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      • Terminal CZ - Romania Zone 3
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    Cost-efficiency - Romania

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    Terminal charging zone - Romania Zone 3

    Unit cost

    Actual and determined data
    Total costs - nominal (M€) 2025 2026 2027 2028 2029
    Determined costs 10.6 11.6 12.2 12.6 13.4
    Actual costs 12.3 NA NA NA NA
    Difference costs 1.7 NA NA NA NA
    Inflation assumptions 2025 2026 2027 2028 2029
    Determined inflation rate 4.0% 3.3% 3.0% 3.0% 3.0%
    Determined inflation index* 121 125.1 128.8 132.7 136.7
    Actual inflation rate 6.8% NA NA NA NA
    Actual inflation index* 124 NA NA NA NA
    Difference inflation index (p.p.) +2.9 NA NA NA NA
    *100 = 2022
    NoteFocus on unit cost

    AUC vs. DUC

    In 2025, the terminal AUC was +18.0% (or +435.70 RON2022, +88.41 €2022) higher than the planned DUC. This results from the combination of significantly higher than planned terminal costs in real terms (+13.0%, or +5.7 MRON2022, +1.2 M€2022) and lower than planned TNSUs (-4.2%). It should be noted that the actual inflation index in 2025 was +2.9 p.p. higher than planned.

    Terminal service units

    The difference between actual and planned TNSUs (-4.2%) falls outside the ±2% dead-band but does not exceed the ±10% threshold foreseen in the traffic risk sharing mechanism. The resulting loss of terminal revenues is therefore shared between the ANSP and the airspace users (see the main ANSP regulatory result).

    Terminal costs by entity

    Actual real terminal costs are +13.0% (+1.2 M€2022) higher than planned. This is the result of higher costs for the main ANSP, ROMATSA (+13.1%, or +1.2 M€2022) while the NSA costs were broadly in line with the plan (+0.1%).

    Terminal costs for the main ANSP (ROMATSA) at charging zone level

    Based on the additional information to the terminal reporting tables, the significantly higher than planned terminal costs in real terms for ROMATSA in 2025 (+13.1%, or +1.2 M€2022) result from:

    • Significantly higher than planned staff costs (+13.1%), reflecting “an increase of pension costs, compensation of personnel with inflation and non-recurring amounts for the higher than planned traffic and achievement of capacity targets”.

    • Significantly higher than planned other operating costs (+30.3%), understood to result from: 1) the impact of higher than anticipated inflation on the prices of materials and external services, 2) the impact of exchange rate fluctuations on the costs of licences maintenance contracts denominated in Euros, 3) procurement delays in 2024 which resulted in recognition of some associated costs in the 2025 accounting year, and 4) the recognition of impairment allowance for amounts due to be reimbursed by the Ministry of Transport and Infrastructure stemming from exempted flights. This item, which constitutes an accounting provision, is understood to be “recorded in accordance with Romanian accounting regulations and was not included in the determined costs for the reference period, nor is it recoverable through charges to airspace users”.

    • Significantly lower than planned depreciation (-15.0%), resulting from delays in implementation and commissioning of some investment projects.

    • Slightly lower than planned cost of capital (-0.6%), mainly reflecting a lower than planned asset base.

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

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

    “In 2025, the real terminal unit cost at TCZ3 level was 2,854.68 RON/US (in 2022 prices), compared to the determined unit cost of 2,418.99 RON/US, representing a deviation of +18.0% above the planned level.

    As at TCZ2, the deviation reflects a double negative effect: total terminal costs in real terms amounted to RON 49,807 thousand against determined costs of RON 44,072 thousand (+13.0%), while terminal service units realised were 17,447 against the plan of 18,219 (−4.23%). The traffic underperformance at TCZ3 is the most pronounced of all charging zones and compounds the cost overrun in unit cost terms.”

    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:

    “The cost overrun is attributable to: other operating costs above plan due to the higher-than-anticipated inflationary environment impacting utility costs, communications services, software maintenance, technical support contracts, spare parts and consumables, adverse EUR/RON exchange rate developments, and the recognition of an impairment allowance on trade receivables - an accounting provision not included in the determined cost base and not recoverable through charges. Depreciation was below plan (RON 1,570 thousand vs. RON 1,847 thousand determined) due mainly to delays in commissioning the ILS/DME system at Suceava airport. Cost of capital was likewise below plan, reflecting lower-than-planned investment spending at Suceava.

    The traffic shortfall of −4.23% is attributable to two distinct factors specific to TCZ3. First, the sustained and elevated military activity in the eastern part of Romania — including daily operations at Kogălniceanu and Fetești air bases — generates active airspace restrictions (LRTRA, LRTSA, LRD zones) in the areas of Constanța and Tulcea that constrain civil traffic flows and impose additional GAT-OAT coordination workload, reducing the effective capacity available for commercial operations. Second, Constanța airport (LRCK) underwent a modernisation programme in 2025, which directly reduced the volume of commercial movements at that aerodrome during the reporting period.”

