REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Articles 9(1c), 21a(5) and 24a(4) of Regulation (EC) No 1008/2008 of the European Parliament and of the Council of 24 September 2008 on common rules for the operation of air services in the Community as amended by Regulation (EU) No 2020/696 of the European Parliament and of the Council of 25 May 2020 in view of the COVID-19 pandemic
Date: 2020-11-13
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: EU Member State, air transport, coronavirus disease, epidemic, ground staff, service concession, transport licence

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 13.11.2020  COM(2020) 714 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Articles 9(1c), 21a(5) and 24a(4) of Regulation (EC) No 1008/2008 of the European Parliament and of the Council of 24 September 2008 on common rules for the operation of air services in the Community as amended by Regulation (EU) No 2020/696 of the European Parliament and of the Council of 25 May 2020 in view of the COVID-19 pandemic  
 
 
1  Contents 
1 

Introduction .................................................................................................................................... 2 

2 

Description of the relief measures .................................................................................................. 3 

2.1  Measures concerning temporary operating licences ............................................................. 3 

2.2 

2.3 

2.4 

Emergency measures (flight restrictions) linked to the COVID-19 pandemic ........................ 3 

Temporary rules on groundhandling services – contracts...................................................... 4 

Temporary rules on groundhandling services – selection procedure .................................... 4 

3 

Conditions for extension of the relevant periods ........................................................................... 5 

3.1 

3.2 

3.3 

Persistent reduction in the level of air traffic between 2019 and 2020  ................................ 5 

The reduction in air traffic is due to the COVID-19 pandemic ................................................ 7 

The reduction in air traffic is likely to persist in the foreseeable future ................................ 9 

The reduction in air traffic has resulted in interruption of supply of groundhandling 
3.4 
services or difficulties in access to financing for groundhandlers .................................................... 11 

3.5 

Flight restrictions are no longer necessary to deal with the COVID-19 pandemic ............... 11 

4 

Conclusion ..................................................................................................................................... 13 

1 

 
 
 
 
 
 
Introduction 

1 
Since the beginning of 2020, the COVID-19 pandemic has had a profound negative impact 
on  air  transport  in  Europe  and  worldwide.  The  health  and  travel  restrictions  introduced  by 
Member  States  and  third  countries  in  response  to  the  pandemic  have  heavily  depressed 
consumer demand and confidence which in turn has led to a record and enduring drop in air 
traffic in Europe.1   

The number of flights operated in European airspace fell by up to 90% in March-April 2020 
compared  to  the  same  period  in  2019.2  Europe’s  airports  still  handled  over  5  million 
passengers on 1 March 2020 but that number had reduced to just 174 000 by 31 March 2020 
(down 97.1% compared to the same day in 2019). Since 2 August 2020 the decrease has been 
by  around  70%  compared  to  the  same  day  in  20193.  Freight  is  less  impacted,  being  19% 
lower  in  August  in  terms  of  cargo  tonne  kilometres4.  In  October  2020  data  collected  by 
ICAO’s  Economic  Impact  Analysis  estimates  that  2020  will  be  characterised  by  an  overall 
reduction of seats offered by airlines in a range of 50% to 52%, a reduction in a number of 
passengers  in  a  range  of  2  875  to  2  978  million  and  losses  in  gross  passenger  operating 
revenue in the range of EUR 330 to 340 billion.  

The COVID-19 pandemic has led to difficulties in complying with certain provisions of the 
Air  Services  Regulation5  and  the  Groundhandling  Directive6.  The  unprecedented  drop  in 
demand and high rate of cancellations has  resulted in  a number of sudden problems for air 
operators  and  groundhandling  companies.  First,  air  carriers  faced  severe  liquidity  problems 
that could trigger the suspension or revocation of their operating licence, or its replacement 
by  a  temporary  licence,  without  there  being  a  structural  economic  need  for  this  to  occur. 
Second,  groundhandling  companies  whose  contracts/authorisations  were  coming  to  an  end 
faced  severe  difficulties  in  access  to  finance.  Third,  because  of  the  financial  exposure  of 
groundhandling  companies,  airports  were  put  in  a  vulnerable  position  whereby  they  could 
lose the only groundhandling provider in case of its bankruptcy.  

Moreover, the rates of contagions or deaths from COVID-19 as well as the fact that it was an 
unknown disease led many Member States to impose intra-EU flight restrictions under article 
21  of  the  Air  Services  Regulation  in  an  attempt  to  stop  or  slow  down  the  spread  of  the 
disease,  which  due  to  the  unprecedented  length  of  the  crisis  and  the  applicable  procedural 
rules,  created  a  heavy  and  unnecessary  administrative  burden  for  Member  States  and  the 
Commission. 

Therefore,  on  25  May  2020,  in  view  of  the  COVID-19  pandemic  the  European  Parliament 
and the Council adopted Regulation (EU) 2020/696 amending the Air Services Regulation to 
address  the above problems  and offer the  affected  stakeholders, the Member States and the 

1   The World Health Organisation declared it a “Public Health Emergency of International Concern” on 30 January and a 
pandemic  on  11  March  2020  (see  https://www.who.int/dg/speeches/detail/who-director-general-s-opening-remarks-at-
the-media-briefing-on-covid-19---11-march-2020). 
2  
https://www.eurocontrol.int/Economics/DailyTrafficVariation-States.html 
3  
https://www.aci-europe.org/industry-topics/covid-19.html 
4  
https://www.iata.org/en/iata-repository/publications/economic-reports/air-freight-monthly-analysis---august-2020/ 
5   Regulation (EC) No 1008/2008 of the European Parliament and of the Council of 24 September 2008 on common rules 

for the operation of air services in the Community (Recast), OJ L 293, 31.10.2008, p. 3–20. 

