COMMISSION STAFF WORKING DOCUMENT on Military Mobility Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on establishing a framework of measures to facilitate the transport of military equipment, goods and personnel across the Union
Date: 2025-11-19
Institutions: Directorate-General for Defence Industry and Space, European Commission
Subjects: European defence policy, armed forces, crisis management, cross-border cooperation, logistics, military equipment, rail transport, simplification of formalities, trans-European network, transport infrastructure

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 19.11.2025  SWD(2025) 847 final  COMMISSION STAFF WORKING DOCUMENT on Military Mobility Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on establishing a framework of measures to facilitate the transport of military equipment, goods and personnel across the Union {COM(2025) 847 final}  
 
 
Contents 

1 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ................................................. 7 

1.1  The importance and definition of military mobility .............................. 7 
1.2  Political commitments and achievements to date .................................. 8 
1.3  Stakeholder consultation on Military Mobility ................................... 12 
PROBLEM DEFINITION AND PROBLEM DRIVERS ..................................................... 13 

2 

2.1 

Inadequate/incomplete regulatory framework at EU and national level
 ............................................................................................................. 16 

Regulatory  fragmentation  across  Member  States  governing  cross-border 
2.1.1 
rules and procedures ................................................................................................. 17 

2.1.2 
Non-binding  nature  of  arrangements  in  European  Defence  Agency  and 
Member States’ initiatives ........................................................................................ 19 

2.1.3 
needs 

EU  legislation  in  different  policy  areas  not  adapted  to  military  mobility 
21 

2.2  Limited and vulnerable infrastructure ................................................. 28 
2.2.1 

Inadequate dual-use infrastructure for military mobility.......................... 29 

2.2.2 
Insufficient  and  uncoordinated  identification  and  protection  of  strategic 
military mobility infrastructure ................................................................................ 31 

2.3  Low availability of transport assets ..................................................... 33 
2.3.1 
Underinvestment  or  supply  shortages  of  (or  gaps  in)  military  mobility 
capabilities at the disposal of EU Member States. ................................................... 34 

2.3.2 
Limited visibility on existing military mobility capabilities (including dual-
use capabilities) across the EU ................................................................................. 37 

Inefficiencies  in  optimal  use  of  military  mobility  capabilities  (including 
2.3.3 
dual-use capabilities) ................................................................................................ 39 

2.4  Coordination  challenges,  and  the  whole-of-government,  whole-of-
society approach. ................................................................................. 41 
3  WHY SHOULD THE EU ACT? .......................................................................................... 44 

3.1  Legal basis ........................................................................................... 44 
3.1.1 
OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................. 47 

Subsidiarity: the added value of EU action .............................................. 45 

4.1  General objective ................................................................................. 47 
4.2  Specific objectives ............................................................................... 47 
POLICY OPTIONS .............................................................................................................. 49 

4 

5 

5.1  Baseline - Status quo (no EU legislative action) ................................. 49 
5.2  Discarded policy option ....................................................................... 49 
5.3  Preferred policy option ........................................................................ 51 
5.3.1 

On Regulatory aspects .............................................................................. 51 

5.3.2 

5.3.3 

On Infrastructure ...................................................................................... 57 

On capabilities .......................................................................................... 60 

 
 
 
On governance .......................................................................................... 63 

5.3.4 
IMPACTS OF THE PREFERRED POLICY OPTION? ...................................................... 65 

6 

6.1  Economic impacts ............................................................................... 65 
6.2  Societal impacts ................................................................................... 71 
6.3  Environmental impacts ........................................................................ 72 
ANNEX: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) ..................................... 75 
ANNEX: BIBLIOGRAPHY .......................................................................................................... 87 

2 

 
 
 
 
 
Glossary 

Term or acronym   Meaning or definition  

ASAP 

BCP(s) 

CARD 

CBMP 

CDP 

CEF 

CER 

CINEA 

Act in Support of Ammunition Production 

Border control post(s) 

Coordinated Annual Review on Defence (Report) 

Cross-border movement permission procedures 

Capability Development Plan 

Connecting Europe Facility 

Critical Entities Resilience (Directive) 

European Climate, Infrastructure and Environment Executive 
Agency 

CSDP 

Common Security and Defence Policy 

DG DEFIS 

Directorate-General for Defence Industry and Space 

DG MOVE 

Directorate-General for Mobility and Transport 

DG TAXUD 

Directorate-General for Taxation and Customs Union 

DTIB 

EDA 

EDEM 

EDF 

EDIP 

EDIRPA 

EDIS 

EEAS 

EIB 

Defence Technological and Industrial Base 

European Defence Agency 

European Defence Equipment Market 

European Defence Fund 

European Defence Industry Programme  

European Defence Industry Reinforcement through Common 
Procurement Act 

European Defence Industrial Strategy  

European External Action Service  

European Investment Bank 

EMERS 

European Military Mobility Enhanced Response System 

EPRS 

European Parliament Research Service 

3 

 
 
ERA 

ERDF 

ESF+ 

ESG 

European Union Agency for Railways 

European Regional Development Fund 

European Social Fund Plus 

Environmental, Social, and Governance 

ESOCA 

European System for Outsized Cargo Airlift  

EU 

EUCO 

EUMC 

EUMS 

GDP 

G2G 

HNS 

JRC 

JSEC 

MFF 

NATO 

NIS 

PESCO 

R&D 

R&D&I 

RSN 

SATOC 

SEAP 

European Union  

European Council 

European Union Military Committee 

European Union Military Staff 

Gross Domestic Product 

Government-to-Government 

Host Nation Support  

Joint Research Centre  

(NATO’s) Joint Support and Enabling Command 

Multi-Annual Financial Framework 

North Atlantic Treaty Organization 

Network and Information Security (Directive) 

Permanent Structured Cooperation 

Research and Development 

Research and Development and Innovation 

Reinforcement and Sustainment Network (NATO) 

Strategic Air Transport for Outsized Cargo 

Structure for European Armament Programme 

SDMMS 

Secure Digital Military Mobility System (project) 

SESI 

SME 

(EIB’s) Strategic European Security Initiative 

Small and Medium Enterprise 

4 

 
 
SOFA 

SWD 

TAs 

TEN-T 

TFEU 

UA 

UAF 

UAV 

UCC 

(NATO) Status of Forces Agreement 

Staff Working Document  

Technical Arrangements 

Trans-European Transport Network 

Treaty on the Functioning of the European Union 

Ukraine 

Ukrainian Armed Forces 

Unmanned Air Vehicle  

Union Customs Code 

UCPM+ 

Union Civil Protection Mechanism Plus 

UN 

US 

United Nations   

United States   

5 

 
 
 
 
 
PURPOSE OF THIS STAFF WORKING DOCUMENT 

The present Staff Working Document (SWD) serves to provide the analytical underpinning 
for  the  2025  Military  Mobility  Package  consisting  of  the  Joint  Communication  on 
Military Mobility and a Regulation on establishing a framework of measures to facilitate 
the transport of military equipment, goods and personnel across the Union . The purpose 
of this Staff Working Document is threefold: first, to clearly set out the political and legal 
context in which EU action is taking place; second, to identify the core problems and 
underlying  problem  drivers  that  continue  to  hinder  military  mobility  despite  progress 
achieved since 2018;  and third, to  present  the  policy options and analyse the preferred 
policy option to address these challenges, in line with the EU’s competences and in full 
complementarity with efforts undertaken by Member States in other frameworks and in 
alignment with NATO, while building on existing achievements in this domain. 

This Staff Working Document explains the urgent need to frame military mobility within 
the broader strategic debate on European defence-readiness, as highlighted in the Strategic 
Compass of 2022 and the Joint White Paper on European Defence-Readiness 20301. It 
must also be addressed in the context of a transport system which is inherently dual use 
and closely regulated at EU level.  In particular, the SWD seeks to explain the rationale for 
EU-level intervention, to demonstrate the EU’s capacity to bring added value through its 
regulatory, budgetary, and coordinating actions, and to prepare the ground for the adoption 
of the Military Mobility Package itself. In doing so, the document also fulfils the Better 
Regulation requirement to ensure that new proposals are supported by a structured analysis 
of the problems, objectives, and options available, while recognising that the urgency of 
the security context may preclude the preparation of a full impact assessment. 

The  Staff  Working  Document  explains  why  the  EU  must  act  now  to  reinforce  military 
mobility  as  a  strategic  enabler  of  European  security  and  defence.  By  consolidating  the 
evidence base submitted through a dedicated targeted stakeholder consultation and call for 
evidence, this SWD provides the foundation for the policy option designed to address 
these shortcomings in a comprehensive and systemic manner. In particular, the document 
articulates the need for a whole-of-government and whole-of-society approach, drawing 
together all relevant actors across sectors and levels of governance.  

1 European Commission, High Representative of the European Union for Foreign Affairs and Security Policy, 
“White Paper for European Defence – Readiness 2030”, dated March 2025”. 

6 

 
 
 
 
1 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

1.1  The importance and definition of military mobility 

The  strategic  context  for  the  European  Union  and  its  Member  States  has  changed 
profoundly since 2014, and particularly since Russia’s full-scale invasion  of Ukraine in 
February 2022. This act of aggression, in flagrant violation of international law and the 
principles of the United Nations Charter, has destabilised the European security order and 
brought  high-intensity  war  back  to  the  European  continent.  The  risk  of  further  Russian 
aggression, including against EU Member States, remains serious. The EU and its Member 
States must therefore prepare for the most extreme military contingencies.  

Military  mobility  refers  to  the  ability  of  Member  States’  armed  forces  to  move 
personnel,  equipment,  assets  and  supplies  rapidly  and  seamlessly  into,  within  and 
beyond EU territory, by land, air, and sea.2  

Military mobility is an essential element of the EU’s wider security and defence policy. It 
enables the EU and its Member States to respond to the most demanding scenarios, ranging 
from  large-scale  collective  defence  contingencies  to  crisis  management  operations  and 
support for partners such as Ukraine. It is also a cornerstone of EU–NATO cooperation, 
recognised  by  both  organisations  as  a  flagship  area  where  EU  action  delivers  concrete 
added value to the Alliance’s deterrence and defence posture. The prospect of hostile action 
against EU Member States, including hybrid operations and conventional military action, 
cannot be excluded. In this context, the ability of the EU and its Member States to react 
rapidly and decisively has become a matter of strategic urgency. 

While the Eastern flank requires particular attention in terms of deterrence and defence, 
comprehensive approach to military mobility with a “360-degree approach” is needed to 
ensure the ability of Member States to move forces swiftly across multiple theatres.  

Military mobility encompasses three interdependent dimensions: 

•  Regulatory:  processes  and  procedures  for  cross-border  movement  permissions, 
diplomatic clearances, customs formalities and route planning (especially for the 
transport  of  dangerous  goods  and  oversized  vehicles)  which  provide  clarity  and 
allow for speed in handling. 

•  Infrastructure:  transport  networks  (railways,  inland  waterways,  short  sea 
shipping  routes  and  roads  linking  maritime  and  inland  ports,  air  transport 
infrastructure and terminals) adapted to dual-use needs, including airspace, load-
bearing capacity, clearance height, and resilience to hybrid and cyber threats. 
•  Capabilities:  availability  of  military  mobility  capabilities  including  particularly 
transport  assets  (e.g.  abnormal  load  and  dangerous  goods  transportation, 
specialised  road  vehicles,  rail  flatbeds,  outsized  cargo  aircraft,  roll-on/roll-off 
shipping, strategic lift capacity) to execute movement at scale and speed. 

2 European Commission and High Representative of the Union for Foreign Affairs and Security Policy, Joint 
Report to the European Parliament and the Council on the implementation of the Action Plan on Military 
Mobility 2.0, 20.3.2025. 

 
 
 
 
Today barriers in all the above dimensions hamper military mobility and leaves the EU 
and its Member States exposed to insufficient readiness in crises, when time is critical for 
efficient deterrence and response.  

1.2  Political commitments and achievements to date 

Since 2017, the EU has pursued a dedicated agenda to strengthen military mobility. The 
Joint Action Plan on Military Mobility of March 20183, developed by the European 
Commission and the European External Action Service (EEAS) in cooperation with the 
European  Defence  Agency  (EDA),  identified  30  key  actions  across  two  pillars:  (i) 
multimodal  corridors  and  logistical  hubs  (identifying  dual-use  needs  within  the  Trans-
European Transport Network (TEN-T) and aligning EU infrastructure policy with military 
requirements),  and  (ii)  regulatory  support  measures  to  reduce  administrative  barriers. 
Member States simultaneously adopted the first Military Mobility Pledge4, committing to 
develop  national  implementation  plans,  establish  networks  of  points  of  contact,  and 
streamline cross-border procedures. 

In  November  2022,  in  response  to  Russia’s  renewed  aggression  against  Ukraine,  the 
Commission and the EEAS adopted the Joint Communication on a new Action Plan on 
Military Mobility 2.05, endorsed by the Council. Action Plan 2.0 expanded the scope of 
EU efforts to include resilience against hybrid and cyber threats, climate-proof and energy-
secure  infrastructure,  and  enhanced  cooperation  with  NATO  and  key  partners  such  as 
Ukraine,  Moldova,  and  the  Western  Balkan  region.  The  European  Defence  Industrial 
Strategy6  from  March  2024  urges  further  investment  in  military  mobility  to  eliminate 
remaining movement bottlenecks. 

The Strategic Compass for Security and Defence, adopted by the European Council in 
March  20227,  explicitly  recognised  military  mobility  as  a  strategic  priority.  Military 
Mobility is also one of the priorities of the updated Capability Development Plan (CDP), 
as approved by Member States in November 20238. The CDP highlighted the urgent need 
to  substantially  improve  the  military  mobility  of  Member  States  Armed  Forces. 
Furthermore,  the  Council  Conclusions  of  May  20249  reaffirmed  Member  States’ 
commitments through the 2024 Military Mobility Pledge, which introduced a new level 
of  ambition  in  terms  of  investment  prioritisation  and  faster  cross-border  movement 
permissions.  

3 European Commission and High Representative of the Union for Foreign Affairs and Security Policy, Joint 
Communication  to  the  European  Parliament  and  the  Council  on  the  Action  Plan  on  Military  Mobility, 
28.3.2018. 
4 Council Conclusions on EU Security and Defence of 25 June 2018. 
5 European Commission and High Representative of the Union for Foreign Affairs and Security Policy, Joint 
Communication  to  the  European  Parliament  and  the  Council  on  “Action  plan  on  military  mobility  2.0”, 
10.11.2022.  
6 European Commission and High Representative of the Union for Foreign Affairs and Security Policy, Joint 
Communication to the European parliament, the Council, the European Economic and Social Committee and 
the Committee of the Regions on “A new European Defence Industrial Strategy: Achieving EU readiness 
through a responsive and resilient European Defence Industry”, 5.3.2024. 
7 European Council, “A Strategic Compass for Security and Defence - For a European Union that protects 
its citizens, values and interests and contributes to international peace and security”, 21.03.2022. 
8 European Defence Agency, “The 2023 EU Capability Development Priorities”.  
9 Council Conclusions on EU Security and Defence, 27.03.2024. 

8 

 
 
 
 
Substantial progress has been recorded on military mobility across multiple frameworks. 
Researchers  also  point  to  the  fact  that  the  understanding  of  the  underlying  issues  has 
increased  as  pointed  to  by  Chihaia  (2023)  that  the  “understanding  the  importance  of 
strengthening military mobility and political support have significantly increased across 
EU  Member  States  since  the  start  of  the  Russian  war  of  aggression  against  Ukraine  in 
2022.”10 

With regards to  addressing  regulatory barriers, the  EDA  and Member States developed 
three Cross-Border Movement Permission Procedures (CBMP) Technical Arrangements 
(TAs) covering surface, air and maritime domains with the objective of harmonising and 
simplifying  CBMPs.  The  Programme  Arrangement  for  cross-border  movement 
permissions  was  signed  by 27 contributing  Member States  and Norway.  The Technical 
Arrangements for Surface and Air have been signed by 26 and 25 contributing Member 
States  respectively  (including  Norway).  Recent  updates  to  the  Technical  Arrangements 
Surface  forms  have  further  streamlined  the  process  for  obtaining  annual  diplomatic 
clearances. The Technical Arrangement for Sea is in an advanced state of negotiation and 
will  also  trigger  an  amendment  of  the  Programme  Arrangement.  However,  their 
implementation is suboptimal, and changes to the EU framework are necessary to achieve 
harmonization  

Within  Permanent  Structured  Cooperation  (PESCO),  projects  Military  Mobility  and 
Logistical  Hubs11  have  enabled  cooperation  on  harmonising  procedures  and  improving 
infrastructure  planning.  In  2023,  EDA  initiated  consultations  with  the  coordinating 
Member States of the two PESCO projects. European Commission and EDA developed a 
concept to create synergies between both projects, to highlight the gaps in and needs of 
logistics hubs along military corridors in Europe. 

With regards to infrastructure, in the Multiannual Financial Framework (MFF) 2021-2027 
a budget of approximately EUR 1.7 billion was designated to co-fund dual-use transport 
infrastructure through the Connecting Europe Facility – Transport (CEF-T). Following 
the  start  of  Russia’s  war  of  aggression  against  Ukraine,  the  Commission  advanced  the 
implementation of the budget ahead of the initial schedule – testifying to its determination 
to  accelerate  the  development  of  dual-use  transport  infrastructure  projects  along  the 
military and TEN-T networks. The full military mobility budget was eventually spent over 
a  total  of  three  calls  for  proposals  (2021-2023),  supporting  95  projects  in  21  Member 
States, already showing results on the ground. The projects selected under the three calls 
cover all transport modes. More specifically, the projects will upgrade dual-use transport 
infrastructure  in  railways,  roads,  airports,  maritime  ports,  inland  waterways  and 
multimodal terminals. Ultimately, the projects will contribute to the development of multi-
modal transport routes connected by logistical hubs to handle also heavy and large-scale 
military transport at short notice – which is at the heart of military mobility.  

