The Federal Government has initiated the update of the National Action Plan for the reduction of CO₂ emissions in civil aviation, now in its fifth edition. The document is being developed by the Ministry of Ports and Airports (MPOR), in collaboration with the National Civil Aviation Agency (ANAC) and the Department of Airspace Control (DECEA). It serves as Brazil’s primary guideline to the International Civil Aviation Organization (ICAO) in meeting global targets for the decarbonization of the aviation sector.

The new edition will incorporate short-, medium-, and long-term measures for emissions reduction, such as the expansion of the use of Sustainable Aviation Fuels (SAF), operational efficiency improvements, innovation incentives, and alignment with the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA).

The technical consultation is currently underway, and the final version is expected to be published by the end of 2025.

MJAB Insights: The update of the action plan for reducing CO₂ emissions in civil aviation represents a strategic opportunity for airlines, SAF producers, and logistics operators to influence the design of sector-specific public policies and to prepare for new environmental regulatory requirements.

The integration of the Brazilian plan with CORSIA and the targets set forth in Brazil’s Nationally Determined Contributions (NDCs) will require heightened attention to legal consistency and the avoidance of double counting of emissions, a subject still under debate within the national regulatory framework.

Moreover, the plan highlights the need for legal and economic instruments to enable the financing of green technologies through access to public funds and market-based mechanisms; the efficient allocation of climate-related responsibilities between the public and private sectors; and the contractual and institutional adaptation of projects that depend on regulatory predictability for their economic feasibility.

This is a pivotal moment for economic stakeholders in the sector to actively engage in the regulatory process, anticipate risks, and identify opportunities within the new cycle of sustainable investments in civil aviation.