Biscuits contain high proportions of saturated fats, which could lead to an adverse health effect. The objective of this study was to study the functionality of a complex nanoemulsion (CNE), stabilised with hydroxypropyl methylcellulose and lecithin, when used as a saturated fat replacer in short dough biscuits. Four biscuit formulations were studied including a control (butter) and three formulations where 33% of the butter was replaced with either extra virgin olive oil (EVOO), with CNE, or with the individual ingredients of the nanoemulsion added separately (INE). The biscuits were evaluated by texture analysis, microstructural characterisation, and quantitative descriptive analysis by a trained sensory panel. The results showed that incorporation of CNE and INE yielded doughs and biscuits with significantly higher (p < 0.05) hardness and fracture strength values than the control. The doughs made of CNE and INE showed significantly less oil migration during the storage than EVOO formulations, which was confirmed by the confocal images. The trained panel did not find significant differences in crumb density and hardness on the first bite among CNE, INE and the control. In conclusion, nanoemulsions stabilised with hydroxypropyl methylcellulose (HPMC) and lecithin can work as saturated fat replacers in short dough biscuits, providing satisfactory physical characteristics and sensory attributes.