Róman Kok
Director Public Affairs & Communications
By Róman Kok, Director Public Affairs and Communications EBAA
Why the EU Aviation Strategy must reflect the full transport ecosystem and what it will take to make that case land in Brussels.
Each new European Commission brings with it a familiar dynamic. Mandates are negotiated, strategic priorities are established, and stakeholder consultations open across every sector of the economy. In that process, the quality of the argument matters as much as the volume of the voice. We at EBAA have published our views on the EU Aviation Strategy precisely with that in mind.
Business aviation represents 7% of European aviation traffic. It serves over 1,500 airports across the continent, 1,000 of which have no scheduled airline service at all. It saves an average of 127 minutes per flight compared to the fastest available commercial alternative. It performs 60,000 medical missions every year. In 2025, the sector supported around 450,000 jobs and contributed approximately €100 billion to European GDP. These are not marginal figures. They are the foundations of a sector that has earned, and deserves, serious policy attention.
Yet in Brussels, business aviation is still too often reduced to a caricature. The claims are familiar: that the sector escapes regulation, that its environmental footprint is disproportionate, that it serves narrow interests at the expense of broader European goals. These claims are not supported by the evidence. Business aviation accounts for roughly 2% of aviation emissions in Europe and 0.04% of global greenhouse gas emissions. It is already subject to the EU ETS, ReFuelEU Aviation and CORSIA. And the overwhelming majority of its flights serve business, governmental and medical purposes, not leisure. The persistence of these misconceptions in policy debate is itself a challenge that the sector must address, and one that EBAA takes seriously.
EBAA's paper sets out three priorities for the Aviation Strategy: protecting the right to operate, securing fair access to airports, and enabling a credible and proportionate path to decarbonisation. Each reflects a structural problem that arises when regulatory frameworks designed for large scheduled carriers are applied, without adaptation, to a sector that operates on entirely different terms.
The EU Slot Regulation offers the starkest illustration. Its 80% utilisation threshold was designed to prevent slot hoarding by airlines operating fixed timetables on predictable routes. Applied to a non-scheduled operator whose flights are demand driven and often confirmed at short notice, that same rule becomes structurally exclusionary. Business aviation operators cannot accumulate or retain the historic slot portfolios that give scheduled carriers their dominant position at congested airports.
The Eindhoven case made this concrete. A District Court in the Netherlands confirmed that under the current Regulation, there is no legal basis to protect non-scheduled access where airline priority rules and historic rights dominate available capacity. Business aviation was effectively excluded from an airport it had served for years, not through any deliberate act of discrimination, but as the logical consequence of rules calibrated to a different operating model. Without reform, this outcome will be reproduced at other constrained European airports. The legal analysis is clear, and the policy response needs to match it.
EBAA is not seeking preferential treatment for business aviation. The ask is a proportionate access mechanism designed to reflect how non-scheduled aviation actually operates. That is a reasonable position, grounded in how airport markets function, and it deserves to be treated as such.
Business aviation's commitment to decarbonisation is longstanding and substantive. The Business Aviation Commitment on Climate Change, established in 2009, sets a net zero target for 2050 and reflects a genuine record of technological leadership: the sector helped pioneer winglets, composite materials and fly-by-wire systems, and is now at the forefront of SAF adoption and the early commercialisation of electric and hydrogen aircraft. The pipeline of zero and low emission platforms advancing through EASA certification is real, and business aviation, with its shorter ranges, lower passenger loads and access to regional aerodromes, is structurally well placed to be among the earliest adopters.
The concern is with the design of the compliance architecture, not with the direction of travel. The anti-tankering provisions of ReFuelEU Aviation were conceived with large network carriers in mind, operators with fixed routes, established fuel supply relationships at major hubs, and dedicated compliance teams. Around half of all business aviation flights are under 500 kilometres, and the sector operates across hundreds of airports, many outside the Union. Applying rigid SAF uplift requirements uniformly across that landscape imposes substantial administrative costs on small and medium sized operators without delivering commensurate environmental benefit. That is not a climate argument. It is an effectiveness argument.
Proportionality and ambition are not in tension. A book and claim mechanism that decouples SAF credits from physical uplift location, targeted adjustments to the anti-tankering provisions, and simplified ETS compliance pathways for smaller operators would allow the sector to contribute more effectively to the green transition — not less. That is the case EBAA is making, and it is one that the evidence supports.
Aviation policy is being written now. The question is not whether business aviation will feature in it, but on what terms. That depends on the quality and persistence of the case being made, in Brussels and through the Member States alike.
For those working on transport, competitiveness or sustainability policy across the EU institutions: the European transport ecosystem extends well beyond the major hub airports and high speed rail corridors that tend to dominate the policy conversation. It includes the aircraft that delivers an organ to a hospital within hours, the flight that connects a company's headquarters to a production facility in a region with no viable rail alternative, and the emergency mission that can be mobilised when no other asset is available.
An aviation strategy that overlooks that reality is not a strategy for European aviation. It is a strategy for part of it.