6   Council Directive 96/67/EC of 15 October 1996 on access to the groundhandling market at Community airports,   

OJ L 272, 25.10.1996, p. 36–45. 

2 

 
 
                                                           
Commission,  the  necessary  relief  from  certain  administrative  rules  and  to  secure  better 
financial perspective to the stakeholders in the affected sector.  

Pursuant to Articles 9(1c), 21a(5) and 24a(4) of the Air Services Regulation, the Commission 
shall  continuously  monitor  the  situation  in  order  to  address  the  criteria  set  out  in  the 
Regulation.7 

According  to  the  same  Articles,  based  on  the  information  and  data  available  to  it,  the 
Commission is to present a summary report to the European Parliament and to the Council by 
15 November 2020 and, where necessary, adopt delegated acts extending the periods of the 
temporary provisions. Those delegated powers are granted to the Commission for a period of 
one year from 28 May 2020. 

This summary report assesses the situation based on data gathered from Eurocontrol, and data 
on  flight  cancellations  and  load  factors  from  a  sample  of  EU  airlines.  It  also  relies  on 
evidence  and  data  published  by  the  European  Centre  for  Disease  Prevention  and  Control 
(ECDC) on the persistence of the COVID-19 pandemic. The Commission also consulted in 
July-August  2020  the  relevant  stakeholders,  namely  Member  States  and  organisations 
representing  airlines,  airports  and  groundhandlers  on  the  implementation  and  the  ongoing 
necessity of the measures.  

2  Description of the relief measures  
2.1  Measures concerning temporary operating licences 
Pursuant to Article 9(1) of the Air Services Regulation, Member States’ competent licencing 
authorities  must  revoke  or  suspend  the  operating  licence  of  an  EU  air  carrier  in  financial 
difficulties and may replace them with a temporary operating licence.  

With the COVID-19 pandemic, Union air carriers, which were financially healthy before the 
pandemic, started facing liquidity problems that could trigger the suspension or revocation of 
their  operating  licence,  or  its  replacement  by  a  temporary  licence,  without  there  being  a 
structural economic need for this to occur. Issuing a temporary licence could send a negative 
signal  to  the  market  about  the  ability  of  an  air  carrier  to  survive,  which  in  turn  would 
aggravate any, otherwise temporary, financial problems.  

Regulation  (EU)  2020/696  therefore  allowed  the  competent  licensing  authorities  not  to 
revoke or suspend the operating licence in the period from 1 March to 31 December 2020 if 
the financial viability assessment was carried out during that period and provided that safety 
was  not  at  risk  and  there  was  a  realistic  prospect  of  a  satisfactory  financial  reconstruction 
within the following 12 months.  

2.2  Emergency measures (flight restrictions) linked to the COVID-19 pandemic 
Pursuant to Article 21 of the Air Services Regulation, a Member State may refuse, limit or 
impose  conditions  on  the  exercise  of  traffic  rights  to  deal  with  sudden  problems  of  short 
duration  resulting  from  unforeseeable  and  unavoidable  circumstances.  Such  action  shall 

7   These criteria are set out in Articles 9(1b), 21a(4) and 24a(3) and listed under section 4. 

3 

 
 
 
                                                           
respect the principles of proportionality and transparency and shall be based on objective and 
non-discriminatory criteria. 

In order to make sure that such action respects the principles of proportionality, transparency 
and objective and non-discriminatory criteria, the Commission and the other Member States 
should be informed without delay of such action with an adequate justification. Moreover, if 
the problems necessitating such action continue to exist for more than 14 days, the Member 
State must inform the Commission and the other Member States accordingly and may, with 
the agreement of the Commission, prolong the action for further periods of up to 14 days. The 
Commission grants its agreements to the prolongation periods by a decision.  

Article 21 addresses problems of short duration and the experience in the early stages of the 
COVID-19 outbreak showed that it was not adapted to the COVID-19 crisis, expected to last 
several  months,  placing  an  unnecessary  administrative  burden  on  the  Commission  and  the 
Member States.  

Regulation  (EU)  2020/696  therefore  introduced  a  temporary  derogation  to  the  procedural 
requirements set out in Article 21 for the period from 1 March until 31 December 2020. This 
derogation  allows  the  Member  States  to  maintain  a  temporary,  justified  and  proportionate 
emergency  measure  addressing  the  COVID-19  pandemic  without  the  agreement  of  the 
Commission provided that it respects the principles of proportionality and transparency and is 
based on objective and non-discriminatory criteria.  

2.3  Temporary rules on groundhandling services – contracts 
Pursuant to Article 6(2) and Article 9 of the Groundhandling Directive, Member States may 
limit  the  number  of  suppliers  of  groundhandling  services  at  airports.  In  such  cases,  the 
suppliers must be selected for a maximum period of seven years. The COVID-19 pandemic 
has  led  to  a  sudden  reduction  in  air  transport  activity  on  an  unprecedented  scale,  which 
resulted  in  severe  financial  difficulties  for  suppliers  of  groundhandling  services.  Suppliers 
whose contracts  expire during the crisis or by the end of the  year following the start of the 
crisis  therefore cannot  provide a sufficient  guarantee of sustainability to  their creditors as a 
criterion for getting a loan and consequently may experience difficulties in obtaining access 
to financing. 

