Cost-efficiency - Germany

PRB monitoring

The en route 2025 actual unit cost of Germany was 71.56€2022, -0.4% lower than the determined unit cost (71.87€2022). The terminal 2025 actual unit cost was 249.50€2022, -1.6% lower than the determined unit cost (253.46€2022).
The en route 2025 actual service units (14.9M) were +0.9% higher than the determined service units (14.8M).
The en route 2025 actual total costs were slightly higher than determined (+4.6M€2022, or+0.4%). This was mainly driven by negative exceptional items for DFS that were included in the determined costs so that this amount would not be charged to airspace users, as it related to unspent depreciation costs from RP2 and was therefore not included in the actual costs (+10.3M€2022). It was also driven by higher other operating costs (+7.1M€2022, or +6.8%) than planned due to additional costs for IT-security and bad debt losses. This was partially compensated by lower depreciation (-7.1M€2022, or -11.4%) than planned, which the NSA attributed to changes in projects and product management.
A deviation from the criteria to achieve capacity targets was considered justified for Germany. Actual costs for the measures necessary to achieve those targets were lower than determined (-14.1M€2022, or -28.1%), mainly due to lower staff costs (-12.2M€2022, or -42.2%) than planned.
DFS spent 98.2M€2022 in 2025 related to costs of investments for both en route and terminal charging zones, -11.2% less than determined (110.6M€2022). According to the NSA, this reduction was mainly due to “interest income from temporarily invested fixed deposits” and changes in some projects.
The en route actual unit cost incurred by users in 2025 was 77.21€ (-1.5% below the 2025 DUC), while the terminal actual unit cost incurred by users was 256.15€ (-7.7% below the 2025 DUC). The difference between the AUCU and the DUC for the terminal charging zone is mainly driven by the application of lower unit rate.

En route charging zone

Unit cost (KPI#1)

Total costs - nominal (M€)	2025	2026	2027	2028	2029
Actual and determined data
Determined costs	1,158.1	1,193.6	1,232.0	1,253.8	1,242.1
Actual costs	1,166.7	NA	NA	NA	NA
Difference costs	8.6	NA	NA	NA	NA

Inflation assumptions	2025	2026	2027	2028	2029
Determined inflation rate	2.1%	1.9%	2.1%	2.2%	2.2%
Determined inflation index*	110.9	113	115.4	118	120.5
Actual inflation rate	2.3%	NA	NA	NA	NA
Actual inflation index*	111.1	NA	NA	NA	NA
Difference inflation index (p.p.)	+0.2	NA	NA	NA	NA
*100 = 2022

Focus on unit cost

AUC vs. DUC

In 2025, the en route AUC was -0.4% (or -0.31 €2022) lower than the planned DUC. This results from the combination of slightly higher than planned TSUs (+0.9%) and slightly higher than planned en route costs in real terms (+0.4%, or +4.6 M€2022).

En route service units

The difference between actual and planned TSUs (+0.9%) falls inside the ±2% dead-band. Hence, the gain of additional en route revenues is kept by the ANSPs.

En route costs by entity

Actual real en route costs are +0.4% (+4.6 M€2022) higher than planned. This is the result of higher costs for the main ANSP, DFS (+1.0%, or +9.1 M€2022) and lower costs for the other ANSP (MUAC, -2.0%, or -2.2 M€2022), the MET service provider (-2.1%, or -0.2 M€2022) and the NSA/EUROCONTROL (-3.1%, or -2.1 M€2022).

En route costs for the main ANSP (DFS) at charging zone level

Based on the additional information to the en route reporting tables, the higher than planned en route costs in real terms for DFS in 2025 (+1.0%, or +9.1 M€2022) result from:

Slightly higher than planned staff costs (+0.4%), due to “additional costs for special payments to increase capacity provision”.
Significantly higher than planned other operating costs (+6.8%), due to “additional IT security costs and higher bad debt losses”.
Significantly lower than planned depreciation (-11.4%), mainly “due to changes in the projects MaRS, iCAS Lower Airspace as well as in the product management ATS-LAN”.
Significantly lower than planned cost of capital (-8.9%), which is understood to mainly reflect the fact that the actual cost of capital is netted off using an “interest income from temporarily invested fixed deposits” (see also the analysis of Regulatory Result for details).
No deduction of exceptional costs which were included as part of the determined cost-base for DFS for 2025 (negative amount). This negative amount of -11.4 M€ (in nominal terms) which was used to reduce the chargeable cost base for 2025 is understood to be related to depreciation costs charged to the airspace users but not spent during RP2.

Assessment of the actual performance in the charging zone reported by the NSA

The NSA of Germany provides the following overall assessment of the actual performance in 2025 at charging zone level:

“There are no major deviations between determined and actual enroute costs. Slightly lower costs and higher than determined traffic led to lower actual unit costs. Overall actual costs for NSA, MUAC and MET were below determined costs while DFS incurred higher actual costs.

