COMMISSION STAFF WORKING DOCUMENT EVALUATION of the European Union Aviation Safety Agency's performance in relation to its objectives, mandate and tasks, and 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
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  SWD(2023) 298 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  of the European Union Aviation Safety Agency's performance in relation to its objectives, mandate and tasks, and 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 {SWD(2023) 299 final}  
 
 
Table of contents 

Introduction ......................................................................................................................... 4 
1. 
1.1. 
Purpose and scope of the evaluation ..................................................................................... 5 
1.2.  Main issues of the evaluation and criteria ............................................................................. 5 

2.  What was the expected outcome of the intervention? ...................................................... 7 
2.1.  Description of the intervention and its objectives ................................................................. 7 
Points of comparison........................................................................................................... 17 
2.2. 

How has the situation evolved over the evaluation period? .......................................... 19 
3. 
3.1. 
Evolution of the points of comparison ................................................................................ 19 
3.2.  Recent developments .......................................................................................................... 29 

Evaluation findings (analytical part) ............................................................................... 32 
4. 
To what extent was the intervention successful and why? .................................................. 32 
4.1. 
4.2. 
EU added value ................................................................................................................... 53 
4.3.  Relevance ............................................................................................................................ 55 

5.  What are the conclusions and lessons learned? .............................................................. 58 
To what extent was the intervention successful and why? .................................................. 59 
5.1. 
EU added value ................................................................................................................... 63 
5.2. 
5.3. 
Is the intervention still relevant? ......................................................................................... 63 
5.4.  Monitoring and evaluation system for future evaluations ................................................... 64 
Scoring of individual evaluation categories ........................................................................ 66 
5.5. 

Annex 1. 

Procedural Information ................................................................................... 69 

Annex 2. 

Methodology and Analytical models used ...................................................... 72 

Annex 3. 

Evaluation matrix (by criterion) ..................................................................... 81 

Annex 4. 

Overview of benefits and costs ........................................................................ 99 

Annex 5. 

Stakeholders consultation - Synopsis report ................................................ 103 

Annex 6. 

EASA’s KPIs – excerpt from the evaluation study ..................................... 112 

 
 
 
 
 
 
 
 
Glossary 

Term or acronym  

Meaning or definition  

AAM  

Advanced Air Mobility  

AI 

AMC 

ANSP 

AOC 

ATM 

ATO 

Artificial Intelligence 

Acceptable Means of Compliance 

Air Navigation Service Provider 

Air Operator Certificate 

Air Traffic Management  

Approved Training Organisation  

CAEP 

Committee on Aviation Environmental Protection 

CAMO 

Continuous Airworthiness Management Organisation  

CAAR 

Consolidated Annual Activity Report 

CAGs 

DOA 

EASA 

ECAC 

Collaborative Analysis Groups 

Design Organisation Approval 

European Union Aviation Safety Agency 

European Civil Aviation Conference 

EOSM 

Emergency Oversight Support Mechanism  

EPAS 

European Plan for Aviation Safety 

EQ 

EU 

Evaluation Question 

European Union 

eVTOL 

Electric and Hybrid-electric Vertical Take-off and Landing 

FSTD(O) 

Flight Simulation Training Devices (Organisation) 

FTE 

Full-time Equivalent 

 
 
 
 
GM 

HICP 

IA 

Guidance Materials 

Harmonised Index of Consumer Prices  

Impact Assessment  

ICAO 

International Civil Aviation Organisation 

KPI 

LSA 

MAB 

MOA 

Key Performance Indicator 

Light Sport Aircraft 

Member States Advisory Board 

Memorandum of Agreement  

MTOA 

Maintenance and Technical Operations Approvals  

NAA 

NCA 

NIS 

NoAs 

NPA 

OA 

National Aviation Authority  

National Competent Authority 

Network and Information Security 

European Network of Analysts  

Notice of a Proposed Amendment   

Organisation Approvals  

RSOO 

Regional Safety Oversight Organisation 

SAB 

SAF 

SARP 

SDGs 

SES 

Stakeholder Advisory Board 

Sustainable Aviation Fuel  

ICAO Standard and Recommended Practices 

Sustainable Development Goals 

Single European Sky 

SESAR 

Single European Sky ATM Research  

SES2+ 

Single European Sky II 

SME 

Small and Medium-sized Enterprise 

 
 
SPD 

SPO 

Single Programming Document  

Single Pilot Operations 

SSMS 

Sustainable and Smart Mobility Strategy 

TCO 

UAM 

UAS 

UK 

Third-country Operator 

Urban Air Mobility  

Unmanned Aircraft Systems  

United Kingdom of Great Britain and Northern Ireland  

UK CAA 

UK Civil Aviation Authority 

US 

VLA 

United States  

Very Light Aircraft 

 
 
 
1.  INTRODUCTION 

Air  transport  is  key  for  Europe’s  economy.  By  connecting  people,  businesses  and  regions 
within the EU and with the rest of the world, it plays a vital role in the integration and global 
competitiveness  of  Europe.  The  sector  has  developed  significantly  over  the  last  30  years 
thanks to the gradual implementation of the internal market for air services and the substantial 
growth of demand in air transport both within the EU and worldwide. This trend, however, 
also  results  in  growing  negative  impacts  on  climate  and  the  environment  offsetting 
technological developments.  

Safety is a pre-requisite for a competitive aviation sector. The European Union Aviation Safety 
Agency  (hereinafter  “EASA”  or  “the  Agency”)  was  established  in  2002  and  became 
operational  in  20031.  Since  then,  the  scope  of  Union  competence  and  the  Agency’s 
responsibilities were extended through Regulation (EC) No 216/2008 (2) and Regulation (EC) 
No 1108/2009 (3). The entry into force of Regulation (EU) 2018/1139 on common rules in the 
field of civil aviation and establishing a European Union Aviation Safety Agency (hereinafter 
“the Regulation”) (4), which replaced Regulation (EC) No 216/2008, consolidated the scope 
of Union competence to reinforce the European aviation system as a whole, including aspects 
such as environmental protection. While its headquarters are in Cologne, EASA also has an 
office in Brussels, and five international permanent representations (5). 

The initiative that led to the adoption of the Regulation was contained in the Commission’s 
Aviation Strategy for Europe from 2015(6). The objective of that review was to prepare for the 
challenges of the next 10-15 years and thus to continue to ensure safe and secure air transport, 
while addressing its environmental impacts. 

(1)   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. 

(2)   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, 
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32008R0216. 

(3)   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 
repealing  Directive  2006/23/EC,  https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX%3A32009R1108. 

services 

and 

(4)   https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32018R1139 

(5)  In Montreal, Washington, Beijing, Singapore and Panama City 

(6)   COM(2015) 598 final   

4 

 
 
 
1.1.  Purpose and scope of the evaluation 

The Commission is carrying out the evaluation of the Regulation at this specific point in time 
as it is legally mandated by Article 124 of Regulation (EU) 2018/1139 to do so “no later than 
12 September 2023” (7). The goal of this evaluation is two-fold: it combines the assessment of 
“the  Agency’s  performance  in  relation  to  its  objectives,  mandate  and  tasks”  with  the 
assessment of the overall impact of the Regulation and the changes it introduced. In addition, 
Article  124  stipulates  that  “the  evaluation  shall  assess  the  impact  of  this  Regulation,  the 
Agency and its working practices in establishing a high level of aviation safety. The evaluation 
shall also address the possible need to modify the mandate of the Agency”. 

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 Union agreements signed multilaterally and bilaterally with those countries 
(8). The evaluation covers the period between August 2018 and December 2022. However, in 
many  cases  complete  data  was  only  available  for  the  period  until  the  end  of  2021  and  is 
therefore reported as such. 

1.2.  Main issues of the evaluation and criteria  

The evaluation was supported by an external support study (9). It covers the five evaluation 
criteria  (effectiveness,  efficiency,  relevance,  coherence,  and  EU  added  value),  for  each  of 
which dedicated evaluation questions were defined. The evaluation systematically reviews and 
analyses all available evidence, from a variety of sources (10). 

In that regard, the evaluation is based on a broad range of tools including a desktop literature 
analysis, an analysis of EASA statistics and reports, two dedicated workshops with industry 
and national authorities, consultations of EASA’s advisory bodies and the EASA Management 
Board, followed up by bilateral contacts with individual members of the EASA Management 
Board.  In  addition,  a  series  of  stakeholder  interviews  and  a  broad  survey  with  public  and 
private  stakeholders  were  undertaken,  particularly  in  order  to  estimate  the  costs  and  the 
benefits of the Regulation.     

However,  an  important  part  of  these  efforts  did,  unfortunately,  not  provide  the  expected 
results. This is due to the fact that the changes that were introduced by the Regulation and that 
have already been implemented are relatively minor. In this context it is important to stress 
that the Commission has not yet adopted implementing and delegated acts in some of the new 
areas, such as for ground handling or air traffic management (ATM) ground equipment. As a 

(7)  The Call for Evidence was published on 21 April 2022: https://ec.europa.eu/info/law/better-regulation/have-

your-say/initiatives/13404-EU-Aviation-Safety-Agency-evaluation_en  

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

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

evaluation  

(10)  More details about the methodology of the evaluation is contained in Annex II. 

5 

 
 
 
result the scope of the evaluation is quite narrow. This also explains why the evaluation has 
not identified relevant academic analysis that could have been used to support this work.   

The Regulation has brought limited changes so far is further supported by the fact that – with 
very few exceptions - stakeholders were not able to calculate the compliance costs and benefits 
of the new Regulation compared to the previous one (in financial or FTE terms), nor to provide 
a sufficiently accurate assessments to support the evaluation. In this context, it is important to 
stress the significant additional efforts that were made to collect data during the evaluation 
process, including steering the work on the support study. Following up on the difficulties in 
the  gathering  of  data,  two  additional  rounds  of  direct  contacts  with  stakeholders  were 
undertaken,  including  direct  conversations  with  individual  stakeholders.  During  all  these 
additional efforts stakeholders consistently confirmed that – despite their eagerness to support 
this  work  –  it  was  not  possible  for  them  to  provide  the  requested  quantitative  detailed 
information. This experience leads to the conclusion that further requests and additional efforts 
would not improve this situation.  

Thus, only limited data sets received from two national authorities (Spain and Belgium) were 
used as the basis for an extrapolation effort to assess the potential impact of the changes for 
all EU Member States (chapter 4.1.2.2).  

The report contains various explicit caveats to explain this situation (e.g. in section 4.1.2).  

While the lack of quantitative data has to be acknowledged, this evaluation was cautious not 
to compensate for this by overly relying on internal EASA information on activities and their 
effects in order to avoid bias. It rather sought to establish a balanced approach between own 
literature  review  and  desk  research,  and  where  necessary,  information  on  EASA’s  own 
activities. An example of this can be seen on page 28 where the analysis of EASA’s outputs 
on rulemaking uses data that was collected from EASA's European Plans for Aviation Safety. 
It  is  against  this  background  that  the  results  of  the  stakeholder  consultation  became  the 
backbone of this evaluation.         

A particular challenge for the evaluation was that a large part of the evaluation period was 
extremely atypical due to the COVID-19 pandemic that impacted aviation, both during the 
pandemic itself but also  afterwards during the ongoing recovery period. The crisis led to a 
significant decline in passenger revenues in 2020 and 2021. Airlines responded by reducing 
their  fleet  in  use  (mainly  by  parking  aircraft).  Profitability  of  passenger  airlines  fell 
dramatically in 2020 and recovered only slightly in 2021. Airports reported significant losses 
in 2020 and airport debt increased during the crisis. The drop in air traffic coupled with the 
limited  ability  of  air  navigation  service  providers  (ANSPs)  to  reduce  expenditure  levels 
required them to manage the gap in revenues using either own resources, loans or injection of 
equity  by  their  owners  (which  to  a  large  extent  are  the  Member  States).  Air  transport 
employment  was  significantly  affected  by  the  pandemic  and  there  are  some  significant 
concerns across the entire industry about how services will be delivered when traffic returns 
to 2019 levels due to resourcing gaps.   

Furthermore, the pandemic had direct effects on the implementation of various new provisions 
of the Regulation by the Agency.  As a conclusion, the impact of the COVID-19 pandemic 

6 

 
 
creates significant challenges for this evaluation, including but not limited to the availability 
of data and difficulties related to their interpretation.   

Given the complexity of the EU’s overall legal framework in the area of aviation safety (which 
is  mainly  contained  in  Implementing  and  Delegated  Acts  based  on  the  Regulation),  this 
evaluation focuses on the role and the impact  of the Regulation itself. The objective of the 
evaluation  is  therefore  not  to  enter  into  a  detailed  assessment  of  the  rules  adopted  in  the 
different technical areas.    

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1.    Description of the intervention and its objectives 

2.1.1.  The Commission’s 2015 Impact Assessment   

The  Commission’s  proposal  for  the  revision  of  Regulation  (EC)  No  216/2008  was 
accompanied by an Impact Assessment from 2015 (“the IA”). (11)  The IA identified four main 
problems:   

Problem  1:  The  existing  regulatory  system  might  not  have  been  sufficiently  able  to 
identify and mitigate safety risks in the mid to long-term 

The IA looked at aviation safety from a systemic perspective, identifying two main issues: (1) 
resource shortages and the risk of inefficient use of resources by aviation authorities and (2) 
the reactive nature of the existing safety regulation and oversight system. The IA considered 
that these factors could make it difficult to maintain the system’s good safety record in view 
of the expected traffic growth and the increasing complexity of the aviation system. The IA 
also found that the fragmentation of the EU safety management system had a negative impact 
on the availability of safety-related information.   

Problem 2: The existing regulatory system was not proportionate as it created excessive 
burdens, especially for smaller operators 

The  EU  aviation  safety  system  achieved  good  safety  performance,  however,  at  a 
disproportionate cost for SMEs and General Aviation. Besides, the overly complex regulatory 
framework for this segment diverted oversight resources from more important tasks. The IA 
identified two main issues in this context: (1) the level/type of regulation did not correspond 
to the risks that are associated with the respective aviation activity and (2) the overall system 
risked  becoming  overly  reactive.  The  main  concern  was  that  the  absence  of  an  adequate 
distinction between acceptable levels of risk had led to a "one-size-fits-all" approach that was 
the root cause for the disproportional impact for smaller organisations. Besides, the regulatory 
framework attempted to cover all conceivable dangers, even though only a limited number of 
recurrent issues are responsible for the great majority of accidents.  

(11)  SWD(2015) 262 final, 7.12.2015 

7 

 
 
 
The IA also stated that the EU overly relied on legislative instruments to address safety risks 
while  not  sufficiently  exploring  other  tools  (e.g.,  industry  standards,  training  or  safety 
promotion) which could provide more flexibility in managing risks. 

Problem  3:  The  existing  regulatory  system  was  not  sufficiently  responsive  to  market 
developments  

The  IA  found  that  the  EU’s  regulatory  system  was  not  sufficiently  responsive  to  market 
developments.  This  impacted  on  the  system’s  ability  to  quickly  accommodate  safety  and 
efficiency-enhancing  technologies  and  to  respond  to  new  operational  industry  practices. 
Prescriptive regulation hindered the uptake of new technologies that could have led to safety 
or efficiency improvements. Such an approach restricted choices for obtaining compliance and 
discouraged  innovation.  Moreover,  on  the  side  of  environmental  standards,  the  regulatory 
system still contained an automatic link with the International Civil Aviation Organization’s 
(ICAO) (12)  environmental  standards  (which  did  not  exist  for  safety  rules).  Besides,  the 
emergence of electric engines was also not reflected in Regulation (EC) No 216/2008, which 
defined  ‘complex  aircraft’  by  referring  to  turbine-powered  engines  only.  Finally,  the 
manufacturing industry voiced concerns regarding the certification system stating that, due to 
lengthy  procedures  and  limited  availability  of  resources  at  EASA,  it  might  not  be  able  to 
respond  to  future  industry  demand  for  product  certification  promptly.  This  could  lead  to 
financial  penalties  and,  more  generally,  to  a  competitive  disadvantage  for  the  European 
industry.  

Problem 4: Differences in resources across Member States 

The fourth problem identified by the IA was linked to the availability of qualified personnel. 
Differences in organisational capabilities of Member States created potential safety risks (as 
some Member States and particularly national authorities in smaller Member States were not 
sufficiently  capable  of  ensuring  effective  oversight)  and  that  this  contributed  to  mistrust 
between  the  Member  States  (as  a  number  of  national  authorities  were  not  automatically 
accepting certificates issued by some other authorities). 

Specific objectives for the intervention and the preferred policy package 

The objective of the intervention was to develop a more complete and proportionate regulatory 
system by incorporating the concepts of risk hierarchy and performance-based standards. The 
expectation was that increased use of performance-based regulation and of industry standards 
would leave more room for technological developments in the market. Gains in safety  and 
environmental  protection  would  be  made  possible  through  cooperative  safety  management 
between organisations, Member States, and EASA. Improved aviation oversight was expected 
from the introduction of the possibilities offered by resource-sharing and pooling.  

Concretely, the IA identified the following specific objectives:  

–  Eliminate  unnecessary  requirements  and  ensure  that  the  regulatory  framework  is 

proportionate to the risks associated with different types of aviation activities; 

(12)  All EU Member States are members of ICAO, while the Union as such is only an observer in ICAO. 

8 

 
 
 
 
–  Ensure that new technologies and market developments are efficiently integrated and 

effectively overseen; 

–  Establish  a  cooperative  safety  management  process  between  the  Union  and  its 

Member States to jointly identify and mitigate risks to civil aviation; 

–  Close  the  gaps  in  the  regulatory  system  and  ensure  its  consistency,  e.g.,  with 

environmental policies; 

–  Create an effectively working system of pooling and sharing of resources between the 

Member States and the Agency. 

The preferred policy package (13) combined the preferred options from each of these five policy 
domains: 

Policy domain 

Policy option 

Quality and management of resources 

Proportionality and safety performance 

Gaps and inconsistencies – ground handling 

Include the “Emergency Oversight Support 
Mechanism” as a new element in the scope 
of the Regulation 

Strengthen enablers for the development of 
a  proportional  and  performance-based 
safety system 

Include  ground  handling  as  a  new  element 
in the scope of the Regulation 

Gaps and inconsistencies – aviation security  Strengthen  provisions  supporting  a  more 
safety-  and 
coordinated  approach 
security-related matters in the scope of the 
Regulation 

to 

Gaps  and  inconsistencies  –  environmental 
protection 

Include  EU  essential  requirements  for 
environmental  protection  for  aeronautical 
products in the scope of the Regulation  

The preferred policy package was primarily based on voluntary collaboration between EASA 
and the national competent authorities. Regulatory measures prioritised fostering cooperation 
within the European aviation safety system to improve resource utilisation. Besides, it was 
suggested to increase the scope of EU competence in some areas such as ground handling.  

All these elements were included in the Regulation that was adopted, with exceptions related 
to funding (no introduction of a more flexible framework for funding EASA activities), cyber-
security  (no  establishment  of  EU essential  requirements),  and  safety-security  related  issues 
(no clarification of the competences of EASA to issue security directives).  

(13) IA SWD (2015) 262, 2015, p. 69 

9 

 
 
 
 
2.1.2.  Projected impact of the preferred policy package 

The IA divides the impacts of the preferred policy package into nine categories:  

–  internal market,  

–  compliance costs and other operational costs for businesses,  

–  SMEs and light aviation,  

–  innovation,  

–  aviation safety,  

–  competitiveness,  

–  creating jobs, 

–   implementation costs and  

–  resource needs for EASA. 

Internal market 

The IA expected an improved level playing field through more uniform oversight. This should 
have been enhanced by the pool of European inspectors and enhanced possibilities for Member 
States to delegate and pool responsibilities for certification and oversight. Additional benefits 
were expected from the promotion of EU-wide training standards. 

The IA also expected that the avoidance of overly prescriptive rules and the introduction of a 
broader range of possibilities to demonstrate compliance with essential requirements would 
stimulate  economic  activity.  In  order  to  reap  such  benefits,  new  methods  for  product 
certification, quality  assurance  from  manufacturers and increased use of industry standards 
should be progressively built into the system.  

Compliance costs and other operational costs for businesses 

The  IA  expected  additional  costs  for  the  industry  in  Member  States  that  used  the  pool  of 
experts,  delegated  responsibilities  to  EASA  or  established  an  emergency  oversight  support 
mechanism. It was anticipated that the delegation of certification and oversight responsibilities 
from Member States to competent users' organisations (e.g., a national aeroclub) would reduce 
compliance  costs  for  non-commercial  aviation.  The  removal  of  the  staffing  cap  on  EASA 
resources financed from fees and charges was not expected to create additional costs for the 
manufacturing industry, as certification work was in any way subject to fees and charges. In 
the domain of product certification, it was estimated that in the mid to long term, the number 
of EASA staff would increase by around 12%, compared to the 2015 Multiannual Staff Policy 
Plan, corresponding to about 30 posts. 

Environmental protection 

10 

 
 
The IA expected to allow easier fine-tuning of the aviation environmental requirements for 
aeronautical products to the EU environmental and climate policies and their ambition level. 
It would allow for a separate and hence more targeted cost-effectiveness assessment from a 
European perspective and should lead to a more optimised mix of mitigation measures than 
the global measures that are agreed in ICAO. Another significant benefit would be that the EU 
could react more quickly to new developments, as the current system de facto has to wait for 
the relatively slow ICAO process to be completed.   

Overall, positive effects on compliance and other operational business costs were expected.   

SMEs and light aviation 

The IA expected a reduction of administrative burden on SMEs and light aviation as well as 
an improved environment for SMEs. For the certification of light aircraft that are used in low-
risk  activities,  a  procedure  other  than  a  type  certification  was  suggested.  Manufacturers  of 
aircraft included in Annex II of the Regulation would be given the choice to have their goods 
governed by standard rules and enjoy unrestricted circulation inside the internal market. To 
ensure that the supervision is done in accordance with the regulated entities, competent user 
organisations (such as national aero clubs or light aviation associations) would be permitted 
to  operate  as  qualified  entities  on  behalf  of  the  national  aviation  authorities  under  certain 
conditions. The IA expected that it should be easier to tailor requirements to the risks involved 
with  light  aircraft  and  the  operations  of  small  organisations  using  a  modular  approach  to 
certification of aviation activities.  

Innovation 

The IA expected a swifter introduction of new technologies. Adding en-route charges as an 
additional source of income for EASA to finance its activities in the field of ATM/ANS was 
expected  to  ensure  the  necessary  resources  to  support  the  deployment  of  new  SESAR (14) 
technologies. By removing the staffing cap on EASA resources that are financed through fees 
and charges, additional positive impacts on innovation were expected, by making sure that 
new technologies could be certified according to market demand. Further positive effects were 
expected by the elimination of overly  prescriptive regulations, the reduction of compliance 
costs and the introduction of additional options for proving compliance, with an increased use 
of performance-based rules, i.e. rules that define a desired outcome without prescribing the 
method of how to achieve it, offering industry more flexibility in developing new technologies. 
Notably,  increased  use  of  industry  standards  was  expected  to  shorten  the  time  for  new 
technologies to reach the market (e.g., in the areas of electric engines or drones).  The preferred 
policy  package  also  recommended  the  use  of  essential  requirements  in  the  areas  of  cyber-
protection and improved resilience of critical Air Traffic Management (ATM) infrastructure 
parts.  Those  systems  were  expected  to  stimulate  the  development  of  innovative  technical 
solutions.   

(14)  SESAR  is  the  Single  European  Sky  ATM  Research  and  is  the  technological  pillar  of  the  EU’s  Single 
European  Sky  policy  and  a  key  enabler  of  the  European  Commission’s  Sustainable  and  Smart  Mobility 
Strategy. SESAR defines, develops and deploys technologies to transform air traffic management in Europe. 

11 

 
 
 
Aviation safety 

The  IA  expected  a  positive  impact  from  improved  training,  qualification  levels  and  more 
uniform  oversight.  In  addition,  the  possibility  of  delegating  certification  and  oversight 
responsibilities to competent user organisations was expected to free up resources in national 
authorities,  which  could  then  be  shifted  to  the  oversight  of  higher-risk  activities  with  the 
related safety benefits. An improved overall safety performance of the EU aviation sector was 
expected from a collaborative, risk-based safety management approach.  

Competitiveness  

Overall positive effects on the competitiveness of the EU industry were expected from further 
harmonisation and integration of the European aviation oversight system. Positive side-effects 
could consist in facilitating the consolidation process for the EU airline industry. 

Creating jobs 

Positive  employment  effects  were  expected  to  derive  from  increased  competitiveness. 
Beneficial effects of reduced costs from streamlined certification processes were particularly 
expected  in  the  general  aviation  industry.  The  implementation  of  minimum  training 
requirements as well as minimum quality standards for operational safety  were expected to 
lead to improved working conditions and lower injury rates.  

Implementation costs 

As  regards  implementation  costs  for  industry  and  public  authorities,  the  new  approach  on 
safety management is in line with evolving ICAO requirements that have to be respected by 
Member States in any event. Besides, most of the suggested actions were of a voluntary nature 
and would therefore only be implemented  as  a result of  a  favourable  cost-benefit analysis. 
After  some  initial  setup  and  training  expenses,  it  was  anticipated  that  improvements  in 
efficiency  via  resource  pooling  and  sharing  and  the  transition  to  more  targeted,  risk-based 
oversight  could  have  a  favourable  mid-  to  long-term  impact  on  Member  State  resources. 
Besides, according to the "user pays principle”, fees and charges would be used to fund the 
pooling and sharing of resources. 

Resource needs for EASA 

EASA's sources of revenue consist of contributions from the EU, from any European third 
country  that  the  EU  has  agreements  with,  fees  and  charges,  any  voluntary  financial 
contribution  from  Member States,  third countries  or other entities and grants (15). The table 
below shows the estimated resource needs of EASA. 

(15)  In  light  of  one  of  the  operational  objectives  of  the  preferred  policy  package,  namely  ‘Introduce  a  more 
flexible framework for funding EASA activities’, Regulation (EU) 2018/1139 added one source of revenue 
to this list, which is represented by grants to EASA's budget. 

12 

 
 
 
Table 1. Estimated resource needs of EASA under preferred policy options 

Policy option 

Resources in 
FTE 

One-off costs in EUR  
(Non-staff costs) 

Annual costs in EUR  
(including staff costs) 

NPV 2016-2030 in 
EUR 

1.3(b): 
Emergency 
Oversight support 
mechanism 

2.2: Enablers for 
a proportional 
and performance-
based safety 
system 

3.1(b) ground 
handling 
(industry 
standards/no 
certification) 

3.2(c) Coord. 
approach to 
safety and 
security related 
matters 

3.3(b) EU 
essential 
requirements for 
environmental 
protection with 
respect to 
aeronautical 
products 

1 FTE 
(repository of 
certificates)  

1 FTE (pool of 
experts)  

1 FTE 
(accreditation 
scheme for 
training 
institutes and 
monitoring) 

Tasks are 
expected to be 
absorbed by 
present staff 

12.7 m (annual 
costs)  

2.6 m (one-off 
costs) 

Central repository of 
certificates: 1.2 m  

Pool of experts: 0.4 m 

Development of virtual 
training academy: 0.1 m  

Additional training 
guidance material: 0.2 m  

Setting up of administrative 
and contractual framework 
for delegations: 0.7 m 

Central repository of 
certificates annual 
maintenance: 0.5 m  

Pool of experts:  
0.1 m 

Promotion of risk and 
performance based 
oversight methods: 0.2 m  

Accreditation scheme: 
0.095 m 

No additional costs for EASA. Possibility for cost reduction due to increasing reliance on 
accreditation mechanisms and declarations of compliance for product certification should 
also reduce the costs of EASA in product certification etc. 

1.5 FTE 

n/a 

3 FTE 

n/a 

2 FTE 

n/a 

2.05 m 

set up and maintain the 
system of common 
requirements incl. initial 
rulemaking standardisation 
and implementation 
support: 0.142 m 

Support to rulemaking and 
inspections:  
0.295 m 

4.3 m 

Update of environmental 
rules: 0.095 m  

7 m 

IT equipment: 0.3 m  

European environmental 
report: 0.095 m 

Total 

9.5 FTE 

2.6 m 

1.822 m 

28.65 m 

Source: IA SWD (2015) 262, 2015, p. 72 

Contribution to the UN Sustainable Development Goals (SDGs) 

The intervention contributes to the achievement of several of the UN Sustainable Development 
Goals (SDGs) (16). 

(16)  https://sdgs.un.org/goals 

13 

 
 
 
 
 
 
SDG 3 concerns good health and well-being, along with the reduction of air pollution, noise 
and radiation exposure. The aviation industry has also several other potential effects on global 
health. The Regulation and EASA contribute directly to define and implement policies and 
measures with the objective to reduce the environmental impact of aviation, more generally, 
the protection of citizens from health risks posed by aviation directly such as noise and air 
pollution. 

SDG 13 concerns climate action, which is an important part of EASA’s work e.g., the CO2 
certification standard, the European Aviation Environmental Report, work on environmental 
labelling of aviation, the analysis of non-CO2 effects of aviation on the climate, foreseen work 
on the implementation of the ReFuelEU Regulation on sustainable aviation fuels, etc. 

SDG 17 relates to the strengthening of global partnerships. Although the Regulation does not 
directly relate to SDG 17, it indirectly promotes it by fostering worldwide coordination and 
collaboration in  aviation safety oversight. The Regulation intends to raise safety standards, 
lower the risk of accidents, and increase the effectiveness of aviation operations, all of which 
ultimately support sustainable development.  It establishes standard safety requirements and 
oversight procedures for third-country operators (TCOs) and promotes the cooperation with 
third countries, which is crucial for attaining the SDGs in a globalised world. 

2.1.3.  Intervention logic  

On the basis of the information presented in Section 2, Figure 1 below presents the intervention 
logic  for  the  evaluation.  Figure  1  provides  a  visual  representation  of  the  problems,  inputs, 
outputs, results and impacts, and how these link to the objectives of the Regulation and EASA. 
This  visualisation  builds  upon  the  legal  text  of  the  Regulation  and  the  IA  (as  discussed  in 
Section 2.1.1.).  

The starting point of the intervention logic consists in the four ‘Problems’ (i.e., the four main 
issues identified by the IA, discussed in Section 2.1.1.) justifying the EU intervention, i.e., the 
Regulation.  

The ‘Objectives’ of the intervention are directly linked to those ‘Problems’. As specified by 
the legal  text of the Regulation,  the general  objective of  the  Regulation  is to  establish and 
maintain a high uniform level of civil aviation safety in the EU. Moreover, the IA identifies 
five  specific  objectives  that  the  Regulation  (and  therefore  EASA’s  activities)  aims  to 
pursue (17). 

The intervention logic then illustrates how the monetary and non-monetary ‘Inputs’ lead to 
concrete  and  measurable  ‘Outputs’  of  EASA’s  activities.  The  intended  ‘Outputs’  of  the 
intervention  are  a  synthesis  of  the  work  of  the  Agency  across  the  different  domains.  Such 
outputs should lead to the desired ‘Results’ of the EU intervention.  

Moreover, the intervention logic presents the expected ‘Impacts’ of the Regulation and EASA. 
Lastly,  the  intervention  logic  suggests  that  ‘External  factors’  (e.g.  unforeseen  crises  and 

(17)  See Section 2.1.1 ‘Specific objectives for the intervention and the preferred policy package’ 

14 

 
 
 
technological  developments)  and  ‘Other  EU  and  international  policy  interventions’  (e.g. 
Sustainable and Smart Mobility Strategy, European Green Deal) have to be taken into account 
in the evaluation.  

In addition to providing an understanding of what the Regulation and EASA sought to achieve 
and how, the intervention logic serves as a basis to assess whether the intended results of the 
intervention have indeed been achieved and identify any shortcomings in the causal chain.  

15 

 
 
Figure 1. Intervention Logic  

Source: elaboration of the contractor (2023) 

 
 
 
2.2.  Points of comparison  

This section presents the points of comparison that are used to evaluate the Regulation. The 
IA baseline considered the evolution of the problems and the expected future resources and 
provided categories of points of comparison linked to the general objectives and needs of the 
Regulation. The variables used in the IA and its support study were critically reviewed and 
adapted to form the baseline situation.  

Table 2 outlines the expected outcomes from the IA and the variables considered for each 
point  of  comparison.  The  progress  on  the  points  of  comparison,  measured  through  the 
variables, is presented in Section 3.1. 

Table 2. Summary of the points of comparison and variables 

Point of 
comparison 

Expected outcomes from the Impact 
Assessment 

Variables 

Internal market 
(IA) 

Positive impacts were expected on the level 
playing field in the internal market through more 
uniform oversight. These impacts should have 
been enhanced by a more robust pool of 
European inspectors and enhanced possibilities 
for Member States to delegate and pool 
responsibilities for certification and oversight. 

Compliance 
costs and other 
operational 
costs for 
businesses (IA) 

The Regulation was expected to have positive 
effects on compliance and other business 
operational costs. Those positive effects were 
foreseen to result from a regulatory system that 
is more proportionate and performance-based, 
from the ability to satisfy requirements with 
greater flexibility, and from greater dependence 
on industry standards. 

SMEs and light 
aviation 

It was expected that the Regulation would ease 
the administrative burden on SMEs and light 
aviation players. The regulatory environment 
for small business owners would also be 
improved. The performance-based regulation 
could be favourable to SMEs, as it could provide 
them with a choice of applying prescriptive or 
performance-based rules on a case-by-case basis. 