However, while important improvements to the military network have been realised with 
the first dedicated CEF military mobility funds, the investment possibilities have remained 
below the needs, with increasingly more funding demand from the Member States than 
could  be  accommodated.  A  notable  example  is  the  third  call,  which  also  exhausted  the 

10  Chihaia  M.S.,  ‘Advancing  military  mobility  in  Europe:  An  uphill  battle”,  European  Policy  Centre, 
11.4.2023. 
11 PESCO Project “Network of Logistic Hubs in Europe and Support to Operations”. 

9 

 
 
 
military  mobility  envelope  under  CEF,  when  the  demand  for  funding  significantly 
exceeded the available resources, with a heavy oversubscription by a factor of 4.7.12 

Figure 1: Connecting Europe Facility military mobility funding by transport mode  

Note: following Commission Implementing Decision of 7.3.2024 on the selection of Military Mobility projects following 
the 2023 call for proposals for grants under the Connecting Europe Facility - Transport sector pursuant to Implementing 
Decision 
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52025JC0011 

Decision 

C(2023) 

C(2024) 

final. 

1421 

4886 

and 

In  2021,  the  European  Commission  presented  its  proposal  to  revise  the  TEN-T 
Regulation13, another significant achievement. In July 2022, the Commission presented 
an  amended  proposal  reflecting  the  changed  geopolitical  situation.14  Following 
negotiations between the Council and the European Parliament, the amended proposal was 
finally  adopted  in  June  2024.15  The  Regulation  contains  four  key  elements  to  support 
military mobility into, within and beyond the EU:  

12 Commission Implementing Decision of 7.3.2024 on the selection of Military Mobility projects following 
the 2023 call for proposals for grants under the Connecting Europe Facility  - Transport sector pursuant to 
Implementing Decision C(2023) 4886, { C(2024) 1421 final }. 
13  Proposal  for  a  Regulation  of  the  European  Parliament  and  of  the  Council  on  Union  guidelines  for  the 
development of the trans-European transport network (COM (2021) 812), dated 14.12.2021. 
14 Amended proposal for a Regulation of the European Parliament and of the Council on Union guidelines 
for  the  development of  the  trans-European  transport  network,  amending  Regulation  (EU)  2021/1153  and 
Regulation (EU) No 913/2010 and repealing Regulation (EU) 1315/2013 (COM(2022) 384 final). 
15 Regulation (EU) 2024/1679 of the European Parliament and of the Council of 13 June 2024 on Union 
guidelines  for  the  development  of  the  trans-European  transport  network,  amending  Regulations  (EU) 
2021/1153 and (EU) No 913/2010 and repealing Regulation (EU) No 1315/2013 (Text with EEA relevance), 
OJ L, 2024/1679, 28.6.2024. 

10 

 
 
 
 
Firstly,  it  anchors  within  EU  law  the  notion  of  a  (dual-use)  military  mobility  transport 
network;  secondly,  through  its  new  Article  48  on  military  mobility,  it  mandates  the 
Commission  to  identify  possibilities  for  short-notice  large-scale  movements  across  EU, 
including  priority  military  mobility  corridors;  thirdly,  it  sets  the  TEN-T  on  the  path  of 
becoming  a  largely  dual-use  transport  infrastructure  network,  notably  by  requiring 
Member  States  to  consider  military  mobility  needs  when  constructing  or  upgrading 
infrastructure  on  the  TEN-T;  and  fourthly,  it  strengthens  and  aligns  several  transport 
infrastructure requirements with Military Requirements, especially for rail, including the 
migration to European standard gauge (1435mm) in concerned Member States as a key 
military mobility enabler.  

It also extends the TEN-T corridors to neighbouring countries, such as Ukraine, Moldova 
and Western Balkans partners. Four of the nine European Transport Corridors of the TEN-
T  already  extend  into  Ukraine,  with  a  first  set  of  important  investments  ongoing  by 
extending European standard gauge as important dual-use infrastructure enabler.  

Figure 2: TEN-T EU Overview Maps - Mobility and Transport - European Commission 
(2024) 

As announced in the Action Plan on Military Mobility 2.0, the Commission and EEAS, in 
close coordination with NATO’s Joint Support and Enabling Command, identified  four 
Priority  Military  Mobility  Corridors,  which  were  endorsed  by  the  EU  Military 
Committee (EUMC) in October 2024. These new priority corridors were included in the 
revised Annex II of the Military Requirements, which were adopted by the Council on 17 
March 2025. The corridors will better guide and prioritise future investments in the military 
mobility network at both EU and national levels. This will also serve as a stable basis for 

11 

 
 
 
the EU to identify and prioritise dual-use projects with a high added-value and maturity 
for defence. In addition, the EIB’s Strategic European Security Initiative (SESI) might 
play a crucial role in short-term investments for Member States.  

The European Defence Fund (EDF) has financed several projects on digital information 
exchange  systems,  outsized  cargo  airlift,  and  studies  for  future  air  systems.  These 
initiatives contribute to addressing capability shortfalls relevant for military mobility but 
remain at an early developmental stage. The work of projects such as EDF’s project Secure 
Digital Military Mobility System (SDMMS) stands out. The project is receiving EUR 9 
million in funding from the EDF. Project SDMMS stands to be “a comprehensive digital 
solution facilitating the exchange of information on military mobility in an efficient, secure 
and  timely  manner  (during  peacetime).”16  The  system  facilitates  direct  and  secure 
exchange of information between nations requesting and approving the mobility of military 
units, personnel, equipment, and supplies.17  

These  initiatives  also  reflect  the  recommendations  of  the  2024  Coordinated  Annual 
Review on Defence (CARD) report, which points at the need for Member States to “align 
national  planning  timelines  and  develop  multinational  defence  projects,  in  areas  like 
military mobility, strategic enablers and force multipliers.”18 

Military  mobility  has  also  been  consistently  recognised  in  Joint  Declarations  on  EU–
NATO cooperation (201619, 201820, 202321) as a “flagship area”. NATO has repeatedly 
called  for  progress  in  this  field  to  support  alliance  defence  planning  and  reinforcement 
concepts.22  Convened  bi-annually,  the  EU-NATO  Structured  Dialogue  on  Military 
Mobility  provides  effective  framework  to  exchange  on  the  latest  developments  and  to 
explore  areas  of  further  cooperation,  with  a  view  to  ensuring  coherence  and  mutual 
reinforcement. 

1.3  Stakeholder consultation on Military Mobility  

To collect qualitative and quantitative data and feedback on key issues that ought to be 
addressed in the Military Mobility Package 2025 a targeted stakeholder consultation for 
the  Military  Mobility  package  was  conducted  to.  Launched  on  12 June  2025  by  the 
European Commission and the High Representative, it addressed Member States and all 
relevant  actors  including  NATO,  relevant  PESCO  projects,  military  mobility  areas, 
industry,  transport  infrastructure  and  assets  managers,  customs  and  energy  sector 
stakeholders and the financial sector among others. This targeted stakeholder consultation 
encompassed  a  dedicated  online  survey  and  possibility  to  submit  position  papers  and 

16 EDF 2021 Project SDMMS factsheet. 
17 Project Secure Digital Military Mobility System (SDMMS) 
18 European Defence Agency, “Coordinated Annual Review on Defence – Report 2024”. 
19 Joint Declaration on EU-NATO Cooperation by the President of the European Council, the President of 
the European Commission, and the Secretary General of the North Atlantic Treaty Organization, 8.7.2016. 
20 Joint Declaration on EU-NATO Cooperation by the President of the European Council, the President of 
the European Commission, and the Secretary General of the North Atlantic Treaty Organization, 10.7.2018. 
21 Joint Declaration on EU-NATO Cooperation by the President of the European Council, the President of 
the European Commission, and the Secretary General of the North Atlantic Treaty Organization, 09.1.2023. 
22 Van Hoeymissen S. ‘Dual Use and Military Mobility Seminar Report: Fast-tracking Military Mobility’, 
Royal Higher Institute for Defence, 26 April 2024.  

12 

 
 
 
 
written contributions until 31 July 2025. The EEAS and the European Commission also 
conducted a dedicated consultation of Member States until 30 September 2025. 

In  total,  the  Commission  received  107  contributions  to  the  survey,  of  which  39  from 
Member States and 2 from Norway, 36 from companies, 12 from industry associations, 4 
from other organisations. Other contributions included 12 from port authorities, 1 from rail 
authority and 1 representing workers. With regards to sectors represented, where possible 
to  provide  a  specific  allocation,  6  originated  from  air  sector,  3  representing  customs 
authorities, 1 from energy sector, 21 from rail sector, 2 from road sector and 18 from sea 
domain.  

76 position papers were also received in the consultation, 7 from Member States and 69 
from industry, think tanks, and other organisations. Input was also received from NATO. 

The bilateral meetings with the Member States who responded positively to the invitation 
provided  an  opportunity  to  further  discuss  and  deepen  the  understanding  of  the  written 
contributions  provided  and  present  the  aggregate  results  of  the  stakeholder  survey  to 
Member States. In addition to the structured consultation process, the Commission and the 
EEAS met bilaterally with those Member States who wished to avail of the opportunity 
further discuss each of the thematic areas. The bilateral meetings took place in September 
2025 and were organised by the European External Action Service. 

The results of the targeted stakeholder consultation are presented in the Annex.  

2  PROBLEM DEFINITION AND PROBLEM DRIVERS 

Despite political attention and progress achieved since the adoption of the Action Plans, 
the  EU  continues  to  face  a  persistent  and  systemic  overarching  problem:  barriers  to 
movement continue to exist, hindering a guarantee of seamless military movements across 
its territory under operationally relevant timelines.  

This chapter provides a structured analysis of the problems and their drivers. It builds on 
stakeholder input and bibliographical evidence.  

The EU’s approach  to  military mobility  remains fragmented  and insufficiently binding, 
calling for more robust EU-level action to overcome persistent bottlenecks. In broad terms, 
remaining barriers exist in the following areas: 

•  Regulatory  and  administrative  barriers:  cross-border  movement  permissions 
procedures remain lengthy and divergent across Member States, in particular as EU 
rules  are  not  applied  consistently  and  coherently  and  do  not  always  apply  to 
military transport, national regulations diverge, and military transport is not given 
sufficient  priority.  Additionally,  military  transport  operations  have  far  more 
demanding  requirements  than  civilian  ones.  The  lack  of  binding  EU-wide 
procedures  hampers  predictability  and  speed.  In  relation  to  customs  formalities, 
insufficient  use  of  the  EU/NATO  form  302  for  customs  formalities  is  also 
considered  to  be  an  avoidable  obstacle.  Lack  of  digitalisation  of  cross-border 
permissions remains an obstacle increasing the time to handle permissions and the 
risk of errors in the completion of the forms 302. 

13 

 
 
 
•  Infrastructure problems: critical gaps persist in dual-use transport infrastructure, 
particularly along the agreed military corridors. Available funding remains below 
the  level  required  to  meet  identified  needs,  with  load-bearing  requirements  not 
being met; ports, airports, and rail hubs requiring adaptation for outsized military 
equipment; airports and airspace management systems not compliant with military 
requirements.  Resilience  of  dual  use  infrastructure  against  all  types  of  threats 
including cyber and hybrid remains insufficient.  

•  Capability shortfalls: limitations in strategic transport assets (air, rail, sea), rail 
flatbed  availability,  and  inland  waterway  transport  assets  constrain  operational 
readiness. Availability of existing assets is not always guaranteed, alongside with 
a limited availability of existing commercial assets for military use. An absence of 
pooling or pre-contracting mechanisms at EU-level also persists, and there is no 
mechanism providing oversight at EU level of civilian assets with potential dual 
use.  

•  Coordination challenges and the need for a whole-of-government, whole-of-
society approach. The challenges posed by military mobility cannot be addressed 
by defence or transport actors, or by individual Member States, alone and there is 
a need for cross-sectoral coordination among the relevant authorities as much as 
possible,  in  and  among  the  Member  States  and  in  wider  context.  The  current 
approach shows its limitations with the relatively low level of implementation of 
the Technical Arrangements.   

The  correlation  between  (i)  the  causes  (problem  drivers)  and  main  problems;  and  (ii) 
problems, objectives and measures is presented in the two problem trees below.  

14 

 
 
 
 
 
Figure  3:  Problem 

tree 

for 

the  2025  Military  Mobility  Package 

–  Relation 

between  problem  drivers 

and  problems

Source: European Commission

PROBLEM DRIVERSNon-binding nature of arrangements in EDA and MS initiativesCoordination challenges, and the whole-of-government, whole-of-society approachEU legislation in different policy areas not adapted to military mobility needs Absence of clear emergency framework at EU level Inadequate dual use infrastructures for military mobilityLack of emergency definition and uncoordinated approach to address emergencyInsufficient and uncoordinated identification and protection of strategic military mobility infrastructureUnderinvestment or supply shortages of (or gaps in) military mobility capabilities at disposal of EU MSLimited visibility on existing military mobility capabilities (including dual use capabilities) across the EU Inefficiencies in optimal use of military mobility capabilities (including dual use capabilities)PROBLEMSRegulatory fragmentation across MS governing cross-border rules and proceduresProblem 1. Inadequate/incomplete regulatory framework at EU and national levelProblem 2. Limited and vulnerable infrastructuresProblem 3. Low availability of transport assets  
 
 
As detailed above, the identified problems are not confined to a single sector but result 
from  the  interaction  of  multiple  structural  drivers.  Divergent  and  complex  regulatory 
requirements, lengthy and unpredictable authorisation procedures, insufficiently adapted 
dual-use infrastructure, and limited availability of transport capabilities combine to create 
significant delays and uncertainty. The consequences are severe, as they undermine our 
ability  providing  credible  European  deterrence  and  defence,  complicate  EU-NATO 
cooperation,  and  weaken  readiness  in  responding  rapidly  to  crises  and  challenge  the 
Union’s ability in supporting Ukraine. The 2025 Special Report of the European Court of 
Auditors confirmed that progress remains incremental, voluntary measures have reached 
their limits, and national implementation is uneven. 

Figure  4:  “Examples  of  military  mobility  issues  in  the  EU”,  taken  from  ECA  Special 
Report 04/25, p. 7. 

2.1 

Inadequate/incomplete regulatory framework at EU and national level  

The current framework governing the cross-border movement of military personnel and 
equipment  within  the  European  Union  remains  fragmented,  inconsistent,  and  largely 
national in character.  

Each Member State applies its own set of legal requirements, administrative procedures 
and approval timelines for granting movement permissions, issuing diplomatic clearances, 
and  facilitating  customs  formalities.  There  are  inadequacies  in  the  existing  framework 
dealing with the transport of military goods, particularly if dangerous or oversize. These 

 
 
 
 
procedures  often  reflect  institutional  divisions  between  Ministries  of  Defence,  Foreign 
Affairs, Transport and/or Interior. As a result, military transport across several Member 
States  faces  multiple,  unaligned  systems,  often  requiring  successive  rather  than 
parallel  approvals.  This  leads  to  redundant  exchanges  of  information,  duplicated 
documentation, and cumulative lead times that are incompatible  with  operational  needs 
and realities on the field. The current fragmentation governing cross-border movement at 
national level significantly hampers the ability to move troops and equipment across the 
EU,  especially  in  times  of  crises  when  quick  and  decisive  reaction  is  needed  ensuring 
credible deterrence and effective defence. 

Existing alignment and coordination mechanisms among Member States, such as the EDA 
Technical Arrangements, have provided a voluntary framework but remain insufficient to 
deliver the level of coherence required for rapid military mobility. Although the majority 
of Member States have signed these arrangements, they are not legally binding and rely 
entirely on national commitment for their implementation. This voluntary character has 
resulted in uneven application across  the EU. The  Technical  Arrangements  set  out a 
desired  end-state  but  lack  enforceable  obligations,  leaving  Member  States  without  the 
necessary tools or incentives to implement a genuine whole-of-government approach to 
military  mobility.  As  a  consequence,  military  transport  across  the  EU  operates  under  a 
patchwork  of  national  practices  and  arrangements  that  fall  short  of  providing  the  legal 
certainty and predictability needed for cross-border transport at scale and speed. 

Lack  of  clarity  and  transparency  in  procedural  requirements  due  to  national 
differences,  varied  terminology  and  definitions  between  Member  States  complicate 
effective cross-border movement permissions process. Key terms such as “convoy”, “pre-
notification  timeframe”  or  “movement  priority  code”  are  not  uniformly  understood  or 
applied.  The  procedures  themselves  are  often  opaque  and  fragmented  across  different 
administrative entities, leaving sending, transit and host Member States uncertain  about 
the  expected  documentation,  points  of  contact,  and  decision-making  timelines.  This 
unpredictability  also  affects  civilian  authorities  and  operators,  who  must  manage  the 
impact  of  military  movements  on  civil  transport  networks,  infrastructure,  and  safety 
systems. The absence of standardised rules and digital tools (or their limitations for the 
types of transport they cover when they do exist) hampers effective coordination between 
military and civilian actors, increases administrative burden, and risks operational delays 
during both routine and emergency movements. What is more, civilian transport regulatory 
frameworks often do not take into consideration military planning needs.  

The  cumulative  effect  of  these  shortcomings  results  in  a  system  characterised  by  its 
administrative  complexity  and  limited  relative  responsiveness.  These  inefficiencies 
also  impose  unnecessary  administrative  and  financial  costs  on  national  authorities  and 
reduce the credibility of the EU’s defence and deterrence posture. The inadequacy of the 
current  regulatory  environment  manifests  in  slow  and  unpredictable  permission 
processes,  duplication  of  administrative  processes,  and  limited  interoperability 
between  and  coordination  of  national  systems.  It  prevents  the  full  exploitation  of 
synergies between military and civilian transport networks and weakens the EU’s ability 
to act quickly and effectively in a crisis.  

