REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the evaluation of the European Union Aviation Safety Agency and Regulation (EU) 2018/1139 on common rules in the field of civil aviation and establishing a European Union Aviation Safety Agency
Date: 2023-09-12
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: European Aviation Safety Agency, air safety, air traffic, aircraft, airport, civil aviation, crew, environmental protection, operation of the Institutions

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 12.9.2023  COM(2023) 524 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the evaluation of the European Union Aviation Safety Agency and Regulation (EU) 2018/1139 on common rules in the field of civil aviation and establishing a European Union Aviation Safety Agency  
 
 
EXECUTIVE SUMMARY  

The European Commission conducted an evaluation of the European Union Aviation Safety 
Agency (‘EASA’) and of Regulation  (EU) 2018/1139  on common rules in the field  of  civil 
aviation  and  establishing  a  European  Union  Aviation  Safety  Agency  (1).  The  evaluation 
assessed  the  Regulation’s  effectiveness  in  reaching  its  objectives,  efficiency,  relevance  in 
responding to the stakeholders’ needs, coherence with other EU legislation and policy actions, 
and its overall EU added value. The evaluation also assessed EASA’s performance in relation 
to its objectives, mandate, and tasks. The present report is submitted to the Parliament and the 
Council on the basis of art 124 of Regulation (EU) 2018/1139 . It presents the findings of this 
evaluation,  highlighting  the  achievements  of  both  EASA  and  the  Regulation  towards  the 
overall objective of establishing and maintaining high uniform level of civil aviation safety in 
the Union. The report also identifies areas where future improvements is needed, such as an 
appropriate financing of EASA’s activities.  The findings presented in this report are further 
developed in a dedicated Commission Staff Working Document (2) and they are supported by 
data  gathered  in  a  study  contracted  by  the  Commission  to  evaluate  both  EASA  and  the 
Regulation (3).  

1.  INTRODUCTION  

Regulation  (EU)  2018/1139  on  common  rules  in  the  field  of  civil  aviation  and 
establishing  a  European  Union  Aviation  Safety  Agency  is  applicable  as  of  1  September 
2018.  With  safety  being  the  pre-requisite  for  a  competitive  aviation  sector,  the  principal 
objective  of  the  Regulation  is  to  establish  and  maintain  a  high  uniform  level  of  civil 
aviation safety in the Union. The Regulation also aims at, among others, facilitating, in the 
fields covered by this Regulation, the free movement of goods, persons, services and capital, 
providing a level playing field for all actors in the internal aviation market, contributing to a 
high, uniform level of environmental protection, as well as promoting, worldwide, the views 
of  the  Union  regarding  civil  aviation  standards  and  civil  aviation  rules,  by  establishing 
appropriate cooperation with third countries and international organisations. 

(1)   Regulation (EU) 2018/1139 of the European Parliament and of the Council of 4 July 2018 on common rules 
in  the  field  of  civil  aviation  and  establishing  a  European  Union  Aviation  Safety  Agency,  and  amending 
Regulations (EC) No 2111/2005, (EC) No 1008/2008, (EU) No 996/2010, (EU) No 376/2014 and Directives 
2014/30/EU  and  2014/53/EU  of  the  European  Parliament  and  of  the  Council,  and  repealing  Regulations 
(EC)  No  552/2004  and  (EC)  No  216/2008  of  the  European  Parliament  and  of  the  Council  and  Council 
Regulation (EEC) No 3922/91, OJ L 212, 22.8.2018, p. 1.  

(2)  SWD(2023) 298 

(3)   Study supporting the evaluation of the European Union Aviation Safety  Agency’s (EASA) performance in 
relation to its objectives, mandate and tasks as set out in Regulation (EU) 2018/1139 – Final Report, 2023 

1 

 
 
 
 
 
 
The  objectives  of  the  Regulation  are  achieved  through,  among  others,  the  preparation, 
adoption  and  uniform  application  of  requirements  covering  all  key  areas  of  civil  aviation, 
including airworthiness, air operations, aircrew, aerodromes, and air navigation services. The 
Regulation also covers new technologies, in particular drones (unmanned aircraft systems).  

The  objectives  of  the  Regulation  are  mainly  achieved  with  a  help  of  the  European  Union 
Aviation Safety Agency (‘EASA’) who is tasked with a broad range of responsibilities.  