For  this  reason,  Regulation  (EU)  2020/696  provided  that  contracts  of  suppliers  that  expire 
between 28 May 2020 and 31 December 2021 may be prolonged until 31 December 2022.  

2.4  Temporary rules on groundhandling services – selection procedure 
Article  11(1)(e)  of  the  Groundhandling  Directive  states  that,  in  case  a  supplier  of 
groundhandling  services  ceases  its  activity  before  the  end  of  the  period  for  which  it  was 
selected by a tender carried out in accordance with that Article, it shall be replaced using that 
same procedure.  

The COVID-19 pandemic may lead to possible insolvencies of suppliers of groundhandling 
services  resulting  in  ceasing  of  their  activity.  In  airports  where  the  number  of  suppliers  is 
limited,  this  could  result  in  a  situation  that  one  or  several  suppliers  ceases  to  provide  their 
services before a new supplier can be selected on the basis of the normal procedure laid down 
in Article 11(1) of the Groundhandling Directive. To ensure the continuity of the service, a 
fast replacement of this supplier would be necessary.  

4 

 
 
Regulation (EU) 2020/696 therefore allows the managing body of the airport, for the period 
from 1 March 2020 until 31 December 2020, to choose a service provider directly to provide 
the  services  for  a  maximum  period  of  six  months  or  for  a  period  until  31  December  2020, 
whichever is the longer. 

3  Conditions for extension of the relevant periods 
Pursuant  to  Regulation  (EU)  2020/696,  the  Commission  is  granted  delegated  powers  to 
extend  the  periods  of  applicability  of  the  relevant  exceptional  measures  mentioned  in 
paragraphs 3.1- 3.5. The table below gives an overview of the conditions to be met: 

Reduction in 
the level of 
air traffic as 
compared to 
the level of 
traffic in the 
corresponding 
period in 
2019 is 
persisting  

Reduction 
in air 
traffic is 
due to the 
outbreak 
of the 
COVID-
19 
pandemic 

Reduction 
in air 
traffic is 
likely to 
persist in 
the 
foreseeable 
future 

x 

x 

x 

Interruption of 
supply of 
groundhandling 
services or 
difficulties in 
access to 
financing for 
suppliers of 
groundhandling 
services at 
Union airports 

Persistence 
of COVID 
19 
pandemic 

Limitations or 
impositions of 
conditions on the 
exercise of traffic 
rights by Member 
States are likely 
to be necessary 
beyond 31 
December 2020 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

Measures 
concerning 
temporary 
operating 
licences (art. 
9(1b)) 
Emergency 
measures (flight 
restriction) 
linked to the 
COVID 19 
pandemic) (art. 
21a(4)) 
Temporary 
rules on 
groundhandling- 
contracts (art. 
24a(3) 
Temporary 
rules on 
groundhandling 
– selection 
procedure (art. 
24a(3)) 

3.1  Persistent reduction in the level of air traffic between 2019 and 2020 

(corresponding period) 

For the purpose of this report, data on  air traffic  levels,  slot use, load factor, and cancelled 
flights in a given week of 2020 have been compared to the same week of 2019. 

Eurocontrol data sets the start of the downturn of air traffic in the EEA in week 11 in 2020 
with a drop of 17% compared to the same week in 2019. Air traffic continued to fall quickly 

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
resulting in a 59% and 82% decrease compared to 2019 in weeks 12 and 13 respectively. The 
lowest points were recorded in weeks 15 and 16 (89% decrease). Afterwards traffic started to 
gradually pick up, but was only at 26% of 2019 levels as of 22 June 2020 (week 26), a 74% 
decrease  in  air  traffic  compared  to  the  previous  year.  During  the  month  of  August  2020 
(weeks 32-36) air traffic levels reached 53% compared to August 2019, but early September 
2020 the levels started to decline again and by the end of the month were at 46 % compared 
to the same period in 2019. 

EEA  traffic 2019 vs 2020 

Figure 1.1  

180.000
160.000
140.000
120.000
100.000
80.000
60.000
40.000
20.000
0

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40

2019

2020

(source: Eurocontrol) 

As a result of the drop in traffic, flight cancellations soared (figure 1.2) compared to the same 
period in 2019. Flight cancellations pick up from week 9 and increase at a steeper rate from 
week 11. 

Cancelled flights 2019 vs 2020 

Figure 1.2  

60000

50000

40000

30000

20000

10000

0

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35

Source: Data collected by the Commission from air carriers8 

2019

2020

8  

6  major  European  air  carriers  (legacy,  low-cost  and  regional)  provided  the  Commission  with  the  dataset  on  slot use. 
Figures refer to the number of slots operated compared to slots held before the start of the season (Historic Baseline 

6 

 
 
 
                                                           
 
Meanwhile,  the  average  load  factor  for  ten  European  air  carriers,  which  have  provided  the 
Commission  with  data decreased from 80% in  week 9 to  26% in  week 15.  Not only do  air 
carriers fly less, but the few remaining flights remain under-booked.  

By week 23, when intra-EU air travel had been reopened to a significant extent, the average 
load factor recovered to 44% and during mid-August went up to 56%. During the same week 
in 2019, the average load factor of the same  air carriers ranged from 75% (week 4) to 89% 
(week 26). 

