AENA, which operates most airports in Spain, has proposed a 3.8% annual increase in airport charges for the five-year period covered by the Third Airport Regulation Document (DORA III). Airlines have rejected this proposal, arguing that AENA has consistently underestimated passenger traffic growth and earned excessive regulated returns during previous regulatory periods.
From 2017 to 2025, excluding the two pandemic years, actual passenger numbers were on average 15.3% higher than AENA’s forecasts under DORA I and DORA II. This discrepancy led to AENA earning €1.3 billion more in regulated returns than anticipated, with these additional costs ultimately paid by airlines and consumers. In 2024 alone, AENA’s regulated return was reported at 10.2%, four percentage points above its expected level, resulting in nearly €400 million overpaid by airlines and passengers that year.
Rafael Schvartzman, Regional Vice President for Europe at the International Air Transport Association (IATA), said: “AENA has gamed the regulatory system for years, earning millions of euros more than it should have, at the expense of passengers, airlines, and the Spanish economy. This must stop. AENA has generated excessive returns through a creative approach to forecasting, and its request for further increases is absurd. If granted, it would deliver the highest regulated return of any comparable airport operator in Europe. This is unsustainable and unrealistic—we need to see a reduction in charges.”
IATA and the Spanish Airline Association (ALA) are proposing an annual reduction of 4.9% in airport charges instead of an increase. They argue that this cut would not hinder AENA from delivering its planned €10 billion investment program during DORA III. Independent studies commissioned from consultancies Steer and CEPA project passenger traffic growth at about 3.6% per year on average—higher than AENA’s estimate of just 1.3%. With these projections, IATA says that AENA could still fully fund its investments while achieving a return on capital of 6.35%, which is above what was intended under DORA II.
Schvartzman added: “Our proposal for a 4.9% cut in charges will improve Spain’s competitiveness as an international destination, stimulating investment and job creation across the wider economy. At the same time, AENA can still afford its €10 billion investment plan and deliver reasonable returns to its shareholders. This is a win-win for passengers, Spain, and the aviation industry. We look forward to regulators reviewing the evidence and reaching the right conclusions.”
The International Air Transport Association works globally to enrich air transport through safety initiatives and sustainability efforts according to its official website https://www.iata.org/. The association represents around 360 member airlines responsible for over 80% of global air traffic https://www.iata.org/, engaging in advocacy work to advance industry standards https://www.iata.org/. Founded in 1945 with headquarters in Montreal https://www.iata.org/, IATA seeks to lead airline industry development through partnerships focused on secure operations and environmental responsibility https://www.iata.org/.














