Cost-efficiency - Portugal

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PRB monitoring

  • The en route 2025 actual unit cost of Portugal was 33.44€2022, -9.5% lower than the determined unit cost (36.94€2022). The terminal 2025 actual unit cost was 133.14€2022, -7.4% lower than the determined unit cost (143.72€2022).

  • The en route 2025 actual service units (4.9M) were +3.2% higher than the determined service units (4.7M).

  • The en route 2025 actual total costs were -11.5M€2022 (-6.6%) lower than determined with all cost categories registering lower-than-planned costs, except depreciation. This is mainly due to lower staff costs for NAV Portugal (-10.0M€2022, or -8.9%). The NSA explained that this decrease is partly driven by favourable financial market conditions, which had a positive impact on the defined benefit pension fund.

  • NAV Portugal spent 25.3M€2022 in 2025 related to costs of investments for both en route and terminal charging zones, -3.9% less than determined (26.3M€2022). According to the NSA, this reduction is due to a smaller asset base.

  • The en route actual unit cost incurred by users in 2025 was 37.68€ (-5.5% below the 2025 DUC), while the terminal actual unit cost incurred by users was 151.68€ (-3.0% below the 2025 DUC). The difference between the AUCU and the DUC for the en route and terminal charging zones is mainly driven by pension costs in cost exempt from cost sharing.

En route charging zone

Unit cost (KPI#1)

Actual and determined data
Total costs - nominal (M€) 2025 2026 2027 2028 2029
Determined costs 187.5 196.2 202.2 204.6 203.9
Actual costs 175.9 NA NA NA NA
Difference costs -11.6 NA NA NA NA
Inflation assumptions 2025 2026 2027 2028 2029
Determined inflation rate 2.0% 2.0% 2.0% 2.0% 2.0%
Determined inflation index* 109.8 112.1 114.3 116.7 119.1
Actual inflation rate 2.2% NA NA NA NA
Actual inflation index* 110.5 NA NA NA NA
Difference inflation index (p.p.) +0.7 NA NA NA NA
*100 = 2022

AUC vs. DUC

In 2025, the en route AUC was -9.5% (or -3.50 €2022) lower than the planned DUC. This results from the combination of significantly lower than planned en route costs in real terms (-6.6%, or -11.5 M€2022) and higher than planned TSUs (+3.2%).

En route service units

The difference between actual and planned TSUs (+3.2%) falls outside the ±2% dead-band, but does not exceed the ±10% threshold foreseen in the traffic risk sharing mechanism. The resulting gain of additional en route revenues is therefore shared between the ANSP and the airspace users (see the main ANSP regulatory result).

En route costs by entity

Actual real en route costs are -6.6% (-11.5 M€2022) lower than planned. This is the result of lower costs for the main ANSP, NAV Portugal (-7.5%, or -11.4 M€2022) and the NSA/EUROCONTROL (-5.2%, or -0.6 M€2022), and higher costs for the MET service providers (+3.2%, or +0.2 M€2022) and the other ANSP (Portugal Continental SAR, +4.9%, or +0.3 M€2022).

En route costs for the main ANSP (NAV Portugal (Continental)) at charging zone level

Based on the additional information to the en route reporting tables, the significantly lower than planned en route costs in real terms for NAV Portugal in 2025 (-7.5%, or -11.4 M€2022) result from:

  • Significantly lower than planned staff costs (-8.9%), mainly due to significantly lower-than-expected defined benefit pension costs, driven by favourable financial market conditions, while remuneration and other social charges remained in line with plan.

  • Significantly lower than planned other operating costs (-6.6%), mainly due to lower electricity prices and reduced expenditure on rent and leasing, maintenance and repairs, and travel, partially offset by increased investment in IT and security.

  • Slightly higher than planned depreciation (+0.8%), driven by the commissioning of investments implemented in recent years.

  • Significantly lower than planned cost of capital (-10.1%), resulting from a smaller-than-expected asset base.

