Publication by the European Commission of the Evaluation Support Study for the Revision of the Aviation Guidelines
The European Commission is currently reviewing the Guidelines on State aid to airports and airlines adopted in 2014 (“Aviation Guidelines”).
As part of this review, the Commission launched a public consultation at the end of 2024 to gather feedback from the sector on the application of these Aviation Guidelines.
In parallel with this consultation, the Commission instructed external consultants to assess the revision of the Aviation Guidelines, taking into account changing market dynamics, the impact of the pandemic and the challenges posed by the green transition for the air transport sector within the European Union. This study followed on from a previous study carried out in 2019, which confirmed the structural lack of profitability faced by airports handling fewer than 700,000, or even 1,000,000, passengers per year.
In March 2026, the Commission published this study, which will guide it in determining its future rules on State aid for airports and airlines.
The Aviation Guidelines
The Aviation Guidelines set out the conditions under which the European Commission authorises operating and investment aid for airports and start-up aid for new routes in the context of notifications made by Member States. The Commission may also approve such aid at a later stage if there are investigations into unlawful aid following complaints or on its own initiative.
As a reminder, operating aid is available for airports handling up to 3 million passengers per year, with a more favourable regime for airports handling fewer than 700,000 passengers per year, provided certain strict conditions are met. In practice, the compatibility conditions – and in particular the cap on the subsidy at a certain percentage (50% or 80% depending on the size of the airport) of the average deficit of the airport concerned over the 2009–2014 period – have made their practical application extremely complicated, as evidenced by the limited number of notifications of such aid to the Commission. However, more than half of European airports are unprofitable and should in practice benefit from such aid, as confirmed by the Evaluation Support Study for the Revision of the 2014 Aviation Guidelines.
Investment aid may be granted to airports handling up to 5 million passengers per year to finance airport infrastructure (excluding commercial facilities such as car parks, restaurants and hotels). The amount of aid may not exceed the funding gap of the investment project and is capped in any case at a maximum aid intensity rate, which is degressive depending on the size of the airport: a maximum of 75% of investment costs for airports with fewer than 1 million passengers per year, a maximum of 50% for airports with between 1 and 3 million passengers per year, and 25% for airports with between 3 and 5 million passengers per year.
This category of aid has seen more notifications from Member States to the Commission than operating aid. However, the conditions remain problematic for the smallest airports, which are unprofitable and must be able to finance at least 25% of investment costs from their own resources. This is particularly the case for investments needed for upgrading facilities to meet safety standards or for modernising infrastructure, which do not generate additional revenue.
Finally, the Aviation Guidelines provide for the possibility of authorising start-up aid for airlines launching new routes from regional airports. Start-up aid are granted in the form of discounts on airport charges and ground handling fees. Such aid may be granted at airports handling up to 3 million passengers per year and up to 5 million passengers per year in exceptional circumstances. The European Commission authorises such aid subject to certain conditions, notably non-competition with high-speed rail services and the airline’s obligation to submit an ex ante business plan demonstrating the route’s profitability after three years, or the airline’s irrevocable commitment to operate the route for a period at least as long as that during which it receives the start-up aid. This aid has not been as successful as hoped, particularly due to European case law in the Lübeck Airport case, which confirmed that the introduction by an airport of transparent and non-discriminatory discounts on airport charges did not constitute aid to the airlines concerned and therefore did not require prior notification to the European Commission.
The revision of the Aviation Guidelines
The Aviation Guidelines were adopted for an indefinite period, with the exception of operating aid for regional airports – those handling between 700,000 and 3,000,000 passengers per year – which was authorised for a transitional period of 10 years, extended until April 2027 due to the pandemic. For airports with fewer than 700,000 passengers per year, the Commission was required to carry out an assessment of the application of this aid five years after its entry into force. This five-year period has been renewed and the duration of the operating aid has been extended in view of the impact of the pandemic.