Innovation (IA)  The IA expected that new technologies would be 

more rapidly introduced thanks to the more 
efficient use of resources in the Member States 
and EASA under the Regulation. Removing 
unduly prescriptive regulations, lowering 
compliance costs, and offering a variety of ways 
to show compliance, were foreseen to free up 

•  Level playing field 
•  Ratio of registered 

commercial aircraft to the 
number of thousands of 
intra-EU flights per 
country 

•  Number of EASA Air 
Operator Certificates 
(AOCs) 

•  Achieved level of quality 
and management of 
resources 

•  Achieved level of 

proportionality and safety 
performance 

•  Achieved level of aviation 

security 

•  Achieved level of 

environmental protection 

•  General aviation market 

growth 

•  Expected impacts of the 

Regulation 

•  EASA tariffs for type 

certification 

✓  Share and number of electric 

aircraft projects  
✓  Number of hydrogen 

technology patents  

✓  Number of electric and hybrid-
electric vertical take-off and 
landing (eVTOL) concepts 

17 

 
 
 
Point of 
comparison 

Expected outcomes from the Impact 
Assessment 

Variables 

✓ 

Incident and accident rate 

✓  Airlines’ market share 
✓  Number of active and parked 

fleet by manufacturer 

✓  Amount of confirmed orders 

✓  Number of aviation employees 

in the EU 

✓  EASA’s costs and revenues 

per category 

o  Cost type explanation 
and the Regulation’s 
possible impacts 

Aviation safety 
(IA) 

Competitiveness 
(IA) 

Creating jobs 
(IA) 

Implementation 
costs (IA) 

resources and make it easier to implement 
new technologies. 

The IA expected that the Regulation would have 
a positive impact through improved training and 
qualification of staff and more uniform 
oversight. Gains in safety would be made 
possible through a collaborative safety 
management approach connecting the 
organisation, Member States, and EU levels and 
enhanced supervision due to simpler resource 
sharing and pooling 

With regard to the competitiveness of the EU’s 
aviation industry, positive effects were 
expected, as the safety record of the EU aviation 
sector is a factor in its competitive ability. It was 
foreseen that safety improvements and a more 
favourable environment for innovation would 
help the European aviation industry compete 
more successfully. 

More appropriate regulations and a conducive 
environment for innovation were anticipated to 
have a favourable influence on employment in 
the European aviation sector. The Regulation 
was foreseen to help the EU aviation industry to 
expand safely and by encouraging innovation 
and new technology, as well as by reducing 
expenses that can be justified from a safety 
standpoint, particularly in the general aviation 
and SME sector. This was anticipated to help 
create new employment in the European aviation 
industry. 

State safety programmes were seen to be 
implemented by Member States that had not yet 
done so since the IA was published. The 
requirement for more training was expected to 
result in increased expenditures. After some 
initial setup and training expenses, it was 
anticipated that improvements in efficiency via 
resource pooling and sharing and the transition 
to more targeted, risk-based oversight could 
have a favourable mid- and long-term impact 
on the resources of NCAs. According to the 
“user pays principle”, fees and charges would be 
used to fund the pooling and sharing of 
resources. As there are no additional 
certification requirements under the 
recommended ground-handling and security 

18 

 
Point of 
comparison 

Expected outcomes from the Impact 
Assessment 

Variables 

alternatives, Member States’ oversight costs 
were not anticipated to be very high. 

Resource needs 
for EASA (IA) 

See Table 2 in Annex 2 

✓  Number of staff at EASA 

✓  EASA’s revenues 

✓  Number of organisational 

approvals 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

The purpose of this section is to present the main developments that took place during the 
analysed period between 2018 and 2022. This section therefore discusses (18): 

•  How the variables identified in Section 2 evolved during the evaluation period; and 
• 

Important economic, geopolitical, and technological developments during the evaluation 
period. 

3.1.  Evolution of the points of comparison 

This section dives deeper into the above-described points of comparison by comparing the 
most relevant IA predictions with the current situation. 

3.1.1.  Internal market  

The Regulation aimed at further facilitating the free movement of goods, persons, services, 
and capital, thus providing a level playing field for all actors in the internal aviation market. 

The countries with the largest registered commercial aircraft in 2020 are Germany, Ireland, 
Spain,  France, Malta,  and Austria. Countries such as Malta and  Ireland have considerably 
higher numbers of registered aircraft, compared to their aviation activity, with respectively 
27.75 and 10.02 registered aircraft per thousand intra-European movements. Larger aviation 
countries  such  as  Germany  and  France  only  have  1,90  and  1,54  registered  aircraft  per 
thousand intra-European movements. In 2019, 4,77% of the European fleet was registered in 
Malta and 12,57% in Ireland. While most countries saw their commercial fleet decrease from 
2015 to 2020, both in absolute and relative terms, Malta’s fleet increased significantly. This 
suggests  that  air  carriers  exercise  conscious  choices  when  registering  their  aircraft.  It  is 
worthwhile for EASA to monitor and better understand this difference in the choice of the 
competent  NCA  for  aircraft  registration  and  to  understand  the  reasons  (e.g.  customer-
orientation of the NCA, throughput time for requests, differences in the legal systems between 
Member States such as regards seizure law) for these choices. 

(18)  Statistical evidence and details on the legal implementation of the intervention and on EASA’s KPIs on the 
different  activities  of  the  agency  are  presented  in  Appendix  5  of  the  support  study.  The  methodology 
employed and the number of sources analysed on the legal implementation of the intervention are presented 
in Appendix 1 of the support study. 

19 

 
 
Figure 2. Ratio of registered commercial aircraft to the number of thousands of intra-
EU flights per country 

30

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Source: Ramboll based on Eurostat [AVIA_EQ_ARC_TYPREG & AVIA_TF_ACC], 2022 

Article 65 of the Regulation introduced the possibility, for an organisation with a certificate 
from a Member State, but that has or that intends to have a substantial proportion of facilities 
and personnel located in one or more other Member States, to request that EASA (instead of 
the  national  competent  authority)  becomes  the  competent  authority  responsible  for 
certification, oversight and enforcement tasks – and so issues their Air Operator Certificates 
(AOCs). So far, as far as air operators are concerned, EASA approved three AOCs (WIZZ 
Air Hungary Airlines Limited, LUXAVIATION E.A., S.A., and Wizz Air Malta Limited). 

3.1.2.  Compliance costs and other operational costs for businesses 

Compliance  costs  refer  to  the  expenses  incurred  by  businesses  in  order  to  comply  with 
regulatory requirements and standards. As part of the IA, the assessment on the compliance 
costs  and  operational  costs  of  the  Regulation  on  businesses  was  mixed.  The  following 
subsections follow the evolution of the different elements which were targeted under the IA 
in relation to compliance and operational costs.  

According  to  the  IA,  the  policy  issue  of  the  quality  and  management  of  resources  was 
supposed  to  be  addressed  through  the  introduction  of  the  Emergency  Oversight  Support 
Mechanism (EOSM). The EOSM was expected to create additional cost for operators. The 
purpose of the EOSM is to ensure that necessary measures are taken promptly to ensure the 
safety of air travel and to restore public confidence in aviation. However, this mechanism has 
so far never been used. For this reason, the actual costs for operators cannot be measured.  

The quantitative estimates were included in the IA only for Air Operator Certificate (AOC) 
issuance and its continuous oversight for a mid-sized airline: initial AOC issuance totalling 
EUR 90,000, and an annual fee of EUR 464,000. In addition, an EASA fee for approval of a 
repair station would incur an annual fee of EUR 32,080 with a fee for technical ratings. Figure 
3 outlines that in 2021, the number of AOC aeroplane holders was above the previous 4-year 
average and exceeded the numbers of previous years. The number of CAT aeroplanes further 
dropped and ended below the previous 4-year average, however still exceeding the lowest 
level of 2017. 

20 

 
 
 
 
 
 
 
 
 
 
 
Figure  3.  Numbers  of  Air  Operator  Certificates  Aeroplanes  and  Commercial  Air 
Transport aeroplanes in EASA MS 

Source: EASA, 2022 Annual Safety Review 

With regards to the proportionality and safety performance provisions under the Regulation, 
the  IA  expected  that  a  simplification  of  certification  procedures  would  occur  along  with 
increased  reliance  on  industry  standards,  simplification  of  leasing  approvals  and  more 
extensive use of Qualified Entities (19) in the certification and oversight processes. This in turn 
would  lead  to  reduced  compliance  costs  for  businesses.  However,  data  on  the  number  of 
businesses that used Qualified Entities over the period 2018-2021 does not currently exist, 
thus it is not possible to measure the degree to which the point of comparison evolved.  

In  relation  to  aviation  security,  the  IA  put  forward  a  coordinated  approach  to  safety  and 
security related matters. The overall impact of this measure were expected to be neutral to 
positive thanks to better assessment of safety and security trade-offs (20).  

No quantitative data on the assessment of safety and security trade-offs by EASA is available. 
However,  EASA  has  undertaken  a  range  of  activities  since  2018  aimed  at  assessing  and 
managing  safety  and  security  risks  in  aviation,  and  this  includes  considering  trade-offs 
between  safety  and  security.  For  example,  EASA’s  safety  and  security  risk  assessment 
processes are designed to identify and prioritize risks based on their potential impact on safety 
and  security.  This  includes  considering  trade-offs  between  safety  and  security  risks  and 
determining appropriate mitigation measures based on these trade-offs. Similarly, EASA’s 
regulatory  impact  assessments  (RIAs)  are  designed  to  evaluate  the  potential  impacts  of 
proposed regulatory changes on safety and security, as well as other factors such as economic 
and  environmental  impacts.  In  conducting  these  assessments,  EASA  considers  trade-offs 
between safety and security and other factors and seeks to identify the most optimal solutions. 

Environmental protection 

To  address  gaps  and  inconsistencies  in  environmental  protection,  the  IA  put  forward  the 
approach to define EU essential requirements for environmental protection with respect to 

(19)  Qualified  Entities  (QEs)  are  third-party  organizations  that  are  authorized  by  regulatory  authorities  to 
perform  specific  functions  related  to  the  certification  and  oversight  of  aviation  products,  services,  and 
operations.  The  use  of  QEs  in  the  certification  and  oversight  processes  can  help  to  enhance  safety  and 
efficiency by leveraging specialized expertise and resources 

(20)  However,  there  are  cases  where  the  preferred  solutions  to  address  security  and  safety  concerns  are 
contradictory.  An  example  is  the  requirements  for  the  flight  crew  compartment  door:  while  the  current 
solution addresses the security concerns, it presents a potential safety risk. 

21 

 
 
 
aeronautical products. Under this option, the cost-benefit analysis of deviating from minimum 
ICAO requirements would be done on a case-by-case basis, when the new flexibility would 
be  actually  used.  The  IA  therefore  was  unable  to  estimate  such  impacts  upfront.  It  was 
highlighted, however, that the cost-effectiveness analysis carried out by ICAO may not be the 
same as for the EU. Thus, the overall impact in terms of costs could not be estimated upfront, 
and was therefore considered as neutral under the IA.  

EASA  published  European  Aviation  Environmental  Reports  in  2016,  2019  and  2022,  the 
latter also including recommendations. (21) The 2019 report showed a mixed picture on noise 
and  emissions  (greenhouse  gases  and  air  pollutants),  albeit  generally  observing  increasing 
emissions of noise, CO2 and NOx. The 2022 report showed a significant drop in noise and 
emissions  (including  net-CO2  emissions)  in  2020  and  2021,  to  a  large  extent  due  to  the 
influence of the COVID-19 pandemic on aviation traffic (22). 

3.1.3.  SMEs and light aviation 

Although  it  is  too  early  to  estimate  the  effects  of  the  Regulation  in  sufficient  detail,  the 
regulatory  burden  for  SMEs  could  have  increased  due  to  stricter  requirements  for  aircraft 
certification,  parts,  and  maintenance  organisations.  An  important  element  is  related  to 
additional  requirements  for  the  submission  of  additional  documents  to  the  competent 
authorities  (e.g.  as  regards  the  oversight  and  certification  of  aircraft  operators  or  the 
certification  for  appliances,  parts  and  products).  Compliance  with  such  requirements  is 
typically more burdensome for smaller firms with limited resources. The Regulation does, 
however, also include provisions to help SMEs (such as the establishment of a dedicated SME 
desk at EASA, which can offer direction and support during the certification process). The 
Regulation  allows  to  set  a  proportionate  regulatory  framework  alleviating  the  burden  for 
certain aircraft and their users, those primarily intended for sports and recreation. The burden 
alleviation  is  built  on  the  possibility  offered  by  the  Regulation  for  the  product  to  declare 
compliance with standards instead of receiving a certificate as well as for the organisations 
(design  and  production)  to  become  declared  organizations,  instead  of  going  through  an 
approval process. 

The  standardisation  of  certification  for  light  aviation  is  stimulated  by  new  certificate  and 
oversight provisions for new aircraft types, including Very Light Aircraft (VLA) and Light 
Sport  Aircraft  (LSA).  However,  the  compliance  with  these  rules  also  brings  technical, 
operational and administrative requirements (such as the creation of a quality management 
system). 

The Regulation also supports innovation and provides more opportunities for small operators. 
It contains provisions to encourage industrial innovation, which can benefit SMEs and small 
manufacturers.  In  the  design  and  operation  of  aircraft,  for  instance,  the  regulation  permits 
using new technologies and alternative fuels. A new category of air operator certificate for 
small commercial air transport operations is one of the provisions in the Regulation that will 
increase prospects for small operators. This may contribute to levelling the playing field for 
small  business  owners  and  enhancing  industry  competition.  Additionally,  the  more 
streamlined  certification  processes  for  new  aircraft  types,  including  VLA  and  LSA,  can 
reduce the time and cost to certify new aircraft designs.  

(21)  See Downloads | EASA Eco (europa.eu) 

(22)  For Details see Figures 4 and 5 of Annex 2. 

22 

 
 
Increased safety requirements for aircraft and parts imposed by the Regulation can increase 
the cost of certification and compliance for SMEs and small operators. However, these safety 
requirements also improve the overall safety of the aviation industry, which is beneficial for 
all stakeholders.  

The  EASA  certification  tariffs  (EASA  fees  and  charges)  are  modulated  according  to  the 
aircraft weight (Maximum Take-Off Mass), which makes them relatively  cheaper for light 
aviation as well as for SMEs. Similar modulated tariffs are applicable for supplemental type 
certificates  but  also  for  the  design  organisation  approvals  and  production  organisation 
approvals (according to staff size and scope of activity/product value).  

This demonstrates EASA’s effort to support light aviation by offering lower prices.   

Overall, even if the implementation of the Regulation can be complex for SMEs and small 
operators, it also contains tools to help these businesses expand their potential in the aviation 
sector.  

3.1.4.  Innovation 

There is  evidence that the current  European regulatory situation  fosters  new technological 
developments and is therefore supportive to industrial leadership. This is particularly the case 
in  the  areas  of  electric  aircraft  technologies,  Advanced  Air  Mobility  (AAM)  Research  & 
Development (23)  and  the  development  of  electric  and  hybrid-electric  vertical  take-off  and 
landing (eVTOL) technologies. 

Figure 7. Electric and hybrid-electric vertical takeoff and landing (eVTOL) concepts by 
country/region 

Source: Own composition based on https://evtol.news/aircraft 

3.1.5.  Aviation Safety 

The IA expected aviation safety to improve or at least not worsen under the preferred policy 
package.  The  performance  of  aviation  safety  levels  of  a  country/region  is  traditionally 
assessed via the number of (certain categories) of accidents and incidents over a specific time 
period.  An  analysis  of  incident  and  accident  rates  indicates  that  this  objective  has  been 
achieved. 

(23) Roland Berger: Regional Air Mobility : How to unlock a new generation of mobility, Figure 6 in Annex 2. 

23 

 
 
 
The left axis of Figure 8 shows the number of (non-) fatal accidents and serious incidents of 
airlines registered to operate in EASA Member States from 2011-2021. The number of serious 
incidents decreased from 2013 until 2016, then increased to 90 in 2018. The serious incident 
levels  since  2019  remained  below  the  levels  of  2011  to  2019.  The  number  of  non-fatal 
accidents decreased from 24 in 2011 to 12 in 2018. It increased to 20 in 2019 to then decrease 
to 12 in 2021. The number of fatal accidents represents infrequent events and in the last five 
years,  no  fatal  accidents  have  been  reported.  The  right  axis  describes  the  rate  of  serious 
incidents and non-fatal accidents per million departures: the rate of serious incidents, which 
typically have a higher probability of occurring compared to accidents, is similar to the period 
pre-pandemic. Both rates increased in 2021, however the increases are not a cause for concern 
as lower than past trends. 

Figure 8. Incident and accident rates  

Source: Annual Safety Review, 2022 

A deeper analysis of the two safety rates is made by using structural break regression models 
to analyse the impact of the intervention on safety (24). The analysis ultimately suggests that 
there is no significant structural break to be observed in the data regarding the serious incident 
rate. The evolution of the serious incident rate appears random with no outspoken trend over 
the period 2011 – 2021. However, with regards to the accident rate, a significant breakpoint 
is observed in 2016. The accident rate follows a decreasing trend from 2011 until 2016. In 
2017  there  is  a  further  drop  in  the  accident  rate,  after  which  an  increasing  trend  can  be 
observed. This leads to the conclusion that the Regulation has not had an impact here, as the 
break point is before the evaluation period. In 2021, the accident rate is still below the highest 
point in the observed period. 

3.1.6.  Competitiveness  

In  order  to  assess  the  competitiveness  of  the  airline  industry,  Figure  10  shows  the  market 
share  of  the  flights  from  and  to  worldwide  airports  performed  by  non-EU  airlines  in 
comparison with EU operators. Although the market share of EU airlines decreased slightly 

(24)  Methodological framework and analytical models providing a detailed explanation of the methodology, the 
assumptions  and  the  limitations  of  structural  break  analysis  is  explained  in  Annex  2,  together  with 
supporting charts is shown in Figure 9 in Annex 2. 

24 

 
 
 
since the COVID-19 pandemic, it has nevertheless been stable over the years, which further 
indicates that Europe is maintaining its competitiveness towards non-EU airlines. 

Figure 10. Airlines' market share 

As regards the aircraft manufacturing sector, a comparison of the development of the fleets 
of Airbus and Boeing during the analysed period shows that Airbus gained an additional six 
percentage points of the overall market, as shown in Figure 11, demonstrating that Europe is 
very competitive at global level in the aircraft manufacturing sector. 

Source: Own composition based on Eurostat, 2022 

Figure 11. Active and parked fleet by aircraft manufacturer 

The competitiveness of the European aircraft manufacturing industry is also reflected by the 
total amount of orders shown in Figure 12. 

Source: Ramboll composition based on Airfleet, 2022 

Figure 12. Total amounts of orders and Airbus’ relative share  

25 

 
 
 
 
1800

1600

1400

1200

1000

800

600

400

200

0

The total amount of orders and Airbus' relative share

90,00%

80,00%

70,00%

60,00%

50,00%

40,00%

30,00%

20,00%

10,00%

0,00%

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022

# of Airbus orders

# of Boeing orders

Relative share Airbus

Linear (Relative share Airbus)

Source: Own composition based on Boeing’s and Airbus’ order report, 2023 

Besides, the EASA framework is used as a reference in many countries outside the EU and 
thereby contributes to the competitiveness of the European aviation system.  

It  is,  not  possible  to  establish  a  direct  causal  relationship  between  the  (changes  that  were 
introduced  by  the)  Regulation  and  the  level  of  competitiveness  of  the  EU’s  aviation  and 
aircraft manufacturing industries. 

3.1.7.  Creating jobs 

When it comes to the creation of jobs, Figure 13 shows the employment levels in the aviation 
sector for the EU-27. During the evaluation period, there was a very positive development 
until the layoffs caused by the COVID 19 pandemic brutally reversed this trend. However, 
this must be seen as a result of an extraordinary singular event making it impossible to draw 
any conclusions as regards the impact of the Regulation.  

Figure 13. The evolution of employment in EU aviation 

Source: Ramboll, composition based on Eurostat (ifsa_egan22d), 2022 

26 

 
 
 
 
3.1.8.  Implementation costs 

The IA expected efficiency improvements, although in a longer-term perspective.   

The  funding  to  EASA  through  fees  and  charges  has  not  increased  over  the  period  under 
review, the same applies to the EU subsidy and third-country contributions. The costs and 
revenues by category from 2018 to 2021 as reported in the yearly activity reports of EASA. 
Figure 14 presents the same table adjusted for inflation (based on the Harmonised Index of 
Consumer Prices (HICP)). The tables show a positive total in 2020 and 2021 from fees and 
charges. However, these conclusions come with caveats. Some costs can vary over time and 
are  only  known  by  EASA.  Also,  a  number  of  projects  costs  are  allocated  to  the  product 
certification profit centre, which might bias the results of the analysis below. Finally, subsidy 
revenues are assigned to each profit centre based on costs only when they are known.  

Figure 14. Costs breakdown of Human and Financial resources by activity of EASA (in 
thousands, 2018-2021) 

Cost category 

Sub-cost category 

2018 

2019 

2020 

2021 

Activity category: Fees and charges 

Product 
certification 

Revenue 

Organisation 
approval 

Subtotal costs 

Difference 

Revenue 

Subtotal costs 

Difference 

Totals 

Total revenue under fees & charges 

Total costs under fees & charges 

Difference 

Activity category: Subsidy and other contributions 

Total 
contributions 

EU subsidy Third country 
contributions other income 

Total costs 

Third country operators 

Standardisation 

Safety Assessment of Foreign 
Aircrafts 
Rulemaking 

International cooperation 

Safety Intelligence & performance 

Totals 

Total contributions 

Total costs 

27 

€ 
70.610,0
0 
€ 
74.599,0
0 
€ -
3.989,00 
€ 
35.197,0
0 
€ 
33.954,0
0 
€ 
1.243,00 

€ 
105.807,
00 
€ 
108.553,
00 
€ -
2.746,00 

€ 
42.103,0
0 
€ 
2.219,00 
€ 
11.930,0
0 
€ 610 

€ 
15.351,0
0 
€ 
4.929,00 
€ 
6.403,00 
€ 
42.103,
00 
€ 
41.441,
00 

€ 
69.792,0
0 
€ 
75.872,0
0 
€ -
608,00 
€ 
40.220,0
0 
€ 
34.834,0
0 
€ 
5.386,00 

€ 
110.012,
00 
€ 
110.706,
00 
€ -694 

€ 
40.219,0
0 
€ 
2.741,00 
€ 
11.842,0
0 
€ 689 

€ 
13.002,0
0 
€ 
4.731,00 
€ 
7.432,00 
€ 
40.219,
00 
€ 
40.437,
00 

€ 
57.571,0
0 
€ 
65.330,0
0 
€ -
7.759,00 
€ 
49.311,0
0 
€ 
32.157,0
0 
€ 
17.154,0
0 
€ 
106.882,
00 
€ 
97.487,0
0 
€ 
9.395,00 

€ 
40.993,0
0 
€ 
2.353,00 
€ 
9.970,00 

€ 736 

€ 
12.174,0
0 
€ 
4.922,00 
€ 
7.630,00 
€ 
40.993,
00 
€ 
37.785,
00 

€ 
61.216,0
0 
€ 
62.283,0
0 
€ -
1.067,00 
€ 
52.074,0
0 
€ 
39.779,0
0 
€ 
12.295,0
0 
€ 
11.329,0
0 
€ 
102.062,
00 
€ 
11.228,0
0 

€ 
41.907,0
0 
€ 
2.082,00 
€ 
10.900,0
0 
€ 665 

€ 
12.449,0
0 
€ 
5.503,00 
€ 
9.989,00 
€ 
4.136,0
0 
€ 
41.588,
00 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Cost category 

Sub-cost category 

2018 

2019 

2020 

2021 

Difference 

€ 662 

€ -218 

€ 
3.208,00 

€ -228 

Source: EASA 2018-2021 Consolidated Annual Activity Report 

3.1.9.  Resource needs of EASA 

The support study on resources at EASA highlighted the difficulties to  recruit skilled staff 
and identified increased staff efficiency as the preferred option. This indicated that no staff 
increase was needed as long as the resource efficiency increased accordingly. However, the 
broadening of EASA’s tasks makes this approach more challenging.  

Since  the  Regulation’s  implementation,  the  workforce  has  slightly  decreased,  despite  the 
additional competencies brought by the Regulation. 

Figure 15. Staffing at EASA 

Source: Ramboll, based on EASA annual activity reports 

The impact of the Regulation on the total staff at EASA  (composed of establishment plan 
posts, namely the temporary agents,  and external staff, represented by contract  agents  and 
seconded  national  experts)  can  also  be  estimated  using  the  structural  break  regression 
model (25). This research also analysed the division of the staff into different staff categories, 
as the Regulation might have (unintendedly) changed EASA’s staff structure by broadening 
its scope of activities. However, the Regulation’s causality on the number of staff cannot be 
estimated with the structural break analysis.  

The IA stated that the budgetary pressures on Member States, national aviation authorities 
and EASA would likely continue. This was considered a risk for the functioning of the EASA 
system.  

The impact of the Regulation is analysed via structural break regression models for all of the 
revenue categories shown in Figure 17 in Annex 2. The Regulation’s causality on the revenues 
cannot  estimated  with  the  structural  break  analysis.  However,  this  does  not  mean  that  the 
Regulation did not impact the revenue streams. The analysis suggests that the Regulation did 
not significantly impact revenues, apart from the third countries’ contributions. From Figure 

(25)  The structural break analysis of the total staff at EASA is found in Figure 16 in Annex 2  

28 

 
 
 
18, it can  be observed that  a structural  break in  the number of third country contributions 
occurred after 2018. This structural break could be partly linked to the implementation of the 
Regulation.  

The  broadening  of  EASA’s  scope  of  activities  could  result  in  an  increased  workload, 
especially since the number of staff at EASA did not increase. Figure 19 shows the increase 
of organisational approvals of EASA (26), which indicates that the workload for EASA is rising 
while there is less staff available. 

Figure 19. Organisational approvals under EASA oversight 

800

700

600

500

400

300

200

100

0

AOC

CAMO

ATO

DOA

POA

FSTDO

MTOA

MOA

FSTD

2019

2020

2021

0

2

2

2

4

8

18

18

61

29

19

20

46

48

44

62

65

80

78

81

107

356

344

549

530

524

749

2019

2020

2021

Source: EASA yearly report, 2022 

3.2.  Recent developments 

the  evaluation  period, 

During 
developments occurred that are relevant for the overall evaluation.   

important  economic,  geopolitical  and 

technological 

Economic developments 

The COVID-19 pandemic resulted in a previously unseen drop in air passenger demand and 
led to significant financial problems for the aviation industry as well as for EASA, impacting 
directly  on  the  revenues  from  fees  and  charges.  The  lower  number  of  flights  due  to  the 
pandemic reduced the risk of accidents and incidents. Following the significant loss of jobs, 
the industry faced difficulties in recruiting staff during the recovery phase. Consequently, the 
COVID-19 pandemic and the fact that it impacted during the bulk of the evaluation period 

(26)  Continuing Airworthiness Management Organization (CAMO), Approved Training Organisation (ATO), 
Flight  Simulation  Training  Devices  (Organisation)  (FSTD(O)),  Maintenance  and  Technical  Operations 
Approvals  (MTOA)  and  Memorandum  of  Agreement  (MOA)  approvals.  The  Air  Operator  certificate 
(AOC), Design Organization Approval (DOA), and Production Organization Approval (POA) approvals 
have been stable or decreased slightly. 

29 

 
 
 
present  a  significant  challenge  to  assess  EASA’s  performance  and  the  impact  of  the 
Regulation.  

Geopolitical developments 

Two major geopolitical developments had an impact during the evaluation period: the UK’s 
withdrawal from the EU, Russia’s war of aggression against Ukraine. 

The UK’s withdrawal from the EU led to significant changes for EASA as the UK now has a 
third country status and UK operators are considered as third-country operators. This affects 
many  areas  of  EASA’s  work  (since  EASA  cannot  outsource  certification  and  oversight 
activities to UK CAA staff any longer) and had an impact on EASA’s revenues.  

Russia’s war of aggression against Ukraine led to important sanctions and airspace closures, 
for Russian operators in Europe as well as for European operators to and over Russia. This 
resulted in a sudden shift in demand, higher fuel prices, and an increased safety risk above 
several countries.  

EU policy developments 

The  European  Green  Deal,  which  aims  at  making  Europe  climate  neutral  by  2050,  was 
launched by the Commission in 2019. To meet this goal, Europe must cut greenhouse gas 
emissions  by  at  least  55%  from  1990  levels  by  2030.  This  economy-wide  goal  requires 
contributions  from  all sectors of the economy,  including aviation  (for transport, emissions 
must be reduced by 90% from 1990 levels by 2050).  

The  political  agreement  in  December  2022,  on  the  revision  of  the  EU  Emission  Trading 
System (EU ETS) Directive (27) accelerates the implementation of the polluter pays principle 
by phasing out free allowances for aviation by the year 2026. It also dedicates up to 20 million 
allowances (estimated current market value of around €1.6 billion) to further support (28) the 
uptake of eligible alternative aviation fuels. The Directive also maintains its intra-EEA scope 
until  end  2026  when  the  Commission  shall  assess  if  the  ICAO’s  Carbon  Offsetting  and 
Reduction Scheme for International Aviation (CORSIA) is delivering sufficiently on the goals 
of the Paris Agreement. Finally, recognising that the overall impact of global aviation on climate 
may be considerably higher than the CO2 component alone, which the EU ETS currently regulates 
(29), a monitoring, reporting and verification (MRV) framework is introduced for non-CO2 
effects to start on 1 January 2025. Based on the results of the MRV, the Commission will 
submit by end 2027, a report and where appropriate, a legislative proposal after an impact 
assessment, to mitigate those effects by expanding the scope of the EU ETS.  

The European Green Deal fosters the introduction of sustainable aviation fuels (SAF) and the 
development  of  new  aircraft  technologies,  which  in  turn  has  had  positive  effects  on 
innovation. Besides, the reduction of non-CO2 emissions and air pollutants as well as noise 

(27)  Directive (EU) 2023/958 

(28)  The EU ETS already incentivises alternative fuels compared to fossil fuels, as they are zero rated in terms 

of emissions, providing a financial incentive of around €300 per tonne of fuel. 

(29)  As  per  the  special  report  by  the  Intergovernmental  Panel  on  Climate  Change  (IPCC)  from  1999  titled 
“Aviation and the Global Atmosphere”, the total impacts of aviation are estimated to be at least twice that 
of CO2 emissions when the non-CO2 effects are considered and their effect in the atmosphere last much 
shorter.  Addressing  these  emissions  is  relevant  as  the  IPCC  has  singled  out  international  aviation  (and 
shipping), in its Sixth Assessment Report on mitigation of climate change, as sectors with climate goals that 
fall short of what would be required to curb global temperature increase in line with the Paris Agreement. 

30 

 
 
from aviation is needed to contribute to the Commission’s zero pollution targets set out in the 
Zero Pollution Action Plan (30). 

The  ReFuelEU  Aviation  proposal  aims  to  cut  greenhouse  gas  emissions from  the  aviation 
industry  by  mandating  aviation  fuels  suppliers  to  blend  minimum  shares  of  sustainable 
aviation fuel (SAF) into jet fuel supplied to the Union airports. With the intention of ensuring 
a level playing field for aircraft operators and airports and preventing additional emissions 
related to the extra weight of aircraft carrying excessive amounts of fuel, the proposal sets 
harmonised EU rules and also includes obligations on aircraft operators to limit the uptake of 
jet fuel before departing from EU airports to what is needed for safe operation of flights. The 
proposed  Regulation  requires  EASA  to  receive  and  process  reports  from  aviation  fuel 
suppliers, Union airports and aircraft operators, including as concerns’ aviation fuel uplifts, 
aircraft  operators’  yearly  report  on  purchases  of  sustainable  aviation  fuel  and  the 
characteristics  of  fuels.  EASA  will  have  to  report  yearly  to  the  Commission  and  Member 
States on the fulfilment by aircraft operators and aviation fuel suppliers of their respective 
obligations  as  well  as  bi-annually  on  the  Union  airports  projects  into  zero-emission 
infrastructure. 

The Smart and Sustainable Mobility Strategy (SSMS) aims to develop a more efficient air 
traffic management system while reducing costs, delays, and carbon emissions. The SSMS 
concept seeks to standardise rules and regulations across European airspaces to improve air 
traffic  management.  Presently,  national  borders  divide  the  European  airspace,  which  can 
cause inefficiencies and delays.  

Technological developments 

A broad range of technological developments took place during the evaluation period. Main 
areas  are  cybersecurity  (stemming  from  the  digitalisation  of  data  exchanges  and  the 
significant increase of exchanged safety/security relevant data) and the impact on the design 
of  aeronautical  products  as  well  as  the  demonstration  of  compliance  with  certification 
requirements);  environmental  technologies  (related  to  the  development  of  more  kerosene-
efficient  aircraft,  new  technologies  like  electric  and  hydrogen-powered  aircraft)  and  SAF; 
improved air traffic management systems (e.g. remote towers); unmanned aircraft and new 
urban air mobility transportation (such as eVTOL). 

Figure 20. Overview of the impact of the recent developments   

(30)  COM(2021) 400 final 

31 

 
 
 
Impact of the recent developments, Source: elaboration of the contractor 

The single most important impact on the points of comparison during the evaluation period 
stems from the COVID-19 pandemic. 

4.  EVALUATION FINDINGS (ANALYTICAL PART) 

Twelve  Evaluation  Questions  (EQ) (31)  have  been  formulated  around  the  five  Evaluation 
Criteria. 

4.1.  To what extent was the intervention successful and why?  

4.1.1.  Effectiveness 

This section analyses how successful the Regulation and EASA have been in achieving or 
progressing towards their objectives. To this end, the findings to several evaluation questions 
are presented. (32) It should be noted that the assessment is mainly based on qualitative data 
as  only  very  limited  quantitative  data  to  measure  the  effectiveness  was  available.  In  this 
context it is important to recall the different levels of “maturity” of the activities performed 
by EASA: while safety has been EASA’s core task since it started its activities in 2003, other 
tasks have only been added more recently. It is therefore important to acknowledge that legacy 
activities (e.g. rulemaking and certification) can be evaluated over a longer timeframe, whilst 
activities that were only given to EASA in 2018 (e.g. tasks related to drones) are still in the 
early days of implementation. 