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

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

“Total en route costs, in real terms, were 6.6% lower than planned, which, combined with a positive deviation of 3.2% in service units, resulted in an actual unit cost 9.5% lower than projected.

This result was achieved mainly due to NAV Portugal, whose actual costs were 7.5% lower than the estimated costs, associated to the performance of defined benefit pension funds, where savings resulting from market factors – approximately 8.5 million euros – will be returned to airspace users in the next year. With the entry into force of Decree-Law No. 75/2024, of October 22, the powers relating to meteorological services for air navigation, which include the certification and supervision of aeronautical meteorological service providers (in this case IPMA), are transferred from GAMA to ANAC.”

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:

“Actual costs at charging zone level were slightly lower than the determined costs, as justified above but also due to efficiency gains achieved through organizational adjustments. In particular, following the entry into force of Decree-Law No. 75/2024 of October 22, responsibilities related to the certification and supervision of aeronautical meteorological service providers were transferred from GAMA to ANAC. This allowed the same objectives to be achieved with fewer additional resources than initially planned. The situation will continue to be monitored, as the impact of these changes may evolve over the reference period.”

Recommendations formulated by the NSA to the ANSP (NAV Portugal (Continental)) to rectify the situation and actions taken by the ANSP

No information was provided in the NSA 2025 Monitoring Report.

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

AUCU components (€/SU) – 2025
€/SU
DUC 39.85
Inflation adjustment 0.20
Cost exempt from cost sharing -1.96
Traffic risk sharing adjustment -0.28
Traffic adjustment (costs not TRS) -0.12
Financial incentives 0.00
Modulation of charges 0.00
Cross-financing 0.00
Other revenues 0.00
Application of lower unit rate 0.00
Total adjustments -2.17
AUCU 37.68
AUCU vs. DUC -5.5%
Cost exempt from cost sharing by item - 2025 €'000 €/SU
New and existing investments -460.0 -0.09
Competent authorities and qualified entities costs -481.1 -0.10
Eurocontrol costs -89.9 -0.02
Pension costs -8,506.4 -1.75
Interest on loans 0.0 0.00
Changes in law 0.0 0.00
Total cost exempt from cost risk sharing -9,537.3 -1.96

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 (37.68 €) is -5.5% lower than the nominal DUC (39.85 €). The difference between these two figures (-2.17 €/SU) is due to:

  • the positive inflation adjustment resulting from higher than planned inflation (+0.20 €/SU);

  • the impact of adjustments resulting from the costs exempted from cost sharing mechanism (-1.96 €/SU);

  • the deduction of the traffic risk sharing adjustments (-0.28 €/SU); and,

  • the deduction of the traffic adjustment (-0.12 €/SU) for the costs not subject to traffic risk sharing.

The share of the regulatory result (see next sub-section) in the AUCU (before the deduction of other revenues) is 6.4%.

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

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

“The effective savings in 2025 – when comparing the actual unit cost that will be borne by airspace users with the determined unit cost – were €2.17 per service unit, an effect that will be reflected in the price to be paid in subsequent years. This results from multiple factors, mainly those related to costs exempt from cost sharing, as explained in spreadsheet 2.4.1.A.ERT.”

Regulatory result (RR)

NAV Portugal (Continental) net gain/loss on activity in the Portugal Continental en route charging zone in 2025

NAV Portugal reported a net gain of +7.4 M€, as a combination of a gain of +3.5 M€ arising from the cost sharing mechanism, with a gain of +3.8 M€ arising from the traffic risk sharing mechanism.

NAV Portugal (Continental) overall regulatory result (RR) for the en route activity

Ex-post, the overall RR, taking into account the net gain from the en route activity mentioned above (+7.4 M€) and the actual RoE (+4.7 M€), amounts to +12.1 M€ (7.6% of the en route revenues). The resulting ex-post rate of return on equity is 13.5%, which is higher than the 5.3% planned in the PP.