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EUROPEAN BUSINESS AVIATION ASSOCIATION

EBAA

The European Business Aviation Association represents the interests of the business aviation sector across Europe.

Lobbying Activity

EBAA Urges EU Taxonomy Inclusion for Small Aircraft

5 Dec 2025
Topic — The European Commission is reviewing environmental criteria for its sustainable investment classification system.
Message — The association requests the inclusion of aircraft with 19 seats or fewer in the climate regulation. They argue that business aviation serves as a primary incubator for zero-emission flight technologies.12
Why — Inclusion would signal that Europe is open for business and attract sustainable investment.34
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Meeting with Seán Kelly (Member of the European Parliament) and General Aviation Manufacturers Association

11 Nov 2025 · State of the Irish aviation industry

European Business Aviation Association urges proportionality and SAF credit reform

8 Jul 2025
Topic — This consultation evaluates the EU Emissions Trading System for aviation and maritime sectors.
Message — EBAA urges the EU to respect the principle of proportionality for small emitters through streamlined monitoring. They also request the formal recognition of a book-and-claim system for sustainable fuels.12
Why — Lower administrative and financial costs would benefit small and medium-sized aviation operators.3
Impact — Environmental protection efforts lose as sector exemptions may reduce the overall impact of emissions pricing.4
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EBAA urges EU to reject flight bans and operational hurdles

6 Jun 2025
Topic — This consultation updates common rules for air services to ensure sustainable and competitive aviation.
Message — The association opposes flight bans and requests more flexible financial rules for small operators. They also want better access to efficient flight paths and priority for urgent missions.123
Why — These changes would protect small operators and lower their fuel and operational costs.45
Impact — Regional economies lose significant investment if short-haul business flights are restricted.6
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Meeting with Pierpaolo Settembri (Cabinet of Commissioner Apostolos Tzitzikostas)

4 Apr 2025 · Cabinet received a presentation on EBAA and its activities

Meeting with Eddy Liegeois (Head of Unit Mobility and Transport)

6 Feb 2025 · Introductory meeting of the European Business Aviation Association

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

5 Dec 2024 · Panel discussion on business aviation

Meeting with Daniel Attard (Member of the European Parliament)

16 Oct 2024 · Priorities for EBAA

Meeting with Jan-Christoph Oetjen (Member of the European Parliament) and Lufthansa Group

12 Sept 2024 · General exchange on current aviation topics

EBAA Urges Simplified Rules for Non-CO2 Emission Reporting

29 Jul 2024
Topic — The EU is updating rules for monitoring and reporting non-CO2 aviation emissions.
Message — EBAA requests simplified reporting for small operators and a delay in using climate impact metrics. They also advocate for an EU-wide system to track and claim cleaner aviation fuels.123
Why — This would reduce administrative burdens and prevent potentially inflated calculations of the sector's climate impact.45
Impact — Environmental groups lose precise data if climate metrics are omitted from the initial reporting phase.6
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EBAA Urges Inclusion of Small Business Aircraft in EU Taxonomy

3 May 2023
Topic — A classification system defining environmentally sustainable investments to support EU environmental objectives.
Message — The EBAA requests including aircraft carrying 19 passengers or less in the taxonomy regardless of their specific use. They recommend aligning CO2 and noise standards with international ICAO regulations rather than unique EU criteria. Additionally, they ask to synchronize sustainable fuel targets with the ReFuelEU Aviation regulation.123
Why — This would secure necessary investments and lower financing costs for developing cleaner aviation technologies.45
Impact — European manufacturers lose global competitiveness against non-EU actors due to distorted regulatory competition.67
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