4.1.1.1.  Overall impacts of the Regulation and of EASA’s activities, including in response to 

external shocks (EQ3, EQ4) 

(31)  See Annex 3 for details on the evaluation matrix 

(32)  In conjunction with the main evaluation questions under the effectiveness criterion: [1] Overall positive and 
negative impacts of the Regulation and of EASA’s activities, including in response to external shocks (EQ3, 
EQ4); [2] effectiveness of EASA’s product certification, rulemaking and standardisation (monitoring) tasks 
(EQ1, EQ2) and [3] effectiveness of stakeholder consultations and guidance material provided by EASA 
(EQ1). 

32 

 
 
 
There is wide consensus within the aviation industry and the National Competent Authorities 
(NCAs) on the positive impact of EASA’s activities on aviation, resulting in large benefits 
for aviation safety, environmental protection, efficiency and in ensuring a level playing field 
for  the  aviation  industry.  EASA’s  staff  are  perceived  as  “true  experts”  in  their  domains. 
Notably,  most  stakeholders (33)  pointed  out  that,  even  though  the  harmonisation  of  rules 
across countries is not yet fully achieved (more on this matter is presented in the following 
paragraphs), ultimately this does not undermine the overall quality of safety or environmental 
standards at EU level.  

Results from the survey targeting stakeholders from the aviation industry and NCAs on the 
effectiveness of the Regulation show that 22 out of 119 (18%) of respondents believed that 
the Regulation led to a reduction in the number of occurrences (i.e. accidents and incidents) 
compared to the previous Regulation (EC) 216/2008 (Figure 21). 53 respondents (44%) (34) 
are  of  the  opinion  that  the  Regulation  had  at  best  a  neutral  impact  on  the  reduction  of 
occurrences,  if  not  a  small  or  no  impact.  When comparing  the  results  between  public  and 
private stakeholders, no significant differences were observed.  

Figure  21.  To  what  extent  has  the  Regulation  led  to  a  reduction  in  the  number  of 
occurrences (i.e. accidents and incidents), compared to the period in which Regulation 
(EC) 216/2008 was in force? (n=119) 

The figure above shows that while most stakeholders recognise the positive impacts EASA 
brings to aviation safety since the entry into force of the Regulation (EC) No 216/2008, only 
a smaller share of stakeholders makes a clear additional link between the Regulation and a 
further reduction in the number of occurrences. 

The effectiveness  of EASA was also  demonstrated  when responding to  external  shocks  or 
facing  political  pressure.  In  particular,  EASA’s  proactivity  was  visible  in  contributing  to 
ensuring safe flight operations and health conditions during the COVID-19 pandemic: in fact, 
in  2020,  EASA  quickly  mobilised  its  resources  to  re-focus  priorities  aiming  to  actively 
support its stakeholders in addressing the new challenges, on the one hand in managing the 
emergency and on the other hand in supporting the aviation industry (e.g. providing regulatory 
flexibility)35. In reaction to the Russian invasion into Ukraine, EASA’s involvement was seen 
as  positive  by  public  and  private  stakeholders.  Indeed,  already  when  Russia  started  its 
invasion  in  February  2022,  more  than  ten  alerts  had  already  been  issued  by  EASA.  Also, 
EASA  issued  a  conflict  zone  bulletin  recommending  avoiding  Ukrainian  and  Russian 

(33) Further details on the types of stakeholders sharing this opinion are provided in the following paragraphs. 

(34) Sum of respondents who answered "neither to a great or small extent", "To a small extent" and "not at all".  

(35) EASA Consolidated Annual Activity Report 2020. Available at: https://www.easa.europa.eu/en/document-

library/general-publications/consolidated-annual-activity-report-2020 

33 

 
 
 
airspaces.  These  prompt  reactions  by  EASA  show  the  effectiveness  of  the  Agency  when 
confronted with external crises. 

In conclusion, the intervention was successful in terms of effectiveness as the Regulation and 
EASA’s activities had positive impacts on its main stakeholders. In addition, the work of the 
Agency  covered  all  the  real  needs  of  aviation  in  Europe,  especially  considering  the  huge 
impact of the COVID-19 pandemic in the European and worldwide aviation safety system 
and considering the crisis in Ukraine and the implications it has on aviation. 

4.1.1.2.  Effectiveness  of  EASA’s  product  certification,  rulemaking  and  standardisation 

(monitoring) tasks (EQ1, EQ2) 

Certification 

Product certification refers to the certification of the types of products (e.g. aircrafts, engines 
etc.) and whether these meet EU safety requirements.  

Every year, EASA presents data in its KPI reports (36) on a wide range of KPIs regarding the 
certification process (37). The KPI Reports show that the outputs for product certification were 
on  track  overall  considering  the  expected  outputs,  with  delays  limited  to  the  Continuing 
Airworthiness  (CAW)  predictability  time  (i.e.  certification  procedures  related  to  the 
continuing  airworthiness  of  aircraft,  including  any  component  for  installation)  and  on  the 
timely approval of Design Organisation (DOA) continuation (38), which featured only 55% of 
the expected approvals  in  2022.  Annex 6  of this document  presents  the  evolution of these 
KPIs until 2022 in more detail, as well as performance in relation to the expected certification 
outputs (Table 10). 

EASA’s effectiveness in the area of product certification was confirmed by stakeholders from 
the  aviation  sector:  31  respondents  (26%)  believed  that  EASA’s  certification  procedures 
effectively contributed to increasing the safety of the EU aviation system to a great extent, 
while it was the case “to some extent” for 49 respondents (41%). When comparing the results 
between  public  and  private  stakeholders,  public  sector  organisations  were  found  to 
proportionally  be  more  positive  in  their  judgement  of  the  effectiveness  of  certification 
procedures, however the difference is not significant compared to private sector organisations.  

Figure 22. To what extent have EASA's certification procedures effectively contributed 
to increasing the safety of the European aviation system? (n=119) 

(36) EASA (2018). WP17b Historical KPI Timeline and EASA (2022). WP11 Status of EASA KPIs 

(37) These KPIs are: initial airworthiness performance rate, airworthiness directives deficiency rate, continuing 
airworthiness predictability time, occurrences backlog monitoring rate, technical acceptance of occurrences 
timeliness, and timeliness of certification support for validation of products 

(38) I.e. the recognition in time that a Design Organisation complies with EASA requirements 

34 

 
 
Rulemaking 

Based  on  the  Regulation,  the  Commission  is  empowered  to  adopt  Implementing  and 
Delegated Acts in a number of areas such as airworthiness, air operations, aircrew etc. These 
legal acts are based on an opinion prepared by EASA as part of its rulemaking process. 

Data  on  EASA’s  outputs  in  relation  to  rulemaking  were  collected  from  the  Agency’s 
European Plans for Aviation Safety (EPAS) (39) and EASA KPI Reports, presenting the most 
relevant publicly available information on the number and purpose of rulemaking tasks for 
the past years. Evidence drawn from these plans shows that, between 2018 and 2021, EASA’s 
rulemaking  activity  slowed  down  with  an  average  of  42  rulemaking  outputs  (40)  per  year 
compared to 70 per year between 2015 and 2017: this came in response to many stakeholders 
flagging their limited capacity to keep up with such fast-paced changes. The average duration 
of rulemaking tasks was described as ‘significantly above target’ in the 2019-2023 edition of 
the EPAS, which further identifies a delay in the implementation of planned rulemaking tasks. 
Annex 6 to this document presents the evolution of the KPIs in the rulemaking domain until 
2022 in more detail, as well as their performance in relation to the expected outputs (Figure 1 
and Table 8). 

In that context, it is recognized that a long period of time can elapse between the beginning 
of the rulemaking task and the publication of the deliverable (Notice of proposed amendment 
‘NPA’ or Opinion/Decision). One mitigation measure is the possibility for EASA to launch a 
special procedure that reduces this time period. 

As presented in the 2020 EASA Consolidated Annual Activity Report (41), in addition to the 
previously  described  reduction  of  rulemaking  activities,  some  delays  were  caused  by  the 
COVID-19 pandemic.  

In  the  field  of  environmental  protection,  EASA  has  played  a  very  active  role  upstream  in 
ICAO by being actively involved in the work of the Committee on Aviation Environmental 
Protection  (CAEP)  which  develops  and  reviews  aircraft  emission  standards,  guidance  on 
airports  and  air  traffic  management  affecting  the  environment,  sustainability  aspects  of 
alternative aviation fuels, rules of the Carbon Offsetting and Reduction Scheme (CORSIA), 

(39)  The  EPAS  is  EASA’s  key  instrument  to  prioritise  and  manage  actions  to  maintain  and  further  improve 
aviation  safety  and  environmental  protection  in  Europe.  It  seeks  to  do  this  while  ensuring  efficiency, 
proportionality and a level playing field at the same time. EPAS is a safety action plan derived from the main 
safety risks identified at European level. European Plan for Aviation Safety 2019 - 2023 | EASA (europa.eu)  

(40) Rulemaking ‘outputs’ refer to EASA NPAs, EASA Decisions, EASA Decision CS, EASA Opinions and 

EASA ToRs [I would start mentioning the ToRs for chronological purpose] 

(41) EASA (2021). EASA MB 2021-01 WP10c - CAAR 2020 

35 

 
 
 
 
establishes trends in the environmental pressures of international aviation, etc. This aspect of 
EASA’s  work  is  very  important  as  it  ensures  the  consideration  of  European  priorities  and 
expertise  in  ICAO  and  makes  EASA’s  own  subsequent  rule-making  tasks  smoother  while 
ensuring international harmonization as far as deemed appropriate. 

Standardisation 

In its role of regulatory authority, EASA is continuously monitoring NCAs, based on so called 
standardisation  activities  (i.e.  inspections).  These  activities  shall  ensure  the  harmonised 
implementation of common rules at EU level and EASA’s performance in these activities is 
measured in detail in EASA’s KPI reports (42). The KPI Reports point out that in 2020 and 
2021  related  KPIs  (i.e.,  efficient  and  robust  standardisation,  control  of  overdue 
standardisation findings, timely issuance of due standardisation reports) were not in line with 
the expected number of standardisation activities . As of 2022, the standardisation activities 
are back on track.  This is directly due to the impact of the COVID-19 pandemic which led to 
a  significant  reduction  of  standardisation  visits  (in  2020,  only  one  third  of  the  planned 
inspections could take place).  

In  spite  of  these  delays,  from  the  perspective  of  NCAs,  EASA’s  standardisation  activities 
were seen as effective and NCAs recognised the quality of EASA’s work in this field. (43) 
Nonetheless, several NCAs argued that the preparation and the composition of the inspection 
teams  by  EASA  sometimes  made  cooperation  with  the  Agency  unnecessarily  difficult. 
According to NCAs, this is due to diverging approaches of different inspectors.  

Overall,  EASA  delivered  effectively  on  its  product  certification  and  rulemaking  tasks.  As 
regards standardisation activities, the effectiveness of the monitoring of NCAs is also seen as 
positive overall, despite the impact of the COVID-19 pandemic that limited the performance 
of the Agency with respect to its KPIs. 

4.1.1.3.  Effectiveness of stakeholder consultations and guidance material provided by EASA 

(EQ1) 

Before analysing the effectiveness of the EASA stakeholder consultations, it is considered 
relevant,  for  the  evaluation,  to  explain  why  the  overall  effectiveness  and  efficiency  of  the 
governance of the Agency has not been specifically assessed.  

The EASA governance is composed of 1) the Management Board that defines the Agency’s 
priorities,  establishes  the  budget  and  monitors  the  Agency’s  operations,  2)  the  Executive 
Director, who manages the Agency and is accountable to the Management Board, and 3) the 
Board of Appeal. 

The adoption of the Regulation did not bring about any changes to this governance structure 
of EASA (44) as compared to its preceding Regulation.  

The governance in place was  already fully in line with the “Joint Statement and Common 
Approach of the European Parliament, the Council of the EU and the European Commission 
on decentralised agencies”(45), agreed in 2012. As set out in this document, the Management 
Board of EASA consists of two representatives of the Commission and one representative 

(42) Annex 6 provides further information on EASA’s KPIs for certification standardisation tasks. 

(43)  Feedback from MAB members during the MAB workshop. 

(44)  Articles 94 and onwards of Regulation (EU) 2018/1139 

(45)  resource.html (europa.eu) 

36 

 
 
from  each  Member  State.  The  European  Parliament  does  not  have  a  right  to  designate  a 
member. The rules on the selection and role of the Executive Director and on the work of 
other internal bodies, such as the board of appeal, that are set out in the Common Approach 
are also followed in the case of EASA. This framework is hence identical to all other agencies 
where the common approach is applied, such as the other decentralised agencies in the area 
of transport, namely the European Maritime Safety Agency (EMSA) and the European Union 
Agency for Railways (ERA). This framework  has been proven to be effective and efficient 
for the governance of a decentralised agency. 

As  regards  stakeholder  consultations,  EASA  has  two  main  advisory  bodies:  the  Member 
States Advisory Body (MAB) and the Stakeholders Advisory Body (SAB). In addition, EASA 
consults public and private aviation stakeholders through different groups:(46)  

•  Collaborative Analysis Groups (CAGs); 
•  European Network of Analysts (NoAs); 
•  Stakeholder experts and representatives in rulemaking groups;  
•  Targeted consultation to groups of stakeholders; 
•  Working groups of experts. 

Overall,  when  asked  about  the  effectiveness  of  EASA’s  stakeholder  consultation,  survey 
respondents  were  largely  positive:  35  respondents  (44%)  found  these  stakeholder 
consultations somewhat effective, while 15 respondents (19%) even believed these are very 
effective.  (47) When comparing the results  between public and private stakeholders,  public 
sector  organisations  were  found  to  proportionally  find  the  stakeholder  consultations  to  be 
very/somewhat effective, while private stakeholders were split in their views.  

Figure  23.  How  effective  are  the  stakeholder  consultations  within  EASA’s  advisory 
bodies  (i.e.,  are  consultations  inclusive,  timely  and  do  they  allow  for  constructive 
exchanges of ideas)? (n=79) 

N.B. The sample rate for this question is lower as it was only asked to stakeholders that had previously answered that they had 
participated in stakeholder consultations within EASA’s advisory bodies. 

The evaluation also showed that EASA’s stakeholder consultation has improved significantly 
over the years. This improvement is, however, not related to the Regulation as it does not 
contain  any  changes  to  the  previous  consultation  structure,  but  to  the  better  cooperation 
approach that has been gradually put in practice by the Agency. In this respect it is important 
to note that EASA’s relationship with Member States has particularly improved, shifting from 

(46) European Plan for Aviation Safety (EPAS) 2020-2024.  

(47)  EASA  documents  referring  to  EASA’s  stakeholder  consultation  activities,  analysed  during  the  support 

study. 

37 

 
 
 
a  rather  competitive  to  a  more  and  more  cooperative  approach.  An  example  is  EASA’s 
partnership  agreements  (25  currently  in  place)  with  NCAs  to  simplify  and  ensure  broader 
cooperation across all domains that were facilitated by the Regulation. 

Besides the consultation through EASA’s formal Advisory Bodies, stakeholder involvement 
at an early stage of EASA’s work is also seen as an effective step to ensure the buy-in of those 
affected by the work of the Agency (48). In addition, more recently, EASA launched a review 
of the Advisory Bodies aiming to work more with smaller and more focused groups on an ad 
hoc basis in addition to the usual Advisory and Technical Bodies. 

With regard to non-binding EASA material, stakeholders stressed the importance to provide 
clear acceptable means of compliance (AMCs) and guidance material (GM). In this context, 
stakeholders particularly underlined the importance of the timely availability of AMCs and 
GM. A specific concern relates to possible delays between the adoption of the implementing 
rules and the related non-binding material. Such delays tend to render the implementation of 
new rules more difficult. Stakeholders were particularly concerned about cases where relevant 
AMCs/GM were only published at the time of the applicability date of the new regulations.  

Stakeholders also raised cases when AMC/GM were overly prescriptive. This reflects a more 
general observation of stakeholders as regards the  importance of striking the right balance 
between  a  prescriptive  and  a  performance-based  regulatory  approach.  While  stakeholders 
recognised that such balance is not always easy to find, they noted that significant efforts have 
been undertaken in implementing such an approach, as much as possible. Indeed, the balance 
between a prescriptive approach and a performance-based approach is not always clear cut. 
An  analysis  of  the  Implementing  Regulations  adopted  since  the  entry  into  force  of  the 
Regulation shows that the principle of performance-based rules is being used in all domains 
but that its implementation may differ depending on the subject to be regulated, considering 
that  the  objective  of  performance-based  regulations  is  to  better  focus  on  critical  safety 
outcomes and to increase regulatory efficiency. In certain cases, there is a need to have some 
targeted prescriptive rules to ensure that safety is maintained. Nevertheless, the development 
of less prescriptive and  more performance-based regulations  is  seen  by stakeholders  as  an 
area where some improvement could be beneficial for the implementation of the regulations. 

EASA is also ensuring consistency with the environmental work carried out in the European 
Civil Aviation Conference (ECAC) (49) by inviting its Member States’ environmental experts 
involved  in  ECAC  work  to  stakeholder  coordination  meetings  with  national  authorities 
(MAB) and by appointing an Environmental Focal Point.  This coordination was started in 
2021 and is welcomed by both Member States and stakeholders. 

In  conclusion,  the  stakeholder  consultation  procedure  is  effective,  as  it  has  become  more 
inclusive,  timely  and  allows  for  constructive  exchanges  of  ideas  within  the  various 
consultation groups setup by EASA. 

4.1.2.  Efficiency 

This section assesses the relationship between the resources used by the intervention and the 
changes generated by it (both positive and negative).  The starting point for the  efficiency 
assessment is an assessment of costs, which is supplemented by qualitative evidence on costs 

(48)  https://www.easa.europa.eu/en/the-agency/management-board/decisions/easa-mb-decision-no-01-2022-

rulemaking-procedure-repealing-mb 

(49)  The  European  Civil  Aviation  Conference  (ECAC)  is  an  intergovernmental  organisation  of  44  Member 
States, based in Paris, with the objective of harmonising civil aviation policies between its Member States. 

38 

 
 
and benefits collected through stakeholder consultation. This section is therefore structured 
according to two categories, in conjunction with the two main evaluation questions under this 
criterion: 1) sufficiency and adequacy of the human and financial resources of EASA (EQ5), 
and 2) proportionality of the regulatory costs of the Regulation for stakeholders (EQ6). 

4.1.2.1.  Sufficiency and adequacy of the financial and human resources of the Agency (EQ 5) 

This first section analyses whether the additional human and financial resources allocated to 
the Agency were sufficient and adequate to achieve its tasks.  

Financial resources 

The EASA budget is funded from different sources, with fees paid by industry (i.e., through 
various fees and charges), accounting on average for around 63% of the total EASA budget. 
This is accompanied by the funding from the European Commission (i.e., through a subsidy) 
mainly used to perform rulemaking activities which accounts, on average for 22% of the total 
EU contribution revenues. To provide a more granular overview of the financial resources of 
EASA,  Figure  24  presents  a  breakdown  of  the  revenues  over  the  period  2018-2021, 
accompanied by the main categories (in percentages) of revenue. 

Figure 24. Total revenue of EASA (2018-2021) 

Source: EASA Final Annual Accounts 2018-2021 

Table 3 presents the budgetary breakdown of the Agency over the period 2018 to 2021. To 
provide a comparison, the averages for each category of the budget are provided for the period 
2013-2017.  In terms of total revenue, the total amounts grew by, on average, 2%  between 
2018-2021. For the total expenditure, the amounts also grew on average by 0.1% over the 
same period. 

The table also shows that the Agency carried over budgetary surpluses year on year that were 
generated  from  fees  and  charges  activities  into  an  accumulated  reserve.  The  Regulation 
provides that such reserve shall be used to fund future activities related to fees and charges, 
or  to  offset  losses.  Indeed,  as  a  result  of  comprehensive (50)  in  year  budget  monitoring 

(50) As defined in each of EASA Final annual accounts,  the word "comprehensive"  refers to a thorough and 
complete analysis  that  was conducted by EASA  when monitoring the budget in order to achieve a high 
implementation rate. This suggests that the monitoring process was rigorous and covered all aspects of the 
budget, leaving no gaps or oversights. 

39 

 
 
 
conducted by EASA, the final budget implementation rate per year, remained high across the 
reference period, ranging from 96.3% to 99%, surpassing the Commission target of 95%. 

Table 3. Budget breakdown of the Agency 2018-2021, including the average values for 
the reference period 2014-2017 (in EUR 100,000s) 

Avg. 
2014-2017 

2018 

2019 

2020 

2021 

A. Total Revenue 

 €1,451.29   €1,554.49 

€1,715.54 

€1,732.90 

€1,675.03 

B. Total Expenditure 

 €1,772.66   €1,714.39 

€1,868.20 

€1,751.53 

€1,656.69 

C.  Adjustments  and 
differences (51)  

Accumulated 

D. 
surplus 

Budget 
implementation rate 

-€7.82  

-€20.87 

-€5.52 

€126.03 

€115.45 

 €441.07  

€521.94 

€515.03 

€608.98 

N/A (52) 

99% 

98% 

97% 

99% 

96.3% 

N.B. 2022 figures were not available yet at the moment of drafting this evaluation 

While  these  results  over  the  reference  period  do  not  refer  directly  to  the  efficiency  of  the 
Agency for particular activities, they suggest that EASA was efficient in adequately using the 
annual budget, and that the Agency was consistently successful in achieving a high budget 
implementation rate.  

As part of the IA, as discussed in the points of comparison section (see section 2.2.), it was 
expected that EASA’s resource needs would increase by an additional 1.822 million EUR per 
year between 2016 and 2030. Figure 25 presents the total expenditure by the Agency over the 
period  2013-2021,  of  which  a  forecast  was  generated  to  display  the  likely  change  in  the 
budget, had the Regulation not been put into force. This outlines that the actual expenditure 
of the Agency was higher than what was foreseen as part of the IA. This, however, does not 
indicate that EASA became less efficient over time. It rather shows that costs were greater 
than anticipated. 

(51) Adjustments and differences may include: [1] the result before carried over not used, [2] the cancellation of 
unused payment appropriations carried over from previous year, [3] adjustment of assigned revenue carried 
over and [4] the Exchange differences for the year (gain +/loss -).  

(52) This data was not available as the Agency carried over EUR 1,527K from 2016 to 2020 to cover the final 
MOVE related costs. Due to ongoing clarifications with the contractor, the amounts could not be paid in 
2021.  Based  on  legal  advice,  the  related  funds  have  been  placed  in  a  ‘Rechtanwaltsanderskonto 
Treuhandvertrag’ and carried over again to 2022. Additionally, part of the rent retained from the landlord 
in  2017  (EUR  235K),  had  to  be  carried  over  again  to  2022.  Both  cases  are  currently  subject  to  legal 
proceedings and have been carried over in line with Article 75.6 of the EASA Financial Regulation. 

40 

 
 
 
Figure 25. Total expenditure values and forecast (2013-2021) 

Source: EASA Final Annual Accounts 2013-2021. 

Table 4 presents the cost-breakdown of human and financial resources by activity carried out 
by EASA  over the period 2018-2021. As shown  in  the  figure, an overall  mixed picture is 
presented  in  terms  of  the  efficiency  of  different  activities  and  domains.  Areas  such  as 
organisation approval  achieved cost savings/ efficiency year on year, compared to  product 
certification  presenting  the  opposite.  Under  the  activity  category  of  subsidies  and  other 
contributions, fluctuations in the efficiency of human and financial resources are presented 
year on year.  

Table  4.  Cost  breakdown  of  human  &  financial  resources  by  activity  of  EASA  (in 
thousands) (2018-2021)  

Cost category 

Sub-cost category 

2018 

2019 

2020 

2021 

Activity category: Fees and charges 

Product 
certification 

Organisation 
approval 

Totals 

Revenue 

€70,610 

€69,792 

€57,571 

€61,216 

Subtotal costs 

€74,599 

€75,872  

€65,330  

€62,283  

Difference 

-€3,989  

-€6,080  

-€7,759  

-€1,067  

Revenue 

€35,197  

€40,220  

€49,311  

€52,074  

Subtotal costs 

€33,954  

€34,834  

€32,157  

€39,779  

Difference 

€1,243  

€5,386  

€17,154  

€12,295  

Total 
under 
charges 

revenue 
fees  & 

Total  costs  under 
fees & charges 

€105,807  

€110,012 

€106,882  

€113,290  

€108,553  

€110,706  

€97,487  

€102,062  

Difference 

-€2,746  

-€694  

€9,395  

€11,228  

Activity category: Subsidy and other contributions 

Total 
contributions 

EU  subsidy,  Third 
country 
contributions, other 
income 

€42,103 

€40,219 

€40,993 

€41,360 

41 

 
 
 
 
 
Total costs 

Third 
operators 

country 

€2,219 

€2,741 

€2,353 

€2,082 

Standardisation 

€11,930 

€11,842 

€9,970 

€10,900 

Safety  Assessment 
of Foreign Aircrafts 

€610 

€689 

€736 

€665 

Rulemaking 

€15,350 

€13,002 

€12,174 

€12,449 

International 
cooperation 

Safety  Intelligence 
& performance 

Total 
contributions 

€4,929 

€4,731 

€4,922 

€5,503 

€6,403 

€7,432 

€7,630 

€9,989 

€42,103 

€40,219 

€40,993 

€41,360 

Total costs 

€41,441 

€40,437 

€37,785 

€41,588 

Difference 

€662 

-€218 

€3,208 

-€228 

Source: EASA 2018-2021 Consolidated Annual Activity Reports 

Totals 

The COVID-19 pandemic had a significant impact on the Agency’s activities. The challenges 
that  many  stakeholders  faced  also  impacted  EASA’s  revenue  from  fees  and  charges,  with 
reductions  in  the  estimations  from  the  originally  planned  EUR  125  million  to  EUR  106.5 
million received in 2020 - a reduction of EUR 18.5 million (53).  

Human resources 

As a point of comparison (see section 2.2.) the IA foresaw that the Regulation would require 
an additional 9.5 FTEs in total. However, contrary to these expectations, there was a steady 
decrease in the total number of FTEs, falling from 769 FTEs in 2018 to 731 FTEs in 2021. 

Figure 26. Number of FTEs within EASA 2018-2021 

Source: EASA 2018-2021 Consolidated Annual Activity Reports.  

The analysis outlines that while the scope of EASA’s tasks has expanded since the entry into 
force of the Regulation, there has been a steady decline in terms of FTEs across each of the 
activities. This decline resulted in a challenge for EASA to fulfil all its tasks and objectives. 
One  particular  example  was  the  domain  of  innovation,  where  EASA  emphasised  how  the 

(53) EASA (2020). 2020 Final Annual Accounts. 

https://www.easa.europa.eu/sites/default/files/dfu/easa_mb_decision_02-
2021_on_the_2020_annual_accounts_-_annex.pdf  

42 

 
 
 
 
 
Regulation may not have foreseen the resources required to perform the tasks and fulfil its 
activities in this domain (from supporting introduction of new technologies and new concepts 
of operations to perform research projects to assess new risks, support the development of 
new technologies and increase skills and competences available in the EASA system). 

Therefore, while the tasks under each of the activities increased over the period 2018-2021, 
the budgetary planning and resources did not increase in parallel. 

More  specifically,  in  terms  of  recruitment  over  the  period  2018-2021,  the  number  of 
temporary staff recruited compared to the authorised staff levels fell on average by 5%, with 
the rate of difference evolving from -2% in 2018 of placements to -8% of placements filled 
in  2021.  While  the  COVID-19  pandemic  had  an  impact  on  the  recruitment  of  staff,  the 
decrease of the recruitment can only be partly attributed to the pandemic as the percentage of 
temporary staff being recruited was falling even before the pandemic.  

Therefore,  even  if  the  decrease  in  recruitment  of  staff  did  not  seem  to  have  an  important 
negative impact on the work of EASA staff, the overall policy in the recruitment of competent 
staff should be further addressed in the future to avoid any shortage of aviation expertise in a 
competitive environment. 

EASA  allocated  around  10  staff  members  to  activities  carried  out  under  Article  87  of  the 
Regulation i.e., on environmental protection. This includes around 10 staff members working 
on  tasks  in  ICAO’s  CAEP,  the  European  Aviation  Environmental  Report,  environmental 
labelling of aviation, the analysis of non-CO2 effects of aviation on the climate, rulemaking 
on environmental standards on supersonic aviation, environmental capacity-building in third 
countries, etc. 

In  conclusion, the efficiency in  the area of human and financial resources  allocated to  the 
Agency  was  overall  positive.  EASA  was  efficient  in  adequately  using  the  annual  budget 
available and was consistently successful in achieving a high budget implementation rate. 

Outlook: adequacy of EASA’s resources in a longer-term perspective  

The discussion about EASA’s financial needs to fulfil its missions in the longer term is closely 
linked to the ongoing discussion about EASA’s budget for the years 2025-2027 where the 
Agency is confronted with important challenges to balance its budget. This discussion will 
become very dynamic in the September-December 2023 timeframe.   

These discussions give a clear indication of the significance of the longer-term challenges in 
providing the Agency with sufficient resources to fulfil the part of its mandate that is funded 
through the EU contribution (this mainly comprises the Agency’s regulatory tasks, including 
the relatively new tasks stemming from the Regulation such as on ground handling or ATM 
ground  equipment).  Given  these  shorter-term  budgetary  constraints  stemming  from  the 
Commission’s  limitations  in  the  current  Multiannual  Financial  Framework  (MFF),  the 
Agency will have to consider reorganising and restructuring its current working methods to 
meet these challenges.  

Besides the question as regards the necessary size of the EU contribution, another important 
element in this context is the degree of flexibility in EASA’s establishment plan for posts that 
are funded from fees (that are paid by industry for EASA tasks such as the certification of 
products or organisations). Currently, EASA’s establishment plan (which defines the number 
of EASA posts across the organisation irrespective of the funding source) hinders the Agency 
to generate new sustainable fee revenues from new applications, involvement in fee-financed 
EU programmes or other services (e.g. in the area of TCOs or the organisation of events). A 
more flexible establishment plan could also facilitate the recruitment of specialists which are 

43 

 
needed for tasks such as the certification of drones/ATM ground equipment, the involvement 
in  additional  important  research  and  innovation  projects  or  specific  tasks  that  will  be 
attributed to  the Agency under the Green Deal  (e.g. as  regards fuel  standards, labelling  or 
sustainable fuels/clearing house).       

It would therefore be important to consider an adaptation of EASA’s establishment plan to 
provide the Agency with additional financial flexibility. 

4.1.2.2.  Proportionality of the regulatory costs of the Regulation on stakeholders (EQ6) 

This section analyses the impact of the costs imposed by the Regulation and the Agency on 
all relevant stakeholders and assesses if these costs are proportionate to the benefits that the 
stakeholders can expect from the Regulation.  

54% of stakeholders (64 out of 118 respondents) stated that the introduction of the Regulation 
led to increased costs for their organisation to a great/some extent. They raised concerns about 
an increase in requirements that are due to the Regulation (as emphasised in the figure below) 
and pointed at additional work related to more detailed documentation of their procedures and 
results of their work, resulting in increased costs for them. The introduction of the Regulation 
required additional staff to cope with those new tasks.  

Figure 27. Stakeholder survey: Please specify the nature of these costs (n=71) 

During the targeted stakeholder consultations, the issue of costs related to the implementation 
of  new  requirements  were  raised  by  NAAs,  airports,  airlines and  EU  level  industry 
associations, but these costs of implementing new regulations were seen as justified as they 
are necessary to ensure harmonisation and a level playing field across the EU. 

Costs to national aviation authorities and industry 

National Aviation Authorities 

15 out of the 31 EASA Member States answered that their costs had increased as a result of 
the introduction of the Regulation. While NAAs were invited as part of the survey to provide 
estimates of these cost increases in EUR and FTE, meaningful estimates were only provided 
by the NAAs from Spain and Belgium. Based on the data provided, estimations have been 
generated and interpolated to other EASA Member States where possible.  

However, the analysis of the proportionality of costs in relation to the Regulation has several 
caveats  that  must  be  considered  when  interpreting  the  data.  One  of  the  main  qualitative 
limitations is the small sample size, as only two EASA Member States provided data on cost 
increases resulting from the Regulation, thus making it challenging to generalise the findings 
to  all  EASA  Member  States.  Furthermore,  the  data  should  not  be  considered  as  truly 

44 

 
 
representative,  as  their  experiences  may  differ  significantly  from  those  of  other  Member 
States.  Moreover,  self-reporting  may  also  affect  the  estimates  as  the  data  provided  were 
estimates that were calculated by the two Member States.  

In the IA, the future resource needs of NAAs under the baseline scenario were estimated to 
be EUR 21-26 million in 2020 and EUR 49-61 million in 2030 (annually). Based on the data 
from Spain and Belgium on the increase in labour costs alone, the data was interpolated for 
all EASA Member States, with an estimated total annual increase in all NAA budgets (average 
from 2018-2022) of between €26.6 - €29.8million.  

Figure 28. Estimated yearly labour cost increases per NAA 

Source: Extrapolation by the contractor by interpolating cost data from Belgium and Spain NAAs. The graph only presents the 
estimates for the countries which answered in the survey that their costs had increased. 

Notwithstanding that this estimate does not include other costs that could be attributed to the 
introduction of the Regulation (due to a lack of meaningful data being available), the estimates 
are consistent with those provided in the IA. Figure 28 provides an estimation of the increase 
in labour costs for each of the NAA which answered in the stakeholder survey that their costs 
had increased, with the annual yearly labour costs ranging from EUR 45,000 (shown in light 
blue) to EUR 6.5 million (shown in dark blue), depending on the size and complexity of the 
country. 

