What It Means
- The airline fuel surcharge in the Philippines is now at Level 19, one step below the maximum the CAB’s regulatory matrix allows.
- The jump from Level 8 to Level 19 happened within a single 15-day pricing cycle, reflecting a jet fuel price environment the surcharge system was not designed to sustain long-term.
- Domestic cargo rates have also climbed, compressing margins for SME exporters and logistics operators who ship via air.
- Provincial tourism operators, MICE organizers, and event hosts who locked in participant pricing before the crisis now absorb the cost delta with no mechanism to pass it on.
- If jet fuel prices hold at current levels through May, the CAB will face a structurally new problem: what to do when Level 20 proves insufficient.
The Civil Aeronautics Board raised the passenger airline fuel surcharge to Level 19 for April 16 to 30. That puts it one notch below the highest tier the regulator’s own matrix allows. The number sounds technical. The structural position is not.
For the entire month of March, the surcharge sat at Level 4. It moved to Level 8 for the first half of April. Then, in a single 15-day adjustment, it jumped eleven levels. That is not a gradual climb tracking fuel costs. That is the matrix catching up to a fuel price shock it was built to buffer, not absorb.

How the Matrix Works and Where It Stops
The CAB’s fuel surcharge matrix has 20 levels, adopted in 2022. Each level corresponds to a range of jet fuel prices measured in peso per liter under the Mean of Platts Singapore benchmark. Level 19 kicks in when jet fuel is priced between ₱75 and below ₱78 per liter. Level 20 is the ceiling, covering everything above that.
The surcharge is not part of the base airfare. Airlines apply it on top of published fares after filing with the CAB. Under Level 19, domestic passengers pay ₱627 to ₱1,834 depending on distance. International passengers pay ₱2,070.77 to ₱15,397.15. For cargo, domestic rates now run ₱3.22 to ₱9.43 per kilogram, and international cargo ₱10.65 to ₱79.15 per kilogram.
Level 20 adds roughly ₱34 to ₱159 more per domestic passenger ticket, and up to ₱835 more per international passenger on the longest routes. Those are not dramatic numbers on their own. What matters is what Level 20 represents structurally: the matrix has no Level 21. If jet fuel prices remain above the Level 20 threshold, the CAB has no pre-approved mechanism to respond. The matrix, as written under CAB Resolution No. 25, Series of 2022, was not built for a sustained conflict-driven price environment.
Cargo Is a Separate Problem
Most airline fuel surcharge coverage focuses on passenger fares. The cargo dimension is where smaller operators take the harder hit.
Philippine domestic air cargo runs largely through passenger aircraft belly-hold space. When the airline fuel surcharge rises, cargo surcharges rise alongside it. For an MSME exporter shipping perishables or high-value goods by air, the cargo surcharge is a direct margin compression with no offsetting mechanism. Unlike a passenger who can postpone travel, a business shipping time-sensitive product cannot absorb a delay without a commercial cost.
The compounding risk: if Level 19 and Level 20 surcharges suppress passenger demand on thinner domestic routes, airlines may reduce flight frequencies. Fewer flights mean less belly-hold capacity. Less capacity means higher effective cargo rates even independent of the surcharge. SME exporters in Mindanao and Visayas, who depend on domestic air connections to move product to Manila hubs, are sitting at the intersection of both pressures.
The Demand Suppression Nobody Is Pricing In
Air travel on domestic routes is price-elastic at the margins. The C and D income segments that fly to Cebu, Davao, Palawan, and Boracay for leisure do not have fixed travel budgets. When the all-in cost of a ticket rises by ₱1,000 to ₱1,800 per person, some of those trips do not happen.
That demand suppression flows directly to provincial hospitality operators, small tour companies, resort-adjacent MSMEs, and local transport businesses in secondary destinations. Their pricing was set before the crisis. Their labor contracts and supplier commitments are not repriced mid-quarter. They absorb the volume drop.
A related exposure sits with domestic MICE organizers and event hosts who finalized participant pricing and logistics contracts in Q1. Travel costs for attendees have risen by amounts that were not in any pre-crisis budget. The organizer cannot reprice existing registrations without breaking commitments. The attendee who was planning to come may quietly opt out. The gap between projected and actual attendance lands on the event operator.
One Level Left
The CAB shifted to a 15-day surcharge review cycle in April as an interim measure. Transportation Secretary Giovanni Lopez had publicly hoped the surcharge would not reach Level 20. It is now at Level 19.
The International Air Transport Association put average global jet fuel at $184.63 per barrel as of April 17. Pre-conflict levels were $80 to $90 per barrel. That is not a temporary price spike with a clear reversal. It is a structural repricing of jet fuel tied to a geopolitical conflict with no visible resolution timeline.
If the May 1 to 15 cycle opens at current fuel price levels, the CAB’s options are Level 20 or a public acknowledgment that the matrix has run out of room. Either path opens a different kind of conversation about airline fuel surcharge architecture in the Philippines, one the regulator has not had to have publicly before.
Airlines will not absorb costs the matrix cannot accommodate. The question of who bears what the matrix cannot carry is one operators in air-dependent sectors should be watching.
Track more regulatory shifts that affect your business in Policy & Regulation section of Hemos PH.