Mean load factor 2019 vs 2020 

Figure 1.3 

100%

80%

60%

40%

20%

0%

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34

Source: Data collected by the Commission from air carriers9  

2019

2020

3.2  The reduction in air traffic is due to the COVID-19 pandemic 
Many countries responded to the COVID-19 pandemic by issuing bans and travel restrictions, 
some  of  which  are  still  in  effect  today.10  This  has  severely  impacted  intra-EU  and 
international air travel as restrictions authorising only “essential travel” suppress demand to a 
level where most routes can no longer be operated commercially.11  

Restrictions on intra-EU flights were used early on by some Member States as a measure to 
prevent  or  contain  the  further  spread  of  COVID-19.  In  order  to  promote  the  continued 
operation  of  cargo  services,  the  Commission  adopted  guidelines  for  facilitating  air  cargo 
operations  during  the  COVID-19  pandemic.12  The  peak  of  the  bans  on  passenger  flights 
between Member States was recorded during the period 20 – 26 March 2020, during which 
20 Member States had introduced flight bans. Thereafter, there has been a slow reduction, on 
31  March  2020  there  were  16  Member  States  with  flight  bans  and  on  6  April,  14  Member 
States.  11  Member  States  had  issued  flight  restrictions  when  the  procedural  waiver  entered 
into force. As of 7 July, seven Member States had flight bans towards a few specific Member 

Date).  6  major  European  air  carriers  (legacy,  low-cost  and  regional)  provided  the  Commission  with  the  dataset  on 
cancelled flights. 
9  
6 major European air carriers (legacy, low-cost and regional) provided the Commission with the dataset on load factors. 
10   https://ec.europa.eu/info/live-work-travel-eu/health/coronavirus-response/travel-and-transportation-during-coronavirus-

pandemic_en for an overview of measures still in place. 

11   Demonstrated by the drop in traffic described in section 3.1 and the reason the waiver was introduced in the first place. 
12   European Commission Guidelines: Facilitating Air Cargo Operations during COVID-19 Outbreak, adopted 26 March 

2020. https://ec.europa.eu/transport/sites/transport/files/legislation/c20202010_en.pdf 

7 

 
 
 
                                                                                                                                                                                     
States which have a higher rate of COVID-19 cases. End of September, four Member States 
still had flight bans (see section 4).  

Regarding extra-EU flights, on 16 March 2020, the Commission adopted a Communication13 
recommending  a  temporary  restriction  of  non-essential  travel  from  third  countries  into  the 
EU+ area14 for one month. On 17 March 2020, the Heads of State or Government of the EU 
agreed  to  implement  the  temporary  restriction  of  non-essential  travel.  The  four  Schengen 
Associated States also implemented it. This restriction was prolonged several times.  

During  the  summer,  Member  States  started  reintroducing  travel  restrictions  within  the  EU. 
On 4 September 2020, the Commission adopted a proposal for a Council Recommendation15 
to  ensure  that  any  measures  taken  by  Member  States  that  restrict  free  movement  due  to 
COVID-19  pandemic  are  coordinated  and  clearly  communicated  at  the  EU  level.  The 
Commission’s  proposal  sets  out  four  key  areas  where  Member  States  should  work  closer 
together,  such  as  on  common  criteria  and  thresholds  for  Member  States  when  deciding 
whether  to  introduce  travel  restrictions,  a  common  framework  for  measures  applied  to 
travellers  from  high-risk  areas,  and  clear  and  timely  information  to  the  public  about  any 
restrictions.  

Beyond  the  regulatory  environment,  consumer  confidence  is  a  key  factor  affecting  traffic 
levels and suggesting a link between a decrease in air traffic and the outbreak of COVID-19. 
There is not much data on this yet. The Irish Central Statistics Office conducted a survey on 
passenger  confidence  to  travel  by  plane.  Almost  four  in  five  (78.0%)  respondents  reported 
feeling “uncomfortable” or “very uncomfortable” with the prospect of taking an international 
trip  by  plane.16  The  re-introduction  of  border  and  quarantine  measures  in  a  number  of 
Member  States  in  an  uncoordinated  and  often  unpredictable  way  has  further  undermined 
consumer  confidence,  as  demonstrated  by  recent  data,  depressing  travel  well  beyond  the 
direct effect of the actual restrictions.   

IATA’s  regularly  published  economic  reports  on  the  crisis  show  that  since  February  2020, 
year-on-year bookings  fell at an increasing rate until about mid-April. Since then, bookings 
have partly recovered but remain down by 82% as of the end of June 2020. There appears to 
be  a  correlation  between  the  increase  in  new  cases  and  the  decrease  in  bookings.17  In 
addition,  IATA has been commissioning regular  surveys on passenger  confidence since the 
outbreak  of  COVID-19.  In  April,  around  60%  of  respondents  indicated  that  they  would  be 
likely to return to travel within a few months of the pandemic having subsided. In June, this 
figure had slipped to 45%. In September more than half of respondents indicated they would 
wait 6 months to a year before returning to travel. Therefore, the willingness to fly remains 
low  and  it  is  expected  to  continue  for  the  months  to  come.  Also  the  risk  of  compulsory 
quarantine at destination is one of the key deterrents. 83% of the respondents indicated that 
they will not travel if there is chance of quarantine after arrival. 

13   COM(2020) 115, 16 March 2020. 
14   The “EU+ area” includes all Schengen Member States (including Bulgaria, Croatia, Cyprus and Romania), as well as 

the four Schengen Associated States.  