In  terms  of  its  geographical  scope,  the  Regulation  is  binding  in  its  entirety  and  is  directly 
applicable in all EU Member States. It is also applicable in Switzerland, Norway, Iceland, and 
Liechtenstein,  which  are  members  of  EASA  by  virtue  of  the  Union  agreements  signed  with 
those countries (4). 

EASA  was  initially  established  in  2002  and  became  operational  in  20035.  Since  then, 
Regulation  (EC) No 216/2008  and Regulation  (EC) No 1108/2009 (6) enlarged the scope of 
Union competence and EASA’s responsibilities . EASA has its seat in Cologne, with offices 
in Brussels, Washington, Beijing, Singapore and Panama City. 

The Regulation replaces Regulation (EC) No 216/2008 on common rules in the field of civil 
aviation  and  establishing  a  European  Aviation  Safety  Agency  (7).In  its  2015  Impact 
Assessment  (8)  supporting  the  revision  of  Regulation  (EC)  No  216/2008,  the  Commission 
identified the following main problems of the legal framework existing at that time:  

- 

- 

- 

- 

the  existing  regulatory  system  might  not  have  been  sufficiently  able  to  identify  and 
mitigate safety risks in the mid to long-term; 
the existing regulatory system was not proportionate as it created excessive burdens, 
especially for smaller operators; 
the  existing 
developments; and 
there  were  differences  in  resources  across  Member  States  creating  potential  safety 
risks and contributing to mistrust among the Member States.  

regulatory  system  was  not  sufficiently 

to  market 

responsive 

(4)  The European Economic Area – EEA - agreement and the bilateral agreement with Switzerland. 

(5)   Regulation (EC) No 1592/2002 of the European Parliament and of the Council of 15 July 2002 on common 
rules  in  the  field  of  civil  aviation  and  establishing  a  European  Aviation  Safety  Agency,  https://eur-
lex.europa.eu/legal-content/EN/ALL/?uri=celex:32002R1592. 

(6)   Regulation  (EC)  No  1108/2009  of  the  European  Parliament  and  of  the  Council  of  21  October  2009 
amending  Regulation  (EC)  No  216/2008  in  the  field  of  aerodromes,  air  traffic  management  and  air 
navigation 
https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX%3A32009R1108. 

repealing  Directive 

2006/23/EC, 

services 

and 

(7)   Regulation  (EC)  No  216/2008  of  the  European  Parliament  and  of  the  Council  of  20  February  2008  on 
common  rules  in  the  field  of  civil  aviation  and  establishing  a  European  Aviation  Safety  Agency,  and 
repealing Council Directive 91/670/EEC, Regulation (EC) No 1592/2002 and Directive 2004/36/EC,  OJ L 
79, 19.3.2008, p. 1. 

(8)   SWD(2015) 262 final, 7.12.2015. 

2 

 
 
 
Consequently,  to  address  those  problems,  the  2015  Impact  Assessment  identified  the 
following specific objectives of the revised Regulation: 

- 

- 

- 

- 

- 

to  eliminate  unnecessary  requirements  and  ensure  that  the  regulatory  framework  is 
proportionate to the risks associated with different types of aviation activities; 
to  ensure  that  new  technologies  and  market  developments  are  efficiently  integrated 
and effectively overseen; 
to  establish  a  cooperative  safety  management  process  between  the  Union  and  its 
Member States to jointly identify and mitigate risks to civil aviation; 
to  close  the  gaps  in  the  regulatory  system  and  ensure  its  consistency,  e.g.,  with 
environmental policies; and 
to create an effectively  working system of pooling and sharing of resources between 
the Member States and the Agency. 

The Regulation requires that no later than 12 September 2023 the Commission carries out the 
evaluation  of  the  Regulation  as  well  as  of  the  Agency’s  performance  in  relation  to  its 
objectives, mandates, and tasks. The Regulation also requires the Commission to  forward to 
the European Parliament and the Council the findings of that evaluation. Consequently, this 
report first presents the methodology used by the Commission to conduct the evaluation and 
then it presents the main evaluation findings and conclusions.  

2.  EVALUATION METHODOLOGY 

The  Commission  conducted  the  evaluation  in  line  with  the  Commission’s  Better 
Regulation  Guidelines.  The  evaluation  assessed  the  Regulation’s  effectiveness  to  reach  its 
objectives,  efficiency,  relevance  in  responding  to  the  stakeholders’  needs,  coherence  with 
other EU legislation and policy actions, and its overall EU added value. The evaluation also 
assessed  EASA’s  performance  in  relation  to  its  objectives,  mandate  and  tasks.  The 
evaluation  covers  the  period  between  August  2018  and  December  2022.  However,  often 
complete  data  was  available  only  for  the  period  until  the  end  of  2021.  The  evaluation  was 
supported by an external support study (9).  

The evaluation is based on qualitative and quantitative evidence gathered via an extensive 
desk research. Further evidence was gathered via interviews and questionnaires disseminated 
among  the  various  relevant  stakeholder  groups  (airlines,  airports,  manufacturers  of 
aeronautical  products,  NAAs,  EU-level  institutions  and  agencies).  Furthermore,  there  were 
two  dedicated  workshops  organised  with  industry  and  national  aviation  authorities  aimed  at 
gathering stakeholder views.   

(9)  The  external  support  study  undertaken  by  Ramboll  et  al,  in  2022-2023  will  be  published  alongside  this 

evaluation.  

3 

 
 
 
 
 
Despite all efforts made to gather sufficient evidence necessary to evaluate the Regulation not 
all  aspects  could  have  been  evaluated  due  to  the  lack  of  sufficient  data.  This  was  partly 
because  the  Regulation  requires  that  the  Commission  adopts  further  detailed  rules  in  some 
new  areas  covered  by  it.  While  in  some  instances,  e.g.,  in  the  area  of  drones,  such  work  is 
fairly  advanced,  in  other  areas,  e.g.,  in  the  ground  handling  or  certification  of  ATM/ANS 
ground  equipment,  the  work  has  only  just  begun.  It  was  therefore  impossible  to  evaluate 
whether the Regulation met all its stated objectives.  

In addition, the Regulation introduced rather limited changes compared to its predecessor and 
therefore  stakeholders  had  difficulties  to  decouple  the  compliance  costs  related  to  the 
Regulation  from  the  compliance  costs  stemming  from  the  pre-existing  requirements. 
Consequently, the efficiency analysis used imperfect estimates of such compliance costs.  

Furthermore, the evaluation period was largely atypical due to the impact of the COVID-19 
pandemic  on  aviation,  both  during  the  pandemic  itself  as  well  as  afterwards  during  the 
ongoing  recovery  period.  Due  to  the  COVID-19  pandemic  passenger  revenues  in  2020  and 
2021  declined  significantly.  Airports  reported  significant  losses  in  2020  and  airport  debt 
increased. The drop in air traffic was coupled with the limited ability of air navigation service 
providers  (ANSPs)  to  reduce  their  expenditure  levels.  ANSPs  had  to  manage  the  gap  in 
revenues  using  either  their  own  resources,  or  loans  or  injection  of  equity  by  their  owners 
(which to a large extent are the Member States). Employment rates in aviation industry  also 
dropped due to the COVID-19 pandemic. 

Furthermore,  the  COVID-19  pandemic  directly  affected    the  Agency’s  capability  to 
implementthe  Regulation,  in  particular  its  new  provisions.  Thus,  the  COVID-19  pandemic 
created significant challenges for this evaluation, including but not limited to the availability 
of data and difficulties related to their interpretation.   

To ensure better availability of data for the future evaluations, the Commission reviewed and 
proposed  revisions  to  the  monitoring  and  evaluation  system  contained  in  the  2015  Impact 
Assessment. The revised system takes into account recent developments and additional types 
of  data,  which  has  become  available  since  the  publication  of  the  2015  Impact  Assessment. 
The  respective  data  points  will  be  collected  annually  by  EASA,  should  facilitate  the 
effectiveness and efficiency of the next evaluation.     

Given  the  complexity  of  the  Union’s  overall  legal  framework  in  the  area  of  aviation  safety 
(which is mainly contained in the numerous implementing and delegated acts adopted on the 
basis of the Regulation), this evaluation focuses on the role and the impact of the Regulation 
itself. This evaluation  therefore  does  not  enter into  a detailed  assessment of the rules in  the 
different technical areas covered by implementing and delegated acts.    

3.  EVALUATION FINDINGS 

4 

 
 
 
 
With regard to the rulemaking activities, EASA aims to ensure a performance-based approach 
when  proposing  requirements  and  procedures.  However,  the  ‘inclusive’  nature  of  the 
rulemaking process (i.e. balancing the needs and the preferred approaches of the industry and 
those of the NCAs) leads in some cases to the development of prescriptive rules. Further 
efforts should be made to reach a balance between the legal requirements and non – binding 
and more flexible measures such as acceptable means of compliance and guidance material.  

Certain  EASA’s  tasks  related  to  the  identification  and  mitigation  of  aviation  risks  are 
contained  in  the  Commission’s  legislative  proposal  on  SES2+ (10).  Such  important  safety 
related  enhancements  include  improving  performance  monitoring  by  creating  a  more  robust 
mutual  reliance between the SES performance review body and EASA, the growing role of 
the network manager (creating incentives to reduce environmental impact) and the new rules 
on  the  provision  of  a  common  information  service  for  unmanned  aviation  operations. 
Unfortunately, the legislative process on the SES2+ is still ongoing.  

When it comes to the safety performance of EASA, the positive results are mostly due to the 
long-standing effectiveness of EASA’s activities in the areas of rulemaking, certification and 
standardisation rather than the specific impact of the Regulation.  

Within  the  reporting  period,  the  aviation  sector  faced  three  major  crises  (the  COVID-19 
pandemic,  the  withdrawal  of  the  United  Kingdom  from  the  EU  and  Russia’s  war  of 
aggression against Ukraine) to which EASA was able to respond effectively and efficiently.  

Overall, EASA’s performance on rulemaking, certification and standardisation activities 
is widely positive. However, the COVID-19 pandemic impacted EASA’s activities, forcing it 
to concentrate on those new challenges and diverting it from its usual work. 

It is perceived that the Regulation increased costs for stakeholders (primarily due to new 
requirements  and  implementing  and  delegated  regulations).  Despite  this,  stakeholders 
identified benefits in terms of an increased safety. The stakeholders diverged in their views on 
the proportionality of costs and Regulation’s benefits.  

EASA’s  Advisory  Bodies  consultations  became  more  effective.  A  better  cooperative 
approach  led  to  significant  improvements  in  the  functioning  of  EASA’s  advisory 
structure and the relationship between EASA and national competent authorities.  

The Regulation has been overall effective in achieving its objectives. Despite the limitations 
of the findings of this evaluation, there are strong indications that EASA and the Regulation 
contributed  to  the  European  integration  in  the  area  of  air  transport  resulting  in  significant 
benefits  for  safety,  efficiency,  environment  and  an  enhanced  level  playing  field  for  the 
aviation industry. 

Despite some identified areas for improvement (e.g. a need for a consistent harmonisation of 
rules across all domains of aviation safety), Union aviation stakeholders consider the overall 
quality of Union aviation safety very high . EASA delivered on its core tasks defined by the 

(10)  https://transport.ec.europa.eu/transport-modes/air/single-european-sky/single-european-sky-ii_en 

5 

 
 
 
Regulation:  i.e.  product  certification,  rulemaking  and  standardisation  activities  are  overall 
perceived as effective with some minor caveats (e.g., too long rulemaking process compared 
to a fast pace of technological developments). Furthermore, EASA remained effective despite 
lasting  resource  constraints  since  2018,  partly  because  it  could  hire  staff  with  advanced 
expertise at high grades early on, bringing knowledge and efficiency.  

Moreover,  EASA’s  effectiveness  is  demonstrated  by  the  role  it  played  in  response  to  the 
external shocks and political pressures: a widely positive feedback was reported in relation to 
EASA’s role during the withdrawal of the United Kingdom from the Union, in ensuring safe 
flight operations  during  the COVID-19 pandemic  and in  the period post-pandemic, or in  its 
reaction to Russia’s war of aggression against Ukraine.  

While the Regulation assigns EASA a very broad role in implementation support, the existing 
resource  constraints  limit  EASA’s  ability  to  fulfil  that  tasks  entirely.  Therefore,  EASA’s 
future  workload  should  be  carefully  assessed  in  the  light  of  its  limited  resources.  The 
Regulation  does  not  provide  a  prioritisation  for  the  different  activities  of  EASA  and 
makes no direct link with its resources. For instance, the Agency’s tasks in innovation and 
research require a balance between managing the current, core tasks of EASA and the need to 
work on future areas. 

EASA and the Regulation have proven to provide a harmonised regulatory framework which 
contributes  to  a  high  level  of  safety  and  ensures  that  all  operators  adhere  to  the  same 
standards.  EASA  has  also  contributed  to  the  standardisation  of  regulations  in  the  Union, 
leading to greater cooperation and coordination between national competent authorities.  

Nonetheless, to maintain EASA’s capability of reacting effectively to external shocks and to 
remain  fully  involved  in  wider  EU  policy  objectives  (e.g.,  environmental  objectives),  it  is 
essential for the Agency to have an adequate level of resources, both staff and finances, 
to use its limited resources wisely, and to adapts its tasks according to priorities. 

The performance-based approach applied by EASA is essential to meet the objectives of 
the Regulation. However, the need for a better balance between legal certainty and flexibility 
of requirements, already identified in the 2015 Impact Assessment as one of the problems of 
the pre-existing framework, has not yet been fully achieved. 

Although there is a wide consensus across stakeholders (and within EASA itself) on the need 
to pursue a performance-based and less prescriptive approach, there is still some resistance to 
this  approach.  Whereas  stakeholders  from  the  aviation  industry  prefer  performance-
based/non-prescriptive  rules,  the  authorities  tend  to  value  more  prescriptive  rules  as  they 
provide for more legal certainty. 

Introducing  more  flexibility  in  the  rulemaking  process  would  increase  the  rulemaking 
effectiveness of EASA. In this regard it should be noted that the guidance materials developed 
by EASA helps to ensure harmonised implementation of regulations. 

6 

 
 
The effectiveness of stakeholder consultations within EASA’s Advisory Bodies is largely 
positive  and  EASA  plays  a  pivotal  role  in  respecting  the  due  process  when  consulting  all 
relevant stakeholders without ad hoc changes in procedures. 

Stakeholders’ feedback highlighted that the relationships within EASA’s Advisory Bodies 
have  significantly  improved  over  the  years,  shifting  from  a  competitive  to  a  cooperative 
approach. To further improve the effectiveness  of stakeholder consultation activities, EASA 
launched a review of the Advisory Bodies activities in 2022 which resulted in the setting up 
of additional groups focusing on specific topics. 

The value of stakeholder involvement at an early stage (i.e., through rulemaking groups and 
other  topic-dedicated  groups)  is  generally  recognised  by  EASA,  national  competent 
authorities and aviation industry stakeholders. Nonetheless, more targeted consultations  of 
stakeholders  outside  the  Advisory  Bodies  might  further  improve  the  effectiveness  of 
EASA’s consultation mechanism. 

In terms of efficiency, EASA was overall successful in implementing the financial resources 
made available to it. On the other hand, the scope of EASA’s tasks expanded (and continues 
to  expand)  while  the  resources  have  not  always  increased  accordingly.  This  resulted  in  a 
challenge for EASA to fulfil its missions in the longer term. 

EASA  was  able  to  maintain  high  budget  implementation  rates,  making  use  of  the  available 
annual  financial  resources  throughout  the  years.  The  COVID-19  pandemic  significantly 
impacted EASA’s activities and its revenue from fees and charges. Russia’s war of aggression 
against Ukraine and the withdrawal of the United Kingdom from the Union also impacted the 
EASA’s  operational  resources,  requiring  EASA  to  reorganise  itself  according  to  these  new 
priorities and to adapt/train its staff to new aviation challenges. 

Irrespective of the COVID-19 pandemic, EASA faced a steady decline in terms of human 
resources (full-time equivalents - FTEs) resulting in a challenge for EASA to fulfil its tasks. 
Indeed, while the 2015 Impact Assessment estimated that the introduction of the Regulation 
would require additional FTEs, the actual number of FTEs within EASA in fact decreased 
during  the  evaluation  period.  This  decrease  is  particularly  notable  considering  the 
expansion of EASA's tasks.  

The Union subsidy  to  EASA does  not  reflect  unforeseen emerging needs.  It remains to be 
assessed  whether  the  Union  contribution  is  still  sufficient  to  fund  EASA’s  tasks.  This 
requires EASA to seek funding for those activities elsewhere (e.g., through other EU funding 
programmes such as the Connecting Europe Facility). The new emerging tasks of EASA will 
require  a  deep  analysis  of  its  capacity  to  deliver  on  them  in  an  efficient  manner.  It  is  also 
necessary  for  EASA  to  prepare  for  unexpected  events  that  may  impact  its  operations 
and revenue streams. 

