EU 2026–2029: Infrastructure and Combined Transport

15. Aviation and Single European Sky II plus

Legal act / status of legislative procedure: Regulation 2024/2803 on the implementation of the Single European Sky entered into force in December 2024.

I. General remarks:

We welcome the implementation of Single European Sky 2+. While the European aviation industry is struggling to defend its share of the global market, the long-overdue integration of Europe’s fragmented and inefficient air traffic management system is essential. Strengthening the legal framework through SES 2+ helps eliminate these inefficiencies and improve European air traffic management (ATM).

The harmonisation of civil European airspace must continue to be pursued.

II. Specific proposals:

In our view the legal act does not yet go far enough and should therefore be regarded as an interim step. The following points remain open in any case:

• Promote sustainable aviation fuels to market maturity

Promoting the market maturity of sustainable aviation fuels can be achieved through various measures, including earmarking revenues from the ticket levy and the emissions trading system (ETS) in aviation. The aim of these support measures is to improve their availability and competitiveness on the market. A coherent EU strategy is needed for the targeted promotion of pilot projects and for creating a regulatory framework to increase the production and use of sustainable aviation fuels.

• Further development of the Performance Review Body (PRB)
  The Performance Review Body (PRB) is an independent advisory body appointed by the European Commission to assist in the implementation of the performance and charging scheme of the Single European Sky (SES). The PRB consists of industry experts and issues recommendations to the Commission. It has also issued recommendations for the Union-wide target areas for the fourth reference period (RP4, 2025–2029) of the SES performance and charging scheme. We propose expanding the competences of the Performance Review Body (PRB) in order to enable a more effective assessment of performance within the framework of the Single European Sky.
• Compensation in the event of failure to meet performance targets or SESAR implementation requirements
  The SESAR project (Single European Sky ATM Research) brings together the resources and expertise of civil and military stakeholders with the EU institutions in order to develop innovative technologies and working methods to improve ATM performance (Air Traffic Management). If SESAR objectives or requirements are not met, an entitlement to compensation should be provided in order to create an incentive for those responsible to implement performance targets or SESAR implementation requirements on time.
• Closer cooperation between national supervisory authorities is desired
  Instead of further equipping national supervisory authorities, they should consolidate and integrate their tasks beyond mere cooperation. Stronger harmonisation of standards and procedures across national borders would facilitate the future implementation of the Single European Sky (SES). In this context, pooling resources for specific projects within Functional Airspace Blocks (FABs) could be considered in order to increase efficiency and effectiveness
• Mandatory selection criteria for support service providers
  Such criteria are intended to ensure the quality and reliability of support services in European airspace and to establish a uniform aviation standard across Europe. The selection criteria should relate to safety standards, technical capabilities and efficiency standards.
• The Network Manager should play a stronger role in facilitating network consolidation and rationalisation
  The Network Manager of the Single European Sky is the key actor for operational and technological network performance in the areas of capacity and flight efficiency. To counter increasing flight delays in the EU, the European Commission has appointed Eurocontrol as Network Manager until 2029, with the mandate to identify short-term measures to reduce congestion and delays during peak travel periods. Measures have also been included in Commission implementing regulations, such as the regulation on network functions and the regulations on performance and charging schemes. We call for the Network Manager to play a stronger role in consolidation and rationalisation, for example by merging flight routes or simplifying operational procedures. The aim is to make the European air transport system more efficient and cost-effective.
• Strengthening InterFAB initiatives and maximising operational efficiency in the FAB context (Functional Airspace Blocks)
  European airspace is divided into nine blocks which are intended to replace or consolidate national areas. The purpose of InterFAB coordination is to provide a structure facilitating coordination and cooperation between FABs, contributing to reduced fragmentation of European airspace, supporting optimisation of the European ATM Network (EATMN), and providing a working structure for this purpose. Initiatives such as InterFAB and FABEC (Cooperation for a Single European Sky) should be strengthened.
  In addition, operational efficiency in the context of Functional Airspace Blocks should be maximised. In many situations, such as strikes, conflicts in neighbouring areas, adverse weather conditions or natural disasters, there may suddenly be an increased need for air traffic control. This often results in air traffic controllers within a Functional Airspace Block being overloaded and operational efficiency being impaired. In such cases, it should be possible for air traffic controllers from a neighbouring FAB to technically step in to manage the situation.
• More ambitious deadlines for structural changes
  Deadlines for structural changes such as the realignment of national supervisory authorities (NSAs), unbundling and the establishment of network management (NM setup) must become more ambitious.
• The European Union Aviation Safety Agency (EASA) should be given the capacity to act as the performance review body of the Single European Sky
  The implementation of the Single European Sky will inevitably strengthen EASA’s role as a certification authority for both airborne and ground equipment and ensure that both are carried out consistently. Since digitalisation and data exchange between ground and airborne systems are becoming increasingly common, it makes sense from a safety perspective for EASA to carry out the review of both system sets
• We strictly reject measures that distort competition, such as bans on short-haul flights or the introduction of a kerosene tax (tax exemption is not equivalent to a subsidy)
  Maintaining short-haul flights is essential in many cases, as these flights often serve regions or cities that are more difficult to reach by other modes of transport. A ban could therefore have serious negative economic effects on these regions, particularly on tourism and the local economy.
  The exemption from kerosene tax is an important means of preserving the competitiveness of the aviation industry and ensuring that airlines remain competitive at international level. The introduction of a kerosene tax could have a negative impact on the economy, as it would potentially affect tourism, trade and the mobility of people and goods. In addition, uniform global implementation of a kerosene tax is not realistically feasible and would therefore only lead airlines to switch to airports in countries with lower taxes, which in turn could result in traffic diversion and distortion of competition.

