The Air Services Regulation (Regulation (EC) 1008/2008) governs the EU internal market for air services. It sets rules on operating license requirements, the freedom to operate services in the EU, and price transparency. Following a 2019 evaluation and impact assessments conducted between 2018-2020 and 2021-2023, the European Commission restarted the impact assessment for a possible targeted revision of the Regulation, reflecting lessons learned from Covid-19 and evolving market, geopolitical, and environmental conditions.

For the European Passengers’ Federation, the revision should prioritise two topics in particular:

➡️ Price transparency. To safeguard and enhance price competition and price transparency, specific provisions are needed with regard to ancillary services. Fares and (core) ancillary fees should be available on all distribution channels, allowing passengers to compare offers across carriers on a like-for-like basis. Furthermore, the right to reimbursement in case of cancellation by the passenger needs to be clarified, non-discrimination in access to fares has to be guaranteed, and more effective enforcement and consumer redress options are necessary.

➡️ Better passenger protection. The revision also needs to address two key issues announced by the Better Protection for Passengers and their Rights initiative and aligning passenger rights under the Package Travel Directive & Air Passenger Rights: protection against the risk of a liquidity crisis or an insolvency (mandatory insolvency protection mechanism/ guarantee schemes & designation of public authorities to coordinate repatriation and passenger assistance); and the right to self-cancellation by air passengers, notably (but not only) in case of a major crisis.

EPF has updated its 2019 position paper on price transparency, incorporating our views on enhancing passenger protection during disruptions and crises, and reaffirming our 2023 response to the Better Protection for Passengers and their Rights initiative on insolvency protection and self-cancellation rights. We also provide brief comments on additional areas, less central to EPF’s focus, addressed in the revision:

• Air Traffic Control (ATC) Strikes: EPF respects workers’ right to strike but advocates for proportionate measures – such as a minimum 15-day strike notice and safeguarding overflights – to mitigate the broader impact of ATC strikes on European air transport and better protect passengers, who are not parties to industrial disputes.
• Competitiveness and Uneven Playing Field: EPF supports the principle that all airlines operating to or from the EU – whether EU or non-EU – should comply with the same rules, including on safety, decarbonisation levies, and passenger rights. Compliance should be mandatory for licensing, with repeated violations leading to sanctions.
• Ownership & Control Guidelines: EPF highlights the risk of further airline consolidation, which could reduce competition, increase prices, and lower service quality. The European Commission should therefore carefully assess mergers and, where necessary, block deals or impose remedies to protect competition and passengers.
• Environmental Flight Bans & PSOs: Modal shift should focus on better service rather than flight bans (which requires adequate alternatives and stakeholder – including passenger – consultation). PSOs may be justified where air services are socially necessary, essential for connectivity, and cannot be replaced by greener transport.

Finally, the Air Services Regulation should align with related passenger protection and price transparency rules to ensure coherent, comparable, and fair travel information and passenger protection across transport modes.

📄 Read EPF’s position paper here