17 

 
 
2.1.1  Regulatory  fragmentation  across  Member  States  governing  cross-border 

rules and procedures 

While  this  challenge  is  clearly  recognised  in  the  Military  Mobility  Action  Plan  2.0, 
regulatory  barriers  remain  a  major  obstacle  to  swift,  efficient,  and  unimpeded 
movement  of  troops  and  equipment  across  and  beyond  the  EU.  At  EU-level,  extensive 
work at technical and regulatory level has been carried out over the decades, especially 
when  it  comes  to  harmonisation.  The  relevant  procedures  that  are  now  apt  for  civilian 
needs will have to reflect the realities of defence-readiness.  

Although  progress  has  been  achieved  through  initiatives  such  as  PESCO  and  EDA 
projects,  the  stakeholder  consultation  results  confirm  that  cross-border  rules  and 
procedures  continue  to  be  fragmented,  slow,  and  insufficiently  harmonised.  This 
decreases military mobility preparedness and the EU’s overall defence readiness posture 
by seriously hampering time-to-movement capabilities and increasing response times.  

Cross-border military consignments face strict administrative rules and procedures, 
especially  for  diplomatic  clearances,  national  rules  related  to  customs  formalities  and 
transporting dangerous or oversized cargo. These rules are often complex, paper-based, 
and not  harmonised across  Member States. Further, military transports  increasingly use 
private  operators  subject  to  civilian  transport  rules,  creating  a  complex  situation  with 
differing  obligations  for  different  operators.  Additionally,  approaches  and  procedures 
standardised  in  the  context  of  NATO  cooperation  do  not  necessarily  align  with  EU 
provisions,  leading  to  the  inefficient  coexistence  of  slightly  different  processes.  These 
barriers generate additional costs and, crucially,  risk causing delays when prompt troop 
and equipment movement is essential. 

Consultation  respondents  from  Member  States  (76.92%)  and  industry  stakeholders 
(58.33%)  identified  customs  clearances  and  movement  permissions  as  critical 
bottlenecks. These barriers are aggravated by divergent national rules for oversized cargo 
and  dangerous  goods.  For  example,  in  Germany,  convoy  movements  require  separate 
permissions  from  each  Federal  State  (Laender),  multiplying  bureaucratic  steps.    Such 
fragmentation  becomes  particularly  problematic  in  situations  requiring  large-scale 
deployments at short notice.   The stakeholder consultation results further revealed that 
both  Member  States  and  industry  see  the  lack  of  a  common  definition  of  “transport 
emergency” as a source of uncertainty.  

Progress towards reducing fragmentation has been demonstrated in ad hoc frameworks, 
such as the NL-DE-PL (or NDP) corridor agreement signed in January 2024, the first 
of six. By abolishing individual cross-border movement permissions and replacing them 
with  standing  authorisations, 
reduced 
administrative  delays,  enhancing  preparedness  and  deterrence  posture.23  This  ‘model’ 
corridor  provides  a  tangible  test  case  for  closer  alignment  of  rules  and  procedures. 
However, these six initiatives remain limited to tri and multilateral agreements and do not 
cover  all  EU  Member  States.  Several  military  mobility  areas  agreements  have  now 
been  signed  (Italy-Albania-North  Macedonia-Bulgaria-Romania;  Greece-Bulgaria-
Romania;  Iceland-Norway-Sweden-Finland-Denmark;  Italy-Slovenia-Croatia-Hungary; 

the  participating  countries  significantly 

23 Hartmann, Jannik. “Military Mobility; Getting Germany’s ­Transportation Infrastructure Up to Speed”, 
German Council on Foreign Relations. 

18 

 
 
 
Romania-Bulgaria-Türkiye).  In  addition,  to  date,  none  of  the  (voluntary)  efforts  to 
harmonise  diplomatic  clearances  have  taken  into  account  the  technical  clearances  or 
arrangements that are essential for a military transport to take place.  

The  regulatory  fragmentation  across  Member  States  persists  as  a  major  cause  of 
delays and inefficiencies in military mobility. The lack of harmonisation in permissions, 
documentation,  and  emergency  procedures,  combined  with  insufficient  digitalisation, 
directly  undermines  the  EU’s  capacity  to  enable  rapid  deployment.24  The  current 
framework remains, thus, overly reliant on national procedures, leading to systemic delays 
that reduce preparedness, deterrence, and the EU’s credibility as a security actor.  

2.1.2  Non-binding  nature  of  arrangements  in  European  Defence  Agency  and 

Member States’ initiatives 

Member  States  preserve  the  prerogative  for  allowing  the  passage  of  foreign  troops  and 
military materiel through their territories. To obtain the right of passage, foreign troops 
therefore need to obtain specific approvals from the ‘host’ nation. These are referred to as 
diplomatic clearances for cross-border movement permissions.  

While in the past the processes for obtaining such diplomatic clearances differed widely 
among EU Member States, important harmonisation work has been done recently by the 
European Defence Agency (EDA). Most notably, the forms used by Member States for 
requesting such cross-border movement permissions have been harmonised, but also the 
timelines for responding to such requests have been streamlined.   

To this end, the EDA developed the aforementioned Technical Arrangements: one for 
movements  over  land  (TA  Surface),  one  for  movements  by  air  (TA  Air),  and  one  or 
movements by sea (TA Sea) and one for movements by air (TA Air). However, the use of 
these forms remains voluntary, and several Member States or regional authorities request 
additional forms in practice.   

The Commission has been involved in the development of these Technical Arrangements, 
in relation to the rules relating to the transport of dangerous goods. The legal framework 
for  the  transport  of  dangerous  goods  by  road,  rail  and  inland  waterways  is  Directive 
2008/68/EC, which in turn transposes into EU law several international agreements on the 
subject,  namely,  for  road  transports  the  ‘Agreement  Concerning  the  International 
Carriage of Dangerous Goods by Road’ (ADR); for rail transport, it is the Regulation 
concerning the International Carriage of Dangerous Goods by Rail (RID), as well as 
dedicated technical specifications for infrastructure and rolling stock; for inland waterway 
transport,  it  is  the  European  Agreement  Concerning  the  International  Carriage  of 
Dangerous Goods by Inland Waterways (ADN). As far as air transport is concerned, 
European rules regarding the transport of dangerous goods can be found in Commission 
Regulation  (EU)  No  965/2012  on  Air  Operations25.  This  Regulation  mandates 

24   CEPA  Task  Group,  “The  CEPA  Military  Mobility  Project;  moving  mountains  for  Europe‘s  defense”, 
March 2021. 
25 Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and 
administrative procedures related to air operations pursuant to Regulation (EC) No 216/2008 of the European 
Parliament and of the Council, OJ L 296, 25.10.2012, p. 1.  

19 

 
 
 
 
 
compliance  with  ICAO  Technical  Instructions  (Doc  9284)  for  the  Safe  Transport  of 
Dangerous Goods by Air.  

These  international  agreements,  and  consequently  Directive  2008/68/EC,  set  rules 
harmonising the procedures for the transport of dangerous goods across EU Member 
States. However, transport performed under the orders or responsibility of military forces 
are excluded, although ammunition and fuels are classified as “dangerous goods”. Such 
military transport therefore tends to require ad hoc national authorisations which creates 
uncertainties  and  delays.  The  Technical  Arrangements  try  to  remedy  this  situation  by 
harmonising the rules and procedures for the transport of dangerous goods also in relation 
to  transports  that  are  performed  under  the  orders  or  responsibility  of  military  forces. 
Moreover, oversized or overweight transport is not included in the scope of the Technical 
Arrangements.  The  absence  of  military  needs  and  requirements  when  it  comes  to 
dangerous goods’ transport legislation also serves as a powerful driving force behind the 
need for EU-level legislative action. 

The  ‘TA  Sea’  for  the  maritime  domain  is  in  an  advanced  state  of  negotiation.  Recent 
updates to the TA Surface forms have further streamlined the process for obtaining annual 
diplomatic. It will also trigger an amendment of the Programme Arrangement. 

The  progress  in  implementation  of  the  signed  TAs  is  monitored  by  the  EDA 
Implementation  Monitoring  Matrix.  The  network  of  national  point-of-contacts  for 
military mobility provides feedback from the Member States.  

Member States are also co-ordinating their national efforts on a strategic level through the 
PESCO project on Military Mobility. This has led to the establishment of a National 
Point of Contact Network, which plays a strong role in testing and using the Cross Border 
Movement Permission Technical Arrangements. 

While substantial progress has been made in the EDA and PESCO frameworks, their non-
binding character represents a major structural weakness. The achieved alignment is 
often hampered in the implementation phase, by lack of translation of the agreed objectives 
into  national  law,  especially  where  they  concern  areas  other  than  those  falling  into  the 
remit of Ministries of Defence.  

Despite repeated pledges, including the 2024 Military Mobility Pledge and the Action Plan 
on  Military  Mobility  2.0,  Member  States’  political  commitments  have  not  been 
matched  by  coherent  implementation  or  systematic  reporting.  Consultation  data 
confirm  persistent  bottlenecks:  64.1%  of  respondents  from  Member  States  and  70.83% 
from industry cited infrastructure deficiencies, while 76.92% of respondents from Member 
States  identified  administrative  procedures  as  a  major  obstacle,  highlighting  the  gap 
between declarations and practice.  

The European Court of Auditors likewise called for a more focused prioritisation of EU 
funding  and  the  improvement  of  selection  of  dual-use  projects  along  strategic 
corridors.  Stakeholder  consultation  reflects  this  perception:  national  implementation 
remains fragmented, with 76.92% of respondents from Member States relying on ad-hoc 
coordination rather than whole-of-government structures, while EU-level reporting has not 
yet produced comparable data on readiness or time-to-movement. Weak follow-through 

20 

 
 
on political commitments, combined with insufficient monitoring, sustains capability gaps 
and undermines EU credibility on military mobility. 

Overall, the reliance on non-binding arrangements leads to fragmented rules, procedural 
delays, and unnecessary administrative and financial costs. Most critically, it undermines 
operational readiness by slowing down the rapid, large-scale, and coordinated movement 
of forces and equipment across the EU. 

2.1.3  EU legislation in different policy areas not adapted to military mobility needs 

Military mobility also remains hindered by the limited adaptation of EU legislation in 
relevant policy areas to the specific needs of armed forces. Existing rules designed for 
civilian  transport,  trade,  taxation  and  customs  do  not  sufficiently  address  operational 
requirements  of  military  movements  in  various  scenarios.  The  armed  forces  also 
significantly  depend  on  civilian  operators  for  their  military  transport  operations.  This 
creates legal uncertainty and systemic delays when Member States attempt to reconcile 
civilian rules and obligations with urgent military transport demands.  

Researchers  point  that  “in  this  context,  Europeans  need  to  enhance  their  defence 
capabilities  dramatically  and  become  more  self-reliant.  Immediate  priorities  include 
[…]ensuring  enablement,  including  through  enhanced  military  mobility.  Further 
improvements  here  are  vital,  for  example,  it  still  takes  about  60  days  to  transport  an 
equipment convoy from a French military site to the Cincu training centre in Romania.” 26 
27 

In  the  European  transport  network,  infrastructure,  assets  and  services  are  often  shared 
between civilian and military users. This shared, and thus limited availability can lead to 
conflicting demands. Today, however, rules on priority access are either patchy or non-
existent  for  most  transport  modes.  There  is  no  specific  EU  legislation  granting  priority 
access to maritime ports and their facilities. In the rail sector, while access rules for track 
and service facilities and arbitration processes are harmonised28, existing legislation does 
not  include  derogations  for  military  transports.  In  the  aviation  sector,  Member  States 
already have the possibility to restrict traffic rights for commercial aviation to deal with 
sudden  problems  of  short  duration  resulting  from  unforeseeable  and  unavoidable 
circumstances, but this is limited to a maximum of 14 days at a time and procedures to 
renew such emergency measures can be burdensome.29 As a result, military transports may 
face delays when competing with civilian traffic for the use of transport infrastructure in 
emergency situations.  

In  the  Military  Mobility  Pledge  of  May  2024,  Member  States  committed  to  “ensure  a 
prioritised access of the armed forces to  relevant transport modes, networks and assets, 
including  required  airspace,  also  through  the  EU  regulatory  framework,  in  support  of 
national efforts, most notably in times of crisis and conflict and where possible already in 
peacetime,  in  full  respect  of  the  sovereignty  of  EU  Member  States  over  their  national 

26 Chiahia, M., “Military Mobility, a critical enabler”, European Policy Centre, June 2025. 
27  Elie  Tenenbaum  and  Amélie  Zima,  “Return  to  the  East:  the  Russian  Threat  and  the  French  Pivot  to 
Europe’s Eastern Flank,” IFRI, June 2024, p. 59. 
28 Directive 2012/34/EU of the European Parliament and of the Council of 21 November 2012 establishing 
a single European railway area and its implementing legislation. 
29 Regulation (EC) No 1008/2008. 

21 

 
 
 
territory and national decision-making processes regarding military movements. To this 
end,  Member  States  should  ensure  the  availability  of  the  necessary  capacity,  inter  alia 
through establishing strategic partnerships, including joint or national initiatives, notably 
framework contracts with the civilian transport providers.”  

This  commitment  was  reflected  in  the  Commission's  proposal  for  a  Rail  Capacity 
Regulation (RCR). In relation to this proposal, which foresees priority access for military 
trains  in  times  of  crisis,  Member  States  and  industry  expressed  differing  views  on  the 
possibility of extending such rules to other transport modes.  

In  addition  to  the  limited  implementation  of  the  pledge  to  issue  diplomatic  clearances 
within 3 working days, cross-border rail movements are further hampered by the absence 
of parallel binding deadlines to allocate train paths for such transports, especially when a 
specific  authorisation  is  required  foran  exceptional  transport30,  which  is  currently  not 
covered  by  harmonised  European  rules  and  thus  subject  to  unharmonised  national 
processes. 

Consultation  respondents  from  Member  States  (76.92%)  and  industry  stakeholders 
(58.33%) identified movement permissions and customs clearances as sources of delay 
in  military  transport.  These  barriers  are  aggravated  by  divergent  national  rules  for 
oversized  cargo  and  military  carriage  of  dangerous  goods.  For  example,  in  Germany, 
convoy  movements  require  separate  permissions  from  each  Federal  State  (lander), 
multiplying  bureaucratic  steps.  A  practical  case  illustrates  this  challenge:  a  convoy 
travelling  from  the  Netherlands  to  Lithuania  must  obtain  permissions  from  all  transit 
countries (and transit sub-regions) individually, often resulting in significant delays. Such 
fragmentation  becomes  particularly  problematic  in  situations  requiring  large-scale 
deployments at short notice.  

As a result, military operators face delays when competing with civilian traffic for the use 
of critical infrastructure such as ports, rail hubs or airports. For air military mobility, the 
lack  of  predefined  cross-border  connections,  covering  the  whole  EU,  prevents  swifter 
military transport operations (i.e. for transport aircraft, fighters, drones, air to air refuelling) 
while it could minimize the impact of such operations on civilian traffic within the EU air 
traffic  management  network.  In  the  area  of  unmanned  aircraft  systems,  regulatory 
fragmentation  hinders  the  effective  use  for  dual-use  transport.  The  current  certification 
process  for  dual-use  drones  is  fragmented,  with  national  military  authorities  certifying 
drones in an un-coordinated manner, creating a risk of non-alignment with future civilian 
regulations.  Moreover,  there  is  currently  no  harmonised  approach  to  the  integration  of 
drones in low altitude airspaces and U-space, which is a complex issue, requiring a joint 
framework for safe sharing of airspace between civil and military users. 

The divergence of national rules is especially evident in the transport of oversized and 
overweight  cargo,  and  of  dangerous  goods  in  the  military  domain.  Despite  some 
facilitation measures at EU level, consultation feedback shows that delays persist: 64.1% 

30 Exceptional transport is defined as ‘a vehicle and/or the load carried which because of construction/design, 
dimensions  or  weight  does  not  meet  the  parameters  of  the  route  and  requires  special  authority  for  the 
movement and may require special conditions over part or its entire journey’ in Commission Implementing 
Regulation (EU) 2019/773 of 16 May 2019 on the technical specification for interoperability relating to the 
operation  and  traffic  management  subsystem  of  the  rail  system  within  the  European  Union,  OJ  L  139I 
27.5.2019, p. 5.  

22 

 
 
 
of Member States and 47.92% of industry stakeholders supported conditional relaxation or 
rules for dangerous goods transport, but only in wartime or crisis scenarios. This highlights 
both  the  operational  importance  of  flexibility  and  the  lack  of  a  clear,  harmonised  legal 
mechanism to apply it.  

In  the  context  of  the  Technical  Arrangements  on  Cross  Border  Movement 
Permissions, applicable to  movements  by road, rail, inland waterways,  air and sea, the 
signing Member States agreed to voluntarily apply the civil legislation on the transport 
of  dangerous  goods  by  different  transport  modes  to  military  transport.  While  this 
represented an important step forward, the voluntary nature of the Arrangements and the 
fact that many Member States still require additional formalities mean that there is still 
significant legal uncertainty for cross-border military consignments containing dangerous 
goods.  

The Weights and Dimensions Directive regulates the issuing of authorisations by Member 
States for civil road transport of indivisible loads where cargo/vehicles exceed the limits 
set in the Directive, i.e. the maximum weight, length, width, or height for standard heavy-
duty  vehicles.  Such  transport  may  require  a  special  permit  issued  by  the  competent 
authorities in each of the transited Member States. The authorities competent to issue these 
permits and the procedure to submit the request and obtain the permits are not harmonised. 
There can be a single national authority or several regional or local authorities, and there 
are variations in the documentation and information requested, its format (paper or digital), 
the conditions assigned to each type of permit (marking, escort, axle weights and spacing, 
etc), the type of permit issued (long-term permits vs one-time/one-route permits) and the 
time to obtain those permits (from 1-2 weeks to 12 weeks) depending on the Member State 
and their national rules.   

As regards rail transport, when the dimensions/weight of the transported goods are outside 
the declared parameters of a line, such cargo transports can only be authorised under time 
consuming, manual route compatibility checks. 