18 Nov 2021

Building a fair and inclusive SAF framework ensuring a level playing field for business aviation (more details in the attached position paper) The business aviation community understands that a serious and credible legislative proposal aiming at increasing the uptake of SAF in Europe has to be realistic and based on an incremental approach so the SAF value chain has the time and the resources to develop the required infrastructures and levels of production to meet the objectives of the proposal and more broadly the goals of the Sustainable and Smart Mobility Strategy. Nevertheless, based on the current provisions and definitions of the proposal, it appears that around half of our operations will be excluded from the benefit of using SAF and contributing not only to the aviation industry wide efforts to reduce the carbon footprint of our sector but also to meet our own Business Aviation Commitment on Climate Change. Indeed the definitions of ‘Union airports’ and ‘aircraft operators’ will have a negative impact on our capacity to use SAF since our sector is composed of many ‘small’ operators sometimes operating one or two aircraft only that do not reach the threshold of 729 departures from Union airports and the definition of Union airports itself will also exclude a significant part of our operations as our sector very much relies on secondary or tertiary airports that do not fall within the definition of Union airports. The business aviation community is convinced that a robust ‘book & claim’ system could overcome the negative externalities of an incremental approach that will make SAF available at key hubs only and will favour airlines flying to those key hubs. A Book & Claim system can: • Allow operators to purchase SAF even if it is not available in their re-fuel location; • Provide customers with a means of supporting decarbonization of aviation; • Help bring finance into the SAF system that might not have been there otherwise; • Support the virtuous cycle of increasing availability and demand of SAF. A Book & Claim system for SAF means one can purchase (“book”) a volume of SAF anywhere on the planet, know it will be used even without having direct access to it, and “claim” the acknowledgment of its use toward sustainability programs, market-based measures, or legislative mandates. For instance, a Book & Claim system should enable operators, through its use, to qualify for credits in the EU ETS and CORSIA, as well as rebates from any future national, EU, or global aviation taxation schemes related to environmental considerations. Such a system has already been in use in the energy market for many years and is commonly recognized for its added value in support of renewable energy production.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

The European Business Aviation Association (EBAA) calls on Member States and the European Commission to build a fair, inclusive and non-discriminatory energy taxation framework for business aviation. Key takeaways (more details in the attached position paper): - Business Aviation is ready to play its role in the transformation of the EU into a modern, resource-efficient and competitive economy, which would lead to a removal of the aviation fuel exemptions for intra-EU flights ; - EBAA calls for tax harmonisation among the European Member States to ensure simplicity and avoid distortion of competition ; - EBAA calls for implementing the general tax regime applicable to all commercial air transport flights to business aviation flights operated for commercial purposes (e.g. flights operated under a CAT licence). EBAA also calls for implementing this aviation tax regime to all flights being operated for remuneration / valuable consideration. EBAA calls for granting the fuel tax exemption to all medical and humanitarian flights; - Any cent collected should be allocated to aviation projects which contribute to environmental improvement, or are environmentally responsible ; - Simplification measures should apply to the low emitters in order to ensure that any new tax is not an impediment to SMEs’ growth.
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Meeting with Henrik Hololei (Director-General Mobility and Transport) and Airlines for Europe and

3 Mar 2021 · SES2+

Response to SESAR Common Project 1: Concluding the pilot phase of the SESAR deployment framework

14 Sept 2020

Thank you for the opportunity to provide comments on the Commission's proposal for a Regulation on CP1. EBAA's comments are detailed in the attached file.
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Response to External dimension of the EU policy on Passenger Name Records

11 Sept 2020

The Business Aviation Association (EBAA) is happy to provide in the attached file its feedback to the European Commission’s roadmap on the external dimension of the EU policy on Passenger Name Records.
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Response to Revision of the Energy Tax Directive