16. Border traffic: free movement for EU licence plates

I. General remarks:

The principle of the free movement of goods is essential as a cornerstone of the internal market for ensuring security of supply, the efficiency of supply chains and the competitiveness of the European economy.

The recent increase in customs controls at borders, in particular the measures carried out by Bulgaria against vehicles with links to Austria, has caused considerable delays and disruptions in freight transport. At times, dozens of Austrian hauliers were stuck at the Bulgarian border for several days. Such unnecessary obstacles to the free movement of goods must be avoided.

II. Specific proposals:

• Free movement, 24/7, 365 days a year
  The objective must be to ensure unrestricted free movement of road freight vehicles with EU licence plates within EU borders, around the clock, 365 days a year.
• Influence Member States to end excessive border control practices
  Until the Union-wide reduction of border controls for EU licence plates in road freight transport is achieved, the Commission should exert influence on Member States to ensure that their border control practices are carried out efficiently and in a targeted manner, without unnecessarily obstructing the free movement of goods.

17. EU-wide standardisation of factory-applied stickers for identifying emission classes in low-emission zones
I. General remarks:

To improve air quality, several federal provinces have introduced driving bans due to particulate matter for lorries and articulated vehicles of various emission classes, mostly Euro 2 and below, in some cases regardless of weight. All vehicle classes covered by the provincial rules, in particular heavy goods vehicles, which are not affected by a driving ban because of their emission classification, must display a corresponding emission-class identification sticker.

At present, there are no equivalent emission-class markings from other Member States of the European Economic Area that are defined by law or by public authorities and from which the necessary information is apparent, meaning that they cannot be recognised as equivalent in Austria. In practice, this creates a considerable burden for businesses, especially where, for example, a windscreen has to be replaced.

Possibilities for agreements on mutual recognition of such markings are being discussed on an ongoing basis with Member States of the European Economic Area.

II. Specific proposal:

The transport industry calls for EU-wide standardisation of factory-applied stickers for identifying emission classes for low-emission zones. Uniform standards create equal framework conditions for all market participants. They ensure fairness in competition and a level playing field and are therefore a foundation of the market economy.

18. No multiple penalties

I. General remarks:

In the transport sector, new and stricter legal requirements are continuously being introduced. The possibility for Member States to provide for different rules leads to a multitude of provisions, making it difficult for those subject to the rules to maintain an up-to-date overview of the applicable requirements and to act in compliance with the law. This often results in disproportionately high penalties imposed both on drivers and on companies.

One example is a situation in which a lorry driver receives a fine because the load was insufficiently secured. At the same time, the company to which the driver belongs may receive an additional penalty, on top of the driver’s fine, for breaching operational rules or failing to comply with transport regulations. Similar situations can also arise in the case of infringements of driving times, rest periods, vehicle defects, vehicle maintenance and equipment. This double sanctioning places a burden on both the driver and the company and may lead to financial burdens that can negatively affect business operations.

In practice, the accumulation principle, according to which several penalties must be imposed side by side if a person has committed several administrative offences through one act, also leads to unfair multiple penalties. In one specific case, a driver was accused three times of inadequate load securing: first, because the existing lashing straps had allegedly been damaged by the load; second, because too few lashing straps had been used; and third, because lashing hooks had not been attached to the lashing points[1].

The problem of multiple penalties exists primarily at national level and is not equally present in all EU Member States. Nevertheless, it can be observed to varying degrees in many EU Member States, including Belgium, Czechia, Denmark and Sweden[2]. We therefore consider it desirable for this issue to be discussed at European level and for cross-border solutions to be identified.

We therefore propose the following:

[1] https://www.dertransporteur.at/news/doppelt-und-dreifach-bestraft/

[2] https://uicr.org/wp-content/uploads/2018/01/IRU-ENFORCEMENT-HANDBOOK.pdf

II. Specific proposals:

• Harmonisation of penalty practices across Europe
  Clear guidelines and standards laid down by the European Union for determining penalties in road transport should be adopted to ensure uniform and fair treatment within the EU and to promote the harmonisation of penalty practices. These standards must be clearly defined so that Member States have no room for divergent implementation; such leeway should in any case be removed or avoided when existing rules are amended and when new regulatory content is introduced. Since implementation in Austria is often very strict or excessive, this leads to unequal competitive conditions for our transport companies. Harmonisation could also be achieved through the exchange of best practices and the development of common guidelines.
• Move away from rigid punishment and make greater use of warnings
  Rigid penalties for minor offences and smaller infringements should be reduced across the EU and replaced in administrative penalty practice by the increased use of warnings. This would allow more flexible handling of traffic infringements while preserving proportionality between the seriousness of the infringement and the penalty imposed.
• EU-wide abolition of multiple penalties for matters over which companies have no direct influence
  Multiple penalties imposed on drivers and companies for offences committed by drivers, over which the entrepreneur had no direct influence at the time of the offence, should be abolished across the EU. This rule aims to relieve companies of responsibility for matters outside their sphere of influence and to ensure that drivers are held individually accountable for their actions without the company being additionally penalised.

19. Uniform application of social legislation on tachographs in road transport

Legal act / status of legislative procedure: Regulation (EU) 165/2014 of 4 February 2014 on tachographs in road transport, repealing Regulation (EEC) No 3821/85 on recording equipment in road transport and amending Regulation (EC) No 561/2006 on the harmonisation of certain social legislation relating to road transport.

I. General remarks:

We propose stronger harmonisation of social legislation. In order to ensure legal certainty and equal competitive conditions within the EU, social legislation must be applied uniformly in all Member States. We therefore propose that national exemptions should be permitted only in special exceptional cases.

II. Specific proposal:

EU-wide harmonised rules on tolerance for minor infringements (Regulation (EU) 165/2014)
Penalties for infringements of obligations relating to recording equipment are regulated by the Member States. This leads not only to penalties of different amounts, but also — depending on differing administrative practices in the Member States — to arbitrary and disproportionate fines for minimal infringements, for example minor violations. Essential provisions should therefore be incorporated directly into EU law.

20. Digitalisation

I. General remarks on the digitalisation of vehicle-related documents:

Carrying many required documents is a considerable burden for drivers. They must keep a large number of physical documents readily available at all times, which is very time-consuming and may result in high penalties if not complied with. Digitalising all these documents would reduce the burden on drivers and increase efficiency by simplifying access to all required information. Greater digitalisation could also significantly speed up procedures for control authorities.

The current division of digital European documents across different databases, such as the risk-rating system, TachoNet, the registration database and the EU Community licence, creates considerable additional effort. It reflects differing responsibilities and impairs efficiency and transparency in the field of vehicle documentation. Harmonising and digitalising these databases is therefore not only desirable but urgently necessary in order to simplify administration and optimise transport operations.

We support the efforts of European associations such as the IRU, ECR (Euro Control Route) and ROADPOL (European Roads Policing Network) to organise pilot projects involving digital documents and their control mechanisms. In the first phase, particular focus is placed on the common roadside control form. We see the updating and digitalisation of this document, as well as its availability in all EU languages, as a very important step.

II. Specific proposals on the digitalisation of vehicle-related documents

European “one-stop digital shop” for vehicle-related documents
We recommend creating a European “one-stop digital shop” in which vehicle-related documents can be stored and retrieved centrally. To support companies, all these databases should be merged into a single database. In addition, a reminder function for renewing certain documents within this database would be helpful. For enforcement authorities, it would be more efficient, and faster for companies, to scan a QR code on the vehicle instead of requiring drivers to search for paper documents, such as the tail-lift logbook. Since the relevant documents would be available online, penalties for drivers and companies could be avoided if drivers, for whatever reason, do not have them physically available.

In principle, we support the same documents being required at European level. However, the database should also make it possible to see whether different document requirements exist in individual Member States and to upload these as well. This would enable drivers and companies to clearly understand which documents are required depending on the countries they pass through. In addition, all necessary measures must be taken to prevent technical problems when documents are retrieved, for example during an inspection.

The following documents should be digitally available to drivers in the European “one-stop digital shop” when carrying out transport operations within the internal market (EU and EEA):

EU-wide abolition of the EU journey form
Digital versions of the EU journey form already exist in many countries. We welcome the fact that the digitalisation of the journey form across the entire Union is now on the agenda, since manually keeping the EU journey form entails the risk of incorrect entries that may lead to penalties.

Although we see the digital solution as a good start, we generally consider the EU journey form to be unnecessary, since the digital tachograph is capable of performing the same task efficiently. We would therefore welcome the complete abolition of the EU journey form.

Dangerous goods examinations and recurring inspections
We recommend digitalising dangerous goods examinations and other recurring inspections in the transport sector. Such an examination format would reduce administrative effort and costs for driving schools and companies, improve compliance with regulations and ensure a standardised quality level.

Ensuring data protection and data security
It is particularly important to us that data protection, data security and transparency, especially regarding which data are checked, are guaranteed. In view of current discussions about initiatives such as the establishment of automatic control systems along the EU’s main transport routes to verify compliance with weight and dimension limits for lorries and buses, as well as the use of digital enforcement tools such as the “Intelligent Access Policy”, it is of the utmost importance to create the appropriate framework conditions for data protection. It is crucial to ensure that only as much data is collected as is available in the current documents and as is necessary for control purposes.

III. General remarks on the Digital Networks Act:

The European Commission has proposed a regulation on digital networks (Digital Networks Act, procedure number 2026/0013(COD)) in order to modernise, simplify and harmonise EU rules on connectivity networks and to create the conditions for network operators to invest in the expansion of advanced fibre-optic and mobile networks. In order to maintain the resilience and operational safety of railway operations, we call for exclusive rights of use for radio frequencies for railway operations to be retained.

IV. Specific proposals on the Digital Networks Act:

Retain exclusive rights of use
Exclusive rights of use for radio frequencies are required for railway operations in order to protect public safety and essential services. Article 15 provides for the principle of shared use of radio frequencies; however, Article 15(1) expressly provides for exemptions where shared use is not possible or not appropriate for certain reasons. Shared use of radio frequencies would be problematic, since even short-term disruptions or capacity bottlenecks can have significant effects on operational safety. This exemption must therefore be maintained in the further legislative procedure.

Restriction of the right of access to physical infrastructure
Article 34(4) provides for a broadly formulated right of access to physical infrastructure controlled by public bodies, including stops and underground stations. The scope of this rule is problematic if it is applied to safety- and operations-relevant public transport infrastructure without explicit exemption provisions.

21. Passenger Package

Legal act / status of legislative procedure: Proposal for a regulation on the issuing of railway tickets; procedure number 2026/0115(COD). Proposal for a regulation on multimodal booking and repealing Regulation (EC) No 80/2009; procedure number 2026/0113(COD). Proposal for a regulation amending Regulation (EU) 2021/782 as regards the protection of passengers with single tickets; procedure number 2026/0114(COD).

I. General remarks on the Passenger Package:

In May 2026, the European Commission presented the “Passenger Package”, consisting of three separate legislative proposals, which aims to simplify the planning and booking of regional, long-distance and cross-border journeys.

From the perspective of the transport industry, it is particularly important to ensure clear exemptions for urban, suburban and local public transport, practicable and proportionate liability rules, and clear definitions for MDMS services and commercial agreements. Realistic technical and economic implementation deadlines are also needed.

II. Specific proposals on the Passenger Package - Proposal for a regulation on the issuing of railway tickets:

Targeted amendment of rail passenger rights
Rail passenger rights must continue to clearly distinguish between regional and long-distance transport on the one hand and urban and suburban transport on the other. These public transport services operate without seat reservations and passengers usually have several travel options.

Exclude urban and suburban transport
It is crucial that urban and suburban transport does not fall within the scope of the relevant requirements. In Austria, the legislator makes use of the possibility to exempt suburban railways from the rules on through-tickets (Article 12). This possibility must be retained in the further course of the legislative process.

The reason for this is, in particular, the allocation of liability in the event of missed connections, which would be disproportionate in terms of both journey time and ticket price. The railway undertaking whose service was delayed or cancelled and thereby caused a missed connection is liable for reimbursement, re-routing and compensation. If an urban or suburban route formed the first part of a travel chain under a “single ticket”, delays in local transport could give rise to direct compensation claims by long-distance passengers.

III. Specific proposals on the Passenger Package - Proposal for a regulation on multimodal booking):

Maintain exemptions for public transport
We welcome that the proposed regulation provides for partial exemptions relevant to integrated transport networks with regard to local public transport. Specifically, B2C Multimodal Digital Mobility Services platforms (B2C MDMS) for transport services that primarily serve an urban area or conurbation do not fall within the scope.

However, this urban exemption does not apply to providers of B2B MDMS services. This is problematic because of the unclear definition of B2B MDMS services, as depending on interpretation, cooperation arrangements in public transport could also fall within this category. Possible borderline cases include congress tickets, job tickets or distribution partnerships. Clarification is required here.

This exemption also does not apply to transport operators if they have a “commercial agreement” with MDMS service providers covered by the regulation. Here too, terminological clarification is needed, since the term “commercial agreement” is not defined in more detail in the regulation. In particular, it should be clarified to what extent cooperation within a transport association also falls under this term.

In order to avoid ambiguities and take account of the specific characteristics of transport undertakings operating primarily in urban and metropolitan areas, it would be appropriate to transfer the exemption in Article 2(1)(a) to Article 2(3). At the very least, the existing wording for B2C should be repeated in the paragraph on B2B in order to avoid unintended effects on local public transport.

V. Specific proposals on the Passenger Package - Proposal for a regulation amending Regulation (EU) 2021/782 as regards the protection of passengers with single tickets):

Exemption of metro and tram from the scope
We welcome the fact that the Commission recognises the specific situation of local public transport by fully excluding metro and tram from the scope of the proposed regulation and by providing for a partial exemption for urban and suburban rail transport. However, the latter applies only to self-contained networks used exclusively for the operation of urban or suburban rail services and is therefore too narrowly defined. It must be clearly regulated in the further legislative procedure that the exemption also applies where suburban rail services are predominantly operated on dedicated networks.

The decisive criterion should not be the formal and technical complete separation of the network, but the main purpose of the respective transport services. The relevant definitions and exemptions should be explicitly aligned with Directive 2012/34/EU so that no new or divergent terms for urban, suburban and regional transport and no additional or narrower exemptions are created. In particular, it should be clarified that hybrid network structures do not preclude the application of the exemption.

Review of existing tariff structures (PSO contracts)
In addition, the Rail Ticketing Regulation explicitly covers competent authorities for public service obligations (PSO contracts), not only railway undertakings. Integrated public transport tickets are exempt only if a separate rail product for the same route can be purchased separately. If a journey can only be purchased as part of an integrated urban tariff, this could fall under the obligation and require technical integration with third-party providers. A detailed review of existing tariff structures is required here.

Appropriate transition periods for smaller undertakings
FRAND conditions (fair, reasonable and non-discriminatory) require the provision of reservations, yield-based fares and real-time data. In addition, there are technical requirements such as compliance with the technical specifications for interoperability relating to telematics applications (TSI-TAF/TAP standards), cybersecurity measures, proof of financial stability and the assumption of one-off connection costs. Appropriate transition periods and cost compensation should be provided for smaller operators in order to cushion the technical and financial burden of implementing the FRAND requirements.