Military mobility is also affected by rules on cabotage, i.e. any road transport by a motor 
vehicle  registered  in  a  country  performed  on  the  national  territory  of  another  country. 
Current rules on civilian cabotage operations by road as laid down in Regulation (EC) No 
1072/2009 impose restrictions on how long a road haulier from a different Member State 
can operate in another Member State.  This is relevant for military transport insofar as the 
armed forces rely significantly on civilian operators. While military movements carried 
out  by  the  armed  forces  themselves  are  already  excluded  from  cabotage  rules,  civilian 
operations  under  the  responsibility  of  the  military  are  not.  This  means  that  cabotage 
restrictions  might  limit  the  operational  flexibility  of  the  military  and  create  additional 
delays. 

The  EU  Form  302  and  NATO  Form  302  are  a  facilitation  of  the  regular  customs 
formalities for the arrival,  movement or use of goods for official military purposes. They 
therefore fall under the exemptions provided by the Union Customs Code (UCC) or the 
NATO Status of Forces Agreement (SOFA). However, the application of Form 302-based 
simplified  formalities  remains  inconsistent  across  the  EU,  due  to  on  the  one  hand  the 
failure by economic operators to use this facilitation and, on the other hand, the lack of 
harmonised  application  by  Member  States’  customs  authorities  of  the  Form  302.  This 

23 

 
 
results in unpredictable delays, increased administrative burden, and a fragmentation of 
military logistics.  

Formalities applicable at the border remain a source of systemic delays. Although customs 
facilitation  measures  have  been  introduced,  76.92%  of  Member  States  and  58.33%  of 
industry stakeholders still identified customs clearance as a major obstacle. Current EU 
legislation does not provide sufficient mechanisms for further speeding up the treatment 
of  the  EU/NATO  form  302  or  for  expedited  procedures  or  waived  requirements  in 
emergency situations, leaving military movements vulnerable to delays due to customs or 
other  non-fiscal  legislation  applicable  at  the  border.  A  specific  example  concerns  the 
import of food supplies for NATO troops stationed in the EU: existing rules include the 
obligation to control every consignment of certain goods entering the Union territory and 
do not provide for any exemption or facilitation during emergency situations. The lack of 
digitalisation of cross border permissions and customs formalities is an area stakeholders 
point to as an additional source of delays.  

This is particularly true when it comes to food imports, especially on the alimentation of 
NATO/non-EU troops. All shipments of animals, food of animal origin and certain other 
foodstuffs and plant products must be presented at border control (the first entry point into 
the EU) posts (BCPs) to verify compliance with  EU legislation relating in  particular  to 
public health, animal health and plant health. In times of an enhanced deterrence situation, 
these requirements can lead to delays that contradict the quick and seamless food supply 
of NATO/non-EU troops. 

Military experts from Member States have developed, within the framework of EDA, the 
military requirements for a Digital Military Customs System. This document has been 
endorsed  in  the  EDA  Programme  on  Harmonising  Military  Requirements  related  to 
Customs  by  25  Member  States  as  well  as  Norway.  Its  content  will  be  assessed  against 
applicable customs legislation to determine how it can reinforce potential digitalisation. 

Liquid  fuels  and  in  particular  jet  fuel  will  remain  vital  for  military  operations  in  the 
upcoming decades.  This reliance on jet fuel will continue in the future given the lack of 
available alternative technologies for aviation. The energy transition has to be effectively 
managed without limiting military readiness and defence capabilities. 

The  EU  has  an  interest  in  encouraging  local  production  of  Sustainable  Aviation  Fuel 
(SAF) to improve energy security. The ReFuelEU mandate for sustainable aviation fuel 
(SAF) uptake represents long-term trajectory to create a SAF EU market. In addition, the 
Sustainable  Transport  Investment  Plan  (November  2025)  will  be  one  of  the  key 
instruments to develop SAF production in the EU. However, it is unlikely that 100% of 
EU SAF consumption could be covered by EU production and Europe’s current reliance 
on imports for fuels is expected to remain. 

The Action Plan on Military Mobility 2.0, the Niinistö Report from 2024 and the White 
Paper for European Defence Readiness 2030 from 2025 highlight that Europe’s military 
preparedness called for a more detailed consideration of fuel infrastructure, the challenges 
posed  to  fuel  supply  by  war  conditions,  and  the  means  by  which  deficiencies  can  be 

24 

 
 
addressed in a timely manner. Additionally, the NIS2  Directive31 identifies energy as one 
of eighteen critical sectors for which cybersecurity requirements apply. Pursuant to 
the NIS2 Directive, the energy sector, includes oil production, storage and transmission 
pipelines, as well as electricity, district heating and cooling, gas and hydrogen subsectors.  

Current  transport  and  fuel  supply  infrastructure  on  the  EU’s  eastern  Flank  and  fuel 
connectivity between East and West is insufficient for a potential high-intensity conflict. 
The military fuel pipeline systems across European countries lack in geographical scope, 
especially within the main military corridors defined by Military Mobility Action Plan 2.0 
towards the eastern flank.  

The energy EU legal framework, such as Directive 2009/119/EC on oil stocks, has been 
designed  around  security  of  supply  of  the  civil  market,  market  efficiency  and 
decarbonisation. It provides no harmonised provisions for ensuring access to fuel supplies 
by  armed  forces  in  times  of  crisis,  this  being  left  for  national  legislation.  Consultation 
results show that 61.54% of Member States already report difficulties in ensuring sufficient 
access to fuel, particularly on the EU’s eastern flank, with industry stakeholders raising 
concerns about insufficient refining capacity and supply chain vulnerabilities. 

The aforementioned fuel supply vulnerabilities pose an acute strategic risk. The lack of 
reliable storage and pipeline connections along strategic corridors (particularly in eastern 
Europe) threatens to sever logistical chains in prolonged “transport crises”. Dependence 
on shrinking refining capacity in Western Europe exposes the EU to external supply shocks 
at a time when resilience is most needed.  

Digitalisation,  while  broadly  supported  as  an  enabler  of  harmonisation,  remains 
underdeveloped.  Although 69% of Member States and 47% of industries supported the 
establishment of a digital tool for cross-border permissions, concerns about cybersecurity, 
NATO  compatibility,  and  fallback  mechanisms  persist.  The  absence  of  a  binding, 
interoperable digital framework reinforces  dependence on fragmented national  systems, 
limiting the ability to accelerate prioritisation and permissions in emergencies. 

Absence  of  harmonised  digital  systems  and  slow  clearance  processes  compound  very 
tangible, physical bottlenecks, leading to convoys facing unpredictable delays at borders, 
undermining coordination between Member States and NATO allies.  

To  characterise  this  specific  problem  driver:  EU  legislation  in  areas  such  as  transport, 
customs,  energy,  and  digitalisation  does  not  adequately  integrate  military  mobility 
requirements.  The  lack  of  harmonised  prioritisation  rules,  unclear  procedures  for  crisis 
situations, and absence of binding obligations (see referred problems with TAs) to ensure 
military  access  to  critical  infrastructure  collectively  undermine  operational  readiness, 
deterrence posture, and the EU’s capacity to respond rapidly to emerging security threats. 

A  finding  of  the  Seminar  on  Dual-Use  Capabilities  and  Military  Mobility  hosted  in 
February 2024 by the Belgian Presidency of the Council was that “information sharing is 
a challenge in military mobility both on the operational and strategic level. Differences in 
the  classification  cultures  between  NATO  and  the  EU,  as  well  as  bilateral  sensitivities 

31 Directive (EU) 2022/2555 of the European Parliament and of the Council on measures for a high common 
level  of  cybersecurity  across  the  Union,  amending  Regulation  (EU)  No  910/2014  and  Directive  (EU) 
2018/1972, and repealing Directive (EU) 2016/1148. 

25 

 
 
 
between  their  respective  members,  preclude  the  sharing  of  plans  and  complicate 
streamlined flows of information. Recurrent information sharing is also required between 
the  two  PESCO  projects  involved.  Too  often,  the  exchange  of  information  relies  on 
personal relations between individual staff members. Enduring cooperation and the long-
term retention of lessons learnt during exercises and operations requires the expansion and 
formalisation of interinstitutional, international and interdepartmental working relations. 
Therefore,  a  comprehensive  and  permanent  information  sharing  platform  must  be 
considered.”32 

Work on digitalisation continues on the EDF project “Secure Digital Military Mobility 
System” (SDMMS) for exchanging information related to military mobility. The project 
is  receiving EUR 9 million  in  funding  from  the  EDF. Project  SDMMS stands to  be “a 
comprehensive  digital  solution  facilitating  the  exchange  of  information  on  military 
mobility  in  an  efficient,  secure  and  timely  manner  (during  peacetime).”  The  system 
facilitates  direct  and  secure  exchange  of  information  between  nations  requesting  and 
approving  the  mobility  of  military  units,  personnel,  equipment,  and  supplies.  The 
consortium is formed by a group of 11 organisations from 10 EU Member States (BG, CZ, 
EE, DE, LV, LT, LU, PL, NL, RO) and Norway as an associated country.33  

The project aims at a “secure and digital sharing of form 302 data among countries and 
between  customs  and  military  agencies”  and  “full  processing  of  diplomatic  clearance, 
deployment  permits,  and  annual  permit  documents  for  sea,  air,  and  surface  modes  of 
transportation”  while  introducing  a  federated  system  architecture.  As  an  important 
achievement, the project introduces “automated data exchange with LOGFAS EVE and 
other  national  systems.”  SDMMS  is  designed  to  handle  the  processing  of  movement 
requests and approvals for various types of missions, including: 

•  Permit to deploy 
•  Request to visit (for personnel visiting foreign bases) 
•  Diplomatic Clearance for military and state aircraft 
•  Diplomatic Clearance for military vessels 
•  Authorisation for convoy and oversized/overweight movements 
•  Permission for rail and inland waterway movement 

61.54% of Member States reported participating in bilateral and/or multilateral agreements 
in place that simplify such procedures, while the vast majority of Industry reported that the 
inquiry  was  not  relevant.  The  most  common  frameworks  for  participations  were: 
Permanent  Structured  Cooperation  (PESCO),  EDA  Customs,  “Secure  Digital  Military 
Mobility  System”  (SDMMS),  and  CBMP,  NORDERFO  and  NATO’s  Joint  Support 
Enabling Command (JSEC). 

In July 2025, a separate consultation procedure with the customs administrations of 
the  Member  States  took  place  about  the  measures  they  have  taken  or  intend  to  take  to 
ensure the correct use of Forms 302. National customs administrations were requested to 

32 Van Hoeymissen S. ‘Dual Use and Military Mobility Seminar Report: Fast-tracking Military Mobility’, 
Ibid. 
33 Secure Digital Military Mobility System (SDMMS). 

26 

 
 
 
report on any other issue that may have arisen at national level in connection with the use 
of these Forms. The outcome of the consultation procedure is summarised below.  

Member States have Confirmed that the form 302 is being used as per the instructions in 
the relevant  EU guidance document, without major issues. The guidance document has 
been uploaded on the websites of the national customs administrations, accompanied, in 
most  of  the  cases,  with  national  instructions  and,  more  rarely,  with  national  legal  acts. 
Dedicated training for the customs officers are organised at national level, as well. The 
customs  authorities  give  priority  to  military  consignments  and  they  maintain  close 
cooperation with the competent military authorities, to facilitate the military consignments 
and address effectively and efficiently any possible incidents on the field.  

According to the majority of the Member States, no significant delays in the transborder 
movements of military goods covered by a 302 Form have been encountered. However, 
some incidents have been reported by few Member States. One Member State stated that 
the customs authorities do not receive any notification by the NATO forces at destination, 
systematically; those NATO movements are discharged, from a customs point of view, by 
alternative  evidence  (the  local  NATO  forces  take  responsibility  for  the  movements). 
Another  Member  State  reported  vagueness  of  the  descriptions  of  the  goods,  incorrect 
declaration  of  the  country  of  destination,  missing  signatures  and  lack  of  shipping 
documents, which may cause delays in the process. A Member State further referred to the 
fact  that  the  form  is  filled  in  by  hand,  which  makes  its  reading  difficult.  Yet  another 
Member State reported one case where the form covered many trucks arriving with a time 
difference at the external borders of the EU (towards a non-Union country), however the 
form  was  presented  to  customs  with  one  of  the  last  trucks.  In  addition,  non-customs 
requirements for the movement of the goods (e.g. prohibitions and restrictions) have been 
reported as a main obstacle for the smooth flow of goods. In many cases there are national 
requirements applicable even to the intra-Union movement of goods. 

To solve these issues, Member States stated that a digitalised environment for Form 302, 
allowing for automated  processing and risk analysis and speeding  up the release of the 
goods, would be welcome. Emphasis has been given to the need for timely and accurate 
provision of information on the military movement of goods by the competent authorities 
of the exporting country, in accordance with the established rules of the European Union 
and the NATO. The quality and completeness of the data provided in Forms 302 play a 
key role in assessing the possibility of their acceptance without delay. One Member State 
would encourage the publication of common guidance for customs and military authorities, 
for a common understanding of the various rules and processes. It was also suggested that 
the non-fiscal requirements be reconsidered by the national authorities, both customs and 
other than customs, when it comes to goods moved in the context of military missions. An 
EU Regulation providing for a waiver from or mitigation of the above requirements at EU 
level would be welcome. 

2.1.3.1  Lack  of  an  emergency  definition  and  uncoordinated  approach  to  address 
emergencies;  absence  of  its  corresponding  clear  emergency  framework  at  EU 
level 

The Seminar on Dual-Use Capabilities and Military Mobility hosted on February 2024 
by the Belgian Presidency of the Council revealed that “EU Member States understand key 
concepts differently when discussing military mobility. The coherent implementation of 

27 

 
 
the actions identified in the Action Plan 2.0 and beyond requires Member States to have a 
shared understanding of the legal and administrative concepts that define their actions.”34 
“In the continuum between peace and war, the extremes will cause the fewest problems 
for military mobility. In times of peace, military transports are limited and can be planned 
and prepared for well in advance. In times of war, administrative burdens and legislative 
hurdles will become largely irrelevant. The most challenging situation is the ‘in-between 
phase’. In a crisis, such as we find ourselves in today, we face a higher demand for military 
movements, but without a clear-cut legal basis to prioritise military over civilian traffic.”35 

A major structural shortcoming in the current regulatory environment is the absence of a 
definition  of  emergency  situation  and  its  associated  framework.  Critical  challenges 
arise when the demand for military movements surges but legal basis for armed forces’ 
activities remain unclear. This gap sustains divergent national practices, legal uncertainty, 
and procedural  delays at precisely the moment  when rapid  deployment  is  most needed. 
The stakeholders in the targeted consultation also pointed to the lack of such definition as 
a problem. 

Even if, for the purpose of the functioning of the internal market, Regulation 2024/2747 or 
IMERA (Internal Market Emergency and Resilience Act) proposes a definition of “internal 
market  emergency  mode”36,  the  absence  of  a  “military  transport  emergency  situation” 
definition  and  framework  constitutes  a  fundamental  problem  driver.  It  sustains 
fragmentation, generates uncertainty for both civilian and military operators, and prevents 
the  EU  from  reacting  with  the  speed  and  coherence  required  in  crisis  scenarios. 
Establishing such a definition, with its corresponding framework graduating its levels of 
urgency and pre-defined rules, is  essential to reduce bureaucratic burdens, and enhance 
readiness. 

2.2  Limited and vulnerable infrastructure  

The effectiveness of military mobility depends not only on the existence of harmonised 
rules  and  procedures  at  EU  level,  but  also  on  the  availability  and  resilience  of  the 
underlying infrastructure. The ability to move military personnel and equipment at scale 
and  speed  across  Member  States  and  beyond  presupposes  that  the  transport  network 
(comprising  roads,  railways,  ports,  airports,  airspace  structures,  logistics  hubs,  bridges, 
tunnels,  fuel  support  infrastructure,  or  storage  facilities)  can  support  such  movements 
under a wide range of circumstances. In practice, the infrastructure necessary for military 
mobility remains limited in capacity, unevenly distributed, and in many cases vulnerable 
to disruption or degradation. 

The EU has already taken important steps and has developed a tested intervention logic to 
address physical and technical barriers to military mobility through initiatives such as the 
military mobility priority corridors and the financing of dual-use infrastructure under the 
Connecting Europe Facility (CEF). However, the investment needs substantially exceed 
the available budget.  

Infrastructure that enables these corridors remains highly exposed to a wide range 
of  risks.  Its  dual-use  character  means  that  most  assets  serve  both  civilian  and  military 

34 Van Hoeymissen S, Ibid. 
35 Van Hoymissen S., Ibid. 
36 Regulation 2024/2747 or Internal Market Emergency and Resilience Act 

28 

 
 
 
purposes,  making  them  critical  not  only  for  defence  and  security  but  also  for  the 
functioning  of  the  internal  market.  As  a  result,  disruptions  caused  by  natural  hazards, 
technical  failures, or deliberate hostile actions  including  cyber and hybrid threats  could 
have  cascading  effects  across  multiple  sectors.  The  strategic  importance  of  certain 
transport nodes, fuel depots, logistics hubs and communication systems further increases 
their attractiveness as potential targets. 

At present, the level of protection of dual use infrastructure is not sufficient to face the 
possible impacts of the threats. While the Council, in cooperation with the Commission 
and the EUMS and in consultation with NATO, has identified priority military mobility 
corridors, the supporting infrastructure along these corridors has not yet been prioritised 
or classified according to its criticality for military operations. This absence of a clear and 
coordinated approach leaves Member States to make such assessments individually, often 
based  on  differing  criteria,  methodologies,  and  levels  of  ambition.  The  result  is  a 
fragmented picture in which some assets receive high levels of protection while others (that 
may result of equal or greater strategic importance) remain insufficiently safeguarded. 

The  vulnerability  of  this  infrastructure  is  compounded  by  the  absence  of  binding, 
harmonised resilience measures specifically tailored to the needs of military mobility. 
The existing EU framework established by Directive 2022/2557 on the resilience of critical 
entities (CER Directive) sets horizontal requirements for the protection of critical entities 
across several sectors, including transport. However, this Directive was not designed to 
address  the  specificities  of  infrastructure  that  supports  military  mobility,  nor  the 
operational  demands  associated  with  defence-related  transport.  Many  assets  that  are 
essential for military purposes (e.g. logistics terminals, including loading and unloading 
infrastructure, refuelling depots, or specific rail and port facilities) are outside the scope of 
the Directive and the entities operating them might not be identified as critical entities by 
Member States.  Even in cases where such infrastructure is covered by the Directive, the 
required resilience-enhancing measures to be adopted may not fully reflect the security, 
confidentiality and interoperability needs of the military domain. 

This  gap  leaves  significant  segments  of  the  military  mobility  network  exposed  to 
vulnerabilities. Infrastructure that is essential for the rapid deployment or reinforcement 
of forces could be rendered unavailable through different kinds of intentional (i.e. hybrid) 
disruption, with obvious consequences for the EU’s capacity to respond to crises. The lack 
of  dedicated  military  resilience  standards  also  limits  Member  States’  ability  to  plan 
preventive measures, allocate resources effectively, and ensure that civilian infrastructure 
can reliably support defence movements under stress. 

Ensuring the resilience and protection  of such infrastructure cannot be considered solely 
a national responsibility as military mobility is inherently cross-border: the interruption 
of one critical node can disrupt entire corridors connecting multiple Member States. 
A purely national approach to infrastructure resilience therefore risks creating weak links 
in  an  otherwise  robust  chain.  The  high  cost  of  securing  all  potentially  relevant  assets 
underlines  the  need  for  prioritisation:  comprehensive  protection  of  every  piece  of 
infrastructure used for military movements is neither feasible nor proportionate.  

This situation creates a structural vulnerability in the EU’s defence posture. The lack of 
sufficient  level  of  resilience  and  protection    of  (strategic)  dual  use  infrastructure 

29 

 
 
undermines  the  continuity  of  cross-border  operations,  and  exposes  critical  civilian 
infrastructure to risks that could have both security and economic consequences. 

2.2.1 

Inadequate dual-use infrastructure for military mobility 

The great majority of the EU’s transport network - and many of the vehicles used on it - is 
dual-use - i.e. used for both civilian and military transport purposes. Such infrastructure 
is  very  expensive  to  construct  and  to  maintain,  and  thus  in  the  apparent  absence  of 
substantial military need, its fitness for military purposes became a lower priority.  Work 
to address this is now well under way (see sections above), but the scale of work - and need 
to keep the transport system operational - require European prioritisation and coordination.  
In  addition,  the  development  of  highly  centralised  control  systems,  while  economically 
optimal, creates new vulnerabilities which must managed.37 The large-scale transport of 
such assets at scale and speed over longer distances requires adequate infrastructure, which 
“must be resilient enough to continue providing the essential services that underpin the 
EU’s  economy  while  also  enhancing  its  competitiveness  and  meeting  the  increased 
demands of the military forces. This includes withstanding potential attacks.”38 

The  EUR  1.7  billion  under  the  current  MFF  allocated  to  support  dual-use  transport 
infrastructure  through  the  Connecting  Europe  Facility  (CEF).  Although  the  military 
mobility budget was initially planned along five calls of EUR 330 each, given Russia’s 
war of aggression against  Ukraine the military mobility  budget was frontloaded  as  of 
2022 and fully spent out in three calls in order to expedite and maximise support to such 
dual-use military and civilian transport infrastructure projects. 

Together with the CEF expenditure of the first ever military mobility budget, important 
improvements to the military network have been realised. However, a takeaway from the 
calls under that envelope, which also echoes ECA’s recommendations included in the 2025 
audit report, indicated that a more strategic targeting of the investments was needed for the 
better use of the limited funding available, and ultimately to speed up the development of 
a well-structured, continuous and coherent military mobility network.    

To  add  to  the  aforementioned  identification  of  the  four  priority  military  mobility 
corridors, adopted in March 2025 by the Council as part of the EU Military Requirements 
for Military Mobility, the Commission started identifying the main gaps and bottlenecks 
on  the  priority  corridors.  Together  with  the  Ministries  of  Transport  and  Ministries  of 
Defence of Member States, and in cooperation with NATO and EUMS, a list of "hotspots" 
has  been  developed  to  determine  the  most  urgent  investment  needs  along  the  EU 
military mobility corridors. This list of approximately 500 projects concerns targeted and 
particularly  short-term  quick-win  investments  to  bring  the  priority  military  mobility 
corridors in line with the Military Requirements and make the network more resilient.  

Over 100 billion EUR is needed for projects such as the reinforcement of road and railway 
bridges,  enlargement  of  tunnels,  and  overall  capacity  increase  of  road,  rail,  ports  and 
airports, etc. The need for an interoperable railway network, as a key enabler of smooth 
military mobility within the EU, highlights the urgency of transitioning to the European 
standard  gauge  and  aligning  key  technical  systems  (in  particular  full  deployment  of 

37  Community  of  European  Railway  and  Infrastructure  Companies,  Position  paper  “Rail's  Vital  Role  in 
Enabling the Future of EU Defence”, February 2025, p. 1. 
38 Idem.  

30 

 
 
 
ERTMS)  along priority corridors in the concerned Member States and in Ukraine. The 
White Paper for European Defence-Readiness 2030 highlighted that these key bottlenecks 
need to be addressed as a matter of urgency.    

Stakeholder  consultation  results  confirmed  what  has  been  reflected  before:  Europe’s 
transport  infrastructure  is  not  sufficiently  adapted  to  dual-use  purposes  when  it 
comes to military mobility, creating systemic delays and vulnerabilities. Civilian transport 
networks  (rail,  road,  maritime  nodes,  and  air)  were  largely  developed  without  military 
requirements in mind and remain under-upgraded for dual-use standards. 

In the air domain, TEN-T has already identified a network of dual-use airports. However, 
in view of increased military operations, including longer-range cross-border operations, 
there is a need to evaluate if the identified airports have the necessary capacity, equipment 
and  capabilities  to  handle  the  requirement  military  operations.  EASA  developed 
Guidelines for the installation of military equipment on civil aerodromes39 that should be 
applied  to  upgrade  these  dual-use  airports  where  required.  The  following  areas  would 
deserve  assessment  in  priority:  rescue  and  firefighting  and  aerodrome  emergency  plan, 
aircraft refuelling, runway surface condition reporting, use of military equipment in civil 
airports, inclusion of military representatives in local runway safety teams and security. 
Moreover, the most performant and immediately available infrastructure and services for 
airspace capacity and decongestion are needed to deal with the increase of overall civil and 
military traffic. In such case the exchange of data between the controller on the ground and 
the  pilot  in  the  air  is  essential  as  well  as  the  supporting  infrastructure  to  provide  such 
service. 

According to the stakeholder consultation results, 64.1% of Member States and 70.83% of 
industry stakeholders emphasised  infrastructure  bottlenecks as  a major obstacle, yet 
less than half of stakeholders confirmed that their national strategic infrastructure lists were 
aligned with EU-wide priorities.  

The EU’s currently fragmented, under-prepared and insufficiently dual-use infrastructure 
base  remains  a  critical  driver  of  the  current  limitations  in  military  mobility.  Unless 
systematically addressed, these gaps will continue to delay deployments, create operational 
vulnerabilities, and erode credibility of EU and NATO rapid reaction capabilities.  

2.2.2 

Insufficient  and  uncoordinated  identification  and  protection  of  strategic 
dual-use infrastructure 

The  resilience  of  the  EU’s  strategic  infrastructure  on  which  military  mobility  relies  is 
increasingly jeopardised by the absence of coordinated and comprehensive protection 
measures. In today’s security environment, shaped by hybrid threats, cyber attacks, and 
sabotage, the safeguarding of transport corridors, logistics hubs, and energy supply chains 
is  a  pre-requisite  for  ensuring  the  continuity  of  force  projection  and  reinforcement 
operations. Yet current protection frameworks remain fragmented, uneven across Member 
States,  and  insufficiently  aligned  with  NATO  standards.  While  significant  progress  has 
been  achieved  through  CEF  investments  and  the  identification  of  EU  military  mobility 
corridors, the need to upgrade, adapt, and protect key dual-use infrastructure remains 
urgent.  The  inadequacies  in  both  capacity  and  protection  not  only  undermine  military 

39 Expected to be published in the last quarter of 2025 

31 

 
 
 
transportation but also place civilian functions at risk, including civil protection operations, 
humanitarian relief, and the continuity of essential supply chains. 

The  dual-use  character  of  infrastructure  adds  further  complexity.  Ports,  airports,  rail 
hubs,  inland  waterways  and  road  networks  serve  simultaneously  as  arteries  of  civilian 
traffic and as potential military lifelines. Insufficient adaptation and protection thus pose a 
dual  risk:  adversaries  targeting  one  corridor  to  delay  military  reinforcements  could 
equally  paralyse  vital  civilian  supply  chains,  humanitarian  aid,  or  disaster  response 
operations. In this respect, the security of dual-use infrastructure is inseparable from 
the  wider  resilience  of  European  societies.  Despite  ongoing  investment,  protection  of 
strategic  dual-use  infrastructure  remains  fragmented  and  nationally  siloed.  While  some 
Member  States  conduct  systematic  vulnerability  assessments  of  ports,  airports  and  rail 
hubs, others apply minimal or inconsistent standards. As a result, military corridors often 
contain single weak nodes that compromise the  entire chain  of mobility.  This  has been 
amply  reflected  in  the  stakeholder  consultation:  64.1%  of  Member  States  identified 
infrastructure  bottlenecks  as  a  major  obstacle,  but  fewer  than  half  confirmed  that 
systematic resilience assessments are embedded in their national planning. In this sense, 
the CER Directive framework sets horizontal requirements for the  resilience of critical 
entities across several sectors, including transport; however, the Directive does not address 
the  particular  characteristics  of  infrastructure  that  support  military  mobility,  nor  the 
operational demands associated with defence-related transport. 

At  the  same  time,  47.91%  of  industry  stakeholders  reported  not  being  systematically 
involved  in  resilience  planning,  despite  controlling  large  portions  of  the  civilian 
infrastructure  on  which  military  movements  depend.  In  the  consultation,  stakeholders 
noted that such infrastructure  not  only  requires protection, but  also  resilience, therefore 
continuous  improvements  in  this  area  must  be  made.  The  procedures  must  be 
standardised and digitalised, improvements must be made in the protection of critical 
infrastructure (e.g., further investment into the protection of sensitive areas), as presently 
critical entities are often insufficiently protected. Industry stakeholders also emphasised 
the necessity to enhance protection on transport infrastructure (mostly railway networks 
against  espionage  and  sabotage,  bridges,  tunnels,  ports,  airports  and  corridors),  critical 
entities (potential targets for cyber-attacks or sabotage), and of data and digital systems. 

In  that  context,  the  ownership  and  control  of  critical  transport  infrastructure  and 
mobile transport assets are of critical importance to stakeholders. The White Paper for 
European  Defence-Readiness  2030  therefore  also  identifies  the  need  for,  stricter  rules 
concerning the ownership and control of such assets.  

In parallel, hybrid threats have exposed systemic vulnerabilities. Transport management 
systems,  customs  platforms,  and/or  satellite  navigation  signals  have  become  frequent 
targets of disruption. While Member States expressed support for digitalisation of systems, 
many warned that without coordinated cybersecurity requirements, such platforms could 
themselves become points of failure. Notwithstanding the progress made (see, for instance 
Directive 2022/255540, NIS2 Directive), recent cyber incidents against European logistics 
networks, as well as repeated GPS spoofing near conflict zones, underscore the urgency of 
establishing robust fallback mechanisms and reinforce cross-border interoperability. 

40 Directive 2022/2555, (NIS 2 Directive) 

32 

 
 
 
A further concern is the lack of pre-agreed fallback mechanisms. At present, there is no 
EU-wide  framework  to  guarantee  alternative  corridors  or  redundant  nodes  in  case  of 
sabotage,  natural  disaster,  or  overload.  The  issue  is  most  acute  along  the  eastern  flank, 
where  infrastructure  is  sparse  and  fuel  supply  chains  remain  underdeveloped.  Member 
States  reported  difficulties  in  securing  sufficient  fuel  for  deployments,  while  industry 
stressed that ports with the storage and handling capacity required for naval operations are 
limited in number and unevenly distributed. The sabotage of the Nord Stream pipelines in 
2022  demonstrated  how  the  targeting  of  critical  infrastructure  can  create  immediate 
operational and strategic vulnerabilities, yet the EU has not extended a similar protection 
logic to its transport corridors.  

The  consequences  for  operational  readiness  are  direct  and  significant.  Single  points  of 
failure (whether a vulnerable bridge, a non-hardened tunnel, or an inadequately protected 
port)  can  paralyse  cross-border  movement,  delaying  the  reinforcement  of  forces  and 
undermining deterrence capabilities. In the event of potential coordinated hybrid attacks, 
adversaries could exploit weakly protected nodes to systematically disrupt logistics chains, 
forcing re-routing through infrastructure unable to bear oversized military loads. The lack 
of EU-NATO coordination in protection planning further aggravates the problem; NATO’s 
reinforcement strategies assume predictable and resilient corridors, but without EU-level 
alignment, those assumptions are not guaranteed.  

Ultimately, the insufficient and uncoordinated protection of strategic infrastructure 
erodes the EU’s credibility as a security actor. To address this, a common framework is 
required,  harmonising  resilience  requirements,  integrating  EU  and  NATO  vulnerability 
assessments, ensuring (redundancy) and fallback corridors, and establishing robust cyber 
defences  for  digitalised  systems.  Critically,  industry  must  be  systematically  engaged  in 
resilience planning, given its role as the owner and operator of most transport assets.  

Unless such measures are introduced, Europe’s corridors will remain exposed to disruption 
and exploitation, leaving the EU’s deterrence posture vulnerable at the very moment when 
rapid and reliable mobility is most essential.  

2.3  Low availability of transport assets  

While fragmented rules and vulnerable infrastructure already constrain the effectiveness 
of military mobility in Europe, these challenges are furthered by a persistent shortage of 
suitable transport assets needed to carry out large-scale military movements at short 
notice, especially for heavy military equipment. 

Over  recent  decades,  Member  States  have  progressively  reduced  their  national  military 
transport  and  logistics  capabilities,  increasingly  relying  on  commercial  providers  to 
perform  functions  once  covered  by  dedicated  military  mobility  assets.  Being  part  of 
enabling capabilities, logistics capabilities were the first ones to cut in times of decreased 
defence budgets. This structural downsizing, while reflecting post-Cold War budgetary 
and  operational  thinking,  has  left  Europe  dependent  on  market-driven,  fragmented,  and 
often  insufficient  civilian  (and  dual  use)  transport  capacities.  As  Boeke  (2023)  states, 
“collective defence disappeared from sight, and all attention was focused on out-of-area 
operations […] Military logistics adopted business principles and processes were designed 

33 

 
 
for market efficiency. Elements of transport, support and other services have also been or 
will be outsourced to commercial parties.”41  

This dependency and the lack of own military transport assets create vulnerabilities 
that  become  particularly  acute  in  times  of  crisis  or  heightened  operational  demand. 
Commercial transport capacities are optimised for civilian logistics chains and may not be 
readily  available,  adaptable,  or  secure  for  urgent  military  transport.  The  civilian  sector 
operates according to commercial incentives, seasonal fluctuations, and private contractual 
commitments, which may not align with the timelines and priorities of defence transport. 
When large-scale or simultaneous military transport needs surge, competition for limited 
civil transport resources intensifies, leading to bottlenecks, delays, and cost escalations. 
There  is  also  currently  limited  visibility  on  available  dual-use  transport  capacities  that 
would be accessible for the armed forces.  

Similarly, procedures for accessing private-sector equipment or services vary widely 
among Member States, reflecting different national legal systems. Some Member States 
maintain ad hoc contractual arrangements or rely on informal cooperation with industry. 

Without sufficient access to transport and logistics resources, Member States cannot either 
adequately simulate large-scale movements or evaluate the resilience of the network under 
operational conditions. As a result, the EU’s overall preparedness to support large-scale or 
time-sensitive military transport remains constrained.  

The  lack  of  cooperation  in  sharing  assets  exacerbates  this  shortfall.  Although  certain 
multinational initiatives, (the European Air Transport Command or the Multi Role Tanker 
Transport  Capability)  have  demonstrated  the  benefits  of  shared  logistics,  their  scope 
remains limited and mode-specific. Member States do not have a framework to request 
or  aid  with  military  transport  needs  in  a  coordinated,  transparent,  and  efficient 
manner. This leads to suboptimal use of available assets, as some Member States may 
possess unused capacity while others face acute shortages. 

2.3.1  Underinvestment  or  supply  shortages  of  (or  gaps  in)  military  mobility 

capabilities at the disposal of EU Member States.  

“It is important to stress that each EU Member State remains primarily responsible for 
investing  in  its  own  infrastructure,  and  that  military  requirements  and  priority 
corridors must be considered as national investment decisions. However, building the 
connections between respective national plans requires additional EU funding [...] Member 
States  must  therefore  complete  the  identification  of  the  priority  military  corridors,  the 
technical  and  geographical  gaps  as  well  as  the  additional  actions  and  funds  required  to 
mitigate those gaps as soon as possible.”42  

Persistent  underinvestment  and  chronic  shortages  of  specific  transport  capabilities 
continue to constrain military mobility in the European Union, despite recent advances in 
the policy framework. Stakeholder consultations confirm the magnitude of this perceived 
problem: 66.67% of Member States identified the availability of transport assets as an 
obstacle,  with  41.03%  qualifying  it  as  a  major  problem  and  25.64%  as  a  somewhat 
problematic  issue.  Industry  input  reflects  a  similar  pattern  of  perception,  with  45.83% 

41 Boeke S., ‘The Magic Move’, Militaire Spectator, 14 April 2023. 
42 Van Hoeymissen S., Ibid. 

34 

 
 
 
considering the matter  relevant, and over  25% describing  it as a  major  problem.  These 
figures  indicate  a  structural  gap  between  the  demand  for  transport  capabilities  and  the 
ability  of the current  systems (both national  and  EU-wide) to  supply them  in  sufficient 
quantity, quality, and to ensure interoperability.  As Van Hoeymissen (2024) states, “we 
are currently managing this more demanding and precarious strategic situation with fewer 
and more fragmented resources at our disposal than before. We have lost the institutional 
memory  to  organise  logistical  support  for  the  force  posture  that  is  needed  to  deter  and 
defend.”43 

The  shortages  manifest  across  all  modes  of  transport.  In  the  land  domain,  deficits  are 
evident  in  the  availability  of  rail  flatbeds,  heavy  equipment  transporters,  and  medical 
wagons, with additional interoperability constraints caused by differing rail track gauges 
(European  Standard  Gauge  of  1435mm  vs.  1520/1524mm  and  1667mm  broad  gauges) 
across the continent. Furthermore, stepwise authorisation of vehicles, that is the suppliers’ 
approach to authorise their vehicles one Member State at a time, leads to delays for vehicles 
to  become  useable  for  cross-border  military  transports.  Long  procedures  and  small 
specified  areas  of  use  determined  by  commercial  interest  delay  the  time  to  market  and 
hamper  a  vehicle’s  availability  for  cross-border  military  transports.  The  air  domain 
remains  critically  dependent  on  limited  fleets  of  strategic  and  tactical  airlift,  where  EU 
assets cannot match the scale of demand in crisis deployments.  

When it comes to unmanned aircraft systems for dual-use and military mobility, shortages 
also persist. Drones are increasingly being explored for their potential to transform military 
logistics,  enabling  the  rapid  and  efficient  transport  of  supplies,  equipment,  and  even 
personnel  over  long  distances,  particularly  in  areas  where  traditional  transportation 
methods are limited or impractical. In the dual-use context, drones can be used for a range 
of civilian applications, such as border surveillance, search and rescue, and environmental 
monitoring, while also having the potential to be rapidly adapted for military use in crisis 
situations. The development and deployment of drones can also drive innovation, create 
new capabilities, and provide a strategic advantage, making them a critical component of 
modern military and dual-use strategies. The lack of a harmonized framework for drone 
testing  and  demonstration  is  hindering  the  development  of  unmanned  technologies. 
Moreover, there is no common methodology for the development of AI-based functions 
for drones to assess trustworthiness, taking into account unique military requirements. 

At  sea,  the  scarcity  or  Ro-Ro  (Roll-On-Roll-Off,  or  ferries)  vessels  and  limited  port 
facilities adapted for military handling create severe bottlenecks. Across all domains, there 
is  a  shortfall  in  ADR-approved  vehicles  and  other  dual-use  capacities  essential  for  the 
transport  of  dangerous  goods.  Such  gaps  directly  undermine  readiness,  particularly  in 
scenarios requiring rapid reinforcement on the eastern flank.  

The  problem  driver  is  reinforced  in  its  logic  by  fragmented  procurement  patterns. 
Member States continue to acquire mobility assets largely on a national basis, following 
diverging  specifications  and  timelines.  This  reduces  economies  of  scale,  drives  up  unit 
costs, and perpetuates a high level of non-standardisation. As highlighted in the Defence 

43 Van Hoeymissen S., Ibid. 

35 

 
 
 
Investment  Gaps  Analysis  and  Way  Forward44  and  reflected  in  the  European  Defence 
Industrial Strategy (EDIS), the absence of coordinated procurement of enablers (such 
as transport fleets, airlift, and logistics assets) has created “critical shortfalls” that persist 
despite  rising  defence  budgets.  Instruments  such  as  the  EDF,  the  proposed  European 
Defence Industry Programme, and PESCO projects on mobility offer potential remedies, 
but uptake has been slow and uneven, with priorities often directed towards high-visibility 
weapon systems rather than mobility enablers. 

Industrial constraints further exacerbate the problem.  Supply  chain  fragility, scarcity of 
raw materials, and dependence on non-EU suppliers for critical components have created 
production delays and limited surge capacity. These vulnerabilities, noted in EU-level 
debates on security of supply, expose mobility planning to risks outside the direct control 
of  Member  States.  In  practice,  this  has  led  to  reliance  on  ad  hoc  leasing  from  civilian 
providers or non-EU partners, increasing costs and compromising predictability.  

The  EDA  is  conducting  a  series  of  studies  to  identify  existing  gaps  and  future 
requirements  across  the  different  modes  of  transport  relevant  for  military  mobility. 
These  studies  are  designed  to  provide  evidence-based  input  for  possible  regulatory  and 
policy proposals. 

•  The EU Rail Transport Capacity Study and the EU Inland Waterways Transport 
Capacity Study have both produced interim reports. These have been shared with 
the Commission and are serving as a starting point for the preparation of regulatory 
proposals in the military mobility package. 

•  Forthcoming work includes the EU Maritime Transport Capacity Study , foreseen 
for  2026,  and  the  EU  Strategic  Air  Transport  Capability  and  Capacity  Study, 
planned for late 2026 or 2027. 

Ongoing  PESCO  projects,  notably  the  Strategic  Air  Transport  for  Outsized  Cargo 
(SATOC)  and  the  Future  (Unmanned)  Air-to-Air  Refuelling  Capability  project 
consolidate Member States efforts. In addition, the EDF European System for Outsized 
Cargo Airlift (ESOCA) Project is ongoing, while the 2026 EDF Work Programme will 
include a focus on Autonomous Air-to-Air Refuelling. 

Complementary conceptual work is progressing through the European Family of Tactical 
Air Transport Assets Capability Development Concept Paper, which is developed with 
Member  States  and  aligned  with  NATO.  In  parallel,  the  Military  Mobility  Air  Portal 
(MMAP), operated by the EDA, continues to support Member States in the implementation 
of Diplomatic Clearances and TAs, including the CBMP TA Air. 

In support of long-term resilience, the EDA  presented a draft Food for Thought Paper on 
an  EU  Strategic  Airlift  Reserve,  promoting  the  “whole  of  society”  defence  principles 
outlined in the White Paper for European Defence-Readiness 2030. This concept foresees 
the potential employment of a EU Civilian Reserve Air Fleet  to  mitigate current  heavy 
airlift shortfalls and address identified challenges. 

43 European Commission & High Representative of the Union for Foreign Affairs and Security Policy, Joint 
Communication to the European Parliament, the European Council, the Council, the European Economic 
and Social Committee and the Committee of the Regions – On the Defence Investment Gaps Analysis and 
Way Forward, JOIN(2022) 24 final, 2022. 

36 

 
 
 
The consequences of these capability gaps cannot be overstated; at operational level, asset 
shortages directly reduce the EU’s ability to move equipment and personnel at scale 
and speed, particularly during large-scale or multi-domain operations. At strategic level, 
insufficient  transport  capacity  weakens  deterrence,  as  adversaries  can  exploit 
bottlenecks or target fragile nodes with hybrid attacks, knowing that redundant capacity is 
lacking.  At  societal  level,  the  dependence  on  civilian-operated  assets  without  pre-
negotiated frameworks risks generating friction with commercial operators, particularly in 
periods of crisis when both civilian and military demands converge. 

Underinvestment and uncoordinated procurement have left the EU with insufficient 
and unevenly distributed mobility assets. Without systematic and collaborative investment 
in  enablers (rail and road transport  fleets,  Ro-Ro vessels,  strategic  airlift  capacity, etc.) 
combined  with  stronger  coordination  of  industrial  policy  and  security  of  supply 
frameworks, Europe’s military mobility will remain constrained, vulnerable and dependent 
on external actors.45 46 Fragmented and under-strength transport assets mean that the EU 
cannot guarantee sufficient lift capacity during transport crises. Rail shortfalls, insufficient 
Ro-Ro  or  airlift  capacity,  and  structural  weaknesses  in  bridges  and  tunnels  may  risk 
creating chokepoints and critical junctures. This evidently undermines the credibility of 
both EU and NATO commitments to rapid response.  

Labour shortages aggravate these gaps. Both Member States and industry stakeholders 
reported insufficient qualified personnel in the rail, road and logistics sectors. As well as a 
lack  of  trained  customs  officers  familiar  with  military-specific  requirements.  The 
predominance of non-national truck drivers in several Member States raises concerns over 
capabilities during crises, while industry stakeholders have flagged the urgent need for re-
skilling in digital competences and military standards.  

Production  and  procurement  constraints  further  exacerbate  the  asset  deficit.  Only 
23.08%  of  Member  States  and  50%  of  industry  reported  the  ability  to  scale  up 
manufacturing  during a  crisis,  conditional upon  financial support,  clear  demand signals 
and streamlined governance. The absence of common EU standards for procurement risks 
perpetuating interoperability issues, particularly in the rail sector.  

While 69.23% of Member States and 62.5% of industry expressed support for pooling and 
sharing of strategic dual-use assets, stakeholders cautioned that such mechanisms require 
strict allocation rules, legal clarity and centralised management, ideally in cooperation with 
NATO. Concerns remain that pooling may be feasible in peacetime but could hinder rapid 
mobilisation during crises.  

2.3.2  Limited visibility on existing military mobility capabilities (including dual-

use capabilities) across the EU 

Another problem driver impeding the optimisation of military mobility in the EU is the 
lack of comprehensive, reliable, and interoperable data regarding existing transport 

45  European  Parliament  Research  Service,  European  Added  Value  in  Action  briefing  ”  Towards  a 
comprehensive and beneficial approach to military mobility”, September 2025. 
46 Abundant reference in Joint White Paper for European Defence-Readiness 2030 (ST 7293/25, dated 20 
March 2025). 

37 

 
 
 
 
and mobility capacities (both purely military and dual-use) among Member States. This 
limited  visibility  exacerbates  already  existing  capability  shortfalls  and  undermines 
effective planning, procurement, interoperability, and joint operation capacities.  

Stakeholder  consultation  input  points  at  evidence  that,  although  most  respondents 
recognise capability shortages (66.67% of Member States flagged availability of transport 
assets  as  problematic,  whereas  45.83%  of  industry  respondents  did  so)  the  precise 
inventory of assets, their location, readiness status and compatibility remain considerably 
opaque. There is currently no EU-wide registry or portal that allows decision makers to 
see in real time (or near real time)  what assets are available in which Member State, 
under  what  conditions,  and  with  what  technical  specifications  (e.g.  load  capacities,  rail 
gauge compatibility, ADR-approved vehicles, etc.).  

This  lack  of  visibility  extends  to  dual-use  assets.  Industry  stakeholders  and  Member 
States alike indicated that they are not always aware of the capacities managed by civilian 
infrastructure  operators  (ports,  rail  operators,  road  hauliers)  that  could  be  mobilised  in 
times  of  need.  Because  many  dual-use  transport  assets  are  owned  and  operated  outside 
defence ministries, and because national reporting to EU bodies is inconsistent in scope 
and  frequency,  planning  for  mobilisation  is,  then,  based  on  partial  and  often  outdated 
information.   

Legal and policy documents consistently confirm this perceived problem: the Military 
Mobility Action Plan 2.0 calls for improved data sharing, yet no binding mechanism has 
been established to mandate Member States to submit inventories of mobility capabilities. 
The Defence Investment Gaps Analysis and Way Forward emphasises the need to close 
“deficiencies  in  mapping  and  transparency  of  defence  assets”,  particularly  for  enabling 
capabilities such as mobility, logistics, airlift, sealift, and transport infrastructure. Policy 
briefs  such  as  the  European  Parliament’s  Military  Mobility  briefing  (07/04/2025)47 
acknowledge, likewise, that while four strategic corridors have been identified under TEN-
T  in  coordination  with  NATO,  the  oversight  over  which  national  dual-use  nodes  and 
transport hubs along these corridors are actually fit for military loading, over-dimensioned 
cargo or reinforced to withstand disruption, remains weak.  

It is important to understand the adverse operational and strategic consequences that follow 
from  this  lack  of  full  visibility  of  existing  capacities.  Firstly,  procurement  and 
investment  decisions  are  less  efficient:  gaps  may  be  overestimated  in  certain 
domains/areas while underinvestment may persist in others (leading to the consequential 
waste or misallocation of scarce budgetary resources).  

Secondly, there are pernicious consequences when it comes to interoperability: without 
having visibility on exactly which assets in which Member States meet required standards 
(e.g.,  gauge,  loading  capacity,  off-road  capability,  ADR  compliance),  national  military 
plans or joint operations must build in guard-bands for compatibility, constraints on routes, 
or  duplicative  logistic  assets.  This  increases  cost,  complexity,  and  time  needed  for 
mobilisation. 

47 Military mobility | Think Tank | European Parliament  

38 

 
 
 
Thirdly, readiness and surge capacity can be said to be compromised. In crisis or “in-
between” phases (i.e. heightened tension without a formal status of armed conflict, what 
has been previously described as a “transport emergency situation” in this SWD), delays 
in  identifying  what  transport  assets  are  available  (and  where)  mean  that  assembling 
capabilities  for  large-scale  movement  becomes  slower.  The  lack  of  an  EU-level 
consolidated legal picture prevents thus rapid cross-border pooling or mutual support, as 
military  planners  might  not  be  able  to  call  up  assets  whose  existence  is  not  officially 
recorded or whose status is unclear. 

Fourthly, strategic resilience is reduced as a consequence of the issues discussed above. 
Adversaries  and/or  systemic  rivals  may  exploit  this  lack  of  preparedness  in  poorly 
catalogued  infrastructure  or  unnoticed  weak  nodes.  Disruptions  (whether  naturally 
occurring, technical or cyber-related) affect nodes whose importance has not been fully 
assessed or publicised, thereby cascading effects along critical mobility corridors.  

Multiple systemic factors can be said to contribute to this lack of visibility: 

•  Many transport assets, especially those with dual use, are owned by non-defence 
ministries and/or sub-national entities, private companies or civil operators; their 
reporting  obligations  to  defence  or  mobility  authorities  being  weak  or  non-
standardised.  This  decentralised  ownership  problem  has  consequences  when  it 
comes to the very visibility of the assets as well as their classification.   

•  Some Member States maintain inventories of military mobility assets; others do 
not  or  only  do  so  partially.  Technical  specifications,  readiness  state,  and 
interoperability  criteria  vary,  so  even  where  data  exists,  comparability  remains 
weak.  European  visibility  over  railway  rolling  stock  has  been  provided  by  the 
European Vehicle Register (EVR) for many years48 and access can be obtained for 
legitimate users, including national armed forces49. However, the potential of these 
access  rights  has  not  been  fully  utilised  and  it  may  not  contain  sufficient 
information to determine the vehicle’s usefulness for military transports. Similar 
systems do not exist at EU level for other modes of transport. 

•  Defence authorities are often reluctant to share detailed asset data across borders 
or with civilian bodies due to security classification requirements, national security 
concerns, or concerns about exposure to intelligence or cyber risks. This reduces 
granularity and timeliness of shared data. 

•  As mentioned before in this SWD, the lack of a binding EU requirement or legal 
framework  means  that  existing  initiatives,  including  reporting  under  TEN-T 
corridors  and PESCO mobility  projects,  do not  yet  impose binding  standards or 
timelines for the provision of data on (existing) capabilities. 

•  Resource  constraints  are  always  a  systemic  factor  impeding  visibility:  even  in 
those  cases  with  good  data-collection  practices,  financial,  institutional,  and 

48 Report From the Commission to the European Parliament and the Council on the progress made towards 
achieving interoperability of the Union rail system and the functioning of the European Union Agency for 
Railways in this context, COM/2025/384 final. 
49 Sections 3.3.1 and 3.3.2 of Commission Implementing Decision (EU) 2018/1614. 

39 

 
 
 
 
 
 
 
technical  resources  to  maintain  up-to-date  registries  (on  the  operational  status, 
potential deterioration of assets or maintenance cycles) are often insufficient. 

The  White  Paper  for  European  Defence-Readiness  2030  explicitly  identifies  “Military 
Mobility: EU-wide transport network enabling rapid movement of troops and equipment” 
as  one  of  the  seven  Critical  Defence  Capability  Areas.  As  part  of  it,  the  European 
Commission proposes to increase the visibility and mapping of dual-use transport assets 
and ensure regulatory reforms to better reflect military mobility needs. Furthermore, in the 
Military  Mobility  call  for  evidence  launched  mid-2025,  the  European  Commission 
committed to “identifying critical infrastructures for military mobility having a European 
dimension and strengthen their resilience.” 

The limited visibility of existing military mobility capabilities across the EU functions as 
a  key  driver  of  low  asset  availability.  It  undercuts  efficient  procurement,  hinders 
interoperability,  complicates  logistical  planning,  and  increases  time  lags  in  rapid 
deployment scenarios (“transport emergency situation”). Without concerted effort towards 
building an interoperable, secure, and regularly updated capability registry (dual-use assets 
included),  Member  States  and  the  EU  as  a  whole  risk  persistent  underperformance  in 
military mobility under crisis conditions. 

Military mobility capabilities extend beyond the availability of transport assets and include 
a  wide  range  of  enabling  services  essential  not  only  for  the  movement  but  also  for  the 
sustainment  of  forces.  In  NATO  doctrine,  such  services  are  embedded  in  the  broader 
framework  of  Host  Nation  Support  (HNS)  and  are  critical  to  ensuring  operational 
continuity during transit and deployment. These capabilities cover, inter alia, the provision 
of  accommodation,  restroom  and  washing  facilities,  dining  facilities  and  meal  services 
(including pre-packaged rations), medical support, and secured areas for rest, assembly, 
and light maintenance (e.g., small workshops). They further encompass logistical functions 
such as the establishment of refuelling points, supply of fuels and lubricants, waste disposal 
(including hazardous waste), and the provision and operation of exchange services (PX) 
for items of daily necessity. The absence or fragmentation of such HNS-related services 
across  Member  States  creates  additional  friction  in  military  mobility,  as  forces  may  be 
delayed or rendered dependent on ad hoc arrangements, undermining the predictability, 
sustainability, and of large-scale movements. 

2.3.3 

Inefficiencies in optimal use of military mobility capabilities (including dual-
use capabilities) 

Even where military mobility and dual-use transport assets are available, inefficiencies in 
their  utilisation  significantly  reduce 
their  operational  effectiveness.  These 
inefficiencies stem from suboptimal matching of capacity to need, insufficiently targeted 
project  selection,  bureaucratic  delays,  and  under-utilisation  of  existing  dual-use 
infrastructure.  Together,  they  contribute  to  redundancy,  cost  inflation,  and  loss  of 
readiness. 

In the stakeholder consultation, a major proportion of respondents identified that transport 
assets are under-utilised or not activated rapidly enough. Although 66.67% of Member 
States considered asset availability a problem, many also reported that even those assets 
that exist are not always used to full capacity due to regulatory, procedural, or logistical 
barriers.  For  example,  industry  inputs  noted  that  last-minute  route  changes,  escorting 

40 

 
 
requirements,  and  delays  in  obtaining  cross-border  permissions  reduce  throughput  of 
transport assets.  

Complementary  data  stems  from  the  European  Court  of  Auditors  audit  of  the  Military 
Mobility Action Plan 2.0.50 The audit reported that EU funding under the CEF earmarked 
for  dual-use  transport  infrastructure  (EUR1.7  billion  for  2021-2027)  has been  allocated 
rapidly to meet the urgency and to expedite the effects of dual-use investments, but project 
selection did not always clearly align with strategic planning . Inefficiencies also may arise 
from redundant (and) underused assets or civilian dual-use assets not integrated into 
military readiness. Because dual-use assets frequently belong to civilian operators, there 
is  often no prearranged  framework for their activation or prioritisation in  crises  (which 
leads to delays in mobilisation or missed opportunities for harnessing an efficient use of 
economies of scale).  

Several structural and regulatory sources contribute to these inefficiencies: 

•  CEF calls for dual-use projects have a high oversubscription rate indicating that 

the considerable demand could not be met by available resources.  

•  Regulatory/procedural  delays  appear 

in 
mismatches between local infrastructure limits (e.g. load limits, bridge capacity...) 
and military load requirements,  and in  bureaucratic barriers for route approvals. 
The ECA Special Report highlights cases in which, for example, tanks could not 
traverse certain infrastructure due to road weight regulations in transit states. 

in  cross-border  permissions, 

•  Many dual-use infrastructures are available but are under-utilised; meaning, not 
integrated  or  scheduled  for  military  use  in  a  prioritized  or  predictable  manner. 
Assets  may  then  be  left  idle  or  used  in  low-military-value  ways  due  to  lack  of 
interoperability, lack of readiness planning, or because civilian regulations restrict 
their use under certain conditions. 

•  Even  when  assets  are  procured  or  infrastructure  is  upgraded,  the  gap  between 
physical capacity and activation  for military mobility remains  wide. Transport 
assets  sit  unused  or  under-deployed  because  necessary  legal  or  administrative 
triggers (clearances, emergency definitions, priority access) are not in place or are 
too slow. 

The  impact  of  these  inefficiencies  on  readiness  is  substantial.  Precisely  because  asset 
utilisation  is  sub-optimal:  (i)  the  time  to  mobilise  is  lengthened,  reducing  the  EU’s 
capacity for rapid response and deterrence especially in “in-between” phases of crises; (ii) 
costs  may  escalate  considerably.  Underused  assets  still  incur  maintenance,  staffing  or 
depreciation  costs  without  yielding  readiness,  while  emergency  activation  often 
necessitates expensive last-minute solutions (e.g. chartering, rerouting); (iii) operational 
plans  must  include  larger  margins  of  error  (buffer  times,  alternate  routes,  excess 
capacity), thereby reducing efficiency and scalability; (iv) interoperability is considerably 
weakened. When dual-use assets are not standardised or activated, different Member States 

50 ECA Special report 04/2025.  

41 

 
 
 
 
 
 
are much more likely to maintain redundant or incompatible inventory, which complicates 
cross-border logistics and increases administrative overhead. 

Under the existing, aforementioned policy instruments (Action Plan on Military Mobility 
2.0,  TEN-T  revised  Regulation,  PESCO  projects  related  to  mobility)  there  is  no 
recognition of these inefficiencies. For example, TEN-T now includes legal recognition 
of military mobility; however, the implementation of priority access rules and cross-border 
movement permissions remain uneven. The mentioned EP briefing on military mobility 
notes that, while 95 dual-use infrastructure projects have been funded in 21 Member States, 
criticisms  persist  that  project  selection  “overlooks  geopolitical  priorities”  and  that 
“bureaucratic barriers remain”.  

Most  recently  published  European  Commission  estimations  of  needed  investment  also 
underscore inefficiency: a recent estimate indicated that approximately EUR70 billion will 
be required to adapt rail, road, sea, and air corridors to allow for short-notice, large-scale 
movements across the EU and partner countries (far exceeding current dual-use mobility 
investment envelopes). 

2.4  Coordination  challenges,  and  the  whole-of-government,  whole-of-society 

approach. 

The effectiveness of the EU’s efforts to strengthen military mobility depends not only on 
the existence of clear rules, resilient infrastructure and sufficient transport assets, but also 
on coherent and effective coordination and governance at the national level and in broader 
context.  

While  Ministries  of  Defence  remain  central  in  defining  operational  requirements  and 
identifying priority movements, the practical implementation of military mobility depends 
to a large extent on civilian authorities, national regulators, infrastructure managers and 
civilian transport contractors. This reflects the inherently dual-use nature of the domain: 
military movements rely primarily on civilian transport networks, subject to national and 
EU regulatory frameworks, and are deeply intertwined with broader questions of customs, 
infrastructure, energy, and overall resilience. An example of  a specific issue for the  air 
domain is the lack of airspace available for training purposes while the new military assets 
will require more airspace than before. 

The  experience  of  recent  years  has  shown  that  regulatory  fragmentation,  insufficiently 
adapted infrastructure, and capability shortfalls are often the result of obstacles outside the 
competence of defence authorities. Cross-border permissions for troop movements depend 
heavily  on  ministries  responsible  for  transport,  customs  and  border  management,  and 
sometimes  even  environment  or  public  safety.  The  adaptation  of  bridges,  tunnels,  and 
airports  to  accommodate outsized military equipment  require coordination with  civilian 
transport  planners  and  operators.  The  protection  of  transport  corridors  against  cyber  or 
hybrid threats engages not only defence but also national cyber security centres, energy 
regulators, and law enforcement bodies.  

Military  mobility  therefore  requires  a  systemic  approach  that  goes  beyond  traditional 
defence policy and embeds security considerations across multiple civilian domains. At 
national level, this translates into the necessity of genuine inter-ministerial cooperation. 
Ministries of transport play a decisive role in ensuring that infrastructure planning takes 

42 

 
 
account of military requirements and that projects financed under EU or national budgets 
are designed accordingly.  

Customs  and  taxation  authorities  are  indispensable  to  the  harmonised  application  of 
customs procedures, including the use of the EU/NATO Form 302. Ministries of foreign 
affairs are responsible for the coordination of cross-border arrangements, including those 
involving  NATO  and  partner  countries,  while  civil  protection  authorities  contribute  to 
ensuring  the  resilience  and  continuity  of  transport  corridors  in  the  event  of  crises.  The 
engagement of ministries responsible for energy, environment, and climate adaptation is 
equally necessary to ensure that transport infrastructure is not only physically adapted to 
military requirements but also resilient to long-term systemic risks.  

An example of best practices: multi-stakeholder platforms in Lithuania and Finland. 

•  Cooperation between national stakeholders in Lithuania (ministry of defence, 
transportation,  and  others)  takes  place  naturally  based  on  the  general 
understanding  of  the  need  to  have  a  whole  of  government  approach  and  the 
urgency to enhance military mobility.  

•  The whole of government  Finnish model is an approach undertaken in  many 
policy areas for decades. Finland has set up a National Coordination Group on 
military  mobility  since  2018  that  comprises  of  ministries  and  governmental 
agencies. Any government entity or local level administration structure can be 
invited to join based on needs and relevance. 

At EU level, a whole-of-government approach requires the systematic involvement of 
all  relevant  Commission  services  and  other  EU  bodies.  The  European  External  Action 
Service (EEAS), including the EU Military Staff, is also a co-implementor of the Action 
Plans and ensures coherence with the Common Security and Defence Policy (CSDP) and 
with the EU’s external action more broadly, while the European Defence Agency (EDA) 
provides technical expertise, acts as an interface on behalf of the Ministries of Defence of 
Member  States,  specifically  in  the  areas  of  cross-border  movement  in  all  domains. 
Moreover,  the  framework  of  Permanent  Structured  Cooperation  (PESCO)  provides  a 
forum for cooperation and exchange of information and good practices.  

Beyond  the  need  for  whole-of-government  approach  military  mobility  also  requires  a 
whole-of-society  approach, 
involving  stakeholders  beyond  public  authorities. 
Infrastructure  operators,  logistics  companies,  rail  and  port  authorities,  and  the  wider 
transport sector are key to ensuring the availability and resilience of critical assets. Civil 
stakeholders, such as research organisations and technology providers, support innovation 
in  mobility  and  resilience,  while  social  partners  and  local  authorities  help  ensure 
acceptance and implementation at local level.  

These combined approaches could also “help to create more awareness of EU actions and 
initiatives  on  military  mobility  in  EU  member  states”  (Chihaia,  2024)51.    The  Draghi 

51 Chihaia  M.S., ‘Military mobility 2.0 revisited: Lessons learnt’, European Policy Centre, 13 November 
2024. 

43 

 
 
 
 
Report  of  September  2024  on  “The  Future  of  EU  Competitiveness”52  and  the  Niinistö 
Report  of  October  2024  “Safer  together:  Strengthening  Europe’s  civilian  and  military 
preparedness and readiness”53, reiterate the relevance of the whole-of-government, whole-
of-society approaches. In fact, “investment in transport infrastructure can be of triple use, 
simultaneously benefitting the EU’s trade flows, the EU’s Common Security and Defence 
Policy and NATO’s Concept  for Deterrence and  Defence of the Euro-Atlantic Area.”54 
Taken together, these two approaches provide the only framework capable of delivering 
the systemic improvements necessary to remove all remaining barriers to military mobility 
and to ensure the EU’s readiness in the face of future crises.  

Figure 5 : Whole-of-society approach, as presented by “Towards a comprehensive and 
beneficial  approach  to  military  mobility”,  European  Parliament  Research  Service 
briefing.  

The ECA Special Report 04/2025 is particularly poignant when evaluating coordination 
challenges in this area.55. ECA recommends to improve the governance arrangements for 
military mobility in the EU by streamlining coordination between the EU, member states 
and other stakeholders and enhancing existing synergies and interaction.  NATO, whose 
membership overlaps with that of the EU, remains a parallel but essential framework in 
shaping military mobility requirements and standards.56  

Although  the  dual-use  nature  of  military  mobility  requires  close  cooperation  among 
ministries of defence, transport, interior, finance and foreign affairs, many Member States 
still manage their responsibilities through separate administrative channels. Only a 
few have established dedicated inter-ministerial coordination structures or national contact 
points empowered to act across departments. The lack of a coherent whole-of-government 
approach complicates decision-making on cross-border permissions, funding priorities and 

52 Draghi, Mario. “Report on the future of European competitiveness”, dated September 2024.  
53  Niinistö,  Sauli.  “Safer  Together:  Strengthening  Europe’s  Civilian  and  Military  Preparedness  and 
Readiness”, dated October 2024. 
54 NATO’s Deter and Defend concept.  
55 ECA Special Report 04/2025.  
56 Ibid. 

44 

 
 
 
 
 
crisis response. It  also hampers the effective integration of civilian stakeholders, whose 
participation is essential to a functioning whole-of-society model of military mobility.  

3  WHY SHOULD THE EU ACT?   

3.1  Legal basis  

Acknowledging the dual use dimension of military transport and with a view to effectively 
address  the  problems  identified  above,  the  EU  should  establish  a  set  of  measures  
mobilising and developing the common transport policy to support the specific needs of 
military transport.  

Further, rules on cross-border military transport need to be appropriately integrated and 
developed within the common transport policy, developed at Union level, in particular to 
take account of relevant specificities of transport carried out on behalf of the armed forces 
by  civil  companies,  and  also  to  ensure  that  its  impact  on  other  civilian  transport  is 
minimised and mitigated to the extent possible. 

Taking  into account  the  above,  and also the  fact  that the Regulation  includes measures 
applicable for road, rail and inland waterway transport, but also for air and sea transport, 
it is based on Articles 91 and 100(2) of the  Treaty  on the Functioning of the European 
Union (TFEU). It establishes a set of measures and lays down appropriate provisions aimed 
at facilitating military transport in the Union and across its external borders and minimising 
and mitigating the impact of such transport on civilian transport. 

3.1.1 

 Subsidiarity: the added value of EU action 

Under the subsidiarity principle, EU action is warranted where objectives cannot be 
sufficiently achieved by the Member States acting alone but can be better delivered 
at EU level. The EU can achieve speed, scale, and predictability in military mobility that 
Member  States  cannot  deliver  alone.  It  ensures  coherence  of  investments,  reduces 
duplication, unlocks economies of scale, and creates binding frameworks for regulatory 
harmonisation,  creating  interoperability  and  predictability.  As  the  European  Court  of 
Auditors  has  noted,  only  coordinated  EU-level  prioritisation  prevents  fragmented, 
inefficient outcomes. 

EU-level intervention has the potential to deliver distinct, demonstrable added value over 
unilateral Member-State action or purely intergovernmental arrangements because it can 
(i) remove cross-border regulatory fragmentation through binding regulatory frameworks, 
ensuring seamless interoperability; (ii) mobilise EU budgetary instruments at scale; (iii) 
create transparent, interoperable information and digital coordination; (iv) provide a legal 
and institutional interface for synchronising EU and NATO operational requirements; and 
(v) unlock economies of scale for capability/asset acquisition and stockpiling.  

These  advantages  are  relevant  in  light  of  the  operational  shortfalls  documented  in  the 
stakeholder consultation and by ECA audits, since the EU can deliver binding regulatory 
harmonisation where voluntary arrangements have proved insufficient. Only a binding EU 
instrument  can  ensure  uniform  cross-border  application  of  permissions,  priority  access 

45 

 
 
  
rules and the legal triggers for exceptional procedures, thereby reducing  serial approval 
delays inherent to cross-border military transport operations.  

This imperative was explicitly recognised in the EU’s Action Plan on Military Mobility 
2.0,  which  identifies  harmonised  procedures  and  legal  clarity  as  pre-conditions  for 
effective cross-border movement. 

Both national action and voluntary intergovernmental coordination have not generated the 
required pace or scale of improvement. Stakeholder consultation results are clear in this 
regard: 76.92% of Member States  reported that  cross-border military mobility is  still 
managed through ad hoc coordination between ministries, rather than structured and 
permanent governance frameworks. Similarly, while most Member States have signed on 
to  the  mentioned  TAs,  not  all  of  them  have  integrated  the  TAs  into  national 
procedures,  leaving  the  agreements  non-binding  and  unevenly  applied.  From  an 
operational perspective, 64.1% of Member States and 70.83% of industry stakeholders still 
identify  infrastructure  bottlenecks  as  major  obstacles,  while  76.92%  of  Member  States 
highlight regulatory requirements (permissions, customs, dangerous goods) as the primary 
sources of delay.  

These findings confirm that voluntary measures, pursued primarily through the EDA and 
PESCO,  have  delivered  progress  but  remain  insufficient  to  reduce  duplication, 
harmonise timelines, or produce interoperable systems across the EU.  

EU-level  action  also  provides  unique  budgetary  leverage  to  upgrade  dual-use 
infrastructure and finance enablers at a geographic scale unattainable by most Member 
States acting alone. While the ECA has previously criticised the scale and prioritisation of 
budgetary  allocations,  the  resources  demonstrate  the  EU’s  capacity  to  direct  capital  to 
cross-border (e.g. “last-mile”) upgrades, strengthening logistic nodes in a way that national 
budgets  alone  frequently  cannot.  Coordinated  EU  financing  also  allows  projects  to  be 
selected  and  staged  according  to  cross-border  reinforcement  logic  rather  than  narrowly 
national cost-benefit calculus. 

Action at EU level is indispensable in three respects that have been extensively reflected 
upon in the “Problem definition and problem drivers” chapter of this SWD:  

Firstly, removing regulatory barriers: harmonisation of cross-border permissions and of 
the implementation of simplified customs procedures for goods to be moved or used in the 
context  of  military  activities  and  priority  rules  is  necessary  to  reduce  systemic 
inefficiencies, which currently generate measurable delays and administrative costs. In the 
absence of EU action, divergent interpretations of national security concepts (e.g. “crisis” 
or “transport emergency”) will continue to delay movement requests, with convoy transit 
across multiple Member States requiring serial approvals and redundant documentation.   

Secondly,  pooling  resources  and  ensuring  visibility:  the  EU’s  unique  budgetary 
instruments (CEF, EDF, EDIP) allow investments into dual-use infrastructure and enabling 
capabilities that no single Member State could finance or coordinate at scale. Projects such 
as the North-Eastern Border Shield, investing in logistic nodes and “rocade” or “beltway 
roads” along the EU’s external borders, show the potential of coordinated EU-level support 
to  enhance  resilience.  At  the  same  time,  EU-level  action  can  incentivise  stockpiling 
systems and transnational logistical hubs, ensuring coherent use of scarce civilian and dual-
use assets across Member States.  

46 

 
 
Thirdly, strengthening coherence with NATO, since the Alliance lacks the EU’s legal 
and  budgetary  instruments  to  drive  regulatory  harmonisation  and  infrastructure 
investment. EU action therefore complements NATO by ensuring that Member States (23 
of  whom  are  NATO  Allies)  have  a  harmonised  and  reinforced  set  of  procedures  and 
infrastructures at their disposal.  