Although  EASA  demonstrated  its  ability  to  efficiently  use  its  annual  budget  and  generate 
revenue  through  its  activities,  EASA’s  growing  number  of  tasks  requires  an  assessment  as 
regards  the  availability  of  the  necessary  resources.  This  raises  the  question  of  whether  the 
Union would not be better served with an Agency that is fully financed from users’ fees. 

7 

 
 
The  discussion  about  EASA’s  long  term  financial  needs  is  closely  linked  to  the  ongoing 
discussion about EASA’s budget for the years 2025-2027 where EASA is confronted with 
important  challenges  to  balance  its  budget,  stemming  inter  alia  from  inflation-induced  cost 
increases and the need to update EASA’s IT infrastructure. Given those short-term budgetary 
constraints stemming from the limitations under the current 2021-2027 Multiannual Financial 
Framework  (MFF),  EASA  will  have  to  consider  reorganising  and  restructuring  its  current 
working methods.  

Besides the issue of the Union contribution, another important element in this context is the 
degree of flexibility in EASA’s establishment plan for posts that are funded through users’ 
fees and charges. Currently, the establishment plan, which defines the number of EASA posts 
across  the  organisation  irrespective  of  the  funding  source,  hinders  EASA  to  generate 
sustainable fee revenues from new applications, involvement in fee-financed EU programmes 
or other services (e.g. in the areas such as third-country operators or organisation of events) as 
EASA is not allowed to recruit more staff for these tasks. A more flexible establishment plan 
could  also  facilitate  the  recruitment  of  specialists  needed  for  tasks  such  as  certification, 
research  and  innovation  projects  or  specific  tasks  attributed  to  EASA  under  the  upcoming 
Refuel  Aviation  regulation  (e.g.  as  regards  fuel  standards,  environmental  labelling  or 
reporting tasks on sustainable fuels).       

EASA’s establishment plan should therefore  provide for a necessary financial flexibility. 

The  Regulation  is  perceived  as  leading  to  the  increased  costs  for  a  majority  of 
stakeholders,  primarily  due  to  the  increase  in  new  requirements  and  implementing  and 
delegated regulations. On the other hand, stakeholders also identified benefits in terms of 
an  increased  safety.  While  EASA’s  oversight  costs  were  perceived  to  be  largely  justified, 
stakeholders  raised  concerns  about  the  difficulty  of  complying  with  some  of  the 
implementation  requirements,  especially  for  smaller  countries  and  operators.  The 
simplification and burden reduction foreseen in the 2015 Impact Assessment has not yet taken 
place,  however  a  better  use  of  the  tools  offered  by  the  Regulation  should  reduce  the 
compliance and operational costs for stakeholders in a mid- to long-term.  

To further increase the efficiency of the existing framework, more effort should be made to 
develop  a  less  prescriptive  and  more  performance  based  regulatory  framework. 
Furthermore,  more  attention  should  be  given  to  assessing  the  cost  impact  of  new 
requirements  developed  within  the  Regulation’s  framework  vis-à-vis  the  stakeholders 
(particularly focusing on small entities).  

The Regulation is overall internally and externally  coherent. Only in few specific areas, 
the  Regulation  is  not  fully  coherent  with  the  SES  regulatory  framework,  and  with  some 
international  standards,  notably  the  standards  and  recommended  practices  developed  by  the 
International  Civil  Aviation  Organization.  Therefore, continued efforts  are needed to  ensure 
coherence  of  Union  aviation  legislation  and  a  better  alignment  with  standards  adopted  at 
international level. 

8 

 
 
Stakeholders’  feedback  on  the  internal  coherence  of  the  Regulation  was  overall  positive. 
Ssome stakeholders noted however some diverging interpretations of the implementing rules 
and incoherencies between Member States. 

When it comes to the EU added value, EASA fulfils its role in ensuring the application of 
common rules and standards for aviation safety and cooperation on environmental protection, 
research and innovation as well as its role in international cooperation.  

The Regulation achieved benefits that could not have been achieved at the national level 
or  through  other  international  bodies.  Having  the  Regulation  is  preferable  to  a  more 
fragmented system with different set of rules at  different levels. A key benefit of an  Union-
wide regulatory framework consists in the provision of common requirements across Union. 

The Regulation also has an added value compared to the pre-existing legal framework, mainly 
due  to  its  expanded  scope  covering  important  new  areas  such  as  unmanned  aircraft, 
certification of ATM ground equipment and environmental protection. 