Note: The determined costs for DFS in 2025 included an exceptional item for depreciation costs charged but not spent during RP2. They lowered the amounts charged to airspace users in 2025 but aren't reflected in the actual costs structure of the given year”

Explanation of the differences between actual and determined costs at charging zone level reported by the NSA

The NSA provides the following explanation for the differences between actual and determined costs in the charging zone:

“In 2025, DFS had higher than expected personnel costs, which can be attributed to incentivised extra ATCO shifts, and other operating costs, mainly for additional IT-security costs and bad debt losses. Depreciation and costs of capital were below planned levels as interest on temporarily invested fixed deposits was generated and projects were changed. Main changes to projects include MaRS, iCAS Lower Airspace and the product management ATS-LAN. Parts of the project PIPE2 were postponed due to resource constraints and a longer than anticipated internal decision process.

MUAC experienced slightly rising staff costs mainly attributable to pension costs. The other operating costs were lower than expected as cost containment measures in multiple areas were implemented, expenditure reprioritized and procurement processes experienced slight delays.

MET costs are below determined costs as changes in interest rates led to lower pension costs while the other operating costs rose slightly.

Changes in NSA costs are mainly rooted within expenses for personnel as actual staffing level is below the planned staffing level.”

Recommendations formulated by the NSA to the ANSP (DFS) to rectify the situation and actions taken by the ANSP

The NSA 2025 monitoring report indicates the following recommendations formulated by the NSA:

“As regards DFS the NSA recommends adhering to planned investment schedules more strictly and monitoring upcoming delays in project schedules more closely.”

DFS reports the implementation of the following actions:

“DFS is committed to adhering to the investment schedule as laid out in the performance plan and implementing planned measures on time. Any shortfalls are analysed and, if possible, actively managed to minimize delays in current and future investment implementation.”

Actual unit cost incurred by the users (AUCU) (PI#1)

	€/SU
AUCU components (€/SU) – 2025
DUC	78.43
Inflation adjustment	0.13
Cost exempt from cost sharing	-0.82
Traffic risk sharing adjustment	0.00
Traffic adjustment (costs not TRS)	-0.04
Financial incentives	-0.32
Modulation of charges	0.00
Cross-financing	0.00
Other revenues	-0.15
Application of lower unit rate	0.00
Total adjustments	-1.22
AUCU	77.21
AUCU vs. DUC	-1.5%

Cost exempt from cost sharing by item - 2025	€'000	€/SU
New and existing investments	-7,819.3	-0.52
Competent authorities and qualified entities costs	-2,086.3	-0.14
Eurocontrol costs	36.7	0.00
Pension costs	-2,304.8	-0.15
Interest on loans	0.0	0.00
Changes in law	-80.0	-0.01
Total cost exempt from cost risk sharing	-12,253.6	-0.82

Focus on AUCU

En route AUCU monitoring at charging zone level

The actual en route unit cost incurred by airspace users (AUCU) in respect of activities performed in 2025 (77.21 €) is -1.5% lower than the nominal DUC (78.43 €) which includes DUC initially charged: 79.83 €, and DUC to be charged retroactively: -1.40 €. The difference between the AUCU and the nominal DUC (-1.22 €/SU) is due to:

the positive inflation adjustment resulting from higher than planned inflation (+0.13 €/SU);
the impact of adjustments resulting from the costs exempted from cost sharing mechanism (-0.82 €/SU);
the deduction of the traffic adjustment (-0.04 €/SU) for the costs not subject to traffic risk sharing;
the impact of financial incentives (-0.32 €/SU); and,
the deduction of other revenues (-0.15 €/SU).

The share of the regulatory result (see next sub-section) in the AUCU (before the deduction of other revenues) is 2.3%.

Initiatives implemented or planned that will improve this PI reported by the NSA

The NSA of Germany provides the following information regarding the initiatives:

“During the last years the PI was primarily influenced by adjustments for traffic risk sharing and inflation as well as the incurred malus from the incentive scheme. The indicator is monitored on an ongoing basis while the possibility and necessity of a regulatory adjustment through Art. 29(6) is being assessed respectively.”

Regulatory result (RR)

Focus on regulatory result

DFS net gain/loss on activity in the Germany en route charging zone in 2025

DFS reported a net loss of -16.6 M€, as a combination of a loss of -20.2 M€ arising from the cost sharing mechanism, with a gain of +8.4 M€ arising from the traffic risk sharing mechanism and a loss of -4.8 M€ relating to financial incentives.

DFS overall regulatory result (RR) for the en route activity

Ex-post, the overall RR, taking into account the net loss from the en route activity mentioned above (-16.6 M€) and the actual RoE (+41.0 M€), amounts to +24.4 M€ (2.5% of the en route revenues). The resulting ex-post rate of return on equity is 3.1%, which is lower than the 6.2% planned in the PP.