15   https://ec.europa.eu/info/sites/info/files/council-proposal-coordinated-approach-restriction-movement_en.pdf 
16   https://www.cso.ie/en/releasesandpublications/ep/p-sic19cler/socialimpactofcovid-

19surveyjune2020measuringcomfortlevelsaroundtheeasingofrestrictions.  To  be  noted  that  Ireland  had  a  quarantine  in 
place for all international travellers arriving in Ireland  when the survey  was carried out, which had an impact on the 
public’s perception of the safety of flying. 

17   https://www.iata.org/en/iata-repository/publications/economic-reports/Flexibility-will-be-critical-to-restart/ slide 4. 

8 

 
 
                                                           
The foregoing shows a strong link between the drop in air traffic and the outbreak of COVID-
19. 

3.3  The reduction in air traffic is likely to persist in the foreseeable future 
Under  the  current  circumstances,  it  is  difficult  to  predict  the  exact  evolution  of  air  traffic 
levels, but available forecast show that the reduction in air traffic will persist in 2021 and a 
return to pre-COVID levels will not occur before 2024.18. Factors that will have an impact on 
how air traffic levels evolve are flight and travel restrictions, consumer booking patterns, and 
regulatory  health  measures  imposed  on  the  industry.  These  are  closely  linked  to  the 
possibility of a resurgence in cases and the absence of a vaccine. All forecasts are tainted by a 
high degree of uncertainty. 

According  to  Eurocontrol19  the  total  number  of  flights  expected  in  Europe  will  again 
gradually decrease. In August a small recovery to 51% had been noted after the lowest point 
was reached in April 2020 but it was not sustainable. In January 2021, the number of flights 
is  anticipated  to  be  60%  lower  than  in  2019  (instead  of  20%  in  its  earlier  scenario).  This 
scenario assumes the likelihood that Member States remain uncoordinated in their response to 
cross-border air travel, that passenger demand remains extremely low as a result of COVID-
19 uncertainty, unpredictability and confusion over restrictions/quarantine measures, and that 
airlines  will  further  reduce  capacity  in  light  of  very  low  forward  bookings.  According  to 
Eurocontrol the traffic should slowly pick up in February 2021, still being 50% lower than in 
February 2020.  

As  of  29  September  202020,  IATA  also  downgraded  its  economic  forecast.  It  now  expects 
global revenue passenger kilometres (RPKs)21 to decline by 66% in 2020 compared to 2019 
and by 68% in December 2020 compared to December 2019 against a 55% reduction that it 
forecasted in July 2020.  

Regarding travel restrictions, the Commission recommended22 Schengen Member States and 
Schengen Associated States to  lift internal border controls  by  15 June 2020. Most Member 
States  that  had  previously  reintroduced  internal  border  controls  due  to  the  COVID-19 
pandemic  heeded  the  recommendation,  which  resulted  in  commercial  scheduled  passenger 
traffic picking up (see Figure 1.1). With regard to the restriction on non-essential travel into 
the Union, from 1 July 2020, a Council Recommendation23 advised the lifting of restrictions 
on non-essential travel from an initial list of third countries, to be reviewed regularly.  

However,  while  a  continued  improvement  in  air  traffic  was  expected  over  the  European 
summer period, due to measures being relaxed and restrictions being lifted in the context of 
decreasing trends in a number of cases in Europe overall, an increase in COVID-19 cases was 

18   https://www.iata.org/en/iata-repository/publications/economic-reports/Five-years-to-return-to-the-pre-pandemic-level-

of-passenger-demand/ 

19   See Eurocontrol’s latest “Current Status Scenario” from September 2020 -   

https://www.eurocontrol.int/sites/default/files/2020-09/eurocontrol-draft-traffic-scenarios-14092020.pdf 
20   https://www.iata.org/en/iata-repository/publications/economic-reports/downgrade-for-global-air-travel-outlook/ 
21   Revenue  passenger  kilometres  (RPK)  is  an  airline  industry  metric  that  shows  the  number  of  km  travelled  by  paying 

passengers. It is calculated as the number of revenue passengers multiplied by the total distance travelled. 

22   COM(2020)399 final. 
23   https://data.consilium.europa.eu/doc/document/ST-9208-2020-INIT/fr/pdf. 

9 

 
 
                                                           
reported  again  in  many  EEA  countries  during  summer  2020.24  There  is  also  a  historic 
precedent on pandemics developing in several waves. This may induce renewed decreases in 
air traffic. 

Regarding future demand for air traffic and consumer confidence, notably in the context of 
the summary report on slots25, stakeholders contacted by the Commission services (airlines, 
travel agents, computer reservation systems) stated that it is very difficult to make projections 
beyond  the  winter  2020/2021  scheduling  season.  While  pre-COVID-19,  airlines  may  have 
already  been  able  to  offer  schedules  for  the  year  ahead,  airlines  are  currently  facing 
difficulties  in  predicting  schedules  for  the  upcoming  season.  Airlines  are  keeping  flight 
schedules  under  constant  review,  to  react  to  unpredictable  changes  in  travel  or  flight 
restrictions and hard-to-predict passenger demand.26  

While intra-EU bookings started to  pick up for summer 2020, recovery in passenger traffic 
across  the  European  airport  network  stopped  in  August,  most  likely  as  a  result  of  travel 
restrictions being reinstated by several States.27 Booking rates for extra-EU flights were even 
lower. IATA’s latest update on global air travel outlook points to weaker passenger bookings 
in the fourth quarter compared to third quarter 2020.28  

Regarding other regulatory health measures, as part of the exit strategy, sanitary measures are 
being implemented in aviation, widely based on the EASA/ECDC guidelines.29 Measures on 
distancing  and  disinfection  of  spaces  may  reduce  the  amount  of  passengers  and  flights 
airports can service, compared to the situation before the outbreak. They may temporarily or 
durably  reduce  effective  airport  capacity  compared  to  the  pre-COVID19  situation.  These 
measures may at the same time contribute to restoring consumer confidence, however still to 
a limited extent.  

As  a  result,  airlines  are  now  again  gradually  decreasing  the  capacity  offered  to  the  market. 
The foregoing suggests that the passenger air traffic levels in 2020 will not reach even half of 
the  2019  levels.  Domestic  markets  will  recover  faster  than  international  markets.  ICAO 
expects  a  decrease  in  the  number  of  seats  offered  in  Europe  in  2020  by  52%-58%  for 
international passenger traffic and by 33% to 36% on domestic flights30.  

In light of the above, the outlook beyond 2020 is highly uncertain, but the renewed rises in 
COVID-19  cases  and  the  need  to  maintain  sanitary  containment  measures  suggest  that  the 

24   https://www.ecdc.europa.eu/sites/default/files/documents/covid-19-rapid-risk-assessment-20200810.pdf.  The  ECDC 

reported on 10 August 2020 an overall risk of escalation of COVID-19 across all EU/EEA countries. 

25   COM(2020) 558 final. 
26   Airlines have to plan and prepare for multiple scenarios in the absence of clear trends on consumer behaviour, evolution 
of the disease, and alleviation from the slot usage rules. This leads to sub-optimal decisions on costs for infrastructure, 
labour  and  marketing.  Even  in  a  normal  year,  the  winter  season  is  a  more  challenging  one  for  airlines,  which  would 
typically  make  most  of  their  profits  during  the  summer  season.  This  year,  without  the  buffer  of  a  profitable  summer 
season behind them, the outlook for airlines for winter and beyond looks challenging. 

27   Airlines  point  out  that  consumer  booking  practices  have  changed.  Previously  consumers  would  book  months  in 
advance, whereas now as a result of decreased predictability and confidence in travelling, bookings happen much later. 
Information provided by IATA suggests that about 60% of bookings now  come in the 2 weeks before the operation, 
whereas compared to the same period in 2019, more than 60% of bookings were made between more than 20 days to 11 
days in advance. 

28   https://www.iata.org/en/iata-repository/publications/economic-reports/downgrade-for-global-air-travel-outlook/ 
29   https://www.ecdc.europa.eu/sites/default/files/documents/EASA-ECDC_COVID-19_Operational-guidelines-for-

management-of-passengers-issue-2.pdf 

30   https://www.icao.int/sustainability/Documents/COVID-19/ICAO_Coronavirus_Econ_Impact.pdf 

10 

 
 
                                                           
passenger air traffic may not reach 2019 levels for several years – even assuming a COVID-
19 vaccine would be available in 2021.  

3.4  The reduction in air traffic has resulted in interruption of supply of 

groundhandling services or difficulties in access to financing for groundhandlers 

According to the information available to the Commission, groundhandling companies have 
been severely  affected by  the COVID-19 pandemic and the reduction in air traffic outlined 
above.  Many  groundhandling  service  providers  have  encountered  financial  difficulties,  as 
demonstrated  by  the  Swissport  group  entering  restructuring  and  the  news  about  financial 
difficulties encountered by its subsidiaries31, Wisag laying off 800 employees in Germany32, 
the  rescue  package  granted  to  Aviapartner  Belgium  and  Malév  Ground  Handling  ceasing 
operations33.  This  shows  that  the  reduction  in  air  traffic  results  in  interruption  of  supply  of 
groundhandling services and difficulties in access to financing for groundhandlers. 

Based on the predictions for the level  of air traffic till  end December 2021, it is  likely that 
more groundhandling service providers will have to interrupt their supply of groundhandling 
services before the market has recovered from the crisis caused by the COVID19-pandemic.34 
There is real risk that further bankruptcies among groundhandling service providers may take 
place  throughout  2021.  Such  bankruptcies  may  very  likely  lead  to  sudden  interruptions  of 
groundhandling  services.  Hence,  airports  may  find  themselves  in  a  situation  where  they 
would need to find an alternative groundhandling provider within a very short period of time. 
The case of Brussels airport, where Brussels Airport Company (BAC) was able to urgently 
select a replacement after the demise of Swissport Belgium, demonstrated the usefulness of 
the measure.35     

However,  suppliers  of  groundhandling  services  that  have  difficulties  in  access  to  financing 
due  to  the  expiry  of  their  contracts  can  continue  benefiting  from  their  extension  under  the 
current  derogation  (until  31  December  2022)  in  order  to  obtain  the  necessary  credits  and 
assure  their  business  continuity.  Moreover,  the  extended  contracts  give  airports  sufficient 
time to tender for additional groundhandling providers to improve their resilience in case of 
ongoing volatility in the air transport sector. 

3.5  Flight restrictions are no longer necessary to deal with the persisting COVID-19 

pandemic 

Since Article 21a of the Air Services Regulation was adopted, the Commission have been in 
close  contact  with  the  Member  States,  in  particular  the  civil  aviation  authorities,  to 

31   E.g., Swissport Belgium’s demise and Swissport Finland’s announcement of the need to lay off up to 700 of its 1350 
employees,  (https://yle.fi/uutiset/osasto/news/upm_swissport_to_cut_1200_jobs/11512488)  while  Swissport  Western 
Europe is considering cutting some 4500 jobs in UK and Ireland (https://www.euronews.com/2020/06/24/swissport-to-
cut-over-4-000-jobs-in-uk-and-ireland-due-to-covid-19). 

