Closing the Gap: the case for a GGR mandate

In October 2025, the Government published the Whitehead review, an independent review of greenhouse gas removals in the UK. For aviation, expected to be one of the sectors with the largest residual carbon emissions in 2050, it proposed a ‘Net Zero Aviation Mandate’, a mechanism to expand the scope of the SAF mandate to allow in greenhouse gas removals (GGRs). AEF has worked with independent consultant Matt Finch to suggest ways such a mechanism might be designed; here are his thoughts: