients the confidence that SAFc emissions reductions could be recognised within our programmes.
Alongside this, with the absence of consistent and widely recognised accounting guidance, Toitū identified a need to establish our own high-integrity approach to ensure robust accounting practices for SAFc reporting for our clients.
Why Toitū
Toitū is a trusted and respected voice in New Zealand's decarbonisation landscape. Through conversations with prospective Scope 3 SAFc customers, it became clear that many organisations wanted to use Scope 3 SAFc towards their Toitū Climate Impact Programme goals.
Air New Zealand engaged Toitū to determine whether emissions reductions from its Scope 3 SAFc Programme could be recognised within those programmes, providing customers with a credible pathway to incorporate SAFc into their wider decarbonisation strategy.
Approach
Toitū undertook a structured review of Air New Zealand’s SAF certificate retirement statements and underlying systems and controls to ensure they provide robust, auditable evidence for assurance. This work was designed to build on the broader audit of Air New Zealand’s Scope 3 SAFc programme, which focused on the integrity of the methodology, data, and supporting documentation.
The assessment centred on three core pillars: verifying the authenticity and traceability of SAF certificates back to their source; evaluating whether the evidence provided is sufficiently complete and consistent to support emissions accounting and independent assurance; and testing the controls in place to prevent double counting, including clear ownership, unique identifiers, and confirmed certificate retirement.
The framework in the table below summarises the integrity principles used by Toitū to assess Air New Zealand’s SAFc programme towards Toitū’s Climate Impact Programme. This enables Toitū’s clients to access and claim emissions reductions with confidence. This required ensuring Air New Zealand’s SAFc Programme aligned with globally recognised best practice across SAFc attributes, traceability, and governance — providing a defensible, transparent model that delivers real climate impact and is fully accepted within the Toitū Climate Impact Programme.
Through this approach, Toitū established a consistent integrity threshold for evaluating SAF certificates — ensuring that any SAFc issued to customers is underpinned by transparent, verifiable, and high-quality data. This provides confidence that Air New Zealand’s SAF offering can support credible emissions reporting and aligns with the requirements of the Toitū Climate Impact Programme and emerging global best practice.
The Toitū high-integrity approach for SAFc acceptance
| Feature | What this means (and why it matters) |
|---|---|
| 1. Certification of the attributes of the physical fuel | SAF emissions reductions are independently verified, ensuring the claimed impact is certified as real |
| 2. Use credible normative document(s) | SAF certificates are administered following recognised global standards, reducing risk and aligning with best practice |
| 3. Use credible registries | SAF certificates are issued and tracked in trusted systems, ensuring full traceability |
| 4. Prevent double counting | Each emissions reduction is only issued under one registry, protecting the integrity of reporting |
| 5. Ensure additionality | Reductions would not happen without this intervention, confirming real climate impact |
| 6. Enable multiple distinct claims | Different parties can make clearly defined claims without overlap or conflict |
| 7. Robust governance | Strong oversight and rules ensure consistent, reliable, and defensible outcomes |
| 8. Data accuracy | Data is validated and reliable, enabling confident reporting and decision-making |
| 9. Transparency | Information is openly available, supporting trust, auditability, and accountability |
| 10. System acceptance and alignment | The SAF certificate model aligns with relevant best practice discourse *, ensuring certificates align and meet the needs of a wide range of intended end users |
*The SAF certificate model aligns with relevant best practice discourse
Outcomes
Toitū’s work confirmed that emissions reductions associated with SAF certificates (SAFc) within Air New Zealand’s programme meet the integrity thresholds required for use within the Toitū Climate Impact Programme. This provides customers with confidence that SAFc can be used to:
- credibly report reduced business air travel and air transport emissions,
- support progress toward decarbonisation targets,
- and reduce reliance on carbon credits for addressing residual emissions.
Beyond the immediate programme, the work also informed Toitū’s broader position on SAF in a rapidly evolving global landscape. Key insights from this work helped shape Toitu’s guidance on certificate tracking, emissions quantification, accounting treatment, and the transparent disclosure of SAF-related impacts — strengthening consistency and credibility across both client applications and wider market practice.
Impact
This work gives organisations greater confidence to participate in Air New Zealand's Scope 3 SAFc Programme, with the confirmation that the emissions reductions can be recognised within Toitū's Climate Impact Programme. It establishes Air New Zealand’s Scope 3 SAFc Programme as a practical, high-integrity option for addressing Scope 3 business air travel and air transport emissions. By supporting greater participation, this work helps build demand for SAF, supporting its scale-up and the decarbonisation of aviation.
Broader influence
As one of New Zealand’s leading authorities on credible climate impact, Toitū is playing a defining role in shaping how Sustainable Aviation Fuel certificates (SAFc) are understood, accounted for and applied in practice. Following the engagement with Air New Zealand’s SAF Programme, Toitū has developed the first high-integrity, independently developed approaches to SAFc accounting in New Zealand, aligning with emerging global climate reporting frameworks — positioning Toitū as an active contributor to emerging global best practice.
By establishing a rigorous, transparent framework aligned with international standards and evolving guidance, Toitū is helping to set the benchmark for credible SAFc accounting in New Zealand. This work reinforces Toitū’s role as a standard bearer — providing clarity in an uncertain and rapidly developing market, enabling consistent application across organisations, and supporting the wider scale-up of SAF as a critical decarbonisation solution for aviation.
What’s next
With a strong foundation now in place, Air New Zealand's focus is on scaling its Scope 3 SAFc Programme to help drive investment in SAF. New Zealand businesses play an important role in this. With the airline managing the complexity of SAFc, organisations can focus on the impact of their SAFc purchases. Air New Zealand will continue to work with New Zealand organisations to grow awareness and support the market development needed to accelerate adoption of sustainable aviation fuel.
Toitū acknowledges that SAFc accounting remains an emerging field, standards, guidance and market expectations may evolve rapidly. We will continue to monitor developments and refine our approach as required to maintain alignment with international best practice and high standards of credibility and integrity.
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Javier Aylwin
Primary Industries, Manufacturing & Transport