32   https://newsabc.net/aviation-in-crisis-ground-service-provider-wisag-cuts-around-800-jobs-in-berlin/  
33   https://hungarytoday.hu/national-asset-management-terminates-remnant-of-former-hungarian-airline-malev/ 

https://bbj.hu/economy/govt-declares-malev-gh-of-strategic-importance_185815  

34   https://www.ft.com/content/82d6c72a-4a9c-4210-a235-fadbe326ff34  
35   On  8  June  2020,  Swissport  Belgium  had  filed  for  bankruptcy,  leaving  Brussels  Airport  with  one  groundhandling 
company.  Since  1  July  2020,  Alyzia  SAS  has  been  providing  the  service.  Pending  the  organisation  of  the  usual 
procedure for selecting a new handler, the French company has been granted a temporary licence  for a period of six 
months for baggage and ramp handling. It can also offer passenger handling services (such as check-in) and cleaning. 
Source: BAC. 

11 

 
 
                                                           
continuously monitor the situation. This has shown that flight restrictions as such may not be 
the  most  appropriate  and  necessary  measure  to  contain  the  COVID-19  outbreak  as  further 
explained below. 

There have been quite differing approaches from one Member State to the other throughout 
the  period  of  application  of  the  Regulation.36  The  Commission  published  the  information 
once  received  from  the  Member  States  to  ensure  transparency37  and  Eurocontrol  has  been 
issuing  on  a  daily  basis  summaries  of  the  corresponding  NOTAMs38.  In  line  with  its 
guidelines  on  how  to  progressively  restore  transport  services,  connectivity  and  free 
movement  as  soon  as  the  health  situation  allows  it39,  and  also  taking  into  account  the 
implementation  of  the  COVID-19  Aviation  Health  Safety  Protocol  adopted  by  the 
EASA/ECDC40  providing  guidance  on  how  to  facilitate  the  safe  and  gradual  restoration  of 
passenger  air  transport,  the  Commission  has  been  regularly  inviting  the  civil  aviation 
authorities to review their flight bans. As a result, Member States have been gradually lifting 
their  flight  restrictions,  sometimes  replacing  them  with  other  measures  such  as  travel 
restrictions and public health measures. During the summer period, however, a few Member 
States started reinstating flight bans towards a number of Member States as a reaction to the 
increase in COVID-19 cases in several countries.41 

The  simplified  procedure  under  Regulation  (EU)  2020/696  allows  Member  States  to  take 
emergency  measures  to  address  COVID-19  pandemic  without  unnecessary  administrative 
burden,  but  still  leaves  the  obligation  for  Member  States  to  adequately  justify  the  measure 
given its significant adverse effect on the functioning of the internal market and ensure it is 
proportionate to the public health objective pursued.  

COVID-19 has now spread across the globe with cases appearing on five continents.  In the 
early  stages  of  the  crisis,  both  the  WHO  together  with  the  International  Civil  Aviation 
Organisation  (ICAO)  and  the  ECDC  suggested  that  short-term  travel  restrictions  could 
contribute  to  the  containment  of  the  outbreak  by  slowing  down  the  spread  of  the  disease. 
However, evidence shows that restricting movement of people and goods in the longer-term 
is ineffective in countering pandemics in most situations and may divert resources from other 
interventions.42 Today, even if the pandemic continues to pose a major public health threat to 
EU countries, there have been important developments since the beginning of the crisis, such 
as improvements in knowledge about the risk of transmission and the development of other 
diagnostic and preventive measures, which allow to progressively restore transport services.43 
All Member States have put in place other  measures, such as health and sanitary measures, 

36   A few Member States notified bans on all intra-EU flights with some exemptions (such as for emergency or repatriation 
flights). Some notified bans directed to one or a few Member State(s). Seven Member States did not make use of the 
possibility offered in Article 21 or 21a of the Regulation as they considered the need to do so for public health reasons 
did  not  exist.  They  privileged  measures  restricting  or  conditioning  access  to  their  territory  to  people  from  certain 
regions or countries and health measures (such as testing and tracing). 

37   https://ec.europa.eu/transport/coronavirus-response_en 
38   https://www.public.nm.eurocontrol.int/PUBPORTAL/gateway/spec/index.html  Notices  to  Airmen  contain  all  the 

information on the conditions imposed by countries on the operation of air services. 

39   See https://ec.europa.eu/info/files/covid-19-guidelines-progressive-restoration-transport-services-and-connectivity_en 
40   See https://www.easa.europa.eu/document-library/general-publications/covid-19-aviation-health-safety-protocol 
41   On 1 October 2020, four Member States still had intra-EU flight bans. 
42   https://www.icao.int/Security/COVID-19/Pages/default.aspx; 

https://www.ecdc.europa.eu/sites/default/files/documents/Considerations-related-to-measures-for-travellers-reduce-
spread-COVID-19-in-EUEEA.pdf 

43   See EASA/ECDC Aviation Health and Safety Protocol. 

12 

 
 
                                                           
which appear more suitable, effective and proportionate to contain the COVID-19 pandemic 
than flight restrictions as such.44  

Few  Member  States  take  the  view  that  since  the  epidemiological  situation  is  difficult  to 
predict  there  could  be  a  need  to  reinstate  flight  bans  while  the  other  Member  States  that 
responded  to  the  Commission’s  consultation  consider  that  there  are  other  measures  and 
mechanisms  in  place  to  ensure  that  the  spread  can  be  limited  and  that  imposing  unilateral 
restrictions  on  flights  would  interfere  with  the  coordinated  response  to  COVID-19  and 
hamper  recovery.  Moreover,  they  argue  that  Article  21  of  the  Air  Services  Regulation  will 
continue to allow Member States to take necessary emergency measures, where justified.  