Interviews with NAAs provided qualitative insights into why these costs have increased. They 
pointed  to  the  burden  that  was  caused  by  the  number  and  frequency  of  implementing 
regulations  and  requirements  that  originated  from  EASA  as  a  result  of  the  Regulation.  In 
particular, concerns were raised in relation to the difficulty of complying with some of the 
requirements. New areas such as cybersecurity were noted by NAAs as having an impact on 
increasing the costs of compliance. This was paired with the view that new regulations can 
often be over prescriptive in their requirements, thus having an impact on administrative costs, 
and potentially making compliance more challenging for operators with limited resources. 

In addition to the estimates on the budget for NAAs, the IA also estimated that the need for 
additional staff to carry out the workload would increase by roughly 7.6–9.3% by the year 
2020 of the base figure of around 5,100 total NAA staff in 2013, amounting to between 5,487 
to 5,572 total staff needed. This roughly amounts to an increase of between 387 and 472 NAA 
staff by the year 2020.  Based on the estimates of the average annual staff increases in the 

45 

 
 
Belgian and Spanish NAAs, the total estimated number of additional FTEs required in 2020 
across all EASA member countries was found to be 532. This thus suggests that the estimates 
of the actual increase in FTE in NCAs is above what was forecasted in the IA by 60 FTE. 

Figure 29. Estimated annual increase in FTE over the period 2018-2022 

The  figure  below  presents  the  estimated  annual  increase  in  FTEs  (based  on  the  data  from 
Spain and Belgium) for the 15 NAAs which in the stakeholder survey stated that their costs 
had increased. 

Source: Extrapolation by the contractor interpolating FTE data from Belgium and Spain NCAs.  

In addition to the estimated increase in labour costs, estimates of other costs were provided 
by the NAA in Spain, however it should be noted that this information was limited and could 
not be interpolated to all EASA Member States. For example, it was estimated that the total 
costs (over the period 2018-2021) related to the increase in investment in equipment, IT and 
machinery as a result of the Regulation amounted to approximately EUR 10.1 million, while 
increased certification requirements amounted to an additional EUR 7.3 million. However, 
these estimates should not be considered as representative but more as indicative examples, 
due to the likely variation between the different needs of NAAs in terms of equipment, IT and 
machinery.  

It should be noted that the IA foresaw that the Regulation would have a positive effect on 
compliance costs. Those positive effects were foreseen to result from a regulatory system that 
is more proportionate and performance-based, from the ability to satisfy requirements with 
greater flexibility, and from greater dependence on industry standards. Despite this, NAAs 
noted that greater considerations could be taken into account by the Agency with regards to 
the impact of new implementing regulations on stakeholders of different sizes and capacities. 
This  primarily  concerned  implementation  costs  for  which  additional  staff,  resources  and 
equipment  were needed  to  fully comply and respond to  the changes  within in  the Agency 
(e.g.,  increase  in  thematic  domains  covered,  increase  and  frequency  of  regulations  to  be 
reviewed and implemented). For example, it was noted that varying resources available across 
Member States and operators should be proportionally assessed, while weighing it against the 
safety  concerns  involved  while  simplifying  regulations  where  possible.  It  is  difficult  to 
evaluate  whether  compliance  costs  would  decrease  overtime  given  that  many  countries 
continue to be in the process of implementing the Regulation. 

While the analysis highlights increases in labour costs and identifies some cost categories, 
such  as  investment  in  equipment  and  increased  certification  requirements,  the  data  is  not 
sufficient  to  determine  the  precise  magnitude  of  these  costs.  Variations  in  the  size  and 

46 

 
 
complexity of the operational set up in different countries, as well as the specific needs and 
resources of individual stakeholders, can significantly impact the overall magnitude of costs.  

Costs to industry stakeholders 

This section assesses the proportionality of the regulatory costs of the Regulation to industry 
stakeholders.  11  out  of  the  62  respondents  who  answered  as  a  private  organisation  in  the 
stakeholder survey provided estimates on costs. As in the case of the NAAs, an additional 
attempt  was  made  to  gather  cost  data  from  industry  stakeholders,  of  which  only  three 
additional organisations provided information. For context, it is important to note that out of 
the 14 organisations that provided data in total, ten answered that they have more than 250 
staff, two between 50 and 250 staff, and two between 10 and 50 staff.  

An attempt was made as part of the analysis to assess the order of magnitude of costs (54) and 
benefits  in  terms  of their relative size or impact. Using small  samples of cost  estimates to 
assess  the  costs  for  industry  does  not  allow  for  meaningful  statistical  analysis  as  it  is  not 
possible to conduct statistical tests to determine the significance of the estimates. Taking into 
account this caveat, the following assessment is based on the data provided from this limited 
sample of industry stakeholders. In addition, precise quantification of the order of magnitude 
of costs versus benefits is challenging given the lack of costs on which to judge the scale, 
volume and direction of costs for stakeholders.  

In the IA, the administrative burden for businesses was anticipated to be minimal compared 
to the baseline, however no cost assessments were provided, thus no comparison can be made 
between what was expected and actual data from businesses. Despite this, quantitative data 
from  13 of the 14 private organisations that provided data  as part of this  study pointed to 
administrative costs both in EUR and in FTE. For example, one airport in Belgium and one 
air  carrier/aircraft  operator  in  Denmark  (both  with  over  250  staff)  estimated  an  additional 
yearly cost of EUR 350,000 due to the additional time required to comply with the Regulation 
as  well  as  an  increased  level  of  oversight  being  necessary,  thus  requiring  additional  FTE 
support. 

Indeed, only eight private organisations noted an increase in FTE per year to comply with the 
Regulation. In order to provide an indicative example of these costs, the data on administrative 
costs from three large airports (over 250 employees) in Belgium and Hungary was assessed. 
The estimates provided of the administrative costs to comply with the Regulation amounted 
to between 3 and 10 FTE costs (per year) – representing an average cost of 6.5 FTE per year, 
per large airport. To provide an indication of the magnitude of this cost, this average FTE cost 
was interpolated across airports in the EU which can be considered as being large (based on 
the assumption that airports with over 0.4% of overall EU traffic are classified as large-sized 
hubs). It can then be estimated that this would account for a minimum of 13,000 staff working 
across over 50 airports in the EU. Considering the data from the large airports in Belgium and 
Hungary,  it  can  be  estimated  that  the  total  administrative  cost  in  FTE  to  comply  with  the 
Regulation is 3% (approximately the cost of 331 FTE) of the total staff per year. While this 
provides an indication of the magnitude of administrative costs for large airports, it should be 
interpreted with caution. The actual costs across the EU may be much higher or lower, and 
the example presented should not be generalised to all airports or sectors within the aviation 
industry. 

(54)  When  analysing  the  order of  magnitude  of  costs,  it  involves  assessing  the  approximate  scale  or  level of 
financial  resources,  investments,  or  expenses  that  stakeholders  bear  as  a  result  of  complying  with  the 
Regulation. 

47 

 
 
Furthermore, an example from one drone operator estimated an increase in 16% in their labour 
costs, which has been estimated to be an increase of 33 FTE. It should be noted that the drone 
operator was not able to differentiate the costs which originated from the Regulation, and it 
was  acknowledged  that  increase  in  costs  was  primarily  due  to  the  additional  requirements 
included in Regulation (EU) 2021/664 (55) and not the Regulation per se. 

These  quantitative  estimates  were  accompanied  by  qualitative  assessments  from  airports, 
airlines and EU level representative organisations which collectively were of the view that 
additional  costs  were  generated  as  a  result  of  difficulties  in  complying  with  some  of  the 
implementation requirements.  

For  airlines  and  airports,  specifically,  additional  training  costs  stemming  from  new 
implementation regulations were a concern due to increased administrative tasks and the need 
to invest in new infrastructure or IT systems. 

Industry stakeholders and NAAs were largely of the view that compliance and administrative 
costs  increased  as  a  result  of  new  implementing  rules.  This  finding  is  contrary  to  the 
expectations  of  the  IA  that  foresaw  that  the  Regulation  would  have  a  positive  effect  on 
compliance  and  other  operational  costs  stemming  from  a  more  proportionate  and 
performance-based regulatory system providing greater flexibility.  

Therefore, stakeholders consider that more attention should be brought to the proportionality 
of new regulations against the need of very different stakeholders.  

While  most  stakeholders  considered  that  the  introduction  of  the  Regulation  has  led  to 
increased costs for their organisation, benefits attributed to compliance and enforcement of 
the Regulation compared to the previous Regulation (EC) No 216/2008 were also identified.  

Overall, the stakeholders identified increased safety and improved information as the greatest 
benefits that can be attributed to compliance and/or enforcement of the Regulation. Besides, 
the environmental benefits of the Regulation were also acknowledged.  

Figure 30. Stakeholder survey: Q. Please indicate which type(s) of benefits, if any, can 
be  attributed  to  compliance  and/or  enforcement  of  Regulation  (EU)  2018/1139, 
compared to the previous Basic Regulation (EC) No 216/2008? (n=116) 

(55)  Commission Implementing Regulation (EU) 2021/664 of 22 April 2021 on a regulatory framework for the 

U-space 

48 

 
 
 
Cost benefit ratio 

In examining the proportionality of the identified costs against the benefits of complying with 
the  Regulation,  there  was  a  diversion  of  views  across  stakeholders  who  responded  to  the 
survey, with 23% (27 out of 117) holding the view that costs related to the Regulation were 
proportionate to the benefits, while 24% answered that they were not proportionate (56).  

Interviews with stakeholders emphasised that the proportionality could be increased through 
EASA  conducting  more  in-depth  assessments  of  the  administrative  impact  of  future 
requirements  and  regulations  for  stakeholders.  For  example,  stakeholders  emphasised  that 
EASA should consider the stakeholder type, organisational size, and timing of implementing 
regulations.  This  was  also  paired  with  a  general  view  that  increasing  the  flexibility  for 
stakeholders  within  the  requirements  and  regulations  (e.g.,  through  more  flexibility  in  the 
timely  distribution  and  expected  implementation  timings  of  new  requirements  and 
regulations) could also help to better distribute costs and increase the perceived benefits from 
complying with the Regulation and EASA’s work as a whole.  

Qualitative insights from interviews with NCAs found a majority view that compliance and 
administrative  costs  increased  as  a  result  of  new  implementing  regulations.  However,  the 
degree to which the regulation directly meets the needs of the stakeholders’ respective sectors 
influences their perception of the cost-benefit ratio. 

While the costs of compliance with EASA and the Regulation have been significant, they are 
overall evaluated as being proportional to the benefits achieved. It should be noted that while 
the analysis suggests that the costs of EASA and the Regulation are generally proportional to 
the  benefits  achieved,  there  are  limitations  due  to  the  small  sample  size  of  quantitative 
estimates from stakeholders. 

While the Regulation and the Agency impose additional costs on stakeholders, these costs are 
in general proportionate to the benefits that the stakeholders can expect from the Regulation. 
Although 
compliance, 
enforcement/implementation  and  administrative  costs)  of  the  Regulation  are  not  always 
proportional with the achieved benefits, it cannot be concluded that the same results could 
have been achieved at a lower cost. 

demonstrated 

regulatory 

it  was 

costs 

(i.e. 

that 

Comparison to the expectations of the IA 

According  to  the  results  above,  the  costs  for  stakeholders  have  increased  despite  the 
expectation in the IA that simplification and burden reduction would reduce the compliance 
and operational costs for stakeholders. This result is linked to the length of the rulemaking 
process  in  the  area  of  aviation  safety.  The  time  from  the  preparation  to  the  adoption  of  a 
regulation  takes  up  to  3  years.  Therefore,  a  number  of  the  necessary  Implementing 
Regulations that were expected to bring about some of the benefits of the Regulation have not 
been adopted yet (e.g. for ground handling). In many cases, regulations also allow regulated 
entities  to  comply  with  the  new  rules  only  after  a  certain  timeframe  which  delays  the 
applicability of certain provisions that can bring simplification or reduce the administrative 
burden, especially for small organisations.  

The IA also expected some cost reductions by using more industry standards to support the 
regulation or by using qualified entities to support national competent authorities or EASA. 

(56)  It  should  be  caveated  that  20%  of  respondents  answered  that  the  costs  were  neither  proportionate  nor 
disproportionate to the benefits, while 32% answered that they didn’t know. The question stated: To what 
degree are the costs associated with Regulation (EU) 2018/1139 proportionate to the benefits of EASA?s 
activities for your organisation? 

49 

 
 
The use of more industry standards has until now been limited due to the time needed for their 
preparation  by  industry  and  adoption  by  the  standardisation  bodies  in  a  number  of  areas. 
Similarly,  the  more  extensive  use  of  qualified  entities  in  the  certification  and  oversight 
processes  did  not  yet  materialize  to  the  extent  foreseen  by  the  IA  because  many  national 
competent  authorities  did  not  make  use  of  this  possibility.  However,  Member  States  and 
EASA  are  now  looking  at  the  possibility  to  accredit  more  qualified  entities  in  a  more 
systematic way. For EASA and the qualified entities, this would simplify the accreditation 
procedures by not going through a lengthy procurement process. Once the accreditation of 
qualified  entities  has  become  more  flexible  and  lighter,  this  is  expected  to  accelerate  the 
simplification and reduce the costs for stakeholders. 

The perception of proportionality provides an indication that stakeholders consider the costs 
to be in balance with the benefits and that the overall cost-benefit ratio is acceptable. This 
suggests that stakeholders do not view the costs as excessively high or significant compared 
to the benefits they are deriving from compliance with the Regulation. However, this does not 
necessarily provide direct information about the order of magnitude or scale of the costs. Due 
to  a  lack  of  specific  quantitative  data  or  a  comparative  analysis  of  the  costs  against  the 
stakeholders' financial resources or budgets, it is not possible to precisely determine the order 
of magnitude of the costs based solely on the perception of proportionality. 

4.1.3.  Coherence  

This  section  evaluates  how  well  different  policy  actions  (internal  or  external  to  the 
intervention)  work  together,  leading  either  to  synergies  (which  improve  the  overall 
performance) or tensions (which are causing inefficiencies). A distinction is made between 
internal coherence (relationship between the different provisions contained in the Regulation 
itself (EQ9)) and external coherence (relationship between the Regulation, EASA’s activities 
and other international bodies or other domains of the EU regulatory framework (EQ10)). 

4.1.3.1.  Internal coherence between the requirements set out in the Regulation (EQ9)  

When asked about the internal coherence of the Regulation, survey respondents were overall 
positive:  60  respondents  (51%)  found  the  legal  requirements  set  out  in  the  Regulation 
somewhat coherent and 12 respondents (10%) even believed these were very coherent. When 
comparing  the  results  between  public  and  private  stakeholders,  public  sector  stakeholders 
were found to proportionally agree that the individual legal requirements were coherent more 
than private sector organisations.  

Figure 31. To what extent are the individual legal requirements set out in Regulation 
(EU) 2018/1139 coherent with one another overall (i.e., do not contradict or overlap with 
each other)? (n=118) 

50 

 
Overall, the requirements and provisions set out in the Regulation are coherent and consistent 
with one another. No specific differences, overlaps or inconsistencies have been identified. 

4.1.3.2.  External coherence between the Regulation, EASA’s activities and other international 

bodies or other domains of the EU regulatory framework (EQ10) 

When asked about the external coherence of the Regulation, a mixed picture emerged based 
on the responses to the survey: 69 respondents (57%) found that EASA’s tasks as set out in 
the  Regulation  were  complementary  and  did  not  overlap  with  other  regulatory  bodies  at 
international or national level, while 36 respondents (30%) believed there are overlaps and 
inconsistencies, 15 respondents (13%) declared that they did not know.  

Most of the survey comments flagged coherence issues related to one of the key elements 
mentioned  in  Section  4.1.2.  on  effectiveness:  different  interpretations  of  EASA  rules  by 
NCAs with the related risk as regards the coherence of the EU’s regulatory framework across 
Member States and a resulting lack of clarity.  

Another issue of external coherence with the broader EU regulatory framework relates to the 
different  requirements  which  apply  to  cybersecurity  (security  of  network  and  information 
systems)  and  the  impact  of  the  NIS  Directive (57)  and  its  application  to  critical 
infrastructures (58)  across  all  industries.  Indeed,  the  provisions  in  the  area  of  security 
contained in the Directive overlapped with national regulations and with EASA’s rules in the 
domain of aerodromes, creating friction or duplications.  

At international level, the relationship with ICAO was perceived as an issue by EASA staff 
at all levels. This is due to the fact that the EU including EASA only has an observer status in 
ICAO despite the fact that the EU/EASA contribute significantly to ICAO’s technical work.  

However, EASA maintains close working relations with ICAO on a wide range of activities. 
Among  others,  EASA  closely  works  with  the  Commission  and  the  Member  States  to 
coordinate common positions on matters addressed at the level of ICAO. The Agency also 
supports its Member States in implementing the ICAO standards.  

EASA has a permanent representation in Montréal, which serves as a liaison office towards 
ICAO,  and  participates  in  ICAO  meetings,  informing  on  EU  policies  and  regulatory 

(57) NIS Directive (EU 2016/1148) 

(58) As per the definition provided by Article 2 of the Council Directive 2008/114/EC, a ‘critical infrastructure’ 
is an asset, system or part thereof located in Member States which is essential for the main tendance of vital 
societal functions, health, safety, security, economic or social well-being of people, and the disruption or 
destruction of which would have a significant impact in a Member State as a result of the failure to maintain 
those functions. 

51 

 
 
 
developments, and maintaining a working relationship on technical matters with the ICAO 
Secretariat.  This  is  also facilitated  through  the  secondment  of  EASA  experts  to  the  ICAO 
Secretariat. In addition, the Agency provides technical expertise to ICAO activities. EASA 
experts take part in the work of around 50 ICAO panels, committees, working groups, study 
groups and task forces. EASA staff are also trained as ICAO auditors and take part in USOAP 
audits  (ICAO’s  Universal  Safety  Oversight  Audit  Programme)  in  the  Member  States  and 
elsewhere. 

Finally, EASA assists the Commission in transposing ICAO SARPs into the EU regulatory 
framework. While some discrepancies may exist between the EU rules and the ICAO SARPs 
due to the nature of the respective regulatory frameworks, a large majority of ICAO SARPS 
are  transposed  into  EU  legislation,  ensuring  the  effective  coherence  with  the  ICAO 
framework.  

Concerning the relationship of EASA with Eurocontrol, some overlaps between the activities 
of  the  two  organisations  exist.  However,  Eurocontrol  supports  EASA  in  its  regulatory 
activities  and  the  establishment  of  the  technical  cooperation  office  by  both  organisations 
demonstrate the willingness to address those overlaps and mitigate them as much as possible. 

4.1.3.3.  Coherence with other Union legislation in the field of aviation   

Regarding  coherence  with  respect  to  other  legal  acts,  the  Regulation  and  the  SES  legal 
framework form the backbone of the European aviation system.  Despite the long-standing 
effort to align the two frameworks, some gaps and overlaps still exist, for instance in the area 
of SES performance monitoring.  

Furthermore,  the  scope  of  the  Regulation  differs  from  the  scope  of  the  SES  regulatory 
framework. While the latter also applies to state aircraft, when operated as general air traffic, 
the former explicitly excludes state aircraft from its scope. The consequence of this difference 
can be observed in the transfer of the safety and interoperability requirements of ATM/ANS 
systems  and  constituents.  Upon  their  transfer  into  the  EASA  regulatory  framework,  these 
requirements,  originally  contained  in  now  repealed  Regulation  (EC)  No  552/2004  and  its 
implementing  acts,  do  not  apply  to  State  aircraft.  Member  States  are  however  obliged  to 
ensure that operations of state aircraft are carried out with due regard to safety objectives of 
the Regulation. 

The Regulation is generally consistent with other pieces of EU legislation addressing aviation, 
such  as  Regulation  (EU)  No  996/2010  on  accident  investigation  and  Regulation  (EU)  No 
376/2014 on occurrence reporting in civil aviation. 

Regulation  (EU)  No  996/2010  lays  down  the  rules  and  procedures  on  the  investigation  of 
aviation accidents and incidents. The Regulation amended Regulation (EU) No 996/2010 as 
regards the investigation of accidents involving UAS and small aircraft. EASA can be invited 
to participate in the accident investigation in an advisory role. At the same time, EASA in its 
role  as  a  competent  authority  and  certifying  authority  can  be  subject  to  safety 
recommendations issued by the safety investigation authorities.  

Regulation (EU) No 376/2014 lays down rules and procedures on reporting of occurrences in 
civil aviation, including rules on protecting the reporters and fostering the ‘just culture’. Some 
overlaps exist between the reporting requirements laid down by Regulation (EU) No 376/2014 
and similar requirements contained in the implementing rules issued under the Regulation. 
Therefore,  to  ensure  consistency  between  these  requirements  and  to  reduce  overlaps,  the 
existing implementing rules have been constantly aligned with the requirements of Regulation 

52 

 
(EU) No 376/2014 (59). There are also no significant gaps in the scopes of the two Regulations, 
in particular as regards the occurrences to be mandatorily reported and the persons who shall 
report such occurrences.  

The Regulation is also consistent with Regulation (EU) No 598/2014 on the establishment of 
rules and procedures with regard to the introduction of noise-related operating restrictions at 
Union airports and Directive 2003/87/EC establishing a system for greenhouse gas emission 
allowance trading.  

The Regulation and the Agency’s tasks are coherent and consistent with other EU regulatory 
instruments  under  the  air  internal  transport  acquis  and  with  international  agreements. 
Although some discrepancies may exist between the EU rules and the ICAO SARPs this is 
due to the differences and overlaps of the respective regulatory frameworks and is not linked 
to the Regulation or the Agency’s activities per se.  

4.2.  EU added value 

This  Section  presents  the  findings  concerning  the  EU  added  value  of  the  Regulation  and 
EASA more generally by considering the added value of this being an EU-level intervention 
as opposed to Member States working alone, bilaterally or multilaterally.  

The conclusions and lessons learnt under this criterion address the added value resulting from 
the  EU  intervention  and  the  consequences  of  stopping/withdrawing  this  intervention. 
Conclusions are based on the triangulated data that were collected during the support study 
through desk research, interviews, workshops, survey, and field visits to EASA.  

4.2.1.  Added value resulting from the EU intervention (EQ 11) 

As already highlighted in the findings related to effectiveness (Section 4.1.2.), stakeholders 
more easily recognise EASA’s positive impact compared to those of the Regulation. The key 
finding as regards the added value of the Regulation is that the Regulation sets out a single 
regulatory  framework  for  aviation  safety  at  EU  level,  which  has  been  identified  by  most 
stakeholders  as  essential  to  achieve  an  integrated  European  aviation  system.  Having  a 
harmonised regulatory framework in place that is up to date with developments in the aviation 
sector, and duly considers EU policy priorities such as the European Green Deal, was seen as 
the key contribution of the Regulation. In view of new technologies and innovations, it was 
identified  that  uniform  requirements  for  unmanned  aircraft  at  European  level  promote  the 
single market in a rapidly evolving sector that was previously unregulated.  

Results from the survey on the EU added value support this and reflect a clear recognition of 
the benefits of the Regulation and EASA. When comparing the results between public and 
private stakeholders, no significant differences in the groups were observed.  

(59)  The  alignment  is  based  on  NPA  2016-19  -  Alignment  of  implementing  rules  and  acceptable  means  of 
reporting: 

compliance/guidance  material  with  Regulation 
https://www.easa.europa.eu/en/document-library/notices-of-proposed-amendment/npa-2016-19 .  

(EU)  No  376/2014 

-  Occurrence 

53 

 
 
Figure 32.  Could the activities carried out by EASA have been performed at regional, 
national (by each Member State acting alone), or international level? (n=118)  

An important side-effect is related to the important role of EASA at international level. There 
is a strong recognition of the benefits of the increased weight of an EU level Agency compared 
to  the potential influence of national  authorities  if EASA did  not  exist.  The  support study 
concludes that EASA’s role is stronger and more influential than that of national authorities 
could  be  at  international  level.  When  it  comes  to  more  concrete  benefits,  the  evaluation 
showcased  particular  benefits  in  the  areas  of  third  country  operators,  certification  (i.e. 
manufacturers  do  not  have  to  get  aircraft  certified  from  all  individual  NCAs)  and  the 
application of a single set of rules across Europe.  

4.2.2.  Consequences of stopping or withdrawing (EQ 12) 

This  section  addresses  the  consequences  of  a  hypothetical  situation  of  not  having  the  EU 
intervention anymore (that of introducing the Regulation). As part of the survey with public 
and  private  aviation  stakeholders,  the  question  was  asked  whether  the  same  effects  and 
impacts  of  the  Regulation  would  have  been  achieved  if  the  previous  Regulation  (EC)  No 
216/2008 was still in force. The results show that somewhat more respondents thought that 
the  effects  and  impacts  could  not  have  been  reached  without  the  Regulation  (40%, 
corresponding to  47 respondents) compared to  respondents  who mentioned that this could 
have happened (35%, corresponding to 42 respondents).  

Figure  33. How likely  is it that the effects and impacts of Regulation (EU) 2018/1139 
would  have  been  achieved  without  having  the  Regulation  in  place  (i.e.  with  only  the 
previous Basic Regulation (EC) 216/2008 in force)? (n = 118) 

Evidence collected during the support study shows that the same results would not have been 
achieved without EU intervention in the field of aviation safety and environmental protection. 
No consulted stakeholder mentioned any opinion in favour of abolishing EASA or ending the 
EU  intervention  in  the  area  of  aviation  safety.  On  the  contrary,  most  stakeholders 
spontaneously  mentioned  they  would  not  wish  for  this  to  occur.  This  is  supported  by  the 

54 

 
 
 
literature  review,  where  no  mention  was  found  arguing  to  stop  or  withdraw  European 
intervention in the area of aviation safety or environmental protection.  

Results from the survey (public and private aviation stakeholders) on the EU added value of 
the Agency show that there is strong support for the statement that the same results could not 
have been reached without EASA (69%, corresponding to 82 respondents). 

Figure  34.  How  likely  it  is  that  the  same  results  would  have  been  achieved  at 
international, national or regional level without an agency such as EASA? (n=118) 

When  comparing  the  results  between  public  and  private  stakeholders,  no  significant 
differences in the groups were observed. The EU added value is largely positive and stopping 
or withdrawing the existing EU intervention is not desired by stakeholders. 

4.3.  Relevance 

This section presents the evaluation findings concerning the relevance of the Regulation and 
EASA. This explores the degree to which the objectives of the Regulation and EASA are still 
in line with the current needs or problems of the EU aviation sector, and whether the original 
objectives  and  activities  of  EASA  correspond  to  foreseeable  future  needs  of  the  aviation 
sector in the EU. 

4.3.1.  The objectives and scope of the Regulation and of EASA corresponding to the 

needs of the aviation sector (EQ 7) 

The relevance of a European Agency harmonising rules across its Member States and at an 
international  level  is  enshrined  in  Article  90  of  the  Regulation.  It  describes  EASA’s 
contribution to the harmonisation of rules, the mutual recognition of certificates in the interest 
of the European industry, and the promotion of European aviation safety standards. When it 
comes to the international cooperation, EASA’s Consolidated Annual Activity reports (see 
Annex 6 of this document for further details on EASA’s role in international cooperation) 
show that the Agency is on track with respect to its workplan on bilateral agreements, working 
arrangements, and recommendations to ICAO. 

The  relevance  of  the  Agency  is  echoed  by  a  majority  of  respondents  to  the  survey,  who 
answered  that  the  Regulation  and  the  activities  of  EASA  are  still  relevant  to  the  current 
problems and needs they face, with 75% of the participants (i.e., corresponding to 89 out the 
total of 118 respondents) who answered with ‘very relevant’ or ‘somewhat relevant’. When 
comparing  the results  between public and private stakeholders, public sector organisations 
were found to perceive the future relevance of the Regulation and activities of EASA slightly 
greater than private stakeholders, however this difference is marginal.   

55 

 
 
Figure 35. To what extent are Regulation (EU) 2018/1139 and the activities of EASA still 
relevant to address the current problems and needs of your organisation? (n=118) 

In terms of other new policy developments such as drones, decarbonisation and digitalisation, 
EASA  staff  recognised  the  need  to  contribute  to  these  developments  and  emphasised  the 
importance of EASA’s role in these developments. 

An  important  recurring  point  during  the  evaluation  was  related  to  the  importance  of 
maintaining EASA’s strong position in key areas such as certification. Stakeholders see a risk 
in case the enlargement of EASA’s competencies (in areas such as digitisation) could come 
at the detriment of EASA’s safety related tasks. In the same vein, stakeholders are concerned 
about EASA’s future financial and human resources if the Agency does not prioritise its work 
sufficiently well.  In this context, reference was  made to  the existing  political  pressure on 
EASA to deliver on its traditional mandate as well as on new upcoming (political) priorities. 

The  Regulation  mandates  the  Agency  to  assume  new  responsibilities  in  important  and 
complex  areas  such  as  safety  and  interoperability  of  ATM/ANS  systems  and  constituents, 
environmental  protection  or  research  and  development.  In  the  field  of  environmental 
protection,  EASA  is  already  mandated  to  prevent  significant  harmful  effects  on  climate, 
environment and human health, and to assist the Commission in defining and coordinating 
environmental policies in the field of aviation. 

The objectives and the scope of the Regulation and of EASA are still relevant to meet the 
needs of the aviation  safety  system  currently in  place  and  are still adequate in  the current 
context.  The  Agency  is  well-placed  to  serve  large  pan-European  stakeholders  that  have  a 
business model which particularly benefits from EU-wide regulation. 

4.3.2.  New emerging issues and needs in aviation (EQ 8) 

Innovation 

New  emerging  technologies,  automation,  artificial  intelligence  and  digitalisation  are 
becoming more relevant in the aviation sector. Since the adoption of the Regulation, EASA 
has been preparing for this through various initiatives.  

In the area of drones, following the adoption of a regulatory framework for drones in 2019, 
EASA proposed standards for the certification of aircraft capable of Vertical Take-Off and 
Landing  (VTOL)  and  issued  rules  for  new  types  of  operations  with  Unmanned  Aircraft 
Systems (UAS). The Agency also published the first set of rules and guidance for U-Space 
and the design of vertiports, the ground infrastructure needed for the safe operation of Urban 
Air Mobility services such as air taxis. 

56 

 
 
In the area of artificial intelligence and “big data”, EASA’ roadmap on artificial intelligence 
(AI) and the setting-up and management of the Data4Safety programme () are good examples 
of EASA’s increased capacity to deal with innovation.  

In  preparing  such  initiatives,  EASA  managed  to  establish  strong  working  links  with  the 
industry  to  deal  with  disruptive  innovation.  For  instance,  EASA  has  signed  a  number  of 
Innovation Partnership Contracts (IPC) and Pre-application Contracts to work together with 
industry on new technologies so that their certifiability can be discussed and assessed at an 
early  stage.  EASA  has  also  been  closely  involved  in  EU  programmes  through  the  close 
cooperation with relevant Joint Undertakings (Clean Aviation, Clean Hydrogen, SESAR) and 
its involvement in Horizon Europe (research) projects.  

A  further  tool  to  allow  for  the  emergence  of  new  innovative  products  and  operational 
concepts,  could  be  the  use  of  “regulatory  sandboxes”(60).  EASA  is  currently  relying  on 
national  exemptions  to  the  existing  requirements  to  allow  for  real-life  testing.  Regulatory 
sandboxes would enable industry to experiment, test and validate innovative and disruptive 
technologies. The effective introduction of this concept may, however, require a change to 
the Regulation which would also increase EASA’s attractiveness as safety regulator in the 
global landscape.  

Reaction to the COVID-19 pandemic 

When it comes to EASA’s role in the COVID-19 pandemic, most stakeholders agreed that 
EASA  managed  all  the  coordination  of  information  and  support  needed  during  the  health 
crisis  in  a  timely  and  efficient  way  –  despite  the  fact  that  EASA  has  not  assumed  such 
responsibilities in the past. A good example is the regular issuance of health safety measures 
for air travel, recommending the mandatory wearing of medical masks in airports or on board 
a flight or lifting this recommendation. EASA also published reviews of aviation safety issues 
arising  from  the  COVID-19  pandemic  as  well  as  safety  information  bulletins  on  the 
vaccination  of  aircrew  and  other  operational  recommendations  (e.g.  for  general  aviation 
operations).  During  the  period  of  the  pandemic,  the  Agency  acted  hand  in  hand  with  the 
European  Centre  for  Disease  Prevention  and  Control  (ECDC).  Both  agencies  regularly 
updated  their  joint  aviation  health  safety  protocol,  thereby  providing  clear  operational 
guidance and risk-based recommendations for health-safe air travel to complement other EU 
initiatives, such as the EU Digital COVID Certificates. Operationally, EASA’s effectiveness 
during the global outbreak of COVID-19 was also demonstrated by granting approvals and 
exemptions that made the transportation of emergency cargo in passenger cabins possible. 

The withdrawal of the UK from the EU 

With  regard  to  the  UK’s  withdrawal  from  the  EU,  stakeholders  confirmed  that  EASA 
managed to adapt to the new situation during the transition period when EASA continued its 
responsibilities but had to take into account that the UK could not be party to decision-making 
or  decision-shaping.  EASA  used  the  transition  period  to  wind  down  its  existing  working 
relations with the UK. After the end of the withdrawal period, EASA effectively reorganised 
its processes in several areas such as third-country operator approvals. Overall, EASA has 

(60)  Regulatory sandboxes can be defined as a legal framework set up for a limited time by a regulator that allows start-ups 
and other innovative actors to conduct live experimental operations covering limited area in a controlled environment 
under a regulator's supervision. 