31 Mar 2020

EBAA would like to thank the Commission for the opportunity to contribute to the review process of the Energy taxation Directive; EBAA’s statement has drastically been adapted to take into account the Coronavirus crisis and its dramatic impact on aviation including Business Aviation. Almost all aircraft are and will remain grounded for several weeks. According to CAPA Centre for Aviation, a consultancy, most airlines in the world will be bankrupt by the end of May unless governments intervene. It is therefore a very challenging time to speak up about revising the aviation fuel exemptions. EBAA calls on freezing the review of the Energy Taxation Directive until the industry is back to a sound operational and financial situation. EBAA ‘s view on the review on the Energy taxation Directive must therefore be considered once the crisis is over and once airspace users will have been able to recover from it.
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Response to Revision of Regulation on performance and interoperability of surveillance for the single European sky

29 Jan 2020

EBAA supports the draft review of the SPI regulation and thanks the Commission for the opportunity to comment. Here are some requests for clarification: • The draft regulation makes reference to Annexes of ICAO Convention. Operators do not have access to the ICAO annexes. The regulation should clearly state the requirements imposed to airspace users and service providers. This comment also prevails for anyother regulation making sometimes reference to Eurocae standards. • Could the Commission clearly indicate in the law to which entity operators must address their retrofit/transition plan? • Could the Commission clarify to which entity operators -flying with aircraft registered in non-EU Member States – must address their plan / any request for clarification? Will it be EASA? • Could the Commission confirm whether a retrofit plan can be updated after June 2020 (as long as it plans for a retrofit before 7 June 2023).
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Response to European Partnership for Integrated Air Traffic Management

23 Aug 2019

ATM is as a cornerstone. As stated in the impact assessment document, ATM in the EU has improved thanks to the Single European Sky policy and, in particular due to the achievements of its technological component, the Single European Sky air traffic management research (SESAR) project. EBAA appreciates the opportunity offered to provide our view on the necessary next steps in order to cope with sustained air traffic growth and operations while maintaining or improving safety and environmental standards will being economical and flight-efficient. It is indeed urgent to set up a workable framework by increasing the capacity to meet the growing demand, reducing the complexity and fragmentation of European airspace management, optimising the flight trajectory without being constrained by airspace configuration or national boundaries. A different framework to handle the future ATM research and innovation program will allow us to embrace these future challenges. Option 2 as proposed in the impact assessment, is certainly a good approach to achieve this transition. The following key points are key to consider: • The SES should set up clearer roles and responsibilities and a robust institutional governance. • The Single European Sky should fit the operational needs of all airspace users, small & large, civil & military. One size does not fit all. The SES requirements must be affordable and workable for all airspace users. • The SESAR R&D and R&I should be customer and result-driven; Airspace Users are the end users carrying the passengers and paying ATC charges. Airspace Users want to have a clear focus on tangible results and quicker return on investments. • There needs to be a synchronized, coordinated and harmonized deployment both onboard and on-the-ground of mature technologies that have a clear and proven benefit. • Better regulation is key: o The SES must develop the required level of regulation (when necessary) and standards to ensure the deployment of only really mature SESAR solutions and avoid the regulatory gap between the validation phases of validation of a project (validation gates). ATM Research and Industrialisation must be shaped in way to avoid imposing the deployment of not mature solutions which require additional testing or additional standards. The poor experience with the Data Link and ADS-B shall not be duplicated. The Concept of Operations must include all the standards & legal requirements required prior to the industrialisation of the technology. o There is no need for any new airborne mandate from EBAA’s perspective. The SES framework should be built on what exists today /on the existing aircraft capabilities and should look for/enable for technical synergies. o In case of any new regulatory mandate, it should be based on a positive CBA or be associated with an easy access to funding to offset the negative CBA (this is often the case for smaller aircraft operators/ aircraft operators flying less hours). AUs are willing to invest in new technologies but only if they bring operational benefits to their business based on a proper business case. o The European mandates should be set up allowing AUs’ proper planning for equipment upgrades and investments in technology . The mandate deadlines should enable to couple several retrofit requirements at once. • The EU should push harmonisation at global level.
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Response to List of aircraft types and models exempted from meeting the requirements on data link services