With the COVID-19 Aviation Health Safety Protocol adopted by the EASA/ECDC in place45, 
airlines  consider  that  unilateral  flight  restrictions  are  no  longer  necessary  and  could  be 
revoked since pre-flight monitoring measures and a high level of health and safety on board 
are considered more effective and proportionate to deal with passengers from countries with 
high  transmission  rates  than  flight  bans  as  such.  Unilateral  intra-EU  flight  bans  based  on 
varying  criteria  from  one  country  to  the  other,  imposed  sometimes  with  just  a  few  hours’ 
notice, and mostly for short periods, have created a lot of confusion and legal uncertainty on 
the market with negative impact on carriers but also on passengers, as well as indirect impact 
on  the  situation  of  groundhandlers  and  airports.  The  industry  considers  that  a  coordinated 
approach at EU-level with objective criteria applied uniformly across the EU would help to 
avoid confusion on the market.46  

While it is  clear that the COVID-19 pandemic is  persisting, the evolution of the pandemic, 
improved  knowledge  of  the  virus  and  its  epidemiology  and  the  implementation  by  all 
Member States of comprehensive health and sanitary measures no longer seem to warrant the 
necessity for Member States to impose intra-EU flight restrictions as such in order to address 
the COVID-19 pandemic. The condition in Article 21a(4) to extend the simplified procedural 
rules beyond 31 December 2020 is therefore not met. 

4  Conclusion 
At  the  time  when  this  report  is  presented  to  the  European  Parliament  and  the  Council,  the 
level of air traffic is still significantly reduced compared to the same period in 2019. Despite 
the difficulties in accurately predicting the recovery path of air traffic levels, it is reasonable 
to expect that the low levels of air traffic and passenger demand attributable to the COVID-
19-pandemic will persist throughout 2021. A return to pre-COVID levels is not expected for 
several  years.  It  is  however  too  early  at  this  stage  to  conclude  whether  capacity  reductions 
will continue to occur beyond 2021 at similarly significant levels.  

National  and  uncoordinated  restrictions  on  passengers  and  flights 
to/from  certain 
destinations,  quarantine  requirements,  sanitary  measures  allowing  for  safe  travel,  and 
consumer confidence, will be key factors driving the speed at which air traffic recovers.  

44   According to the ECDC, given that there are now dedicated COVID-19 surveillance systems, extensive public health 
measures  in  place,  and  ongoing  testing  and  contact  tracing  of  the  population,  countries  should  be  better  prepared  to 
prevent and control any resurgence in cases. 

45   See https://www.easa.europa.eu/document-library/general-publications/covid-19-aviation-health-safety-protocol 
46   See  footnote  15  -  proposal  for  a  Council  Recommendation  on  a  coordinated  approach  to  the  restriction  of  free 

movement in response to the COVID-19 pandemic. 

13 

 
 
                                                           
Because  of  the  persistence  of  the  COVID-19  pandemic  and  its  impact  on  air  traffic,  it  is 
expected that air carriers will continue to  face severe liquidity problems in 2021 that could 
trigger  the  suspension  or  revocation  of  their  operating  licence.  It  is  also  expected  that  the 
difficult  market  conditions  in  the  groundhandling  sector  will  prevail  in  2021  and  further 
aggravate the financial situation of groundhandling service providers with the resulting risk 
of  additional  bankruptcies.  The  interruption  of  supply  of  groundhandling  services  and 
difficulties  in  access  to  financing  for  groundhandlers  are  therefore  also  likely  to  persist 
throughout 2021.  

The  conditions  to  extend  by  delegated  act  the  measures  in  Articles  9(1b)  relating  to 
temporary licences, and 24a(3) concerning groundhandling services that currently end on 31 
December 2020 are thus met.  

In  the  light  of  the  above,  given  their  expiry  already  on  31  December  2020,  and  in  light  of 
their continuing necessity pursuant to the conditions in Article 9(1b) and Article 24a(3), the 
Commission  will  extend  the  derogations  relating  to  operating  licences  and  selection  of 
groundhandlers by delegated act until 31 December 2021. 

Regarding  the  current  derogation  on  the  extended  validity  of  groundhandling  contracts, 
which  enables  prolongation  of  contracts  until  31  December  2022,  and  based  on  the  limited 
long-term data available, the Commission does not consider, at this stage, that the conditions 
for its extension beyond the end of 2022 are met. The Commission will nevertheless continue 
to closely monitor the situation. 

Regarding the possibility for Member States to take emergency measures refusing, limiting 
or imposing conditions on the exercise of traffic rights to  address  COVID-19 pandemic, 
based on available evidence on the developments in the pandemic and the knowledge of the 
risk of transmission of the disease, such measures are no longer necessary  in  view of other 
more appropriate measures to contain the spread of the disease, such as effective health and 
sanitary measures, and in view of Article 21 of the Air Services Regulation. The condition in 
Article 21a(4) to extend the measure by delegated act beyond 31 December 2020 is thus not 
met and the current validity period will not be extended.  

The Commission will continue to keep the situation in the aviation sector under review and is 
ready to consider further measures, where justified, to manage the crisis and aid recovery. 

14