57 

 
 
 
 
been  able  to  effectively  undertake  its  activities  during  and  in  the  aftermath  of  the  UK’s 
withdrawal from the EU.  

Russia’s war of aggression against Ukraine 

Following the outbreak of the war in Ukraine, widely positive feedback was reported both 
from the aviation industry and the NCAs on EASA’s proactivity in applying the restrictive 
measures taken by the EU and ensuring safe flight operations. EASA managed to react very 
quickly by issuing more than ten alerts and published conflict zone bulletins recommending 
avoiding Ukrainian and Russian airspaces. The Agency also developed a safety risk portfolio 
that identified new or emerging safety issues resulting from the war in Ukraine and established 
a list of 20 safety issues affecting commercial aviation stemming from or associated with this 
conflict  (see  EASA  paper  on  ‘Safety  risk  portfolio  in  response  to  Russia’s  invasion  of 
Ukraine’ (61)). 

Conclusion 

Overall, EASA’s capacity to deal with new issues and to react to external shocks demonstrate 
that the Regulation’s objectives and the Agency’s tasks are still aligned with the current and 
emerging needs or problems in the aviation sector. 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

As set out in Chapter 1.2. the results of the evaluation have to be critically assessed against 
the background of the limitations in the data collection. Nevertheless, the available evidence 
suggests that the intervention was overall successful and contributed to a safe and efficient 
level playing field for the EU aviation industry and to addressing environmental aspects of 
aviation. This result is due to a positive assessment of EASA’s rulemaking and certification 
activities, among others, together with a timely and effective response to external shocks. The 
effectiveness of stakeholder consultations between EASA, the aviation industry and NCAs 
has increased over the years. EASA was also largely efficient in adequately using its available 
annual budget.  

Findings linked both to the performance of the Regulation and of EASA 

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. 

Findings linked to the performance of the Regulation 

The Regulation does not contain a clear link between the mandate of EASA, the prioritisation 
of its activities and resource aspects. For instance, the Agency’s mandate on innovation and 
research requires a balance between managing the current, core tasks of EASA and the need 
to prepare for future areas and tasks. The Regulation currently only provides a very limited 
framework for the development of ‘regulatory sandboxes’ to allow the industry to innovate 
and  experiment  whilst  still  ensuring  the  required  level  of  safety  and  obtain  regulatory 
learnings  for  performance-based  rules  based  on  industry  standards.  This  puts  the  EU  at  a 
disadvantage to other jurisdictions such as the United States. 

(61)  https://www.easa.europa.eu/en/safety-risk-portfolio-response-russias-invasion-ukraine 

58 

 
 
 
 
With regard to rulemaking activities, EASA (as required by Article 4(e) of the Regulation) 
should  ensure  a  performance-based  approach  when  laying  down  requirements  and 
procedures.  However,  the  ‘inclusive’  nature  of  the  rulemaking  process  (i.e.,  balancing  the 
needs and the preferred approaches of the industry and of the NCAs) leads in some cases to 
the development of overly prescriptive rules. This somehow deviates from the objectives of 
the  Regulation  to  reach  a  better  combination  between  requirements  and  more  flexible 
provisions such as certification specifications, acceptable means of compliance and guidance 
material.  

Certain EASA tasks related to the identification and mitigation of aviation risks are contained 
in the SES2+ proposals (62), which have not progressed significantly. 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 provision 
of a common information service for unmanned operations.  

Findings linked to the performance of EASA 

The positive results as regards the safety performance are mostly due to the long-standing 
effectiveness of EASA’s activities rather than the specific impact of the Regulation.  

Under the reporting period,  EASA faced  three  major crises:  the COVID-19 pandemic, the 
UK’s  withdrawal  from  the  EU  and  Russia’s  war  of  aggression  against  Ukraine.  EASA 
responded effectively and efficiently to these external shocks.  

Overall, EASA’s performance on rulemaking, certification and standardisation activities is 
widely positive. However, the COVID-19 pandemic impacted on the Agency’s performance 
as it had to concentrate on new challenges in areas which were outside its mandate. 

The  Agency  used  its  available  annual  budget  efficiently  and  achieved  high  budget 
implementation rates.  

The introduction of the Regulation led to increased costs for stakeholders (primarily due to 
the  increase  in  requirements  and  implementing  regulations).  Despite  this,  stakeholders 
identified  benefits  in  terms  of  increased  safety.  However,  there  were  diverging  views 
regarding the proportionality of costs and 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 NCAs.  

5.1.  To what extent was the intervention successful and why? 

The  success  of  the  intervention  is  assessed  in  terms  of  the  extent  to  which  it  achieved  its 
objectives effectively, efficiently and in a coherent way. 

5.1.1.  Effectiveness 

Despite the limitations of the findings of this evaluation which are due to the strong impact 
of the COVID-19 pandemic during the  evaluation period, there  are strong indications that 
EASA  and  the  Regulation  contributed  to  European  integration  in  the  area  of  air  transport 

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

59 

 
 
resulting in significant benefits for safety, efficiency, the environment and an enhanced level 
playing field for the aviation industry. 

Despite  some  identified  areas  for  improvement  (e.g.  need  for  consistent  harmonisation  of 
rules across all domains of aviation safety), the overall quality of EU standards is recognised 
as very high by EU aviation stakeholders. EASA delivered on its core tasks as defined by the 
Regulation: product certification, rulemaking and standardisation activities are perceived as 
effective overall with some caveats (e.g., length  of rulemaking process with respect to the 
pace of technological developments, or some discrepancies in standardisation procedures). 
EASA was able to remain effective despite the resource constraints since 2018, partly because 
it could benefit from hiring staff with advanced expertise at high grades early on, bringing 
knowledge and efficiency. However, this know-how is now being progressively lost due to 
retirement. Additional budget is therefore required to adequately train a new generation of 
professionals. 

Moreover, EASA’s effectiveness is demonstrated by the role played by the agency in response 
to external shocks and political pressure: widely positive feedback was reported in relation to 
EASA’s role during the UK withdrawal, in ensuring safe flight operations during the COVID-
19 pandemic, or in reaction to Russia’s war of aggression against Ukraine.  

In relation to the UK’s withdrawal, EASA managed to continue to fulfil its missions and tasks 
showing the necessary flexibility and resilience despite the creation of additional tasks (e.g. 
including  UK  operators  in  the  Third  Country  Operator  approval  system).  As  regards  the 
COVID-19 outbreak, together with the European Centre for Disease Prevention and Control 
(ECDC), the Agency played a new role in the development of an "Aviation Health Safety 
Protocol" to efficiently guide air travellers and the aviation sector through the pandemic. It 
continuously adjusted its recommendations for public health threats together with ICAO and 
the ECDC, demonstrating its effectiveness when reacting to such an external shock. EASA’s 
reaction vis-à-vis the war in Ukraine showed how quickly the Agency can adapt to a political 
crisis and fulfil efficiently its safety missions at the same time.  

Overall, the Regulation assigns EASA a very broad role in implementation support. However, 
the existing resource constraints limit EASA’s ability to fulfil its tasks entirely. Therefore, 
EASA’s future workload should be carefully assessed in the light of its resources. 

Therefore,  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 across 
Europe, leading to greater cooperation and coordination between NCAs.  

Lessons learnt:  

• 

In order 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.  

EASA’s performance-based approach is recognised as an effective way forward to meet the 
objectives  of  the  Regulation.  However,  a  better  balance  between  legal  certainty  and  over-
prescriptiveness of the rules has not yet been fully achieved. 

The  performance-based  approach  applied  by  the  Agency  is  essential  in  ensuring  the 
effectiveness of EASA’s activities. In fact, the issue of over-prescriptive rules was one of the 
key problems identified at the time of the IA for this intervention. This approach runs the risk 

60 

 
to negatively impact on the uptake of new technologies and industry’s overall adaptability to 
innovation.  

Although there is 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 
further  develop  this  approach.  A  standard  pattern  is  that  stakeholders  from  the  aviation 
industry prefer performance-based/non-prescriptive rules while authorities tend to value more 
prescriptive rules as they provide for more legal certainty. 

Lessons learnt:  

•  The  introduction  of  more  flexibility  in  the  use  of  certification  specifications, 
acceptable  means  of  compliance  and  guidance  materials  rather  than  implementing 
rules and delegated acts would increase the rulemaking effectiveness of EASA; this 
requires either a more top-down approach from EASA and the Commission as rule 
maker,  or  more  awareness  and  training  of  stakeholders  and  authorities  on 
performance-based regulatory techniques. 

•  Guidance materials developed by EASA are key to ensure harmonised implementation 

of regulations. 

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  relationship  of  EASA’s  Advisory  Bodies  has 
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. 

Lessons learnt:  

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

5.1.2.  Efficiency 

The  Agency  was  able  to  maintain  high  budget  implementation  rates,  making  use  of  the 
available annual financial resources throughout the years. The challenges due to the COVID-
19 pandemic had a significant impact on the Agency’s activities and its revenue from fees 
and charges. 

Irrespective of the COVID-19 pandemic, the Agency faced a steady decline in terms of human 
resources  (full-time  equivalents  -  FTEs)  resulting  in  a  challenge  for  EASA  to  fulfil  its 
missions.  Indeed,  while  the  IA  estimations  that  the  introduction  of  the  Regulation  would 
require additional FTEs, the number of FTEs within EASA decreased during the evaluation 
period. This decrease is particularly important considering the expansion of EASA's scope.  

The subsidy part of EASA’s budget does not reflect unforeseen emerging needs. It remains 
to be assessed whether the EU contribution is still sufficient to fund EASA’s core tasks. This 
requires  EASA  to  seek  funding  for  those  activities  elsewhere  (e.g.  from  the  Connecting 

61 

 
Europe Facility). The emerging tasks that EASA will have to face in the near future, require 
a deep analysis of its capacity to deliver in an efficient manner. 

Overall, the Agency was successful in implementing the financial resources made available. 
On the other hand, the scope of EASA expanded (and continues to expand) while the available 
resources might not have. This could result in a challenge for EASA to fulfil its missions in 
the longer term. 

Lessons learnt:  

•  Although the Agency demonstrated its ability to efficiently use its annual budget and 
generate  revenue  through  its  activities,  the  Agency’s  growing  scope  requires  an 
assessment  as  regards  the  availability  of  the  necessary  resources.  This  raises  the 
question of whether the EU would be better served with an Agency that is more fully 
financed from user fees. 

•  Additional foresight planning for unexpected events: the COVID-19 pandemic had a 
significant  impact  on  the  Agency’s  activities  and  revenue  streams.  It  is  therefore 
necessary  for  the  Agency  to  prepare  for  unexpected  events  that  may  impact  its 
operations and revenue streams. 

The  introduction  of  the  Regulation  was  perceived  as  having  led  to  increased  costs  for  a 
majority  of  stakeholders,  primarily  due  to  the  increase  in  requirements  and  implementing 
regulations.  On  the  other  hand,  stakeholders  also  identified  benefits  in  terms  of  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 foreseen simplification and 
burden reduction did not take place yet but the better use of the tools offered by the Regulation 
is expected to reduce the compliance and operational costs for stakeholders in the future.  

Thus, in recognising that new requirements and implementation regulations will remain a key 
aspect of EASA’s work in the future, the findings point to a need to spend more attention to 
the impact of these changes for different stakeholders. This is particularly pertinent for smaller 
entities.  

Lessons learnt:  

•  More effort should be made to develop a less prescriptive and more performance based 

regulatory framework.   

•  More attention should be given to an assessment of the cost impact of new regulations 

for stakeholders (particularly for smaller entities).  

5.1.3.  Coherence 

Although the intervention is overall coherent, both internally and externally, there is room for 
improvement  in  relation  to  external  coherence.  In  specific  areas,  the  Regulation’s 
requirements  and  EASA’s  tasks  are  not  yet  fully  consistent  with  the  requirements  of  the 
broader EU regulatory framework, in particular with regard to the SES regulatory framework, 
resulting in some duplication and inconsistencies. 

Stakeholder  feedback  on  the  internal  coherence  of  the  Regulation  was  positive  overall. 
However, there is a risk that diverging interpretations of EASA’s rules lead to incoherencies 
between Member States. 

Lessons learnt: 

•  Continued efforts are needed to ensure coherence of EASA’s rulemaking activities. 

62 

 
5.2.  EU added value 

The Agency fulfils its role in ensuring common rules and standards for aviation safety and 
technical  cooperation  on  environmental  protection  as  well  as  its  role  in  international 
cooperation.  

The  EU  intervention  continued  to  achieve  benefits  that  could  not  have  been  achieved  at 
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 EU-
wide regulatory framework consists in the provision of common requirements Europe. 

The same effects that the Regulation achieved could not have been achieved by the previous 
Regulation  (EC)  No  216/2008.  This  is  due  to  the  fact  that  the  Regulation  contains  new 
responsibilities in important areas such as unmanned aircraft and environmental protection. 

Lessons learnt: 

•  Requirements are continuously developing, and the EASA system must adapt to these 
changes. Some of the new elements of the Regulation still need to be fully developed 
(e.g.  ground  handling),  and  new  areas  need  to  be  addressed  (e.g.  Higher  Airspace 
Operations (63) or technology developments in ATM). 

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

EASA has been able to establish relationships with other aviation partners around the world, 
including at ICAO, resulting in the mutual recognition of certification and oversight activities. 
This has facilitated the international acceptance of EU 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 EU’s 
ability to maintain its international competitiveness. 

The tasks of EASA could not have been better performed by other actors at regional, national 
or international level. 

Lessons learnt: 

• 

In its effort to harmonise rules and  enhance cooperation with aviation partners, the 
role of EASA needs to  consistently change to adapt to a very complex and rapidly 
changing environment.   

5.3.  Is the intervention still relevant? 

The Regulation and EASA are both perceived to still be relevant for the current and future 
needs of the aviation sector.  

Stakeholders identified new (more environmentally friendly) technologies, digitalisation and 
artificial  intelligence  as  key  emerging  needs  that  impact  aviation  safety  more  since  the 
adoption of the Regulation. 

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

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

the  majority 

(typically 

provided 

services 

today 

are 

FL 

air 

of 

63 

 
 
The Regulation and EASA are relevant to the current needs of the aviation sector. There are, 
however, concerns about the Agency’s capacity to deliver on new tasks (e.g., in the area of 
environmental protection) without creating negative repercussions on its tasks that are directly 
related  to  aviation  safety.  This  requires  an  assessment  on  the  availability  of  sufficient 
resources for EASA to deliver on its increasing number of tasks.  

Lessons learnt:  

•  Further considerations about the role of EASA and its growing number of tasks should 

contain a careful assessment of EASA’s future resource needs.  

Innovation  and  technological  developments  have  intricate  implications  on  the  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  also  have  possible 
implications on aviation safety and thus need to be carefully addressed by EASA. The Agency 
must therefore ensure having access to the necessary technical expertise, train its staff and 
keep being involved in the relevant research projects and innovation programmes.  

Lessons learnt:  

•  EASA should pursue its effort 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. Research projects on 
emerging technologies are a good tool to achieve this. 

•  EASA  should  continue  exploring  new  ways  to  keep  up  to  date  with  recent 
technology innovations and assess their impact on aviation. Continuous cooperation 
with  other  EU agencies  and  other  organisations  involved  in  establishing  and/or 
managing research and innovation programmes should be further exploited to gain 
knowledge and data on novel products, technologies, new types of operation and 
new business models. 

•  The testing of innovative solutions in a safe environment (sandboxes) could benefit 

from additional regulatory flexibility. 

5.4.  Monitoring and evaluation system for future evaluations 

To  facilitate  future  evaluations,  the  proposed  monitoring  and  evaluation  system  that  was 
contained in the IA has been revised. The new system takes into account recent developments 
and additional data which has become available. The respective data points will be collected 
annually and should facilitate the effectiveness and efficiency of the next evaluation.     

Figure 36. Proposed EASA monitoring and evaluation system 

Strategic 
Objectives 

Main indicators (CSWD Impact 
Assessment 2015) 

Future Indicators 

(SO 1) 
Eliminate 
unnecessary 
requirements 
and ensure 
that 
regulation is 
proportionate 
to the risks 
associated 

1.  Positive 
stakeholders 
authorities; 

feedback 
and 

from 
aviation 

Source: General Aviation Flightpath 2030+ 
Indicator: Progress on actions included in the General 
Aviation Flightpath 2030+ programme activities, 
intended to make GA regulation proportionate. 

2. Reducing number of questions 
of interpretation concerning the 
revised rules; 

Source: SPD & CAAR:  
Indicator: Rulemaking process effectiveness 
Measurement: By 2027, 80% of the overall published 
deliverables for regulatory material to be part of the 
strategic tasks identified in EPAS. 

64 

 
with different 
types of 
aviation 
activities 

3.  Number  of  operators  using 
performance  based  rules  for 
demonstrating  compliance  with 
essential requirements; 

4.  Number  of  General  Aviation 
Private Pilot Licences 

5. Reduced costs for operators 

1.  Number  of  new  rules  which 
make  reference  to  recognised 
industry standards; 

2.  Reduced  age  of  the  general 
aviation fleet in EU; 

3.  Reduced  costs  of  aircraft 
certification and production; 

4. Number of new certifications 

1.  Accident  rate  in  relation  to 
traffic growth 

2.  Improving  results  of  EASA 
standardisation  and  continuous 
monitoring activities 

3.  State  Safety  Programmes 
implementation level in Member 
States 

4.  Risk  bearing  occurrences 
involving ground-handling; 

(SO 2) Ensure 
that new 
technologies 
and market 
developments 
are efficiently 
integrated 
and 
effectively 
overseen: 

(SO 3) 
Establish a 
cooperative 
safety 
management 
process 
between 
Union and its 
Member 
States to 
jointly 
identify and 
mitigate risks 
to civil 
aviation: 

 Source: SPD & CAAR:  
Indicator: Implementation Safety Promotion 
Programme 
Description: Percentage of completion and execution 
of the Annual Domain safety promotion plans 
(deliverables and publication) (E.g. 2024 target >90%) 

Source: SPD & CAAR  
Indicator: Percentage increase in number of industry 
standards referenced as acceptable means of 
compliance (AMC) or guidance material (GM). 
NOTE: not new KPI in the existing list in SPD&CAAR, 
but mentioned in CAAR text   

Source: SPD &CAAR 
Indicator: Percentage of research contribution 
agreement funds allocated to projects effectively 
consumed 
Source: SPD & CAAR  
Indicator: Percentage of Innovation Partnership 
Contracts (IPC) and Pre-Application Contracts (PAC) 
leading to Special Conditions or Means of Compliance 
available to industry to support future acceptance of 
new concepts of operations and certificate 
applications (Target: 70%) 

Source: CAAR 
Indicator: Number of new Type Certificate (TC) 
applications received and new TCs issued 
NOTE: not a KPI in the existing list in SPD&CAAR, but 
mentioned in CAAR text   

Source: Annual Safety Review, Chapter 2.1 (Figure 6) 
Indicator:  Rate of accidents (fatal and non fatal) or 
serious incidents per 1 million departures 

Source: SPD & CAAR:  
Indicator: Control of overdue Standardisation findings 
Measurement: Maximum 20% of findings without 
supplementary reports after 6 months from the date 
they became overdue 

Source: Annual Safety Review 
Indicator: Percentage of Member State self 
assessments completed to comply with ICAO 
obligation on State Safety Programme Implementation 
Assessment (SSPIA) 

Source Internal document  
Indicator: Rate of conversion of identified safety 
issues to actions addressed in the EPAS 
Source: EPAS Volume I, Chapter 4 & Annual Safety 
Review 
Indicator: Effectiveness of managing the safety risks in 
Europe 
Measurement: Establishment of European Risk 
Classification Scheme (ERCS) scores per Key Risk Area 
(KRA). 
NOTE: measurable as of 2026 

65 

 
  
  
  
1.  Positive 
stakeholders 
authorities 

feedback 
and 

from 
aviation 

Source: EPAS / Basic Regulation 
Indicator: Establishing a framework for UAS and VTOL 
Measurement: Execution of the RMT.0230 tasks 
included in EPAS. 

Source: EPAS / Basic Regulation 
Indicator: Establishing a framework for ATM Ground 
Equipment Conformity Assessment  
Measurement: Execution of the related rulemaking 
tasks included in EPAS. 

Source: EPAS / Basic Regulation 
Indicator: Establishing a framework for Ground 
Handling 
Measurement: Execution of the related rulemaking 
tasks included in EPAS. 
Source: European Plan for Aviation Safety 
Indicator: Number of evaluation tasks (EVT) or regular 
updates stemming from new concepts of operations. 
NOTE: not new KPI in the existing list, but mentioned in 
EPAS 

2. Reducing number of questions 
of interpretation concerning the 
revised rules 

1. Improving results of the EASA 
standardisation  inspections  and 
continuous  monitoring  with 
its 
respect  to  resources  and 
competence in Member States 

Source: SPD & CAAR  
Indicator: Volume of agency tasks (hours) assigned to 
national competent authorities under Partnership 
Agreement, not limited to certification and oversight 
tasks.  

Source: Standardisation Annual Report, Chapter 3.2  
Indicator: Number of team members from national 
competent authorities effectively assigned in each 
domain. 

Source: Standardisation Annual Report, Chapter 3.8 
Indicator: Feedback from the survey conducted 
among senior managers of the inspected NCAs. 

feedback 

2.  Positive 
from 
Member  States  on  workload 
impact of EU rules 

(delegation 

3.  Number  of  Member  States 
making use of EU aviation safety 
inspectors, and new instruments 
for  pooling  and  sharing  of 
resources 
of 
responsibilities,  opt-in  for  state 
and Annex II aircraft) 
4.  Evolution  of  resources 
in 
national  aviation  authorities  of 
Member  States  measured 
in 
terms of FTEs and budget 

(SO 4) Close 
the gaps in 
the regulatory 
system and 
ensure its 
consistency: 

(SO 5) Create 
an effectively 
working 
system of 
pooling and 
sharing of 
resources 
between the 
Member 
States and 
the Agency: 

5.5.  Scoring of individual evaluation categories 

This  section provides a short  summary  of the  positive  and  negative findings, as  were layed  out in 
chapters 5.1., 5.2. and 5.3. In addition, it allocates a grade to each of the five evaluation categories for 
better reference and comparison of the results achieved in the observed period. 

Figure 37. Scoring across evaluation categories with breakdown of influencing factors 

Category  

Score  

Positives  

Effectiveness   ++  

•  EASA and the Regulation 
contributed to European 
integration in the area of air 
transport resulting in significant 
benefits for safety, efficiency, the 
environment and an enhanced 

66 

Negatives  

•  Some areas for 

improvement have been 
identified, such as need for 
consistent harmonisation 
of rules across all domains 
of aviation safety, the 
length of rulemaking 

 
  
  
  
 
process with respect to the 
pace of technological 
developments, or some 
discrepancies in 
standardisation 
procedures. 

•  EASA has not yet fully 

achieved the right balance 
between legal certainty 
and over-prescriptive 
rulemaking  

•  Subsidy part of EASA’s 
budget not reactive 
enough for unforeseen 
emerging needs   
•  Perceived increased 

administrative/compliance 
costs for stakeholders  

•  The Regulation’s 

requirements and EASA’s 
tasks are not yet fully 
consistent with the SES 
regulatory framework, 
resulting in some 
duplication and 
inconsistencies 
(issue addressed in the 
SES2+ regulatory 
proposal)  

•  There is a risk that 

diverging interpretations 
of EASA’s rules lead to 
incoherencies between 
Member States. 

level playing field for the aviation 
industry. 

•  EASA delivered on its core tasks 
as defined by the Regulation: 

•  Quality of EU standards is 

• 

recognised as very high by EU 
aviation stakeholders  
Important role played by EASA in 
response to external shocks and 
political pressure (Covid 19, 
Russia’s invasion of Ukraine)  

•  EASA’s standardisation of 

regulations across Europe led to 
greater cooperation and 
coordination between NCAs  

•  Effective stakeholder 

consultations within EASA’s 
advisory bodies   

•  EASA was consistently able to 

maintain high budget 
implementation rates  

•  Additional compliance costs are 

considered as proportional to the 
additional benefits  

Efficiency  

+  

Coherence  

++ 

•  Requirements and provisions in 
the Regulation are consistent 
with one another  

•  The Regulation is consistent with 
EU aviation and environmental 
legislation, and international 
transport acquis  

EU added 
value  

+++  

•  The Regulation sets out a single 

regulatory framework for aviation 
safety at EU level, which has been 
identified by most stakeholders as 
essential to achieve an integrated 
European aviation system  

67 

 
  
 
•  EASA’s role is stronger and more 
influential at international level 
than national authorities  

•  The tasks of EASA could not have 
been better performed by other 
actors at regional, national or 
international level  

•  The Regulation and EASA 

activities are aligned with the 
current needs of the aviation 
sector 

•  The Regulation objectives and 

EASA’s tasks are relevant to face 
emerging developments or 
problems in aviation 

Relevance 

++ 

•  Concerns exist regarding 
the Agency's ability to 
handle new tasks without 
negatively impacting its 
primary responsibilities in 
aviation safety 

•  Facing emerging needs 

requires having access to 
the necessary technical 
expertise, train the staff 
and keep being involved in 
the relevant research 
projects and innovation 
programmes. 

68 

 
 
Annex 1. Procedural Information 

•  General information 

-  Lead DG: DG MOVE 
-  Decide reference: PLAN/2022/571 

•  Derogations 
-  No open public consultation (OPC): After careful consideration, the lead DG decided with 
the  Secretariat  General  (A2)  that  no  OPC  is  warranted  for  this  evaluation.  Previous 
experience from a similar exercise (i.e., evaluation of the EU Air Safety List Regulation 
2111/2005) has shown that there is little added value from an OPC when dealing with a 
file of such a technical nature. Instead, extensive targeted consultation activities with the 
stakeholders most affected were undertaken and are explained in Annex IV.  

•  Organisation and timing 

-  General chronology of the evaluation: 

28/03/2022 

14/04-
11/05/2022 

01/07/2022 

23/09/2022 

21/12/2022 

03/03/2023 

19/04/2023 

24/04/2023 

24/05/2023 

1st ISSG meeting (discussion of Call for Evidence & Tender 
specifications for external support study) 

4-week consultation of Call for Evidence on Have your say 

2nd ISSG meeting (Kick-off meeting with the external contractor 
which carried out the support study) 

3rd ISSG meeting (discussion of inception report) 

4th ISSG meeting (discussion of intermediate report) 

5th ISSG meeting (discussion of draft final and stakeholder 
consultation report) 

6th ISSG meeting (discussion of the draft SWD) 

Submission of the SWD to the Regulatory Scrutiny Board 

Regulatory Scrutiny Board meeting 

- 

Inter-Service Steering Group composition:  

o  Secretariat-General,  
o  Legal Service,  
o  Directorate-General for Defence Industry and Space, 
o  Directorate-General for Environment,  
o  Directorate-General for Climate Action. 

- 

In total, 6 ISSG meeting were held throughout the time of the evaluation. 

•  Consultation of the Regulatory Scrutiny Board (RSB) 

The draft evaluation report was discussed by the Regulatory Scrutiny Board on 24 May 2023, which 
issued  a  positive  opinion.  The  Board  also  made  several  main  recommendations  for  improvement 
which were addressed in the final evaluation report as follows: 

69 

 
 
 
 
 
RSB Comment – first opinion 

How the comment has been addressed 

The  report  should  clarify  upfront  that  it  faces 
limitations  and  constraints  due  to  the  ongoing 
implementation  of  the  2018  revision  of  the 
Directive.  

It should better explain both the available evidence 
base  as  well  as  the  challenges  related  to  the 
establishment  thereof.  The  report  should  more 
thoroughly  evaluate  other  available  sources  of 
like  EASA’s  Key  Performance 
evidence, 
Indicators,  and  not  predominantly 
rely  on 
stakeholder views. 

Unexpected events such as COVID-19 pandemic, 
Russian war of aggression against Ukraine or UK’s 
withdrawal from EASA should be analysed more 
the  conclusions  on 
systematically 
whether  the  current  framework  provides  the 
necessary flexibility and resilience. 

to  inform 

The report should identify the challenges related to 
monitoring  and  evaluation  systems.  It  should 
analyse to what extent this system enables to verify 
the achievements of the objectives of the agency. 
The report should draw recommendations how to 
put  in  place  a  monitoring  and  evaluation  system 
that  will  allow  the  existing  data  gaps  to  be 
addressed in the future. 

The conclusions and lessons learned of the report 
should  be  further  substantiated.  The  evaluation 
should  explain  both  the  lack  of  progress  and  be 
more  precise  on  the  lessons  learned  on  a  less 
prescriptive 
and  more  performance  based 
regulatory framework. 

Section 1.2. of the report now provides additional 
clarification on the difficulty to gather quantitative 
data  to  support  the  evaluation.  In  particular,  the 
limited scope of changes to the Regulation made it 
difficult for stakeholders to provide accurate data 
on their compliance costs and the benefits from the 
Regulation compared to the previous one. Section 
1.2. also better explains the efforts that have been 
made  to  gather  as  much  data  as  possible  while 
acknowledging  that  further  data  collection  would 
not change the outcome of the evaluation.  

Section  4.1.1.2.  has  been  revised  to  demonstrate 
EASA’s performance against the expected outputs 
for  rulemaking,  certification  and  standardisation 
activities.  Additional  data  from  the  KPI  reports, 
comparing  the  number  of  delivered  outputs  with 
the  expected  ones  in  the  rulemaking,  product 
certification  and  standardisation  domains,  are 
provided to complement the narrative.  

Section 4.3.2. has been revised to analyse EASA’s 
role during the COVID-19 pandemic as well as the 
Agency’s  reaction  to  the  withdrawal  of  the  UK 
from  the  EU  and  to  Russia’s  war  of  aggression 
against  Ukraine.  Consequently,  section  5.1.1  has 
also been revised to better demonstrate how EASA 
managed to positively react in responses to external 
shocks and political pressure. 

The  revised  report  explains  why  the  original 
monitoring and evaluation system of the 2015 IA 
has to a large extent not been implemented. A new 
section  5.4.  has  been  added  to  include  a  table 
proposing  a  revised  system  for  monitoring  and 
evaluating  the  Agency  in  the  future.  The  table 
contains  a  set  of  indicators  and  measurements  to 
monitor  the  achievement  progress  towards  the 
strategic objectives. 

Section 5.1. has been revised to better substantiate 
the  conclusions.  By  including  more  complete 
information  in  the  conclusions,  this  section  now 
provides  a  comprehensive  description  of  the 
context  and  enhances  the  lessons  learned.  To 
ensure  consistency  throughout  the  document, 
complementary information has also been added to 
explain  the  limited  progress  in  achieving  a  more 
performance-based 
framework 
approach. 

regulatory 

The  report  should  complete  the  analysis  of  the 
necessary resources for EASA allowing it to fulfil 
its missions in the longer term. It should also verify 
the  assessments  of  costs  and  benefits  from  the 

Section  4.1.2.1.  has  been  revised  to  address  this 
comment. It clarifies the challenges related to the 
EASA  financial  constraints  in  terms  of  human 
resources while the Agency is faced with growing 

70 

 
impact assessment against actual outcomes and, if 
no quantification is available, provide indications 
of the direction and order of magnitude of actual 
costs and benefits. 

new tasks and the need for EASA to adapt to these 
challenges. It also further explains the need for a 
more  flexible  establishment  plan  in  the  overall 
discussion about EASA’s budget for 2025-2027.    

A  summary  table  of  effectiveness,  efficiency, 
coherence and EU valued added with clear scoring 
should be provided. 

A  summary  table  of  effectiveness,  efficiency, 
coherence and EU valued added with clear scoring 
is provided in chapter 5.5. 

the  main  reasons  why 

In  relation  to  the  efficiency  criterion,  the  report 
should  explain 
the 
simplification  and  burden  reductions  that  were 
expected in the 2015 impact assessment report did 
not take place. 

Section 4.1.2.2. has been revised to better explain 
why  the  expected  simplification  and  burden 
reduction  did  not  yet  reduce  the  compliance  and 
operational costs for stakeholders, due to the length 
of the rulemaking process and  of the  adoption  of 
industry  standards.  Consequently,  section  5.1.2. 
has been revised to indicate that such simplification 
and burden reduction should have a positive future 
impact on the compliance and operational costs for 
stakeholders. 

•  Evidence used together with sources and any issues regarding its quality 

-  The  evidence  findings  of  an  external  support  study prepared  by  Ramboll 
Management Consulting and TPR fed into the analysis of this evaluation report, 
which complemented the expertise of Commission staff.  

-  Annex  II  provides  an  overview  of  the  methodology  used,  as  well  as  issues 
regarding  the  quality  of  the  evidence  gathered,  through  both  desk  and  field 
research.  

71 

 
 
Annex 2. Methodology and Analytical models used 

Process 

The  starting  point  for  the  evaluation  was  the  Impact  Assessment  accompanying  the 
proposal for a Regulation of the European Parliament and of the Council on common rules in 
the field of civil aviation and establishing a European Union Aviation Safety Agency, and 
repealing  Regulation  (EC)  No  216/2008  of  the  European  Parliament  and  of  the  Council 
SWD/2015/0262 final (64). The IA has notably been used to define the intervention logic, the 
points of comparison, and the overview of costs and benefits. 

Against  that  background,  this  evaluation  was  based  on  a  methodology  consistent  with  the 
Better  Regulation  Guidelines  and  Toolbox,  with  the  support  of  an  external  support  study. 
Further  to  the  Call  for  evidence  (conducted  from  21  April  to  19  May  2022) (65),  the 
Commission launched the process for contracting the external  support study. The terms of 
reference provided a draft intervention logic and draft evaluation questions to address the five 
evaluation criteria: relevance, effectiveness, efficiency, and coherence and European added 
value. 

