Draft Guidelines on State Aid to the air transport sector - T&E consultation response

As Europe transitions to sustainable energy alternatives and away from fossil fuel dependence, the aviation sector and airports must follow. As described in our response to the Aviation Strategy, airports form an important part of the aviation transition. Not only must airports themselves reduce their own emissions, they must also support and incentivize sustainable aviation across the board. Leading in the transition will allow airports and the aviation sector to remain competitive in new technology and the development of e-SAF and zero-emission Aviation. This will also increase Europe’s energy sovereignty and ability to defend itself. Airports, often closely connected to their communities and government, can be a key driver for this transition.

Rather than aiming for volume-based growth and competing for routes, airports should put quality over quantity. They should halt expansion projects and focus on connectivity that adds true societal value while stimulating zero-emission technologies and investing in the aviation sector of the future. The EU State Aid guidelines should accelerate this transition and allow decisive support to those that lead. This briefing highlights the main positions of T&E regarding State Aid for regional airports and concrete proposals to improve the draft guidelines.

First, the draft guidelines extend the exemption on operating Aid to regional airports. The State Aid guidelines published in 2014 clearly specified operating Aid to regional airports was to be limited to 10 years. At the time, T&E provided detailed input on how the guidelines distorted competition and allowed harmful spending of scarce public resources. The exemption was extended by another five years due to Covid-related effects in 2023. Again, T&E concluded that such public funding did not align with the sustainability targets set by the EU for the transport and aviation sector. T&E’s latest analysis shows that European aviation emissions reached record highs in 2025, evidence that the sector has sufficiently recovered and operating Aid should be discontinued.

Second, when exemptions to State Aid prohibition are provided, specifically on investment support, the guidelines should ensure valuable public funding is only provided to airports that act in line with the EU’s climate neutrality objective. To ensure this, strict environmental conditionalities should be attached to any Aid granted, while Aid that supports airport growth or expansion should be discontinued.

Finally, the categories of airports that can benefit under operating and investment State Aid are too broad and not in line with what is necessary to support a transition to sustainable aviation. State Aid should only be provided in cases where there is an undeniable need for connectivity that cannot be provided through any other means of transport. State Aid can also be extended to airports that can play a role in stimulating sustainable aviation alternatives such as zero-emission aviation.