6 Aug 2019

EBAA welcomes the amended version of the Data Link Services Implementing Rule which clearly states exemptions for aircraft ‘which have a certified maximum seating capacity of 19 passengers or less and a MTOM of 45359 Kg (100000 lbs) or less, with a first individual certificate of airworthiness issued before 5 February 2020;” While we warmly welcome this important amendment, several implementing issues still need to be resolved to ensure a smooth deployment of the system; • The lack of capacity of the data link system leads to oversaturation, meaning that some ATC messages are not going through. • The required communication ground infrastructure is not yet in place, or only partly. • More clarity is needed for airspace users that do not hold any agreement with data link service providers • Some of the technical requirements need to be better explained and addressed. More than 700 aircraft were recently asked to not use data link avionics in some parts of the European airspace (e.g. Maastricht area) showing the limits of the system as it stands today. The current AOC activity is already saturating the data link system and the situation is not likely to improve anytime soon. The latest generation of aircraft boast more sophisticated systems which continuously emit AOC messages raising capacity demand to unprecedented levels. Whilst multifrequency provides additional capacity on the short term, a more sustainable solution needs to be found. Business aviation operators don’t usually have significant AOC activity. Most of the newcomers get the datalink equipment onboard solely to comply with the ATC mandate, while airlines also use this for AOC messages. It is therefore essential to find a workable avionic solution, suitable to all airspace users, and to set up a proper datalink infrastructure (Model D as initially proposed in the ELSA study). If a trade off between ATC messages and AOC messages is required, the system should guarantee the flow of ATC messages as a preference at any time. Airspace users that do not hold any agreement with data link service providers should not have any constraint in sending ATC messages. We will continue to work with the European Commission, EASA and our partners to help find answers that benefit all airspace users.
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Response to Decision setting the Union-wide performance targets for the third reference period 2020-2024

25 Mar 2019

Please find attached the coordinated airspace user community response to RP3 target consultation.
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Response to Evaluation - Groundhandling services at airports

12 Mar 2019

One additional comment from one of our members: Our local FBO "FAS Frankfurt Aviation Service“ i.e. cannot provide passenger transport on the ramp because the airport operator FRAPORT insists that only two handling companies (FRAPORT Ground Services and WISAG) hold the license for this service. Therefore have to use them to transport the passengers of our business jet customers. This situation is unique in the Handling market and I do not know any other airport where a handling company faces such restrictions. The EU guideline has been made for commercial airline handling and the requirements for business aviation have not been considered. Most airports have realized this problem and issued additional licenses for business aviation handling companies i.e. we as BAS Berlin Aviation Service can offer the full FBO portfolio. Also other FBOs located outside Germany, for instance in Palma de Malllorca can provide all required services.
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Response to Clarifying the provisions for the data communication between aircraft and traffic controllers.

7 Mar 2019

This to provide you with an updated list of the feedback collected recently.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

16 Nov 2018 · business aviation developments

Response to Multiannual Financial Framework: Connecting Europe Facility 2021-2027

1 Aug 2018

Given the European Union is in the midst of preparing the next Multiannual Financial Framework – an opportunity to ease access to EU funding for Small and Medium-sized Enterprises (SMEs) which represent over 99% of businesses in the EU – EBAA is calling for improved access by SMEs to future calls for proposals and EU funding grants in the area of investment and research & innovation. Business Aviation operators are primarily SMEs, and as with SMEs in any other sector face significant difficulty in accessing the necessary finance to ensure continued growth.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

12 Feb 2018 · Access to airports, environment

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

24 Oct 2017 · Meeting with Mr Mitchener and Mr Baltus

Meeting with Violeta Bulc (Commissioner) and

12 Jan 2016 · Meeting EBAA representatives

Meeting with Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

1 Jul 2015 · Organisation of a meeting of the Board of EBAA with Commissioner Bulc in October

Meeting with Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

1 Jul 2015 · Preparatory meeting of the Board of EBAA with Commissioner Bulc in October