Methodological framework 

Overview of methodology 

The  external  support  study  further  developed  the  initial  intervention  logic  following 
feedback  received  by  the  Commission  in  the  inception  phase  of  the  study.  The  final 
intervention logic diagram (see section 2.1.3) helps capture the logic of the Directive and the 
causal chain linking objectives, activities, inputs and expected outcomes. It provides the basis 

Source: support study 

(64)  https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=SWD%3A2015%3A0262%3AFIN  

(65)  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13404-EU-Aviation-Safety-

Agency-evaluation_en    

72 

 
 
 
for  the  development  of  the  evaluation  matrix  and  the  specific  criteria,  indicators  and  data 
identified as relevant for each evaluation question.  

An evaluation matrix (see Annex 3) was developed that sets out the following aspects for 
each evaluation question:  

•  Operational  questions,  breaking  down  the  evaluation  questions  into  smaller, 

• 

measurable aspects. 
Indicators,  providing  the  measures/metrics  that  correspond  to  each  operational  sub-
question.  These may be qualitative or quantitative. 

•  Data sources & methods, identifying the sources of data and information used to inform 
the indicators and outlining the methodology used to answer the evaluation questions and 
form the conclusions.  

The  evaluation  matrix  was  reviewed  several  times  during  the  study,  taking  into  account 
Commission  inputs  as  well  as  evidence  collection  activities  (desk  research,  interview 
programme, survey responses and data requests), to reflect the identification and review of 
data sources, as well as updated evidence needs and gaps and the improved understanding of 
the mechanisms and structures leading to better targeted questions: 

Effectiveness (see Table 1 in Annex 3) 

The assessment of effectiveness is largely concerned with the degree to which the Regulation 
and the Agency have achieved (or have made progress towards achieving) their objectives, 
along with a focus on the effects associated with both the Regulation’s implementation and 
the Agency’s work, and on potential obstacles to their implementation.  

•  This assessment was based on the review of a range of documentation, including reports 
and studies commissioned by the EU, international organisations, research institutes or 
stakeholder associations. Moreover, it relied on targeted interviews with stakeholders, as 
well  as  the  targeted  survey  addressed  at  EASA  Members  States  and  industry 
representatives. This combination of desk-based research and stakeholder consultations 
led to the gathering a comprehensive combination of qualitative and quantitative data, 
allowing to capture the extent to which the objectives have been achieved and its effects.  
•  Limited quantitative evidence about the effectiveness of EASA and of the Regulation 
was available, based on  desk research activities and the fieldwork.  In particular, such 
challenges relate to quantitative indicators linked to the performance-based approach of 
the  Regulation.  This  was  mitigated  through  stakeholder  consultations  to  gather 
qualitative evidence to obtain a rough approximation of the indicators considered. 

Efficiency (See Table 2 in Annex 3) 

The assessment of efficiency on the one hand concerned the degree to which the financial and 
human resources allocated to the Agency are adequate to undertake its functions. On the other, 
the efficiency assessment concerned the extent to which the regulatory costs (i.e. compliance 
costs,  enforcement/implementation  costs,  etc.)  of  the  Regulation  are  proportional  with  the 
achieved  benefits.  Lastly,  the  assessment  explored  the  unnecessary  regulatory  burdens  or 
inefficiencies  resulting  from  the  Regulation  and  the  Agency’s  provisions,  with  specific 
attention dedicated to the possibility to achieve the same results at a lower cost. 

•  This  assessment  was  initially  based  on  the  review  of  a  range  of  relevant  documents, 
including  reports  and  studies  commissioned  by  the  EU  and  EASA,  as  well  as  by 
stakeholder  organisations  and  national  authorities.  Stakeholder  consultations 

73 

 
complemented the information gathered through desk research. The survey was also used 
to collect data on the main costs and benefits associated with the implementation of the 
Regulation. Targeted interviews were used to further explore these aspects, while also 
relying on EASA staff specifically to obtain an overview of the resources required for 
the tasks carried out by the Agency, as well as of the cost-efficiency of the Agency’s 
internal organizational structure. 

•  An  attempt  was  made  to  explore  the  magnitude  of  cost  of  industry  stakeholders.  The 
analysis provided offers an indicative example of the administrative costs associated with 
the Regulation  for large  airports  in  the EU. However, it is  important  to  note that this 
example is limited in scope and represents only one sector within the aviation industry. 
The data is derived from a small sample of airports in Belgium and Hungary, which may 
not be fully representative of the entire EU. Moreover, extrapolating the average FTE 
cost across large airports in the EU is based on the assumption that airports with over 
0.4%  of  overall  EU  traffic  can  be  classified  as  large-sized  hubs.  This  estimation 
technique  introduces  additional  uncertainties,  as  different  airports  may  have  different 
levels of regulatory compliance requirements and resource allocation. Therefore, while 
the  analysis  provides  an  indication  of  the  magnitude  of  administrative  costs  for  large 
airports, it should be interpreted with caution. The actual costs across the EU may be 
much higher or lower, and the example presented here should not be generalized to all 
airports or sectors within the aviation industry.  

•  Limited quantitative data was provided through the survey to stakeholders. As such the 
analysis was limited by the degree to  which accurate estimates could  be provided for 
costs.  This  was  mitigated  through  additional  targeted  stakeholder  consultation, 
conducted in order to gather more quantitative data. Only a small sample of data was 
provided,  however  this  data  allowed  for  the  basis  of  quantitative  estimates  where 
possible.  

Relevance (see Table 3 in Annex 3) 

The assessment of relevance involved the analysis of the degree to which the Regulation and 
the Agency’s objectives and functions as they were identified at the time of adoption are still 
adequate in the current context, along with the extent to which they still correspond to the 
current problems and needs of the European civil aviation sector. 

•  This assessment was initially based on the desk-based review of reports and studies, as 
well as of relevant legislative and policy documents. This allowed the study team to gain 
an understanding of problems and needs within the sector and subsequently assess how 
far  the  intervention  in  question  is  placed  to  alleviate/meet  these.  Moreover,  the 
assessment of the relevance criterion relied on targeted stakeholder interviews, as well 
as  the  survey  addressed  at  EASA  Members  States  and  industry  representatives. 
Stakeholder consultations lead to the refinement our understanding of current and future 
problems and needs within the sector, as well as to gauge how far the Regulation and the 
Agency are perceived as still relevant by the main stakeholders. 

•  There  were  limited  sources  of  information  about  the  relevance  of  EASA  and  of  the 
Regulation  from  the  desk  research  activities.  To  mitigate  this,  part  of  the  stakeholder 
consultation, was centered on the analysis of relevance. 

Coherence (see Table 4 in Annex 3) 

The assessment of coherence was twofold. Firstly, it consisted of an assessment of the internal 
coherence  of  the  Regulation’s  requirements  and  provisions.  Secondly,  it  consisted  of  an 
assessment of the degree of coherence of the Regulation and the Agency’s tasks with both 

74 

 
other  EU  regulatory  instruments  and  the  internal  (air)  transport  acquis  and  other  relevant 
international agreements. 

•  A desk-based review was carried out to assess similar interventions in the area. The main 
sources  used  for  this  assessment  were  legislative  and  policy/strategy  documents.  In 
addition, targeted interviews, as well as the survey with stakeholders was used to explore 
both the internal and external coherence of the Regulation and the Agency. Specifically, 
stakeholder consultations  were useful to  gather  more detailed data on exactly how an 
intervention fits into a broader policy framework and social ecosystem. 

•  The stakeholder consultation only provided limited and anectodal qualitative evidence 
about  the  coherence  of  EASA  and  of  the  Regulation  was  available,  based  on  the 
fieldwork activities. This was mitigated through additional desk research and the use of 
Support  Study  team’s  sectoral  expertise,  which  provided  an  analysis  enabling  the 
interpretation of stakeholders’ generic feedback. 

EU added value (see Table 5 in Annex 3) 

The  assessment  of  EU-Added  Value  included  an  analysis  of  the  positive/negative  impacts 
which have been achieved resulting from EU intervention (namely, EU level regulation of the 
civil aviation sector and EASA) and the extent to which this could have been achieved at the 
national level without EU intervention. Particular attention was also placed on assessing what 
the consequences of stopping or withdrawing the existing EU intervention would be.  

•  This assessment was based on the review of a range of documentation, including reports 
and studies commissioned by the EU, international organisations, research institutes or 
stakeholder  associations.  In  addition,  targeted  interviews,  as  well  as  the  survey  with 
Member States and industry stakeholders was used to obtain an estimation of the EU-
added value that different stakeholders associate with the Regulation and the Agency. 
•  The main limitation for this criterion was that Evaluation Question (EQ) 11 (“what is the 
added value resulting from having an EU intervention?”) provided no initial separation 
between  answers  regarding  the  added  value  of  EASA  and  the  added  value  of  the 
Regulation. In order to separate between the views received from the stakeholder, the 
support study added a question as part of the interviews with stakeholders to facilitate a 
clearer separation between views about the added value of EASA and views on the added 
value of the Regulation. 

Evidence collection  

Desk  research  was  used  throughout  the  course  of  the  evaluation  to  address  the  following 
objectives:  

• 

• 

• 

Identify and collect qualitative and quantitative evidence to support the analysis of the 
evaluation questions. 
Identify any information gaps and propose how to manage these gaps through targeted 
consultation activities. 
Identify  and  collect  data  used  as  input  to  the  evidence  analysis,  and  for  the  other 
indicators identified in the evaluation matrix that are used to support the analysis. 

The Support Study (Appendix 12) provides the list of the 178 documentary sources used to 
determine the overall fitness of aviation safety rules in the EU and, more specifically, to assess 
the mandate, the resources and the work of the Agency in relation to its objectives before and 
after  the  entry  into  force  of  Regulation  (EU)  2018/1139.  Sources  were  drawn  from 
Commission  Regulations,  Commission  Delegated  and  Implementing  Acts,  Opinions  and 

75 

 
Decisions  by  EASA,  Reports  adopted  by  EASA  (in  particular  the  Consolidated  Annual 
Activity Reports and the Single Programming Documents), and by other aviation actors such 
as ICAO and Eurocontrol, Member States, industry and from the Material from the meetings 
of the EASA Management Board, as well as from the EASA Member State Advisory Body 
and from the Stakeholder Advisory Body. The temporal scope of sources ranged from 2006 
to 2022.  

The  field  research  has  been  structured  within  the  context  of  a  stakeholder  consultation 
strategy, which relies on a combination of stakeholder engagement tools, including targeted 
surveys and interviews, direct information requests and an analysis of other Commission-led 
consultation  activities  (Open  Public  Consultation  -  OPC).  The  approach  to  the  targeted 
surveys and interviews was refined following the undertaking of exploratory interviews which 
took  place during the inception phase of the  evaluation.  More details  on  the stakeholders’ 
consultation are provided in Annex 5.  

Evaluation points of comparison 
The next step for the analysis was focused on the definition of the points of comparison to 
inform on the expected and actual outcome of the intervention. There were actually 3 sets of 
points of comparison: 

•  The no-policy baseline used in the IA, which represents the case in which Regulation 
(EU) 2018/1139 had not been adopted and Regulation 216/2008, amended by 1108/2009, 
would  still  be  in  place.  This  option  means  that  the  distribution  of  roles  and 
responsibilities  between  EASA  and  the  Competent  Authorities  (CAs)  of  the  EASA 
Members States remains as they were. The same applies to the distribution of roles and 
responsibilities between EASA, ICAO and Eurocontrol; Cooperation mechanisms and 
levels between CAs do not change in comparison to what they were; The system evolves 
based on existing interaction mechanisms between MS and EASA. 

•  The preferred policy option of the IA, which reflects the intervention's expected impact 
based on the IA's preferred policy option, under seven categories of variables (Internal 
market; Resources for EASA; Small and Medium Sized  Enterprises (SMEs) and light 
aviation; Innovation; Aviation safety; Competitiveness of the European aviation sector; 
Creating new jobs) 

•  The observed situation, reflecting the evolution of key indicators under the period 2018-

2022, provided data is available. 

For each point of comparison, a set of indicators was defined and reviewed several times, to 
ensure its relevance and alignment with the objectives of the evaluation. This led to the table 
of points of comparison and indicators presented in section 2.2 of this report. 

Intervention impact analysis 

After  the  definition  of  points  of  comparison  and  indicators,  the  impact  of  the  policy 
intervention (the adoption of Regulation (EU) 2018/1139) was assessed, either qualitatively 
or quantitatively for the indicators for which quantitative variables were available. This was 
the case for EASA cost components, staff and revenues, as well as for accident rate. However, 
for  none  of  this  variable,  the  structural  break  analysis  performed  by  the  support  study 
(explained  in  Appendix  1  and  9)  provide  any  meaningful  conclusion.  This  evaluation  is 
therefore exclusively based on a qualitative assessment of the information gathered. 

76 

 
The  data  collected  was  analysed  with  the  aim  to  respond  to  the  each  of  the  12  evaluation 
questions. As far as data was available, information was triangulated from several sources for 
each indicator aiming to have at least input from two different sources for cross-checking.  

Referenced figures 

Figure 4. Summary of noise indicators (% change to 2005) 

Figure 5. Summary of full-flight emission indicators (% change to 2005) 

Figure 6. Evolution in electric aircraft technology 

77 

 
 
 
 
 
 
Another statistic regarding the innovation  dimension is  the number of official electric and 
hybrid-electric  vertical  take-off  and  landing  (eVTOL)  concepts  in  given  countries.  The 
following graph shows that the United States is leading by a large margin, with the EASA 
Member States, China, and the UK trailing behind. This is highly relevant as EASA added a 
dedicated  set  of  technical  specifications  in  the  form  of  a  Special  Condition  for  VTOL 
aircraft (66). 

Figure 9. Structural break analysis of the accident rate (left: optimal breakpoint in 2016, 
right: breakpoint in 2018) 

This statistical technique is used to determine if there is a significant change in the underlying 
structure of a time series data at a specific point in time. Such breaks during the evaluation 
period might suggest that the Regulation has had a significant impact. 

Source: Own composition based on Eurostat, 2022 

(66) https://www.easa.europa.eu/en/downloads/137443/en 

78 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Disclamer:  given  the  complexity  of  the  different  factors  and  variables  that  directly  or 
indirectly  impact  on  these  figures,  it  is  not  possible  to  establish  a  direct  link  between  the 
impact of the (changes that were brought by the) Regulation and such results. 

Figure 16. Structural break analysis of the total staff at EASA (breakpoints in 2010 and 
2014) 

Source: Composition of the contractor based on EASA annual activity reports 

The  number  of  temporary  agents  increased  significantly  until  2007,  followed  by  a  more 
moderate increase until 2015. After 2015, the number of temporary agents at EASA decreased 
slowly. The number of contract agents at EASA grew from 2005 until 2015, after which a 
structural  break  emerged.  In  2016,  the  number  of  contract  agents  dropped,  and  growth 
continued slower than before. The number of seconded national experts had a strong growth 
between  2008  and  2012,  followed  by  a  stable  situation  between  2013-2015.  A  significant 
jump  in  the  number  of  seconded  national  experts  was  discovered  in  2016,  followed  by  a 
significant gradual decrease. No impact of the Regulation was found.   

Figure 17. EASA revenues by source 

79 

 
 
s
o
r
u
e
f
o
s
d
n
a
s
u
o
h
t
n

i

e
u
n
e
v
e
R

160000

140000

120000

100000

80000

60000

40000

20000

0

2014

2015

2016

2017

2018

2019

2020

2021

Fees and charges

European Subsidy

Third countries contributions

Delegation agreements & grants Other contributions

Source: Composition of the contractor based on EASA’s Annual Reports, 2015-2021 

Figure 18. Structural break analysis of contributions from third countries (breakpoint 
in 2018) 

Source: Composition of the contractor based on EASA’s Annual Reports, 2015-2021 

80 

 
 
 
 
 
 
 
 
Annex 3. Evaluation matrix (by criterion) 

Table 1 - Evaluation Questions Matrix (EQM) – Effectiveness 

How successful have Regulation (EU) 2018/1139 and the European Air Safety Agency been in reaching their objectives? 

Evaluation questions 

Operational questions 

Indicators 

Data sources & methods 

1.  EQ  1:  To  what  extent  has  the  Agency 

achieved 

its  objectives  and 

tasks 

supporting 

the  Commission  as  a 

rulemaking  body?  To  what  extent  has 

•  1.1:  To  what  extent  has  the  Rulemaking 
Procedure  been  effective  in  framing  the 
issuing 
certification 
opinions, 
specifications,  means  of  compliance  and 
guidance material by the Agency? 

of 

EASA delivered its opinions in time? Is 

the  stakeholder  consultation  procedure 

efficient  and  effective?  As  part  of  the 

Agency’s  role,  how  effective  is  the 

monitoring  by  the  Agency  of  national 

aviation authorities? 

•  1.2:  To  what  extent  has  the  Rulemaking 
Programme been followed and implemented 
timely and effectively? 

Qualitative indicators:  

•  Stakeholder views on the degree to 

which the Rulemaking Procedure has 
contributed to a swift delivery of 
opinions, certification specifications, 
means of compliance and guidance 
material 

•  Qualitative assessment from EASA 
staff on the extent to which the 
Rulemaking Procedure has been 
working effectively 
Quantitative indicators: 

•  Average time required to prepare and 

deliver opinions, certification 
specifications, means of compliance 
and guidance material 

•  Number of opinions planned vs actuals 
•  Number of Decisions planned vs 

actuals 

•  Number of notices of proposed 
amendment planned vs actuals 

Qualitative indicators: 

•  Desk research 
•  Analysis of relevant documentation 

(e.g. EPAS, CAARs) 

•  Targeted interviews with stakeholders 

(in particular, Commission 
representatives, EASA staff) 

•  Desk research 
•  Analysis of relevant documentation, 
(e.g. EPAS, monitoring reports, 
CAARs) 

•  Analysis of statistical and quantitative 

data 

•  Targeted interviews with stakeholders 

(in particular, Commission 
representatives, EASA staff) 

81 

 
 
 
•  1.3:  To  what  extent  is  the  stakeholder 
consultation  procedure  within  EASA’s 
advisory  bodies  effective  in  ensuring  an 
adequate  and  balanced  contribution  by 
Member States and the Industry? 

to  Member 

•  1.4:  In  what  ways  has  the  Agency  been 
implementing  its  monitoring  activities  with 
respect 
national 
authorities? To what extent has national level 
implementation  of  the  Regulation  improved 
as  a  result  of  the  Agency’s  monitoring 
activities? 

States 

•  Comparison between the foreseen 

Rulemaking Programme and the 
documents delivered 

Quantitative indicators: 

•  Total number of yearly stakeholder 

consultations 

•  Average duration of and number of 

participants in stakeholder consultations 

Qualitative indicators: 

•  Stakeholders’ views on the degree to 
which their input was taken into 
consideration 

•  Stakeholders’ views on the 

effectiveness and efficiency of the 
stakeholder consultation procedure  
•  Qualitative assessment from EASA 
staff on the extent to which the 
stakeholder consultation procedure has 
been working effectively and efficiently 

Quantitative indicators: 

•  Total number of yearly inspections  
•  Average duration of and resource use 
for inspections and continuous 
monitoring activities 

•  Rate of improvement in MS’ level of 
implementation on the basis of 
monitoring procedures’ results 

•  Change in the total number of findings 
raised against Regulations that have 
been applicable for more than 2 years 
•  Percentage of standardisation reports 
issued after the standardisation visit 

•  Desk research 
•  Analysis of relevant documentation 

(e.g., stakeholder consultation reports, 
minutes) 

•  Analysis of statistical and quantitative 

data 

•  Targeted interviews with all 

stakeholders  

•  Targeted survey questionnaire (with 

MS and Industry) 

•  Desk research 
•  Evaluation criterion assessment 
•  Analysis of relevant documentation 

(e.g. monitoring reports, CAARs) 
•  Analysis of statistical and quantitative 

data 

•  Targeted interviews with stakeholders 
(in particular, EASA staff, MS) 
•  Targeted survey questionnaire (with 

MS) 

82 

 
EQ  2:  To  what  extent  has  the  Agency 

achieved 

its  objectives  and 

tasks  as  a 

certifying  body  and 

in  achieving 

the 

objectives  at  both  European  and  worldwide 

levels as established by Article 1 of the Basic 

Regulation? 

•  2.1: To what extent has the Agency been 
effective in certifying 1) aircrafts; 2) 
organisations; 3) engines; 4) propellers; 5) 
specific parts to be installed on aircrafts; 6) 
specific non-installed equipment? 

•  Desk research 
•  Evaluation criterion assessment 
•  Analysis of relevant documentation 
(e.g. certification reports, CAARs) 
•  Analysis of statistical and quantitative 

data 

•  Targeted interviews with all 

stakeholders 

•  Targeted survey questionnaire (with 

MS and Industry) 

Qualitative indicators: 

•  Stakeholders’ views on the extent to 

which monitoring procedures have 
contributed to achieving a certain level 
of implementation 

Quantitative indicators: 

•  Number of yearly certifications and 
final reports issued per product 
category (1) aircrafts; 2) organisations; 
3) engines; 4) propellers; 5) specific 
parts to be installed on aircrafts; 6) 
specific non-installed equipment) 
•  Hours spent per main project category 

as a percentage of the planned hours 
•  Number of applications received and 

number of certificates issued in the area 
of initial airworthiness of type design 

•  Percentage of stakeholders who 
agree/disagree that the Agency’s 
certification role has contributed to 
increasing products’ airworthiness and 
consequently safety of the European 
aviation system 
Qualitative indicators: 

•  Evidence from secondary sources that 
the certification role of the Agency has 
contributed to improving products’ 
airworthiness 

•  Stakeholders’ views on the extent to 
which the Agency’s certification 
procedures are effective and have 
contributed to increasing the safety of 
the European aviation system 

83 

 
•  2.2: Are there any noticeable differences in 
certification procedures across products 
and/or countries? 

•  2.3: What obstacles were observed in 

carrying out the certification procedures? 

•  3.1: What positive and negative effects can 

be associated with the Regulation? 

•  Desk research 
•  Analysis of relevant documentation 
(e.g. CAARs, certification reports)  
•  Analysis of statistical and quantitative 

data 

•  Targeted interviews with stakeholders 
(in particular, EASA staff, MS, 
Industry) 

•  Targeted survey questionnaire (with 

MS and Industry) 

•  Desk research 
•  Analysis of relevant documentation 

(e.g. certification reports) 

•  Targeted interviews with stakeholders 
(in particular, EASA staff, MS, 
Industry) 

•  Targeted survey questionnaire (with 

MS and Industry) 

•  Desk research 
•  Evaluation criterion assessment 
•  Analysis of statistical and quantitative 

data 

•  Targeted interviews with all 

stakeholders 

•  Targeted survey questionnaire (with 

MS and Industry) 

Quantitative indicators: 

•  Comparison of the hours spent per main 

project category as a percentage of the 
planned hours in different countries 

Qualitative indicators: 

•  Evidence from final certification 
reports and other related relevant 
documentation regarding the details of 
the procedure 

•  Stakeholders’ views and explanation of 

the certification procedure 
•  Evidence from previous EQ  
Qualitative indicators: 

•  Stakeholders’ views on the main 

obstacles faced during certification 
procedures 

Quantitative indicators: 

•  Number of accidents and incidents 
•  Number of occurrence reports received 
and closed and number of airworthiness 
directives (ADs) published regarding 
continued airworthiness of type design 

Qualitative indicators: 

•  Stakeholders’ views and evidence from 
desk research on the degree to which 
the provisions of the Regulation 
achieved actual positive/ negative 
observed effects 

84 

EQ 3: What actual observed effects (positive 

and  negative  impacts)  has  the  Regulation 

had? To what extent has the Regulation and 

the work of the Agency contributed to these 

effects?  What  were  the  main  drivers  and 

hindrances 

to 

the  effectiveness  of 

the 

Regulation? 

 
 
•  3.2: To what extent can these effects be 
attributed, directly or indirectly, to the 
Agency’s work?  

•  3.3: What were the main underlying drivers 

to the effective implementation of the 
Regulation? 

•  3.4: What impacts has the Regulation had on 
its main stakeholders (i.e. Member States, 
Industry)? 

•  Evidence from desk research on the 

degree to which the provisions of the 
Regulation achieved actual positive/ 
negative observed effects 

•  Degree to which the positive/negative 

effects identified differ according to the 
stakeholder type 
Qualitative indicators: 

•  Stakeholders’ views on the degree to 
which the effects associated with the 
Regulation can be attributed to the 
Agency’s work 

•  EASA staff and Commission’s 

qualitative assessment of the degree to 
which the effects associated with the 
Regulation can be attributed to the 
Agency’s work 

•  Assessment of relevant KPIs 
Qualitative indicators: 

•  Stakeholders’ views on the main drivers 

behind the implementation of the 
Regulation 

•  EASA staff and Commission’s 

qualitative assessment on the main 
drivers behind the implementation of 
the Regulation 
Qualitative indicators: 

•  Stakeholders’ views on the main 

impacts derived from the Regulation 
•  Evidence from secondary sources on 
the main impacts derived from the 
Regulation 

85 

•  Targeted interviews with all 

stakeholders  

•  Targeted survey questionnaire (with 

MS and Industry) 

•  Desk research 
•  Evaluation criterion assessment 
•  Analysis of relevant documentation 

(e.g. CAARs) 

•  Targeted interviews with all 

stakeholders 

•  Targeted survey questionnaire (with 

MS and Industry) 

•  Desk research 
•  Evaluation criterion assessment 
•  Analysis of relevant documentation 
(e.g. MAB/SAB meeting minutes) 

•  Targeted interviews with all 

stakeholders 

•  Targeted survey questionnaire (with 

MS and Industry) 

 
•  3.5: What were the main hindrances to the 

effective implementation of the Regulation? 

EQ 4:  To what extent does the work of the 

Agency cover all the real needs of aviation in 

Europe, also considering the huge impact of 

the COVID-19 pandemic in the European and 

worldwide aviation safety system? 

•  4.1: What are the primary current and 

upcoming needs within the aviation sector in 
Europe? 

•  4.2: To what extent are such needs 

adequately covered by the Regulation and by 
the activities of the Agency? 

•  Stakeholders’ views on the degree to 
which the impacts of the Regulation 
were positive/negative 

Qualitative indicators: 

•  Evidence from secondary sources on 
the main obstacles within the civil 
aviation sector 

•  Evidence from secondary sources on 

the main obstacles having hindered the 
implementation of the Regulation 
•  Stakeholders’ views on the extent to 
which each obstacle hindered the 
implementation of the Regulation 

Qualitative indicators: 

•  Stakeholders’ views on the main 

current challenges and needs within the 
aviation sector in Europe  

•  Evidence from secondary sources on 

the main current challenges and needs 
within the aviation sector in Europe  
•  Stakeholders’ views on the degree to 
which each of these challenges/needs 
affects the sector 
Quantitative indicators: 

•  Percentage of stakeholders agreeing 
that the Regulation and the Agency 
adequately address current needs and 
challenges within the aviation sector in 
Europe 

Qualitative indicators: 

•  Stakeholders’ views on the extent to 

which the Regulation and the Agency’s 
activities adequately cover current 

•  Desk research 
•  Analysis of relevant documentation 

(e.g. CAARs) 

•  Targeted interviews with all 

stakeholders 

•  Targeted survey questionnaire (with 

MS and Industry) 

•  Desk research 
•  Analysis of relevant documentation 

(e.g. SPDs, EPAS) 

•  Targeted interviews with all 

stakeholders 

•  Targeted survey questionnaire (with 

MS and Industry) 

•  Targeted interviews with all 

stakeholders 

•  Targeted survey questionnaire (with 

MS and Industry) 

86 

 
•  4.3: To what extent has the Agency been 
able to effectively undertake its activities 
during and in the aftermath of the Covid-19 
pandemic? 

•  4.5: To what extent is the Agency able to 

effectively undertake its activities, 
considering the ongoing crisis in Ukraine? 

needs and challenges within the 
European aviation sector  

Quantitative indicators: 

•  Percentage of stakeholders agreeing 

that the Agency was able to adequately 
undertake its activities during and in the 
aftermath of the Covid-19 pandemic 

Qualitative indicators: 

•  Stakeholders’ views on the extent to 
which the Agency was able to 
adequately undertake its activities 
during and in the aftermath of the 
Covid-19 pandemic 

•  Desk research 
•  Analysis of relevant documentation 

(e.g. EASA survey to MS and Industry 
on the new or emerging aviation safety 
issues arising as a result of the 
pandemic, COVID-19 Safety Risk 
Portfolio) 

•  Targeted interviews with all 

stakeholders 

•  Targeted survey questionnaire (with 

MS and Industry) 

Quantitative indicators: 

•  Percentage of stakeholders agreeing 
that the Agency is able to effectively 
undertake its activities, considering the 
ongoing crisis in Ukraine 

Qualitative indicators: 

•  Desk research 
•  Analysis of relevant documentation 

(e.g. EASA Review of Aviation Safety 
Issues Arising from the war in Ukraine) 

•  Targeted interviews with all 

stakeholders 

•  Targeted survey questionnaire (with 

•  Stakeholders’ views on the extent to 

MS and Industry) 

which the Agency is able to effectively 
undertake its activities, considering the 
ongoing crisis in Ukraine 

Source: Support Study 

87 

 
 
 
 
 
Table 2 - Evaluation Questions Matrix (EQM) - Efficiency 

What is the relationship between the resources and the impacts (positive and/or negative) generated by the Agency? How cost effective has the Agency’s work been? 

Evaluation questions 

Operational questions 

Indicators 

Data sources & methods 

EQ5:  Were 

the  additional  human  and 

financial  resources  allocated  to  the  Agency 

•  5.1: What are the main costs (in terms of 

human and financial resources) associated 
with the Agency’s activities? 

sufficient  and  adequate  to  achieve  its  new 

tasks? 

Which 

aspects/means/actors/stakeholders 

or 

processes  render  the  Agency  more  or  less 

efficient? 

•  5.2: Which 

aspects/means/actors/stakeholders or 
processes are most costly for the Agency to 
address/undertake? 

•  5.3: Has the Agency managed to stay within 

its budget during the past years? 

•  5.4: Were any tasks that could be taken up 

not taken up in practice because of 
budgetary issues? 

Quantitative indicators: 

•  Cost overviews from EASA budgets 
Qualitative indicators: 

• 

Insights from EASA staff on available 
resources 

•  Evidence on available resources based 

on relevant documentation  

Quantitative indicators: 

•  Comparison of the costs related to 

different activities undertaken by the 
Agency 

Qualitative indicators: 

•  Evidence from relevant documentation 

on the resources required by different 
aspects/means/actors/stakeholders or 
processes  

•  EASA staff overview of the resources 
needed for different types of activities 

Quantitative indicators: 

•  Analysis of the evolution of the 
Agency’s expenses over time 

•  Comparison of the Agency’s expenses 

with the yearly budget 

Qualitative indicators: 

•  Comparison of initially planned 

activities with activities undertaken in 
practice  

88 

•  Desk research 
•  Analysis of relevant documentation 

(e.g., EASA annual budget, SPDs, 
CAARs) 

•  Targeted interviews with stakeholders 

(in particular, EASA staff, European 
Commission) 

•  Desk research 
•  Analysis of relevant documentation 
(e.g. EASA budget, SPDs, CAARs) 

•  Analysis of quantitative data 
•  Targeted interviews with stakeholders 

(in particular, EASA staff) 

•  Desk research 
•  Analysis of relevant documentation 

(e.g. EASA annual budget, SPDs, 
CAARs) 

•  Analysis of quantitative data 

•  Desk research 
•  Analysis of relevant documentation 

(e.g. EASA annual budget, SPDs, 
CAARs) 

 
•  5.5: To what extent has the organisation and 
management  of  the  Agency  been  cost-
efficient? 

•  6.1:  What  are  the  main  costs  and  benefits 
the 

associated 
compliance/implementation/administration 
of the Regulation? 

with 

•  6.2: Are implementation costs proportionate 
to  the  benefits  brought  to  the  Agency’s 
stakeholders? 

EQ 6: To what extent are the regulatory costs 

(i.e. 

compliance 

costs, 

enforcement/implementation 

costs 

and 

administrative  costs)  of 

the  Regulation 

proportional  with  the  achieved  benefits? 

Could the same results have been achieved at 

a  lower  cost?  Could  the  use  of  other  policy 

instruments or mechanisms have provided for 

better efficiency? 

• 

Insights from EASA staff on 
undertaken activities as opposed to 
foreseen activities 

Qualitative indicators:   

•  Degree to which the administrative and 

management structures of the Agency 
been cost-efficient 

•  EASA staff qualitative assessment of 
the degree to which the administrative 
and management structures of the 
Agency have been efficient 

Quantitative indicators: 

•  Costs data from stakeholders on the 

compliance/implementation/administrat
ion of the Regulation 

Qualitative indicators: 

•  Stakeholders’ views on the main costs 

and benefits associated with 
compliance/implementation/administrat
ion of the Regulation 
Quantitative indicators: 

•  Estimations of the costs associated with 

identified benefits 

•  Comparison between the positive 

benefits and the direct costs from the 
different activities for different 
stakeholders 

•  Percentage of stakeholders who 

agree/disagree that the positive benefits 
outweigh the direct costs 

Qualitative indicators: 

•  Targeted interviews with stakeholders 

(in particular, EASA staff) 

•  Targeted interviews with stakeholders 

(in particular, EASA staff) 

•  Efficiency assessment 

•  Desk research 
•  Analysis of quantitative data 
•  Targeted interviews with stakeholders 
(in particular, MS and Industry) 

•  Targeted survey (with MS and 

Industry) 

•  Desk research 
•  Analysis of quantitative data 
•  Targeted interviews with stakeholders 
(in particular, EASA staff, MS and 
Industry) 

•  Targeted survey (with MS and 

Industry) 

89 

 
 
•  6.3:  What  efficiency  gains  could  potentially 

still be made? 

