Draft Guidelines on State Aid to the Air Transport Sector — T&E Consultation Response

Transport & Environment (T&E) has submitted a detailed response to the European Commission’s draft guidelines on State Aid for the air transport sector, urging a decisive shift away from supporting airport expansion and volume growth. As Europe moves towards sustainable energy and climate neutrality, T&E emphasises that airports must not only reduce their own emissions but also actively promote sustainable aviation technologies, including e-Sustainable Aviation Fuels (e-SAF) and zero-emission aircraft. The organisation argues that prioritising quality connectivity and innovation over passenger numbers will better serve societal interests and enhance Europe’s energy sovereignty. A key concern raised by T&E is the continued exemption of operating aid to regional airports, which was initially limited to ten years under the 2014 State Aid guidelines but has been extended multiple times, most recently due to Covid-19 impacts. T&E’s analysis shows that European aviation emissions reached record levels in 2025, suggesting the sector has recovered sufficiently and that ongoing operating aid is no longer justified. The organisation warns that such subsidies distort competition and waste scarce public funds that could be better invested in sustainable transport solutions. T&E also calls for stricter environmental conditions to be attached to any State Aid granted, particularly investment support, to ensure funding aligns with the EU’s climate neutrality goals. Aid should be directed only to airports that demonstrate a clear role in fostering sustainable aviation alternatives or provide essential connectivity that cannot be met by other transport modes. The current broad eligibility criteria risk supporting airports that do not contribute meaningfully to the green transition, undermining the EU’s wider environmental objectives. The consultation response advocates for a fundamental reform of the State Aid framework, recommending the cessation of operating aid to airports after a decade of exemptions. Instead, investment aid should be tightly targeted to airports that add genuine social value and help stimulate the development of zero-emission aviation technologies. By refocusing public funding in this way, the EU can better support a sustainable future for the aviation sector while safeguarding public resources and meeting its climate commitments.