Nonetheless,  needs  and  requirements  of  the  civil  aviation  sector  are  continuously 
developing  and  EASA  must  continue  to  adapt  to  those  needs.  Some  of  the  new 
requirements  of  the  Regulation  still  need  to  be  delivered  through  additional  implementing 
rules (e.g., on ground handling), and some other  new areas  will need to be addressed in the 
near future (e.g., Higher Airspace Operations (11) or technology developments in ATM). 

EASA continues to play an important and preponderant role in harmonising rules, ensuring a 
level  playing field  across  the  Union,  and supporting  all actors in  European aviation  and the 
public at large.  

EASA  has  also  been  successful  in  establishing  relationships  with  international  aviation 
partners, including at ICAO, resulting in the mutual recognition of certification and oversight 
activities  between  the  Union  and  third  countries.  This  has  facilitated  the  international 
acceptance  of  Union  aviation  products  and  services.  EASA  is  at  the  forefront  of  the 
development  and  implementation  of  innovative  technologies,  such  as  unmanned  aircraft 
systems  and  electric  aircraft,  among  others.  It  also  demonstrates  the  Union’s  ability  to 
maintain its international competitiveness. 

In its effort to harmonise rules and enhance cooperation with  international aviation partners, 
EASA has to consistently adapt to a very complex and rapidly changing environment.   

The  Regulation  and  EASA  are  both  perceived  to  be  relevant  for  the  current  and  future 
needs of the aviation sector. The Regulation is relevant in addressing key emerging needs that 
impact aviation safety such new technologies, digitalisation and artificial intelligence. 

(11)  HAO are operations carried out in higher airspace where the volume of airspace is typically above altitudes 
level  550). 

where 
https://www.easa.europa.eu/en/newsroom-and-events/news/roadmap-higher-airspace-operations-hao-
proposed-easa .  

the  majority  of 

are  provided 

(typically 

services 

today 

flight 

air 

9 

 
 
 
There are, however, concerns about the Agency’s capacity to deliver on  those new tasks 
without creating negative repercussions on its core aviation safety tasks. It is important to 
assess whether EASA has sufficient resources to deliver on its increasing number of tasks.  

Innovation  and  technological  developments  impact  the  already  complex  environment  in 
which EASA fulfils its missions. The use of machine learning and artificial intelligence are at 
the  core  of  many  new  tools.  Such  developments  have  also  possible  implications  on  the 
aviation  safety  and thus  they need to  be carefully  addressed  by EASA.  EASA should have 
the necessary technical expertise, train its staff and keep being involved in the relevant 
research projects and innovation programmes.  

EASA should pursue its efforts to prepare for key technology changes in aviation, such 
as emerging risks or trends, new business models or disruptive technologies and ensure that 
its staff skills and competencies as well as its systems and processes correspond to those new 
technological and innovation needs.  

EASA  should  continue  exploring  new  ways  to  keep  up  to  date  with  recent  technology 
innovations  and  to  properly  assess  their  impact  on  aviation.  Continuous  cooperation  with 
other  Union 
innovation 
programmes  should  be  further  exploited  to  enrich  the  knowledge  and  data  on  novel 
products, technologies, new types of operation and new business models. 

 agencies  and  organisations 

in  research  and 

involved 

Research  projects  on  emerging  technologies  should  be  fostered  to  ensure  that  skills  and 
competences in EASA as well as in the national competent authorities are up to date and that 
EASA  is  able  to  contribute  to  a  safe  and  swift  entry  of  those  new  technologies  into  the 
market.  The  testing  of  innovative  solutions  in  a  safe  environment  (sandboxes)  could 
benefit from additional regulatory flexibility.  

4.  CONCLUSIONS 

The  Regulation  was  overall  successful  and  contributed  to  a  safe  and  efficient  level 
playing field for the Union aviation industry and to addressing environmental aspects of 
aviation. This is mostly thanks to EASA’s rulemaking and certification activities, as well as 
thanks to a timely and effective response to external shocks. The effectiveness of stakeholder 
consultations  between  EASA,  the  aviation  industry  and  national  competent  authorities 
(NCAs) has increased over the years. EASA was also largely efficient in adequately using its 
available annual budget.  

Overall, both EASA and the Regulation have contributed to European integration in the 
area  of  air  transport  with  overall  benefits  for  safety,  environmental  protection,  efficiency 
and the creation of a level playing field for the aviation industry. 

10