•  6.4:  Are 

any 

there 

other 

policy 
instruments/mechanisms  or 
sources  of 
funding  that  could  be  used  to  achieve  the 
same  objectives?  Are  these  more  cost-
efficient? 

•  Stakeholders’ qualitative assessment of 

the degree to which the positive 
benefits outweigh the 
direct/enforcement costs  

•  Stakeholders’ qualitative assessment of 
the degree to which the costs are 
reasonable 

Qualitative indicators: 

•  Stakeholders’ views on potential 

additional areas for improvement and 
increased efficiency gains 

•  EASA staff qualitative assessment of 
areas where efficiency could be 
improved 

Qualitative indicators: 

•  Evidence from secondary sources and 
relevant stakeholders on other policy 
instruments/mechanisms or sources of 
funding available in the aviation sector 
•  Qualitative assessment of the potential 
use of other instruments to achieve the 
same objectives in a more cost-efficient 
way 

•  Targeted interviews with stakeholders 
(in particular, EASA staff, MS and 
Industry) 

•  Desk research 
•  Analysis of relevant documentation 
•  Targeted interviews with all 

stakeholders 

Source: Support Study 

90 

 
 
 
 
Table 3 - Evaluation Questions Matrix (EQM) – Relevance 

To what extent are the Regulation’s objectives and the Agency’s tasks still aligned with the current and emerging needs or problems in the aviation sector?  

To what extent do the original objectives and activities of the Agency correspond to the current and future needs of the aviation sector in the European Union? 

Evaluation questions 

Operational questions 

Indicators 

Data sources & methods 

EQ 7: To what extent are the objectives and 

scope  which  were  identified  at  the  time  of 

adoption  of  the  Regulation  still  adequate  in 

the  current  context,  and  how  do  they  still 

correspond to the problems and needs of the 

aviation  safety  system  that  is  currently  in 

place? 

•  7.1: What are the current problems and 

needs within the aviation safety system (i.e. 
both for Member States and industry)? 

•  7.2: To what extent are the objectives of the 
regulation relevant to the current problems 
and needs of the aviation system in place? 

EQ  8:  Which  issues  that  arose  after  the 

adoption  of  the  Regulation  require  further 

attention in view of the objectives pursued? 

•  8.1: Are there any newly emerged or 

increasingly important needs which are 
currently not (adequately) covered by the 
Regulation? 

Qualitative indicators: 

•  Stakeholders’ views on the current 

needs and problems within the aviation 
safety system, per stakeholder type 

•  Evidence from secondary sources on 

the current needs and problems within 
the aviation safety system 

Quantitative indicators:  

•  Percentage of stakeholders who 

agree/disagree that the objectives of the 
Regulation remain relevant 

Qualitative indicators: 

•  Stakeholders’ qualitative assessment of 
the degree to which the objectives of 
the Regulation remain relevant 

•  Qualitative assessment based on 
previous relevance questions 

Qualitative indicators: 

•  Stakeholders’ views on the extent to 
which the problems and needs 
originally addressed by the Regulation 
evolved 

•  Evidence from secondary sources on 
newly emerged needs and problems 
within the aviation safety system 

•  Desk research 
•  Analysis of relevant documentation 
•  Targeted interviews with all 

stakeholders 

•  Targeted surveys (with MS and 

Industry) 

•  Desk research 
•  Evaluation criterion assessment 
•  Analysis of relevant documentation 
•  Analysis of statistical and quantitative 

data 

•  Targeted interviews with all 

stakeholders 

•  Targeted survey questionnaire (with 

MS and Industry) 

•  Desk research 
•  Evaluation criterion assessment  
•  Analysis of relevant documentation 
•  Targeted interviews with all 

stakeholders 

•  Targeted survey 2 (with MS and 

Industry) 

91 

 
 
•  Stakeholders’ qualitative assessment of 
the extent to which newly emerged 
needs are adequately covered by the 
Regulation 

Source: Support Study 

92 

 
 
 
 
Table 4 - Evaluation Questions Matrix (EQM) – Coherence 

To what extent has the Agency’s intervention been internally and externally coherent (with other EU interventions or international agreements)? 

Evaluation questions 

Operational questions 

Indicators 

Data sources & methods 

EQ  9:  Are  the  requirements  and  provisions 

set  out  in  the  Regulation  coherent  and 

•  9.1: To what extent are there inconsistencies 
among the requirements and provisions of 
the Regulation? 

consistent  with  one  another? If  not  entirely, 

what  are 

the  differences,  overlaps  or 

inconsistencies? 

•  9.2: To what extent are there synergies 

among the requirements and provisions of 
the Regulation? 

•  Desk research 
•  Evaluation criterion assessment 
•  Analysis of relevant documentation 

(e.g. Regulation 2018/1139) 

•  Analysis of statistical and quantitative 

data 

•  Targeted interviews with all 

stakeholders 

•  Desk research 
•  Evaluation criterion assessment 
•  Analysis of relevant documentation 

(e.g. Regulation 2018/1139) 

•  Analysis of statistical and quantitative 

data 

•  Targeted interviews with all 

stakeholders 

Quantitative indicators: 

•  Percentage of stakeholders who 
agree/disagree that there are 
inconsistencies among the requirements 
and provisions of the Regulation 
•  Number of inconsistencies from desk 

• 

research (our own analysis) 
 Number of inconsistences from 
literature review 
Qualitative indicators: 

•  Stakeholders’ views on the degree to 
which inconsistencies (i.e. overlaps, 
contradictions, gaps) exist among the 
requirements and provisions of the 
Regulation  

Quantitative indicators: 

•  Percentage of stakeholders who 

agree/disagree that there are synergies 
between among the requirements and 
provisions of the Regulation 
•  Number of synergies from desk 
research (our own analysis) 

•  Number of synergies from literature 

review 

Qualitative indicators: 

93 

 
 
•  9.3: Are there any synergies which could be 

further exploited between the different 
provisions? 

•  9.4: Are there any real overlaps? 

•  Desk research 
•  Evaluation criterion assessment 
•  Targeted interviews with all 

stakeholders 

•  Desk research 
•  Evaluation criterion assessment 
•  Targeted interviews with all 

stakeholders 

•  Stakeholders’ views on the degree to 
which inconsistencies (i.e. overlaps, 
contradictions, gaps) exist among the 
requirements and provisions of the 
Regulation 

Quantitative indicators: 

•  Number of synergies from desk 
research (our own analysis) 

•  Number of synergies from literature 

review 

Qualitative indicators: 

•  Stakeholders’ views on the extent to 
which certain synergies might be 
further exploited 

•  Qualitative assessment of the extent to 

which certain synergies could be further 
exploited (based on previous EQs) 

Quantitative indicators: 

•  Number of overlaps from desk research 

(our own analysis) 

•  Number of overlaps from literature 

review 

Qualitative indicators: 

•  Stakeholders’ views on the degree to 
which overlaps exist across the 
Regulation’s requirements and 
provisions 

•  Qualitative assessment of the extent to 

which overlaps exist across the 
Regulation’s requirements and 
provisions 

94 

 
EQ 10: To what extent are the Regulation and 

the  Agency’s  tasks  coherent  and  consistent 

with  other  EU  regulatory  instruments  under 

the  air  internal  transport  acquis  and  with 

international  agreements?  If  not  entirely, 

what  would  be  the  differences,  overlaps  or 

contradictions or inconsistencies? 

•  10.1: Are there any potential synergies or 

Quantitative indicators: 

overlaps between the Regulation and other 
regulatory instruments in the framework of 
the European transport acquis (e.g. delegated 
acts and implementing acts, for instance, 
related to the ICAO standards)? 

•  Number of synergies or overlaps from 
desk research (our own analysis) 
•  Number of synergies or overlaps from 

literature review 
Qualitative indicators: 

•  10.2: Are there any potential synergies or 

overlaps between the Regulation and other 
international regulatory instruments? 

•  10.3: Are there any potential synergies or 
overlaps between the Agency’s tasks and 
other regulatory instruments in the 
framework of the European transport 
acquis? 

•  Degree to which there are synergies or 
overlaps between the objectives and 
actions of the Regulation and other 
regulatory instruments in the 
framework of the European transport 
acquis 

• 
Quantitative indicators: 

•  Number of synergies or overlaps from 
desk research (our own analysis) 
•  Number of synergies or overlaps from 

literature review 
Qualitative indicators: 

•  Degree to which there are synergies or 
overlaps between the objectives and 
actions of the Regulation and other 
international regulatory instruments in 
the framework 
Quantitative indicators: 

•  Number of synergies or overlaps from 
desk research (our own analysis) 
 Number of synergies or overlaps from 
literature review 
Qualitative indicators: 

• 

•  Degree to which there are synergies or 

overlaps between the Agency’s tasks 

95 

•  Desk research 
•  Evaluation criterion assessment 
•  Analysis of relevant documentation 
•  Targeted interviews with stakeholders 

•  Desk research 
•  Evaluation criterion assessment 
•  Analysis of relevant documentation 
•  Targeted interviews with stakeholders 

•  Desk research 
•  Evaluation criterion assessment 
•  Analysis of relevant documentation 
•  Targeted interviews with stakeholders 

 
 
•  10.4: Are there any potential synergies or 
overlaps between the Agency’s tasks and 
other international regulatory instruments? 

and other regulatory instruments in the 
framework of the European transport 
acquis 

Quantitative indicators: 

•  Number of synergies or overlaps from 
desk research (our own analysis) 
 Number of synergies or overlaps from 
literature review 
Qualitative indicators: 

• 

•  Degree to which there are synergies or 

overlaps between the Agency’s tasks 
and other international regulatory 
instruments in the framework 

•  Desk research 
•  Evaluation criterion assessment 
•  Analysis of relevant documentation 
•  Targeted interviews with stakeholders 

Source: Support Study 

96 

 
 
Table 5 - Evaluation Questions Matrix (EQM) – EU Added Value 

To what extent have the Regulation and the Agency allowed to produce results that would not have been achieved by Members States acting alone? 

Evaluation questions 

Operational questions 

Indicators 

Data sources & methods 

•  11.1: To what extent could the Regulation’s 

effects have been achieved without EU 
intervention? 

EQ  11:  What  is  the  added  value  resulting 

from EU intervention in regulating each one 

of the several aviation safety domains under 

EU/EASA  competence?  Could  the  same 

results be  achieved at international, national 

or regional level without EU intervention? 

•  11.2: Could the activities carried out by 

EASA have been achieved by each Member 
State acting alone? If yes, are there any 
efficiency/effectiveness gains by doing so at 
EU level? 

•  11.3: To what extent is EU level 

coordination needed in each of the areas 
covered by the Regulation? 

•  Desk research 
o  Evaluation criterion assessment 
•  Targeted interviews  
•  Targeted survey questionnaire (with 

Member States and Industry) 

•  Efficiency assessment 
•  Task 5 outcomes 

•  Targeted interviews 
•  Targeted  survey  questionnaire  (with 

Member States) 
•  Efficiency assessment 
•  Task 5 outcomes 

•  Targeted interviews 
•  Targeted  survey  questionnaire  (with 

Member States and Industry) 

•  Task 5 outcomes 

Quantitative indicators: 

•  Percentage of stakeholders (per group) 

that agree that the same results could 
have been achieved at without EU 
intervention 

Qualitative indicators: 

•  Degree to which there is evidence that 
the same results could be achieved 
without EU intervention, based on 
secondary sources 

•  Stakeholders’ views on the degree to 
which there is evidence that the same 
results be achieved without EU 
intervention 
Qualitative indicators: 

•  Member  States’  view  on  their  capacity 
and resources to carry out the activities 
currently undertaken by EASA 

Qualitative indicators: 

•  Degree  to  which  there  is  evidence  that 
EU  level  coordination  is  needed  to 
achieve  European  targets  in  the  areas 
covered by the Regulation 

97 

 
 
EQ 12: What would be the consequences of 

stopping  or  withdrawing  the  existing  EU 

•  12.1: What would be the consequences of 
stopping or withdrawing the existing EU 
intervention? 

intervention? 

Qualitative indicators: 

•  Stakeholders’ views on what the 
consequence of stopping or 
withdrawing the existing EU 
intervention would be 

•  Targeted interviews 
•  Targeted survey questionnaire (with 

Member States and Industry) 

•  Task 5 outcomes 

•  12.2: In what ways would the services 

provided by the Agency be carried out by 
other actors (e.g. Member States, other EU 
and/or international bodies, etc.)? 

Qualitative indicators: 
•  Degree to which other actors would be 
able  to  provide  the  services  currently 
undertaken by the Agency 

•  Targeted interviews 
•  Targeted survey questionnaire (with 

Member States and Industry) 

•  Task 5 outcomes 

Source: Support Study 

98 

 
 
 
 
 
 
Annex 4. Overview of benefits and costs 

This annex includes a table (based on the Better Regulation Toolbox) providing the overview of costs and benefits identified in the evaluation. This is based on the IA 
and  contains  the  categories  of  costs/benefits  identified  in  the  latter  with  the  information  gathered  on  the  actual  costs/benefits.  However,  as  mentioned  above,  the 
quantitative translation of costs and benefits in time taken, person days, number of records/equipment/staff etc. and their further monetisation is not (yet) available, with 
the exception of some scattered information from stakeholder interview, which is reported in the table.  

A table on “Simplification and burden reduction (savings already achieved)” is not included, because no simplification, burden reduction or cost savings have been 
identified as achieved already by the intervention evaluated. 

More details are provided in Appendix 6 of the support study. 

Table 6 - Overview of costs and benefits identified in the evaluation 

Citizens/Consumers  

Businesses (aviation industry) 

EASA 

National Administrations 

Quantitative  

Comment 

Quantitative  

Comment 

Quantitative 

Comment  

Quantitative 

Comment 

[Cost or Benefit description]: 

Direct compliance costs (adjustment costs, administrative costs, regulatory charges) 

Administrative 
certification 
assessment 

Cost: 

based 

Product 
risk 

on 

Recurrent 

n/a 

This  cost 
is  not 
relevant  to  this 
stakeholder 

Impact on airports 
would 
range 
between  100  and 
2000  FTE,  and  on 
airlines,  between, 
30 and 600 FTE. 

Based 
on 
extrapolation  from  
5  airports  and  2 
airlines (67)  

No  substantial 
change 
detected. 

Administrative  Cost:  Develop  a 
policy 
performance-based 
on 
regulations 

Recurrent 

n/a 

This  cost 
is  not 
relevant  to  this 
stakeholder 

n/a 

This  cost 
relevant 
to 
stakeholder 

is  not 
this 

n/a 

This  cost  is  not 
relevant  to  this 
stakeholder 

Quantitative 
estimates  are 
not available 

No  information 
reported 
by 
National 
Administrations 

For  all  EASA 
members: 
between 
27 
and  30  M€, 
corresponding 

on 

Based 
extrapolation 
from  only  2  MS 
(BE and ES) 

(67)  Scattered evidence gathered indicates that compliance costs may have increased due to the introduction of Regulation 2018/1139, while the IA had foreseen no substantial increases 

in costs for businesses. 

99 

 
 
 
                        
 
Administrative  Cost:  Emergency 
oversight support mechanism 

one-
and 

Both 
off 
recurrent 

n/a 

This  cost 
is  not 
relevant  to  this 
stakeholder 

n/a 

qualitative 
in 

See 
explanation 
footnote (68) 

n/a 

Adjustment  Cost:  involvement  of 
EASA  in  the  work  on  aviation 
security 

Recurrent 

n/a 

Not  relevant  for 
citizen/consumers 

are 

There 
no 
quantitative  data 
to  make 
an 
assessment  of  the 
IA’s expectation of 
additional costs.  

This  is  mainly  due 
to  the  fact  that 
EASA’s  work  on 
related 
security 
isues  is  stil  in  an 
early stage.  

There  are  no 
quantitative 
data  on 
the 
assessment  of 
safety 
and 
security  trade-
offs by EASA.  

Administrative  Cost:  Establish  EU 
for 
essential 
environmental 
of 
aeronautical products 

requirements 

protection 

one-
and 

Both 
off 
recurrent 

n/a 

Not  relevant  for 
citizen/consumers 

Quantitative 
estimates 
available 

not 

The  IA  concluded 
that 
the  overall 
impact  in  terms  of 
not 
is 
costs 
possible 
be 
estimated  upfront, 
therefore 
and 
is 
considered 
as 
neutral 

to 

Quantitative 
estimates  not 
available 

The IA concluded 
that  the  overall 
impact  in  terms 
of  costs  is  not 
possible  to  be 
estimated 
upfront,  and 
therefore 
considered 
neutral 

as 

is 

to  aprox  530 
FTE  

n/a 

There  are  no 
quantitative 
data  to  make 
an assessment 
IA’s 
the 
of 
expectation of 
additional 
costs.  

Quantitative 
estimates  not 
available 

See  qualitative 
explanation 
in 
footnote (69) 

This 
is  mainly 
due  to  the  fact 
EASA’s 
that 
on 
work 
security  related 
isues is stil in an 
early stage. 

IA 
The 
concluded  that 
the 
overall 
impact in terms 
of  costs  is  not 
possible  to  be 
estimated 
upfront,  and  is 
therefore 
considered  as 
neutral 

Enforcement costs: (costs associated with activities linked to the implementation of an initiative such as monitoring, inspections and adjudication/litigation): n/a 

Indirect costs (indirect compliance costs or other indirect costs such as transaction costs): n/a 

(68) The emergency oversight support mechanism has not been used yet. Should the mechanism be deployed, as per IA, mandatory costs would be imposed on market operators to recover 
the costs of certification and oversight tasks exercised by EASA. These costs would most likely apply to Air Operator Certificates (AOC) issuance and oversight. Using the estimated 
fees presented in the IA, it was possible to use the cost assumptions of the emergency mechanism to estimate the total annual costs (278 M€ between 2018 and 2021) incurred by air 
operators holders of Air Operator Certificates (AOC) from EASA Member States, benefitting from continuous oversight from an EASA Member State. 

(69) Should the emergency oversight support mechanism be deployed, mandatory costs would be imposed on market operators to recover the costs of certification and oversight tasks 

exercised by EASA. Therefore, no additional costs would be incurred by the NCAs. 

100 

 
 
 
 
Direct benefits (such as improved well being: changes  in pollution levels, safety, health, employment; market efficiency) 

Benefit: 

Emergency 
Safety 
oversight  support  mechanism  to 
deal  with  weaknesses  in  safety 
oversight  capabilities  of  Member 
States 

One-off 
benefit 

n/a 

This benefit is not 
relevant  to  this 
stakeholder 

Quantitative 
estimates  are  not 
available (70)  

Safety Benefit: Establish a process 
for  involvement  of  EASA  in  the 
work  on  aviation  security  where 
the Agency has relevant expertise 

Recurrent 

n/a 

This benefit is not 
relevant  to  this 
stakeholder 

are 

There 
no 
quantitative  data 
to  make 
an 
assessment  of  the 
IA’s expectation of 
additional 
costs.  (71) 

This  is  mainly  due 
to  the  fact  that 
EASA’s  work  on 
security 
related 
isues  is  stil  in  an 
early stage.  

n/a 

n/a 

Benefit:  Establish  EU  essential 
requirements  for  environmental 
protection 
aeronautical 
of 
products 

Recurrent 

Quantitative 
estimates 
available 

not 

Too  indirect,  not 
possible to assess 

Quantitative 
estimates 
available 

not 

Quantitative 
estimates  not 
available 

footnote 

Cf 
Business 

Indirect benefits (such as wider economic benefits, macroeconomic benefits, social impacts, environmental impacts) 

Wider Economic Benefits:  
Develop  a  policy  on  performance-
based regulations  

Recurrent 

n/a 

This benefit is not 
relevant  to  this 
stakeholder 

Quantitative 
estimates  are  not 
available (72) 

Quantitative 
estimates  are 
not available 

This  benefit 
is 
not  relevant  to 
this stakeholder 

n/a 

This  benefit 
is 
not  relevant  to 
this stakeholder 

This  benefit  is 
not  relevant  to 
this stakeholder 

This 
is  mainly 
due  to  the  fact 
that 
EASA’s 
on 
work 
security  related 
isues is stil in an 
early stage.  

footnote 

Cf 
Business 

There  are  no 
quantitative 
data  to  make 
an assessment 
of 
IA’s 
the 
expectation of 
additional 
costs.  

Quantitative 
estimates  not 
available 

Quantitative 
estimates  are 
not available 

(70)  The emergency oversight support mechanism has not been used yet. The benefit of the mechanism for industry players consists in the possibility to continue operations that would 
have otherwise to be stopped entirely (thus putting certain market operators out of business) in case of serious deficiencies in the safety oversight capabilities of the national aviation 
authorities responsible for oversight. 

(71)  The fieldwork for this study highlighted that although the intervention is overall externally coherent, there are some areas for improvement. In fact, clearer Regulation’s requirements 

and better defined EASA’s tasks would provide synergies with cybersecurity requirements (e.g. the NIS Directive) within the broader EU regulatory framework. 

(72)  Overall,  industry  players  identified  increased  safety  and  improvements  in  information  as  being  the greatest  benefits  that  can be  attributed  to  compliance  and/or  enforcement of 
Regulation (EU) 2018/1139. While it was caveated that on the whole, the activities of EASA and the Regulation do contribute to increasing safety, it was more challenging to establish 
a causal link between the implementing regulations and requirements and the benefit of increased safety. 

101 

 
 
 
 
 
 
 
 
 
102 

 
 
 
Annex 5. Stakeholders consultation - Synopsis report  

This stakeholder consultation synopsis report provides a summary of the outcome of the stakeholder 
consultation activities which were carried out as part of the evaluation of Regulation (EU) 2018/1139 
on  common  rules  in  the  field  of  civil  aviation  and  establishing  a  European  Union  Aviation  Safety 
Agency. It provides a basic analysis of the responses of stakeholder groups involved in the consultation 
process and a summary of the main issues which they raised. Stakeholder involvement was vital for 
the evaluation in order to collect facts and data, to assess the performance of the Regulation and of 
EASA, to identify possible issues with the existing legal framework and, on this basis, derive lessons 
for possible improvement.  

The consultation strategy was developed from the start of the project in April 2022 and included as key 
stakeholders the following groups:  

• 
• 

• 

- Member States' national aviation authorities;  
- Aviation industry stakeholders: aircraft manufacturers and suppliers of aeronautical products, 
air traffic management and air navigation services providers (ANSP), airports, airlines, ground 
handlers, drone operators, and their trade associations;  
- Other key stakeholders: Eurocontrol, SESAR (Single European Sky Air Traffic Management 
Research Joint Undertaking), representatives of aviation employees, etc.  

Two main types of consultation activities were undertaken, namely: 

• 

The call for evidence was published on Have your say webpage between 21 April and 19 May 
2022. As part of this initial feedback mechanism, 78 replies were received. 

•  A targeted stakeholder consultation conducted by Ramboll as part of the external support study, 

which started in October 2022 and ran until March 2023, and which included: 
•  An online survey, with 120 submitted answers 
• 

27 targeted interviews with public and private sector stakeholders and 24 with EASA staff 
during the field visit 
Two workshops gathering 50 stakeholders in total. 

• 

The following table provides an overview of the participants to the different consultation channels.  

103 

 
 
Table 7 - Overview of respondents per consultation method 

Stakeholder 
category 

Stakeholder group 

Total 
# 
stakeholders 
participated 
interview 

of 
who 
in  an 

Total 
# 
of 
from 
stakeholders 
this  category  who 
participated 
the 
online survey 

in 

Total # of  representatives 
in workshop #1 

Total # of representatives 
in workshop #2 

# 

Total 
of 
respondents  to  the 
call for evidence 

Public sector 

Private sector 

and 
level  aviation 

International 
regional 
organisations 

EU-level  Institutions  and 
Agencies 

National 
authorities 
Member States 

aviation 
from  EASA 

National 
authorities 
countries 

aviation 
third 

from 

International 
aviation organisations 

level 

Private company 

Representative 
organisations 
associations 

and 

Civil society 

Trade union 

Research 
Academia 

institute/ 

2 

5 

4 

1 

1 

6 

8 

0 

0 

0 

4 

32 

0 

0 

69 

7 

0 

1 

0 

4 

26 

0 

0 

0 

0 

0 

0 

0 

3 

0 

0 

0 

0 

24 

0 

0 

0 

0 

0 

0 

0 

4 

8 

13 

0 

104 

 
 
 
NGO 

EU citizens 

Other 

0 

0 

0 

0 

0 

0 

7 

0 

0 

0 

0 

0 

0 

2 

44 

7 

105 

 
 
 
Data limitations and integration of results of consultation activities into the answers to 
evaluation questions 
All  stakeholder  consultation  activities  described  above  were  designed  to  be  complementary, 
ensuring a degree of overlap in topics covered for the purpose of triangulation of evidence from 
different sources, while also avoiding stakeholder fatigue. Key to the consultation strategy was that 
different information (quantitative and qualitative) and different stakeholders (from Agency staff 
to  national  authorities,  civil  society  and  industry  representatives)  were  consulted,  providing  a 
variety  of  points  of  views  and  focus.  The  width  of  actors  which  were  involved  prevents  the 
emergence of biases in the data. 

The need to have a better and more encompassing definition of safety to guide related activities 
seemed to be a concern for all stakeholders. Across stakeholder groups, there seemed to be shared 
difficulties  in  quantifying  the  value  of  safety  interventions  such  as  internal  resourcing  and 
operations as well as the lack of defined measures. There was also an apparent lack of quantitative 
data  with  regards  to  the  cost-effectiveness  of  Regulation  (EU)  2018/1139  among  all  types  of 
stakeholders.  

Despite the challenges experienced during the data collection, a broad range of stakeholders were 
reached through the various consultation activities, and qualitative data provided important insights 
to complement quantitative consultation efforts. 

Further, the ‘Call for Evidence’ launched by the Commission was analysed. The analysis showed 
that such tool was mostly used for coordinated action from certain stakeholder categories, as such 
the  insights  that  emerged  from  the  assessment  were  critically  evaluated  against  the  over-
representation of interest-driven answers. 

The main conclusion is that it was particularly difficult to gather input from stakeholders on 
existing costs imposed by the application of the Regulation and notably the changes that were 
brought to it with the 2018 revision. 

Interviews 
As part of the study, 27 interviews were conducted with 33 interviewees to gather inputs on both 
EASA’s performance and the overall impact of Regulation (EU) 2018/1139. A total of 13 public-
sector organisation representatives from the international, EU and national level were interviewed, 
drawing  from,  inter  alia,  members  of  ICAO,  EASA,  the  European  Commission  and  national 
aviation authorities from EASA Member States and from third countries. For what concerns the 
private  sector,  members  of  14  organisations  were  interviewed,  including  airlines,  airports, 
manufacturers and EU-level representative associations.  

Key insights from the interviews  
• 

In terms of effectiveness, there was a consensus that the Agency has been effective in setting 
the basis for European integration in the area of air transport, bringing benefits to safety for 
the industry in Europe. The rulemaking procedure was deemed useful, casting an inclusive 
setting  that  provides  guidance  through  certification  specifications  and  opinions.  Differing 
opinions were provided on the rate of adoption of rules: while some interviewees flagged that 
the inclusiveness of several actors in rulemaking turns this activity into a slow process, others 
reported that the sheer volume of Agency rules is noticeably increasing, making it hard for 
the addressees to implement such regime in a timely manner.   
For what concerns efficiency, it was reported that several factors indicate that the Agency has 
experienced an increase in efficiency, as demonstrated by its stable number of staff despite 
the  expansion  of  its  competences.  However,  many  interviews  also  revealed  that  the  costs 

• 

 
 
 
associated with the administration and implementation of Agency’s rules have risen, making 
it increasingly hard for Member States and operators to comply with requirements.  

•  With regard to the relevance of Regulation (EU) 2018/1139, interviewees provided different 
opinions. Some respondents held that the Agency should continue to focus solely on safety, 
whilst others noted that it is essential to make sustainability a core focus of EASA, even where 
it only relates to safety indirectly. Drones were equally flagged by some interviewees as an 
area that should be further integrated in Regulation (EU) 2018/1139 to remain relevant in light 
of  technological  developments.  Nonetheless,  respondents  highlighted  the  need  for  the 
mandate  of  EASA  to  be  stabilised, to  ensure that  while  its  competences  are extended, the 
Agency does not convey the impression of an unstable partner organisation.  

•  One  important  element  for  the  coherence  of  Regulation  (EU)  2018/1139  and  other  EU 
regulatory instruments is the relationship between EASA and Eurocontrol. Some interviewees 
held that this relationship has now been clarified, eliminating overlaps between the missions 
of  the  two  organisations.  Other  respondents  flagged  that  duplications  still  occur  not  only 
across  the  tasks  performed  by  EASA  and  Eurocontrol,  but  also  between  EASA  and  the 
European Commission or EASA and the national authorities. There was general agreement 
that this is probably caused by the broad wording used in many provisions of Regulation (EU) 
2018/1139, which leaves several grey areas for the interpretation of concepts.  
For what concerns  EU added value, all respondents agreed that the Agency has achieved 
outstanding results in terms of safety compliance, and that Member States alone could have 
not attained this objective in a global context such as the one where the aviation sector situates 
itself. EASA is considered to be pivotal in the creation of one European airspace, and the 
withdrawal of EU coordinated action in this field is neither desired nor recommended by any 
interviewee.  

• 

Online survey 
The  online  survey  gathered  quantitative  and  qualitative  information  from  a  wide  range  of 
stakeholders to inform the evaluation of EASA, its performance, and the impact of the new Basic 
Regulation.  The  survey  was  distributed  to  15  stakeholder  associations,  four  EU  Agencies,  the 
European Commission and one stakeholder from the industry. Receivers were asked to disseminate 
the  survey  to  their  members  and  their  audience  therefore,  differently  from  the  stakeholder 
interviews, the number of stakeholders invited to complete the survey is not known. Of the 120 
respondents most were private companies in the aviation sector (69), followed by national aviation 
authorities (32) and respondents which identified as ‘Other’ (7). 

Key insights from the online survey 
• 

In terms of effectiveness, 75 respondents from the surveyed sample found the ‘Rulemaking 
Procedure’  somewhat  or  very  effective.  However,  questions  regarding  the  stakeholder 
consultations received a lower response rate since only 90 of the 120 respondents participated 
to stakeholder consultations. Of those, 79 rated the effectiveness of the processes and 63% 
within this group found them to be effective.  

•  With regard to efficiency, a vast majority of survey respondents was not able to provide an 
estimate of the costs incurred after the approval of the new Basic Regulation, reported reasons 
concerned quality and availability of data, stakeholder's type and organisation as well as the 
new Basic Regulation itself. Across stakeholders, the main obstacle was the lack of data about 
Regulation-induced  costs  (or  cost  savings),  primarily  because  this  was  not  recorded  and 
because of the difficulty to link new costs to the Basic Regulation. Indeed, another expressed 
hindrance to reporting estimates was the lack of a common methodology to assess such costs 
(and savings). In addition, undertaking cost estimates was perceived as a lengthy and resource 
taking process, as such not efficient. Lastly, stakeholders flagged different issues related to 
the Regulation. For instance, the new Basic Regulation is not fully implemented since several 

 
 
implementing  and  delegated  regulations  are  not  issued  yet,  as  such  costs  cannot  be  fully 
estimated.  Moreover,  lack  of  common  enforcement  across  countries  causes  costs  to  vary 
significantly among member states. Plus, it is difficult to estimate costs and savings given the 
focus of the Regulation on safety. 
76% of respondents expressed that both Regulation (EU) 2018/1139 and EASA are relevant 
to their current problems and needs. Indeed, EASA’s work was deemed as generally relevant 
to the needs of 70% of participants to the survey.  However, only 39% found that the new 
Basic Regulation is fit for newly emerging and increasingly important needs. 

• 

•  With regard to the coherence of Regulation (EU) 2018/1139, 50% of respondents found its 
legal  requirements  to  be  somewhat  coherent,  i.e.,  they  did  not  perceive  contradictions  or 
overlaps between them. Similarly, EASA’s tasks were found to be complementary to those of 
other regulatory bodies at different governance level (international, national or regional) by 
58% of the surveyed sample. 

•  Answers on the added value of the new Basic Regulation did not result into a clear verdict 
to. Indeed, 35% of respondents said that the effects resulting from Regulation (EU) 2018/1139 
could have been achieved by the previous Regulation, yet 40% find that those could have not 
been  achieved  without  it.  In  both  cases,  the  two  main  stakeholder  groups  were  private 
companies and national aviation authorities. On the other hand, when it comes to the activities 
of the Agency, 53% expressed that those could not be carried out at a different governance 
level and 69% stressed that the achieved results could have not been brought forward without 
an agency like EASA. 

Workshops 
As part of the consultation activities, two workshops were organised with, respectively, members 
of EASA’s Member States Advisory Board (MAB) and members of EASA’s Stakeholder Advisory 
Board (SAB). The staff of EASA supported the contractor by inviting members of MAB and SAB 
to the workshop therefore, differently from the stakeholder interviews, the number of MAB and 
SAB  members  that  were  invited  but  did  not  participate  to  the  workshops  is  not  known.  The 
workshop  with  MAB  took  place  on  October  26th,  2022  at  the  premises  of  EASA  in  Cologne, 
Germany, while the workshop with SAB took place on November 16th, 2022 at the premises of 
EASA in Cologne, Germany. Both workshops included the participation of one representative from 
the European Commission (DG MOVE), representatives from EASA with an observer and logistic 
facilitating  role  and  members  of  the  consortium  performing  the  evaluation  support  study  from 
Ramboll Management Consulting and the University of Antwerp, including the Project Manager 
of the Study.  