Recently, the Commission launched a more comprehensive review of the Aviation Guidelines and, in this context, launched a public consultation at the end of 2024 to gather feedback from industry stakeholders on the application of State aid rules.
In parallel with this consultation, the Commission commissioned external consultants to assess the revision of the Aviation Guidelines.
The study supporting the assessment for the revision of the 2014 Aviation Guidelines
This study, published in March 2026 by the European Commission, unsurprisingly confirms the lack of structural improvement in airport profitability since 2014 and concludes that it is unlikely that these regional airports will achieve full cost recovery by 2027, notably due to the impact of the pandemic, geopolitical instability and rising energy costs, which are creating bottlenecks in the supply chain.
The study reveals that just over 50% of European regional airports were covering their costs in 2024. Small regional airports are more vulnerable due to high fixed costs, the seasonal nature of traffic and limited commercial revenue resulting from low passenger volumes.
According to data collected as part of this study, regional airports with fewer than 700,000 passengers per year are less likely to cover their costs on average. Furthermore, the number of passengers required to reach the break-even point is rising due to increased operating and investment costs (decarbonisation measures, safety and security requirements, modernisation and digitalisation).
The study therefore confirms the need to maintain operating and investment aid for these airports. It also demonstrates that regional airports make a positive contribution to connectivity and local economic development, particularly in the outlying regions of the European Union.
The study also analyses the interactions between State aid for airports and airlines and the development of high-speed rail services. Although start-up aid is not permitted for routes already served by such high-speed rail services, the study notes that these services may have an impact and that this may affect climate objectives.
Regarding the decarbonisation of the aviation sector, airports contribute only modestly to the sector’s direct emissions, but the study acknowledges that they have an important role to play in this decarbonisation, notably through the introduction of electric ground support vehicles, Sustainable Aviation Fuel (SAF), renewable energy and environmental reporting. However, small airports face specific challenges in this transition due to their limited financial resources.
Regarding the application of the current Aviation Guidelines, the industry stakeholders consulted consider them to be unclear and overly rigid. Clarifications are needed regarding the concept of non-economic activities such as security, the protection perimeter around an airport and dual-use investments. Furthermore, the requirements for prior notification to the European Commission impose a significant workload on small airports with limited resources, particularly with regard to the detailed preparation of business plans, funding gap analyses and counterfactual scenarios. The notification procedure is considered too slow, bureaucratic and costly.
You will find the link to the study below:
Developments in European State aid rules in the aviation sector
The European Commission is currently finalising its draft of the new Aviation Guidelines based on the conclusions of this study. This draft will be subject to a public consultation shortly. The updated Aviation Guidelines are due to come into force in April 2027.
It should be noted that the Commission has already implemented other measures to simplify the application of State aid rules to airports. Firstly, in December 2025, it adopted its new decision on the application of Article 106(2) of the Treaty on the Functioning of the European Union to State aid in the form of public service compensation granted to certain undertakings entrusted with the operation of services of general economic interest (“SGEI”). This SGEI decision allows public service compensation to be granted to airports in remote regions serving up to 500,000 passengers per year. Unfortunately, the Commission adopts a restrictive interpretation of the concept of SGEI, which is narrower than that of public service in many Member States.
Furthermore, in March 2026, the European Commission presented its draft General Block Exemption Regulation as part of a public consultation. The General Block Exemption Regulation provides for the possibility for Member States to grant, without prior notification to the European Commission, investment aid to airports handling up to 3 million passengers per year and operating aid to airports handling fewer than 200,000 passengers per year.
As part of the revision of this Regulation, the Commission proposes to extend its scope to include operating aid for airports handling up to 500,000 passengers per year, regardless of the presence of other airports in the same catchment area.
However, for investment aid for airports handling between 500,000 and 3 million passengers per year, the Commission is considering extending the exemption from this Regulation in the event of the presence of another airport within a catchment area of 150 km or 200 km, depending on the outcome of the ongoing public consultation. The current catchment area is set at 100 km.
The new General Block Exemption Regulation will enter into force on 1 January 2027.
