Publication of start-up aid tender for new routes at Sardinian airports

The Autonomous Region of Sardinia has launched a tender for start-up aid supporting new air routes to and from its three main airports in 2027 and 2028. The notice was published in the Official Journal of the EU (the “OJ”) on 28 October 2026. It invites airlines to submit their projects within 30 days of this publication. 

The Sardinia start-up aid scheme was approved by the European Commission in June 2024.

This tender comes as the Commission proposes to end such aid following its revision of the 2014 Aviation Guidelines. The Commission refers to the very limited number of notifications to justify the absence of need for such support while this lack of success is due to the actual form of the start-up aid– rebates on airport charges – as many airports have implemented such general incentives outside the scope of State aid rules. 

The announcement to end start-up aid has been criticised by various interested parties, including airports and airline associations that have invited the Commission to provide for a more workable instrument. 

Current framework for start-up aid

Under the 2014 Aviation Guidelines, Member States may support airlines launching new routes from regional airports that have up to three million passengers per year (or up to five million per year in exceptional circumstances). Start-up aid takes the form of rebates on airport charges and ground-handling fees. 

Such aid schemes must be notified by Member States to the European Commission before their implementation. The Commission authorises those aid schemes subject to specific conditions, including:

• The scheme must increase mobility by establishing access points for intra-EU flights or facilitating regional development.
• The supported route must not compete with a high-speed rail service or with another airport in the same catchment area under comparable conditions.
• The airline must either submit an ex ante business plan demonstrating the route’s profitability after three years or irrevocably commit to operating it for at least the double of the duration of the aid, for instance six years if the aid is granted for three years.

Proposed end of start-up aid under the draft revised Aviation Guidelines

The Commission’s draft revised Guidelines on State aid to airports and airlines that was submitted in May 2026 for public consultation provide for the end of start-up aid. The Commission refers to the 2020 Fitness Check and the Commission’s case practice since 2014 to demonstrate that the start-up aid provisions have been used only rarely: the Commission has approved 20 start-up aid schemes and individual measures under the 2014 Aviation Guidelines. The Evaluation Study also found that the sector had opened many new routes since 2014 without relying on start-up aid. On that basis, the Commission considers that start-up aid does not appear to have been an effective tool for promoting regional connectivity through the creation of new air routes.

However, as mentioned above, start-up aid has not been as successful as anticipated. One explanation lies in the Lübeck Airport case law, which confirmed that transparent and non-discriminatory discounts on airport charges introduced by an airport do not constitute State aid to the airlines concerned and therefore do not require prior notification to the Commission.

For the Commission’s public consultation on its draft, interested parties, including airports and airline associations, were invited to submit contributions on the proposed revision of the Aviation Guidelines, and several stakeholders voiced concerns regarding certain aspects of the draft text. As regards start-up aid in particular, ACI EUROPE recommended retaining it as a targeted and proportionate instrument for regional connectivity, while revising the framework to improve legal certainty, administrative practicability and effectiveness. It argued that the complete removal of start-up aid envisaged by the draft Guidelines would undermine broader EU objectives relating to territorial cohesion, accessibility and balanced regional development, while creating legal uncertainty, particularly in countries that rely on State aid guidance rather than airport-charge approval regimes. 

Sardinia moves ahead with start-up aid under the current Aviation Guidelines

Against this background, a notice was published in the OJ on 28 October 2026 announcing a public tender by the Autonomous Region of Sardinia for aid to airlines launching new routes to and from the Alghero-Fertilia Riviera del Corallo, Olbia Costa Smeralda and Cagliari-Elmas Mario Mameli airports. Airlines that are interested in launching new routes under this aid scheme have to submit their applications within 30 days of this publication. 

The call and related documents are available on the Sardinian regional authority’s website:  https://www.regione.sardegna.it

For more information on the revision of the guidelines, we invite you to read our previous articles on EU Evaluation Support Study for Revision of Aviation Guidelines and on the draft new European Commission Guidelines on State aid in the aviation sector.