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

    No information on the recommendations formulated by the NSA was provided in the NSA 2025 Monitoring Report. At the same time, ROMATSA reports the following information:

    “The cost overruns recorded in 2025 are attributable predominantly to factors outside ROMATSA's direct control and, where applicable, are subject to recovery mechanisms already provided for under Regulation (EU) 2019/317, which do not require corrective action by the ANSP. Specifically:

    — The deviation in other operating costs reflects the higher-than-planned inflationary environment, adverse exchange rate developments. ROMATSA continues to apply cost discipline within the parameters of its operational and contractual obligations. The overrun is also attributable to the recognition of an impairment allowance on trade receivables, recorded in accordance with Romanian accounting regulations. This item constitutes an accounting provision and was not included in the determined costs for the reference period, nor is it recoverable through charges to airspace users.

    — The lower depreciation is a direct consequence of implementation delays in certain investment projects and does not indicate underinvestment: the overall investment programme remains on track. No corrective action is required or appropriate.

    ROMATSA considers that no additional corrective measures are warranted beyond the regulatory recovery mechanisms already in place, as the cost deviations do not reflect operational inefficiency or a failure to implement planned measures.”

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

    AUCU components (€/SU) – 2025
    €/SU
    DUC 569.62
    Inflation adjustment 12.93
    Cost exempt from cost sharing 2.96
    Traffic risk sharing adjustment 8.96
    Traffic adjustment (costs not TRS) 0.92
    Financial incentives 4.45
    Modulation of charges 0.00
    Cross-financing 0.00
    Other revenues -0.45
    Application of lower unit rate 0.00
    Total adjustments 29.77
    AUCU 599.39
    AUCU vs. DUC + 5.2%
    Cost exempt from cost sharing by item - 2025 €'000 €/SU
    New and existing investments -17.1 -0.98
    Competent authorities and qualified entities costs 0.0 0.00
    Eurocontrol costs 0.0 0.00
    Pension costs 17.9 1.02
    Interest on loans 0.9 0.05
    Changes in law 49.9 2.86
    Total cost exempt from cost risk sharing 51.6 2.96
    NoteFocus on AUCU

    Terminal AUCU monitoring at charging zone level

    The actual terminal unit cost incurred by airspace users (AUCU) in respect of activities performed in 2025 (3 020.13 RON or 599.39 €) is +5.2% higher than the nominal DUC (2 870.13 RON or 569.62 €). The difference between these two figures (+150.00 RON/SU or +29.77 €/SU) is due to:

    • the positive inflation adjustment resulting from higher than planned inflation (+65.14 RON/SU or +12.93 €/SU);

    • the impact of adjustments resulting from the costs exempted from cost sharing mechanism (+14.92 RON/SU or +2.96 €/SU);

    • the addition of the traffic risk sharing adjustments (+45.16 RON/SU or +8.96 €/SU);

    • the addition of the traffic adjustment (+4.65 RON/SU or +0.92 €/SU) for the costs not subject to traffic risk sharing;

    • the impact of financial incentives (+22.40 RON/SU or +4.45 €/SU); and

    • the deduction of other revenues (-2.27 RON/SU or -0.45 €/SU).

    The share of the regulatory result (see next sub-section) in the AUCU (before the deduction of other revenues) is -10.8%.

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

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

    “The actual unit cost incurred by users in 2025 was RON 3,024.64/US, compared to the nominal DUC of RON 2,870.13/US. The difference of +RON 154.51/US reflects the net effect of adjustments: the inflation adjustment under Article 26 (RON +1.1 million), costs exempt from traffic risk sharing under Articles 28(4) to 28(6) (RON +0.3 million), the capacity incentive bonus (RON +0.4 million), and the traffic risk sharing adjustment under Article 27(2) to 27(5) (RON +788 thousand, reflecting the material traffic shortfall of −4.23% which exceeds the neutral band and triggers partial recovery for ROMATSA). Other revenues (RON −40 thousand) have a negligible effect.

    Given the structural nature of the factors depressing TCZ3 traffic — military airspace restrictions in the Constanța and Tulcea areas — and the absence of a recovery signal in early 2026 data, the cost-efficiency situation in TCZ3 requires close monitoring through the remainder of RP4. ROMATSA's cash conservation approach and avoidance of discretionary cost commitments are the primary mitigation measures currently in place.”

    [It should be noted that the amount of AUCU indicated by the NSA in the extract cited above differs slightly from the amount reported in the submission of terminal reporting tables which serves as the basis of this analysis.]

    Regulatory result (RR)

    NoteFocus on regulatory result

    ROMATSA net gain/loss on activity in the Romania Zone 3 terminal charging zone in 2025

    ROMATSA reported a net loss of -1.6 M€, as a combination of a loss of -1.4 M€ arising from the cost sharing mechanism, with a loss of -0.3 M€ arising from the traffic risk sharing mechanism and a gain of +0.1 M€ relating to financial incentives.

    ROMATSA overall regulatory result (RR) for the terminal activity

    Ex-post, the overall RR, taking into account the net loss from the terminal activity mentioned above (-1.6 M€) and the actual RoE (+0.4 M€), amounts to -1.1 M€ (-10.8% of the terminal revenues). The resulting ex-post rate of return on equity is negative (-33.2%), compared to the 12.7% planned in the PP.

     
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