Key insights from the workshops  
•  Both workshops revealed that the harmonisation of national legislation with Regulation (EU) 
2018/1139  is  a  lengthy  process,  currently  resulting  in  a  slow  and  heterogeneous 
implementation  of  the  Regulation.  This  is  especially  true  in  view  of  the  various  national 
frameworks that need to be aligned with the Regulation’s provisions, paired with the different 
legal interpretations that Member States grant to these provisions.  

•  During the workshop with MAB, it was noted that alignment with the Regulation seems to be 
overall more ambitious for smaller aviation authorities due to resource constraints to their 
national budgets. Differently, participants to the SAB workshop argued that EASA could have 
invested more resources on adequate info-sharing on national implementations to ensure a 
better uptake of Regulation (EU) 2018/1139.    

•  MAB members held that authorities should be granted adequate time to correctly implement 
rules by the Agency, and that EASA should avoid overregulating to decrease the burden on 
national  administrations.  As  emerged  from  the  workshop  with  SAB,  overregulation  also 
impacts the costs borne by aviation actors, who find themselves in need to constantly re-adapt 

 
 
• 

• 

• 

their infrastructure to new requirements. SAB members reported that overregulation is due to 
the  resource  constraints  currently  experienced  by  the  Agency,  paired  with  the  inefficient 
prioritisation of tasks that results into an intensive rulemaking activity.   
Participants  to  the  SAB  workshop  also  noted  that  the  Agency  should  be  allocated  more 
resources to counter the resource constraint it currently operates under, since the extension in 
the  competences  and  scope  of  EASA  through  Regulation  (EU)  2018/1139  has  not  been 
accompanied by adequate increases in resources. 
In addition, some participants to the workshop with MAB flagged that the implementation 
process  of  Regulation  (EU)  2018/1139  indirectly  impairs  smaller  industry  players:  whilst 
large firms are better equipped to comply with the requirements stemming from the provisions 
of the Regulation, smaller players frequently rely on national laws that are still undergoing 
implementation.  
The introduction of opt-ins and opt-outs was welcomed by participants, and some members 
of MAB highlighted that they do not intend to make use of Article 65 of Regulation (EU) 
2018/1139  to  avoid  dispersing  the  in-house  expertise  and  skills  that  authorities  have  built 
overtime. In a different fashion, SAB members remarked that in-house expertise is decreasing 
within  the  Agency  due  to  a  lack  of  seniority  in  its  management  and  its  struggle  in  hiring 
experienced personnel.  

•  During  both  workshops,  the  quality  of  work  of  EASA  was  acknowledged.  Stakeholders 
commended  the  Agency’s  effectiveness  in  safety,  crisis  management,  airworthiness, 
operations,  aerodromes  and  air  navigation.  Mixed  opinions  were  gathered  during  the 
workshop with SAB on EASA’s capability to engage stakeholders. Whilst some participants 
acknowledged  that  EASA  has  proven  to  be  an  overall  compact  organisation,  capable  of 
bringing together stakeholders from several domains for the first time in European aviation 
history,  others  remarked  that  EASA  overlooks  the  costs  borne  by  the  industry  for 
implementation activities because it fails to perform enough field visits to operators.  
In terms of standardisation, while participants to the MAB workshop positively judged the 
activity of EASA in this field, they also raised points on the preparation and composition of 
inspection teams, which differ in terms of reporting styles of inspectors, (i.e., some inspectors 
tend to “overreport”), making cooperation with EASA harder.  

• 

•  Moreover, some MAB members noted that the role of EASA in the area of security should be 
further defined vis-à-vis its overlaps with safety, since decision-making in the field of security 
in  Europe  differs  from  safety-related  decision-making.  SAB  members  highlighted  that 
duplications also occur within the overlapping domains of EASA and Eurocontrol in the area 
of ATM.  

EASA field visit 
The study also comprised of a field visit held on November 23rd – 24th at the premises of EASA in 
Cologne, Germany. A total of 16 interviews were conducted with 24 employees, drawing from the 
Executive Directorate, the Certification Directorate, the Flight Standards Directorate, the Strategy 
and Safety Management Directorate and the Resources and Support Directorate.  

Key insights from the field visit 
•  According to EASA staff interviewed during the field visit, the perception of prescriptiveness 
of Regulation (EU) 2018/1139 varies depending on the type of stakeholders. For instance, 
whilst  Member  States  would  prefer  more  prescriptive  rules  and  clearer  guidance  on 
implementation, stakeholders from the aviation industry perceive the Regulation as already 
rather prescriptive, (i.e., with regard to the certification of simulators which defines device-
based rules instead of setting out independent principles to be complied with). EASA staff 
acknowledged  that  some  areas  might  appear  as  particularly  regulated,  but  also  that  the 

 
 
• 

• 

Agency’s regulatory framework is still flexible enough to evolve overtime according to the 
needs of aviation safety.  
The  ecosystem  approach  created  through  the  different  levels  of  consultation  with  the 
Stakeholder Advisory Board and the Member State Advisory Board for strategic issues has 
positively impacted the relationship between EASA and stakeholders.  EASA staff maintained 
that  the  relationship  between  the  Agency  and  Member  States  has  improved  significantly 
through the years, shifting from a competitive approach to a more cooperative one. Whilst the 
Regulation (EU) 2018/1139 has not changed the organisation of consultation procedures with 
SAB and MAB, it has however facilitated the establishment of partnership agreements with 
NAAs. The progressive operationalisation of more partnership agreements has undoubtedly 
strengthened the collaborative aspect of cooperation between Member States and EASA.  
•  Whilst EASA staff perceive some internal inconsistencies across the activities of the Agency, 
it was flagged that the organisational element of the drones’ department should be further 
improved, since its current resources will likely be insufficient in view of the future expansion 
of the drone domain.  
EASA staff also highlighted that external coherence could be better achieved in the domain 
of ATM/ANS with respect to the activities of Eurocontrol. In addition, further synergies could 
be exploited with the maritime sector, for example by letting agencies which already interact 
with EASA, (like EMSA), benefit from EASA’s experience in relevant areas, (such as the 
intelligence  gathered through  the  Data4Safety  project).  Synergies  in  the  domain  of  drones 
could also be taken more advantage of since, at present, the regulatory framework for smaller 
drones  and  low-risk  operations  is  part  of  Member  States’  responsibility,  while  the  design 
safety of all other drones is a responsibility of the Certification Directorate of the Agency.  
The field visit revealed that EASA staff recognize the EU added value of supranational action 
in the field of aviation safety. Whilst differing safety levels have been achieved depending on 
the  aviation  segment,  the  highest  level  of  safety  has  been  consolidated  in  commercial  air 
transport. Moreover, EASA staff considered that the Agency is especially well-placed to serve 
large pan-European stakeholders with a business model that profits from EU-wide regulation. 
At the same time, according to its employees, the Agency should maintain a leading role on 
safety-related  aspects  connected  to  the  greening  and  digitalisation  of  the  aviation  sector, 
ensuring EASA’s relevance in view of new policy developments.  
EASA staff recognised that the Agency has struggled to recruit personnel with the desired 
level of seniority, especially in the field of standardisation. The entry grade for experts has 
been lowered and less qualified staff has been hired, resulting in issues when the Agency’s 
employees need to interact with their counterparts from NAAs. 

• 

• 

Analysis of Commission’s Call for Evidence 
The  Call  for  Evidence  gathered  78  responses  from  five  different  stakeholder  groups,  notably: 
NGOs, companies or business organisation, business associations, trade unions and EU citizens. 
78% of responses originated from stakeholders in three different countries: France (39), Germany 
(14) and Belgium (9). 

Key insights from the Call for Evidence 
• 

The  Call  for  Evidence  was  widely  used  for  coordinated  actions.  Indeed,  coordinated 
answers (73) were found in the responses provided, mostly from stakeholders who reported to 
be EU citizens, trade unions and business associations. 

(73) A set of coordinated activities designed to achieve a specific policy objective. 

 
 
 
•  A main point of complaint was the implementation of Art.89 of the Regulation regarding the 
socioeconomic aspects of safety. This seemed to reflect what emerged from other consultation 
activities, namely, the need for a better defined and more encompassing scope of safety. 

 
 
Annex 6. EASA’s  KPIs  –  excerpt  from  the  evaluation 

study 

EASA’s rulemaking  

The procedure of developing regulatory material by EASA is presented in more detail in the EASA 
Management Board Decision No 01-2022 (74). Rulemaking refers to the development and issuing 
of  rules  for  the  implementation  of  Regulation  (EU)  2018/1139.  Through  rulemaking,  EASA 
contributes to the production of EU legislation and implementation material in the area of civil 
aviation and environmental compatibility.  

EASA issues the following types of rules: opinions, certification specifications, acceptable means 
of compliance, guidance material. These rules are defined in the following way: 

•  Opinions:  EASA’s  suggestions  in  the  form  of  opinions  are  evaluated  by  the  European 
Commission and, subsequently, ‘Implementing rules’ are issued as legally binding law. 
Opinions are formulated by EASA after issuing terms of reference (ToR) for a rulemaking 
task  and  after  the  creation  of  the  notice  of  a  proposed  amendment  (NPA)  and  the 
consultation period that generates a comment-response document.  

•  Certification specifications: non-binding technical standards adopted by EASA to meet 

the essential requirements of the Basic Regulation.   

•  Guidance  material:  non-binding  explanatory  and  interpretation  material  on  how  to 
achieve the requirements contained in the Basic Regulation, the implementing rules, the 
acceptable means of compliance, and the certification specifications.  

•  Acceptable means of compliance: non-binding rules where the responsibility to ensure 
compliance sits with the National Aviation Authorities. This type of rule serves as a means 
by which the requirements contained in the Basic Regulation and the implementing rules 
can be met. 

The  European  Plan  for  Aviation  Safety (75)  presents  the  most  relevant  publicly  available 
information on the numbers and purpose of rulemaking tasks for the past years in each edition. 
These  5-year  plans  are  important  in  EASA’s  overall  planning  of  its  rulemaking  tasks  as  they 
provide a more holistic approach to the actual capacity of the regulatory system in a balance of 
hard law and soft law.  

In terms of the outputs of the rulemaking activities, between 2015-2016, the number of deliverables 
has been relatively high (Figure 32 below) (76).   

(74)  Management  Board  Decision  No  01-2022  on 

the 

rulemaking  procedure.  Available  at: 

https://www.easa.europa.eu/en/the-agency/management-board/decisions/easa-mb-decision-no-01-
2022-rulemaking-procedure-repealing-mb   

(75)  The  EPAS  is  the  instrument  used  to  prioritise  and  manage  actions  to  maintain  and  further  improve 
aviation safety and environmental protection in Europe. It seeks to do this while ensuring efficiency, 
proportionality and level playing field at the same time. EPAS is a safety action plan derived from the 
level.  Description  of  EPAS  available  at: 
main 
https://www.easa.europa.eu/community/content/priorities-and-safety-actions 

identified  at  European 

safety 

risks 

(76) EASA presentation of the Historic KPI Timeline that presents the status of EASA activities.  

 
 
 
Figure 1. EASA Rulemaking outputs per year (2015-2021) 

Source: EASA (2021). European Plan for Aviation Safety (EPAS) 2021–2025. Available at: 
https://www.easa.europa.eu/en/downloads/123562/en. N.B. NPA: Notices of Proposed Amendments, Decision CS:  
Decision on certification specifications, ToR: Terms of Reference 

While the 2015-2016 period had a high number of rulemaking outputs, this has also been influenced 
by a backlog of rulemaking tasks from previous years. As presented in the figure above, the number 
of rulemaking outputs decreased from 2016 until 2018.  

Since  2019,  EASA’s  regulatory  framework  has  gone  through  a  ‘cool-down’  period,  given  the 
propositions  of  numerous  stakeholders  that  expressed  their  view  in  relation  to  the  burden  on 
Member  States and industry;  this ‘cool-down’ in  the rulemaking process  is materialised by  the 
stabilisation and reduction of opinions delivered every year. This shows that rulemaking since the 
entry into force of Regulation (EU) 2018/1139 was largely adapted to the implementation, but with 
considerations made to the burden that new rules may impose on the aviation sector. In addition, 
in 2019, the average duration of rulemaking tasks was described as ‘significantly above target’ in 
the  2019-2023  edition  of  the  EPAS  which further  identifies  a delay  in  rulemaking  tasks.  Since 
2020, the pandemic had also impacted the delays in rulemaking activities, in a period of extreme 
pressure on all aviation stakeholders, at all levels.  

Table 8 below shows the key performance indicators (KPIs) in relation to the rulemaking tasks for 
the period 2015-2022, aggregating data from more reports. Despite the fact that the relevant period 
for the evaluation study is 2018-2022, a longer timeline is provided to complete the picture.  

Table 8. EASA’s rulemaking KPIs 2015-2022 

Rulemaking 

Measureme
nt unit 

Quality 
NPAs 

of 

published 

Progress 

Timely 
on 
Rulemaking Programme - 
Strategic  actions  planned 
vs. actual 

% 

% 

2015 

2016 

2017 

2018 

2019 

2020 

2021 

2022  – 
Q1 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

1% (77) 

On track 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

64% 

Attention 
required 

Progress 

Timely 
on 
Rulemaking Programme - 
Opinions 
vs 
actuals 

planned 

% 

55% 

50% 

54% 

55% 

100% 

80% 

75% 

N/A 

(77) Number of feedback received, which rates the quality of published NPAs as not or not at all satisfactorily, 

vs total number of commentators. 

 
 
 
 
Rulemaking 

Measureme
nt unit 

2015 

2016 

2017 

2018 

2019 

2020 

2021 

2022  – 
Q1 

Progress 

on 
Timely 
Rulemaking Programme - 
Decisions  planned  vs 
actuals 

Progress 

Timely 
on 
Rulemaking Programme - 
NPAs planned vs actuals 

Rulemaking 
Process 
Efficiency - Average time 
with standard procedure 

Process 
Rulemaking 
Efficiency - Average time 
with Art.15/16 

Rulemaking 
Process 
Efficiency - Average time 
at the EC 

Best 
Intervention 
Strategy (BIS) Coverage 

Number  of  evaluations 
published yearly (79) 

answer 

Timely 
to 
exemption  requests  (as 
defined by regulation) 

% 

% 

55% 

50% 

54% 

55% 

81% 

58% 

82% 

N/A 

N/A 

N/A 

N/A 

N/A 

59% 

73% 

94% 

N/A 

Years 

3.6 

3.6 

3.9 

3.43 

3.5 

3.2 

4.4 

3.31 

Years 

N/A 

N/A 

N/A 

N/A 

1.70 

1.16 

1.2 

N/A 

Years 

N/A 

N/A 

N/A 

N/A 

1.9 

1.7 

0.9 

N/A 

% 

N/A 

N/A 

N/A 

N/A 

100% 

100% 

N/A (78) 

N/A 

Number 

N/A 

N/A 

N/A 

N/A 

N/A 

2 

2 

1 

% 

N/A 

N/A 

91% 

93% 

84% 

97% 

95% 

96% 

Source: EASA (2018). WP17b Historical KPI Timeline, EASA (2022). WP11 Status of EASA KPIs. N.B. The colours denote 
the distance to the target. Green = On track, Yellow = Delayed, Red = Attention required, Grey = Not Measurable/ Not 
available). It should be noted that not all data for 2022 is available/measurable to date. 

Based on the KPI Report of 2020, one reason for delays in rulemaking tasks after the COVID-19 
pandemic  started  was  caused  by  issues  in  on-site  inspections  and  the  need  to  shift  remote 
inspections, which created delays in collecting the necessary information for the tasks. Moreover, 
the pressure that the pandemic had on the industry and delays in payments were also important for 
the delays in the rulemaking activities.  

The  EPAS  also  presents  the  list  of evaluations  used  to  assess  whether aviation regulations  and 
related  initiatives  are  delivering  the  expected  results  at  minimum  cost. (80)  Evaluations  draw 
conclusions  on  whether  the  rules/actions  continue  to be justified  or they  should  be  modified to 
improve their effectiveness and/or eliminate excessive burden. These evaluations respond to the 
evaluation criteria based on the Better Regulation Guidelines. The table below shows the number 
of EASA evaluations between 2018 and 2022, based on all the available information we found in 
the documentation: 

Table 9. Number of EASA evaluations of existing rules 

2018 

2019 

2020 

2021 

2022 

Number of evaluations 

6 

2 

7 

5 

4 

Source: EASA (2021). European Plan for Aviation Safety (EPAS) 2018-2022, 2019-2023, 2020-2024, 2021–2025. 

(78) It should be noted that for the years 2021-2022 no new Rule Making Tasks were created.  

(79) Cover domains with ex post evaluations of rules (3 year moving average) 

(80)https://www.easa.europa.eu/en/downloads/122936/en#:~:text=Hence%2C%20EPAS%20is%20develop

ed%20as,with%20a%20dedicated%20stakeholder%20consultation 

 
 
 
 
 
Product certification 

As of 2003, EASA has the competence for the certification of aircraft for which EASA discharges 
the State of design responsibilities, as well as of aircraft to be registered in the EU Member States. 
Product certification looks at the types of products (e.g. aircrafts, engines etc.) and whether these 
meet EU safety requirements. Product certification takes place under the Certification Directorate 
of EASA (81).  

Regulation (EU) 2018/1139 brought certain changes in relation to airworthiness and environmental 
protection, such as in terms of the design of products, design of non-installed equipment and design 
of parts, and in terms of noise and emissions.  

EASA KPI reports provide relevant information with regard to the progress encountered in product 
certification  activities.  The  table  below  presents  the  progress  in  product  certification  activities 
between 2015 and 2022.  

Table 10. Product certification KPIs (2015-2022)  

Product  certification 
KPIs 

Measurement 
unit 

2015 

2016 

2017 

2018 

2019 

2020 

2021 

2022 

Initial 
(IAW) 
rate 

airworthiness 
performance 

Occurrences  backlog 
monitoring rate 

Technical  acceptance 
of 
occurrences 
timeliness (in days) 

Airworthiness 
directives  deficiency 
rate 

Continuing 
Airworthiness  (CAW) 
predictability time 

Timeliness 
certification 
for 
products 

validation 

of 
support 
of 

Timely  approval  of 
Design  Organisation 
(DOA) continuation 

% 

% 

86% 

89% 

92% 

92% 

89% 

101% 

103% 

95% 

86% 

87% 

118% 

104% 

77% 

114% 

89% 

118% 

Days 

13.8 

15.1 

11.5 

11 

13 

7 

8 

5 

% 

% 

% 

% 

4% 

6% 

5% 

4% 

4% 

3% 

3% 

3% 

71% 

84% 

95% 

110% 

95% 

100% 

102% 

88% 

57% 

64% 

53% 

68% 

67% 

71% 

60% 

81% 

72% 

89% 

82% 

N/A 

97% 

82% 

85% 

55% 

Source: EASA (2018). WP17b Historical KPI Timeline, EASA (2022). WP11 Status of EASA KPIs. N.B. The colours denote 
the distance to the target. Green = On track, Yellow = Delayed, Red = Attention required, Grey = Not Measurable/ Not 
available). It should be noted that not all data for 2022 is available/measurable to date. 

Based on relevant KPI reports, in 2018, the KPIs for certification were on-track, with delays in the 
technical  acceptance  of  in-coming  occurrences.  In  2019,  delays  were  encountered  in  the 
occurrences backlog monitoring rate. Moreover, in the same year, airworthiness directives have 
been delayed and the initial airworthiness (IAW) performance was lower than initial targets. Since 
2020, delays in certification were still identified in relation to the occurrences backlog monitoring. 

Another component of EASA’s responsibilities in this field is related to certification that ensures 
that  aircrafts  and  engines  comply  with  environmental  standards  (under  ICAO  Standard  and 
Recommended Practices (SARPs), Annex 16 (82).  

The figure below presents the number of approvals issued by EASA between 2018 and 2021.  

(81) https://www.easa.europa.eu/en/document-library/certification-procedures 

(82) https://www.icao.int/environmental-protection/CORSIA/Pages/SARPs-Annex-16-Volume-IV.aspx 

 
 
 
Figure 2. Approvals issued by EASA during 2018 - 2021 

Source: EASA 2018-2022 Consolidated Annual Activity Reports 

Environmental protection in relation to product certification is a priority more recently since the 
inception of Regulation (EU) 2018/1139. EASA approves certification noise levels as part of the 
process of aircraft certification, in line with noise standards defined by ICAO SARPs Annex 16; 
this is now part of the aircraft and engine type certification process. Additionally, after the entry 
into  force  of  Regulation  (EU)  2018/1139  in  2018,  EASA  introduced  the  concept  of  innovative 
certification (83) in order to increase efficiency in certifying products that demonstrate compliance 
with environmental standards. 

Consultation activities 

One important task of EASA is to consult with stakeholders from the aviation sector, particularly 
with Member States and with the industry. For these activities, EASA has a number of bodies and 
groups (84):  

•  Advisory Bodies (Technical Body, Member States Advisory Body, and Stakeholder Advisory 

Body) (85); 

•  Collaborative Analysis Groups (CAGs); 
•  European Network of Analysts (NoAs); 
•  Stakeholder experts and representatives in rulemaking groups;  
•  Open public consultation on NPAs; 
•  Targeted consultation to groups of stakeholders; 
•  Working groups of experts. 

In the analysed documents that referred to EASA’ stakeholder consultation activities, most often it 
was highlighted that the process was seen as crucial in ensuring that actors are consulted when 
relevant (i.e. Member States, stakeholders, experts etc.).  

Analysed meeting minutes from the MAB and SAB have been most relevant in providing views 
on consultation activities since 2018 across all analysed documents. In addition to the frequently 

(83) https://www.easa.europa.eu/en/domains/environment/innovative-certification 

(84) European Plan for Aviation Safety (EPAS) 2020-2024.  

(85) https://www.easa.europa.eu/en/the-agency/other-easa-boards-and-bodies/advisory-bodies 

 
 
 
 
outlined importance of consultation activities, a recurring theme brought by members to MAB and 
SAB  meetings  is  the  pivotal  role  of  EASA  in  respecting  the  due  process  when  consulting  all 
relevant stakeholders without ad hoc changes in procedures (86).  

There have been changes in terms of how to structure the consultation mechanisms and how to 
improve them  after  2018. These recent  developments  were mostly  discussed  in  Member  States 
Advisory Body (MAB) and Stakeholder Advisory Body (SAB) meetings, including discussions on 
potential issues in relation to consultation activities.  

Monitoring Member States  

Based  on  the  Regulation,  EASA  is  monitoring  the  way  NCAs  apply  the  common  EU  rules  on 
aviation safety. Monitoring activities refer to EASA’s role in harmonising rules at European level 
and its role in achieving and maintaining a high and uniform level of safety in the EU, as identified 
in the first article of the Regulation. EASA monitors how Member States apply the requirements 
of the Regulation and the related delegated and implementing acts. EASA is continuously assessing 
how NCAs implement these rules, such as through country status information on indicators (based 
on data received from NCAs through the Standardisation Information System (SIS)) (87).  

A  limited amount of information  was found as  part of  the  desk-based  review in  relation to the 
monitoring activities carried out by EASA. The sources that were analysed have predominantly 
focussed on describing the procedures that EASA uses in its monitoring activities.  

As a direct impact of the COVID 19 crisis in relation to monitoring activities carried out by EASA, 
the  standardisation  programme  was  significantly  reduced  with  only  one  third  of  planned 
inspections taking place in 2020 and as a result the number of findings having dropped dramatically 
compared  to  previous  years.  During  2020,  the  on-field  inspections  had  to  shift  to  remote 
inspections, which can account for the delays and issues in relation to inspections.  

The table below presents relevant KPIs in relation to standardisation activities between 2015 to 
2022: 

Table 11. Standardisation activities KPIs (2015-2022) 

Standardisation 

Efficient  and  robust 
Standardisation 
(yearly) 

Control  of  overdue 
Standardisation 
findings 

issuance  of 
Standardisation 

Timely 
due 
reports 

Measurement 
unit 

2015 

2016 

2017 

2018 

2019 

2020 

2021 

2022 

% 

% 

% 

N/A 

N/A 

-24% 

N/A 

-17% 

67% 

217% (88) 

N/A 

N/A 

N/A 

7% 

18% 

17% 

35% 

10% 

8% 

79% 

97% 

89% 

100% 

92% 

86% 

85% 

90% 

Source: EASA (2018). WP17b Historical KPI Timeline, EASA (2022). WP11 Status of EASA KPIs. N.B. The colours denote 
the distance to the target. Green = On track, Yellow = Delayed, Red = Attention required, Grey = Not Measurable/ Not 
available). It should be noted that not all data for 2022 is available/measurable to date. 

(86) Based on MAB and SAB meeting minutes.  

(87)  The  SIS 

is  a  website  dedicated 

to  NCAs 

to 

submit  country 

status 

information: 

https://www.easa.europa.eu/en/data-protection/standardisation-information-system-sis 

(88) In 2020, as a direct impact of the COVID 19 crisis, the  standardisation programme was significantly 
reduced.  Only  1/3 of  planned  inspections  took  place  in 2020  and  as  a  result  the  number  of  findings 
dropped  dramatically  compared  to  previous  years.  The  standardisation  activity  normalised  in  2021 
resulting in a strong increase (compared to 2020) in the number of findings. 

 
 
 
According to the data collected from desk research, EASA’s monitoring of the implementation of 
rules in Member States was impacted by the pandemic, reflected in challenges in 2020 and 2021.    

Resources and costs 

EASA’s budget is funded from different sources, with fees paid by industry (i.e. through various 
‘fees and charges’ (89)), accounting on average (over the period 2018-2022) for around 63% of the 
total  EASA  budget.  This  is  accompanied  by  the  funding  from  the  European  Commission  (i.e. 
through various subsidies, mostly allocated to perform standardisation activities) which accounts, 
on average for 22% of the total budget. Overall, the budget increased by 3% over the period from 
EUR 198 million in 2018 to EUR 205 million in 2022. 

International cooperation and relevance 

This  section  addresses the role  that  EASA  has  in  international cooperation  and the  relevance  a 
European body harmonising rules across its Member States at an international level. Article 90 of 
Regulation (EU) 2018/1139 describes EASA’s role in international cooperation, in matters related 
to Regulation (EU) 2018/1139. Specifically, EASA’s role is to contribute to the harmonisation of 
rules,  the  mutual  recognition  of  certificates,  in  the  interest  of  the  European  industry,  and  the 
promotion of European aviation safety standards. Moreover, EASA cooperates with the NCAs of 
third countries and with international organisations (e.g. its role in the European coordination on 
ICAO  maters) (90).  All  these  activities  are  aimed  at  supporting  EASA  Member  States  in 
international or global matters relevant to the Regulation.  

Part of the EASA Consolidated Annual Activity report of 2018, it is presented that the Agency puts 
more  emphasis  on  international  cooperation  than  in  previous  years,  such  as  in  the  case  of  the 
negotiations  of  the  new  Bilateral  Aviation  Safety  Agreements  with  Japan  and  China,  the  new 
working  arrangements  with  Russia  and  Israel (91).  In  2019,  EASA  signed  new  Working 
Arrangements (92) with other countries (Azerbaijan, Mexico, Singapore, Egypt).  

EASA  collaborates  with  a  number  of  organisations  at  both  European  level  and  internationally: 
Eurocontrol, International Air Transport Association (IATA), European Space Agency, SESAR 
Joint  Undertaking,  as  well  as  others.  In  its  relationship  with  ICAO  (the  main  international 
organisation for aviation safety), EASA has a number of roles. Among others, EASA works with 
the Commission and EASA Member States to coordinate positions on matters at a global level and 
it supports Member States in implementing ICAO standards. EASA is a member of the Regional 
Safety  Oversight  Organisations  (RSOOs)  of  ICAO,  a  mechanism  where  a  group  of  countries 
cooperate with the purpose of a more effective system of aviation safety oversight. Additionally, 
since  Regulation  (EU)  2018/1139  entered into  force, a  bigger  role  in  relation to  environmental 
protection by aligning requirements with the ICAO provisions under Annex 16 (93). 

Table 12 presents the KPIs in relation to EASA’s activities in international cooperation between 
2015-2022, based on available data from more reports. The table shows the progress on bilateral 
agreements,  working  arrangements,  recommendations  to  ICAO  and  other  activities  carried  by 
EASA. 

(89)  Regulation  (EU)  2019/2153  on  the  fees  and  charges  levied  by  the  European  Union  Aviation  Safety 

Agency, and repealing Regulation (EU) No 319/2014. 

(90) Article 90 of Regulation (EU) 2018/1139.  

(91) 

EASA 

Consolidated 

Annual 

Activity 

Report 

2018. 

Available 

at: 

https://www.easa.europa.eu/en/document-library/general-publications/annual-activity-report-2018 

(92)  EASA  has  Bilateral  Agreements  and  Working  Arrangements  with  non-EU  authorities. 
https://www.easa.europa.eu/en/domains/international-cooperation/international-cooperation-explained 

(93) EASA Opinion 03/2020.  

 
 
 
Table 12. International Cooperation KPIs (2015-2022) 

International 
Cooperation 

Measurement 
unit 

2015 

2016 

2017 

2018 

2019 

2020 

2021 

2022 

Timely  progression  on 
Working 
Arrangements 

Timely  progression  on 
Bilateral Agreements 

Timely 
implementation 
of 
technical support to 3rd 
countries 

Quality  of  delivered 
projects 
on 
stakeholder feedback 

based 

Timely  provision  of 
recommendations  on 
ICAO State Letters for 
use by Member States 

Timely  delivery  of 
compliance  checklists 
for use by MS 

% 

% 

% 

N/A 

N/A 

100% 

100% 

N/A 

66% 

85% 

On track 

N/A 

N/A 

100% 

Delayed 

N/A 

100% 

100% 

N/A 

N/A 

N/A 

81% 

87% 

90% 

80% 

88% 

On track 

Avg. score (94) 

N/A 

N/A 

N/A 

N/A 

6.56 

6.5 

6.4 

On track 

% 

92% 

91% 

97% 

<50% 

100% 

100% 

100% 

On track 

N/A 

N/A 

≥ 9 months 
heavily 
delayed 

Delayed 

Delayed 

Achieved 

Achieved 

2 ICAO 
Annexes 
updated 

Source: EASA (2018). WP17b Historical KPI Timeline, EASA (2022). WP11 Status of EASA KPIs. N.B. The colours denote 
the distance to the target. Green = On track, Yellow = Delayed, Red = Attention required, Grey = Not Measurable/ Not 
available). It should be noted that not all data for 2022 is available/measurable to date. 

In 2020, more focus was put on collaboration with international organisations and third countries 
on the topic of COVID-19 pandemic and further emphasis on cooperation in this area (95). EASA 
played an important role in supporting the industry (and thus the recovery of the aviation industry) 
in the midst of a global crisis, as well as in playing a pivotal role in harmonised guidance across 
the EU. The 2020-2024 edition of EPAS presented a report of how EASA assessed the risks that 
the pandemic had in aviation safety and guidance (in relation to aircrew, ground handling, human 
factors, and other fields).  

(94) Average score of all completed feedback forms, on scale from 0 to 7, where 7 is the best score possible 

(95) 

EASA 

Consolidated 

Annual 

Activity 

Report 

2020. 

Available 

at: 

https://www.easa.europa.eu/en/document-library/general-publications/consolidated-annual-activity-
report-2020 

 
 
 
 
 
 
Staffing within EASA 

Table 13. EASA Statutory Staff & SNEs  Establishment plans – temporary agents 

Function 
group  and 
grade 

2018 
Authori
sed 

2018 
Actual 

2019 
Author
ised 

2019 
Actual 

2020 
Authorised 

2020 
Actual 

2021 
Authorise
d 

2021 
Actual 

2022 
Authorised 

AD 15 

AD 14 

AD 13 

AD 12 

AD 11 

AD 10 

AD 9 

AD 8 

AD 7 

AD 6 

AD 5 

1 

26 

33 

57 

81 

103 

119 

80 

44 

13 

0 

1 

5 

7 

22 

44 

70 

121 

137 

75 

42 

23 

1 

29 

36 

68 

86 

108 

115 

78 

30 

11 

0 

1 

2 

6 

22 

48 

76 

129 

118 

70 

49 

23 

1 

25 

33 

66 

88 

110 

120 

78 

32 

11 

2 

1 

2 

5 

16 

45 

75 

129 

116 

70 

50 

25 

1 

25 

33 

66 

88 

110 

120 

78 

32 

11 

2 

1 

2 

3 

15 

60 

82 

128 

106 

54 

51 

26 

1 

25 

33 

66 

88 

110 

120 

78 

32 

11 

2 

AD Total 

557 

547 

562 

544 

566 

534 

566 

528 

566 

AST 9 

AST 8 

AST 7 

AST 6 

AST 5 

AST 4 

AST 3 

AST 2 

AST 1 

1 

4 

13 

27 

34 

23 

17 

4 

0 

0 

0 

2 

11 

36 

34 

21 

13 

3 

1 

4 

12 

29 

30 

24 

16 

2 

0 

0 

1 

2 

15 

39 

29 

18 

7 

1 

1 

3 

11 

27 

30 

25 

15 

2 

0 

0 

1 

1 

14 

37 

30 

18 

6 

0 

1 

3 

11 

27 

28 

25 

15 

2 

1 

3 

26 

33 

22 

15 

4 

1 

3 

11 

27 

28 

25 

15 

2 

AST total 

123 

118 

118 

112 

114 

107 

112 

104 

112 

AST / SC 3 

AST / SC 2 

AST / SC 1 

/  SC 

AST 
Total 

1 

1 

2 

0 

0 

0 

1 

1 

2 

TOTAL 

680 

665 

680 

656 

680 

641 

680 

632 

680 

Diff 

-2% 

-4% 

-6% 

-8% 

N/A 

Source: EASA 2018-2022 Consolidated Annual Activity Reports.