EU Air Services Regulation
Consultation response | December 2025
Introduction
Since the EU Air Services Regulation was last revised in 2008 the aviation landscape has changed, with new decarbonisation objectives and and key legislation framed by the Fit-for-55 package. In response to the consultation on revising the regulation, the SASHA Coalition expressed support for the objectives of the Air Services Regulation to enhance resilience, competitiveness and sustainability.
It also encouraged the revision to integrate these climate obligations. Failing to do so, the Regulation would miss the opportunity to use air-services levers, such as market access conditions, measures in case of serious environmental problems, or public service obligations to support the sector’s transition.
Our recommendations
In order to use the Air Services Regulation as a means of advancing EU climate goals and ensuring the sector’s competitiveness, the European Commission should update the regulation in the following ways:
The Commission must keep its sights on an extended ETS covering international flights as the primary existing tool for ensuring a competitive aviation sector, a mechanism that was not included in the consultation survey.
We strongly support the proposal allowing Member States to require zero-carbon emission aircraft on short and medium-haul flights as part of the solutions to address environmental challenges. They are central for proactive, precautionary measures to drive decarbonisation while preserving connectivity.
We support the proposal to clarify that PSOs must include favourable environmental criteria to accelerate the emergence of “green PSOs”. The duration of green PSOs should also be extended to provide investment and revenue certainty for operators, and sustainability requirements should be integrated into tenders particularly those favouring zero-carbon emission technologies to enable the creation of regional testbeds to drive innovation.
Requiring a mandatory energy-transition plan when assessing the operators’ capacity to operate.