Fourthly, customs legislation is an exclusive EU competence. Action at EU level has the 
potential  to  address  the  cross-border  and  systemic  nature  of  present  and  foreseeable 
military mobility challenges by harmonising procedures and developing digital solutions,  

The  persistence  of  fragmentation  despite  two  action  plans  and  multiple  voluntary 
frameworks  illustrates  that  only  action  at  EU  level;  that  is,  binding,  coordinated,  and 
adequately  financed,  can  ensure  the  speed,  scale,  and  predictability  of  movement 
required under the new security context under which the EU is called to act in today’s 
world. Subsidiarity test as detailed before, military mobility (in particular, its cross-border 
level.  National  and 
dimension)  cannot  be  addressed  effectively  at  national 
intergovernmental  efforts  have  yielded  (initial)  progress  but  remain  non-binding  and 
unevenly  implemented:  only  ~50%  of  Member  States  apply  the  TAs  nationally,  and 
76.92%  of  Member  States  still  rely  on  ad  hoc  coordination  across  ministries.  National 
investments  remain  fragmented  and  risk  creating  “capability  islands”  without  EU-level 
integration.  

4  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1  General objective 

The general  objective of the Military Mobility  Package is  to  establish a coherent and 
harmonised  EU-level  framework  that  enables,  facilitates,  and  accelerates  the 
movement of military personnel, material, and equipment across the territory of the 
EU. The Regulation will contribute to improve military mobility by facilitating military 
transport operations, relying for this on the dual use nature of military transport. 

By  combining  legislative  and  non-legislative  instruments,  the  package  aims  to  provide 
both binding provision (through the Regulation) and political/strategic direction (through 
the Joint Communication), supported by the analytical evidence base provided in this Staff 
Working Document.  

4.2  Specific objectives 

To operationalise the general objective, the Regulation proposal of this Military Mobility 
Package lays down measures aiming at:  

-  Streamlining cross-border military transport (establishing a uniform framework for 
permission procedures and ensuring uninterrupted and safe military transport) 

47 

 
 
 
 
-  Enhancing emergency response (creating an efficient, coordinated, and effective 
framework to facilitate military transport in response to temporary, extraordinary, 
and urgent situations) 

- 

Improving infrastructure readiness and protection (setting out rules to enhance the 
readiness of dual-use transport infrastructure and better protect strategic dual-use 
infrastructure against all hazards and threats) 

-  Fostering solidarity and capability sharing (encouraging the sharing and pooling of 
transport  and  logistics  capabilities  through  a  Solidarity  Pool,  and  increasing 
visibility of existing transport capabilities for military transport) 

: 

Finally,  the  Regulation  also  establishes  a  clear  governance  framework  to  ensure  the 
efficient implementation of the proposed measures.  

48 

 
 
Figure 6 : link between problems, specific objectives and measures for the 2025 Military Mobility Package 

Source: European Commission 

Problem 1. Inadequate/incomplete regulatory framework at EU and national levelProblem 2. Limited and vulnerable infrastructuresProblem 3. Low availability of transport assets SPECIFIC OBJECTIVESMEASURESON THE EUROPEAN MILITARY MOBILITY ENHANCED RESPONSE SYSTEM Introduce temporary and extraordinary measures for efficient and coordinated response in the case of emergency or crisis situations ON PREPAREDNESS AND SOLIDARITYIdentify and protect infrastructure of strategic importanceON RULES AND PROCEDURESEstablish a harmonised unified framework on permission procedures for cross-border transport for military or civil protection purposes and facilitate certain rules and customs processes formalitiesON RESILIENCEImprove transport and infrastructure resilience to enhance solidarity between Member States in resource-sharing Harmonised regulatory frameworkAmendments to EU legislation in policy areasEmergency frameworkGovernance frameworkPreparedness and solidarity measures incl. digital tool and solidarity mechanism Identification of strategic military mobility infrastructureMeasures to increase protection and resilience of strategic military mobility infrastructurePROBLEMS 
 
 
5  POLICY OPTIONS 

5.1  Baseline - Status quo (no EU legislative action)  

The option of maintaining the current framework is the baseline against which the policy 
options are assessed. Keeping the current status quo would be tantamount to recognising 
the aforementioned problems and their causes while abstaining from acting to offer EU-
level  solutions.  Stakeholder  input  confirmed  that  divergent  national  requirements  on 
diplomatic clearances,  customs procedures, and the transport of dangerous or oversized 
goods continue to  generate avoidable delays and administrative burden.  Member States 
and  industry  alike  identified  these  barriers  as  among  the  most  significant  obstacles  to 
military  mobility.  The  voluntary  TAs  developed  under  the  auspices  of  the  EDA  have 
provided useful operational guidance, but their non-binding nature has resulted in uneven 
implementation and persistent procedural bottlenecks. The status quo therefore fails to 
support  the  scale  of  mobility  required  under  the  current  security  environment. 
Continuing  with  the  status  quo  would  not  respond  adequately  to  Member  States’ 
commitment under the Military Mobility Pledge nor provide the EU with the capacity to 
address situations requiring a coordinated, cross-border response.  

5.2  Discarded policy option  

In  the  course  of  the  preparatory  analysis,  one  policy  alternative  was  considered  but 
ultimately discarded: pursuing a legislative initiative in the form of a directive rather than 
a regulation.  

A  legislative  initiative  in  the  form  of  a  directive  was  considered  but  discardedA 
directive  requires  national  transposition,  leaving  significant  scope  for  divergence  in 
implementation, both in terms of substance and timing. This is particularly true since, as 
“the 2026 deadline for meeting the Military Mobility Pledge brings open questions about 
the  ability  to  deliver  in  a  limited  time  span.”57  This  would  perpetuate  the  very 
fragmentation  the  initiative  seeks  to  overcome,  as  Member  States  would  retain 
discretion in adapting common principles to national frameworks. In addition, the need for 
speed and uniformity is paramount in the area of military mobility. Rules, to be effective 
in this area, must be subject to clear, directly applicable that can be implemented without 
delay or interpretative variance. The stakeholder consultation confirmed that both Member 
States and industry attach high importance to legal certainty and predictability; a directive 
would  not  provide  sufficient  assurance  in  this  regard.  Finally,  the  procedural  delays 
associated with transposition would postpone the operational benefits of the initiative by a 
considerable amount of time, at a moment when the security environment requires rapid 
strengthening of EU-level preparedness (see White Paper for European Defence-Readiness 
2030).  

For these reasons, both the status quo and a directive were discarded at an early stage. Only 
a  regulation  can  provide  the  necessary  legal  certainty,  immediate  applicability,  and 
harmonisation of procedures across the EU, while ensuring full coherence with parallel 
NATO actions and avoiding duplication or delays.  

57 Chihaia  M.S., ‘Military mobility 2.0 revisited: Lessons learnt’, European Policy Centre, 13 November 
2024. 

 
 
 
 
Overview 

Main  shortcomings/  Reasons  for  discarding  at  early 
stage 

Baseline: 
Status quo 
(no 
EU 
legislative 
action)  

Continuation 
of  voluntary 
arrangements 
(e.g.  EDA’s 
and 
TAs) 
national 
procedures 
without 
binding  EU 
intervention.  

Discarded 
option: 
Directive  

EU 

Introduction 
of 
legislative 
framework, 
leaving 
transposition 
to  Member 
States  

Does  not  provide  the  uniformity  and  legal  certainty 
required  to  ensure  rapid  cross-border  military  mobility; 
inconsistent  with  commitments  under  the  Military 
Mobility Pledge; insufficient in light of the deteriorating 
security environment:  

•  Persistent fragmentation of rules and procedures 

across Member States.   

•  Non-binding  character  of  existing  arrangements 

results in uneven implementation.   

•  Stakeholders  identify  infrastructure  bottlenecks, 
customs  procedures,  and  dangerous  goods 
clearances as continuing sources of delay.  

•  Lack of predictability, interoperability, and legal 

certainty.  

Ill-suited to the urgency and operational requirements of 
military mobility; does not ensure uniform application of 
rules  across  the  Union;  insufficient  to  address  Member 
States’  and  stakeholders’  demand  for  predictable, 
binding, and directly applicable procedures: 

•  Significant  scope  for  divergence  in  national 
transposition, undermining harmonisation.   
•  Delays  in  implementation  due  to  transposition 

process.  

•  Lack  of  immediacy  and  legal  certainty  for 

operators and planners.  

•  Risk  of  perpetuating  administrative  complexity 

and interpretative variance.  

51 

 
 
 
 
 
 
5.3  Preferred policy option 

The  preferred  option  is  the  adoption  of  a  Regulation  on  establishing  a  framework  of 
measures to facilitate the transport of military equipment, goods and personnel the Union, 
accompanied by a Joint Communication on Military Mobility. The regulation provides a 
binding  basis  to  remove  procedural  barriers,  ensure  transport  crisis  responsiveness, 
strengthen governance, and enable infrastructure and capability readiness across the EU.  

5.3.1  On Regulatory aspects 

Rules and procedures related to military transport 

The  stakeholder  consultation  strongly  confirmed  the  limitations  of  existing  rules  and 
procedures  pertaining  to  Military  Mobility.  During  the  consultation,  Member  States 
emphasised that a common set of rules would enable faster reaction times, particularly 
for large-scale or short noticed deployments, by facilitating access to priority routes, pre-
established corridors, and designated infrastructure. A uniform approach could improve 
coordination between Member States and facilitate interoperability and consistency 
with  NATO,  as  well  as  more  efficient  use  of  dual-use  infrastructure.  This  is  why  the 
preferred policy option entails common rules and procedures related to military transport.  

Cross border permissions 

A majority of respondents from Member States (61.54%) called for a conversion of the 
CBMP TAs into binding rules, citing the need for uniform diplomatic clearance and cross 
border permission procedures. Despite this broad support, several Member States stressed 
the importance of maintaining national oversight of goods transiting their territory. 

Building on the efforts achieved with the TAs, the Regulation would establish within the 
Common Transport Policy a new framework to streamline cross-border military transport 
procedures  (including  diplomatic  clearances)  for  all  transport  modes  (road,  rail,  inland 
waterway, air, and sea). It would not affect the sovereignty of Member States to decide 
whether to move their military forces within the Union or to grant permission for another 
Member State's armed forces to  transit through their territory.  Instead, it would seek to 
enable the effective implementation of such sovereign decisions, thereby enhancing the 
overall  efficiency  of  military  mobility.  The  Regulation  would  ensure  that  all  Member 
States  apply  the  same  procedures  and  forms  for  cross-border  permissions,  thereby 
significantly reducing delays and administrative complexity.  

Two types of cross border permissions would be possible:  

-  Standing military transport permissions:  

This  Regulation  would  aim  to  increase  both  predictability  and  operational 
readiness  by  creating  a  standing  military  transport  permission.  A  standing 
permission  would  be  granted  by  one  Member  State  at  the  request  of  another, 
remaining in effect until revoked by the granting Member State. It would not be 
tied  to  any  specific  military  transport  operations  but  would  constitute  a  pre-
authorised permission for cross-border military transport with a pre-defined scope 
(e.g. number of vehicles, types of equipment transported, …). To execute a specific 

52 

 
 
 
transport operation, the requesting Member States would only have to notify the 
receiving  Member  State  and  request  the  necessary  traffic  arrangements,  where 
relevant.  When granting standing military transport permissions,  Member States 
could agree on pre-planned traffic arrangements and pre-defined routes to facilitate 
permitted transport operations requiring a traffic arrangement.  

The  minimum  scope  of  the  standing  military  transport  permission  would  be 
specified  in  the  Regulation  and  would  cover  only  simple  military  transport 
operations.  The  minimum  scope  could  be  extended  in  the  future,  to  cover  more 
complex  military  transport  operations.  This  process  would  run  in  parallel  with 
investments to upgrade the military mobility corridors, enhanced coordination on 
pre-defined  routes  for  military  transport  operations,  and  reinforced  access  to 
transport  capabilities.  In  the  long  run,  such  efforts  could  pave  the  way  to  a 
“military Schengen”. 

-  Ad hoc military transport permissions:   

These  cross-border  permissions  would  apply  to  specific  military  transport 
operations, either when no standing permission is in place or when the transport 
operation's characteristics exceed the scope of an existing standing permission. In 
practice, ad hoc permissions should mainly apply for short notice military transport 
operations that go beyond the agreed scope of standing permission. 
For this type of cross-border permission, the Regulation would propose deadlines 
in full consistency with the 2024 Military Mobility Pledge, in which Member States 
committed to grant cross-border movement permissions within a maximum of 
three working days. 

The permission of cross-border military transport involving dangerous and abnormal cargo 
raises specific complexities because of fragmented national approaches. The Regulation 
would harmonise relevant rules. Regarding the military transport of dangerous goods, the 
Regulation would make it mandatory to permit it if complying with existing international 
conventions  for  civilian  transport,  relevant  NATO  rules  or  the  national  rules  of  NATO 
Allies. The Regulation  would also extend the existing civilian rules for  the transport of 
abnormal cargo to military transport and deem it permitted if it complies with these rules.  

Traffic arrangements and uninterrupted transport operations  

In  addition  to  cross-border  movement  permissions  and  diplomatic  clearances,  certain 
cross-border  military  transport  operations  require  traffic  arrangements,  which  must  be 
requested  by  the  requesting  Member  State  to  the  receiving  Member  State..  Such 
arrangements can cover: 

- 

the identification of the routes for the transport of abnormal cargo or dangerous 
goods,  
the escorts to accompany road convoys,  
the necessary Host-Nation-Support in the context of a transport operation,  

- 
- 
-  or  specific  traffic  safety  measures  going  beyond  ordinary  rules,  such  as  limited 

access to rail track crossings, blocked roads, or restricted airspace. 

In addition, in the rail sector, the rail infrastructure manager also needs to allocate train 
paths,  give  specific  authorisation  for  exceptional  transports  (including  overweight  and 

53 

 
 
 
 
oversized cargo), while railway undertakings must  carry out route compatibility checks  
for  a  military  transport  operation.  Such  traffic  arrangements  and  path  allocations  help 
minimise adverse impacts on civilian transport activities.  

Common  procedures  and  deadlines  for  requesting  and  granting  traffic  arrangements, 
including  the  coordination  with  infrastructure  managers,  are  needed  to  harmonise  and 
streamline processes and reduce delays and disruptions. 

Streamlined procedural formalities 

The Regulation would also streamline procedural formalities and provide templates 
for military transport  requests and notifications, to  avoid  delays,  inefficiencies, and 
operational  bottlenecks.  All  requests  and  notifications  linked  to  a  military  transport 
operation  would  be  combined  into  a  single  permission  request  or  notification  and  no 
additional forms should be required by any Member State. This would be without prejudice 
to the applicable Union customs rules, including the EU and NATO Forms 302.  

Moreover, any communication between Member States linked to requests and notifications 
of  military  transport  operations  and  traffic  arrangements  should  be  transmitted  through 
their respective National Coordinator for Cross-Border Military Transport.  

To facilitate and accelerate the smooth execution of military transport, Member States will 
also  be  encouraged  to  agree  on  pre-defined  routes  to  be  included  in  military  transport 
permissions,  which  would  also  minimise  the  impact  of  military  transport  on  civilian 
activities. 

Adapting civilian rules for military transport 

In  addition,  the  Regulation  would  introduce  exemptions  of  military  transport  from 
traffic bans during weekends, public holidays and other periods subject to civilian traffic 
restrictions. Given that military road vehicles are often heavier than civilian road vehicles, 
meaning  there are less zero- or low  emission alternatives,  and that the renewal  of such 
heavy military road vehicles is slower than that of the civilian fleet, the Regulation would 
also  exempt  military  transport  carried  out  directly  by  the  armed  forces  from  traffic 
restrictions applied on specific road sections based on the environmental performance of 
vehicles.  Regarding  rules  on  road  cabotage  operations,  the  Regulation  would  allow 
Member  States  to  exempt  military  transport  from  existing  restrictions.  These  targeted 
exemptions  would  reduce  the  administrative  burden  associated  with  varying  national 
practices, enabling a more predictable use of transport networks for military purposes. In 
addition,  to  minimize disruptions to  civilian traffic and ensure timely military transport 
operations, the Regulation would establish rules to streamline border crossings. Security 
and efficiency requirements, such as escorting, flagging, would be balanced with the need 
to  avoid  delays.  Consequently,  any  required  inspections  or  controls  for  goods  moving 
through the customs territory of the Union would be deferred to the first scheduled stop 
after crossing the internal border of the Member State, rather than being conducted at the 
internal border itself. 

Customs  

54 

 
 
76.92%  of  Member  States  and  58.33%  of  industry  stakeholders  identified  customs 
formalities as a major cause of delay. The need to ensure legal clarity and coherence was 
a key takeaway from the consultation.  

A  clear  definition  is  essential  to  avoid  unnecessary  customs  delays  and  to  ensure  that 
military consignments can benefit from the customs simplifications provided for under the 
Union Customs Code (UCC). This is why the Regulation would introduce a definition of 
goods to be used for military activities. This definition would covers military materiel and 
assets used in the context of military operations, excluding goods imported for non-military 
purposes.   

On  the  customs  formalities,  for  the  movement  of  goods  related  to  military  activities, 
customs  legislation  allows  simplified  procedures  through  the  use  of  EU  Form  302  and 
NATO Form 302. These forms offer significant advantages compared to standard customs 
declarations,  though  their  use  has  so  far  been  inconsistent  across  Member  States.  The 
Regulation would therefore establish the use of Form 302 as the default option, while 
maintaining the possibility for military authorities to use regular customs procedures when 
necessary. It also provides for a structured exchange of information between customs and 
military  authorities  through  a  mandatory  and  regularly  updated  list  of  national  customs 
contact  points,  ensuring  access  to  all  relevant  facilitations  and  improved  coordination 
across administrations. To further streamline military transport, the Regulation foresees 
specific provisions, ensuring that related customs controls are treated with priority. The 
digitalisation of EU Form 302 would also contribute to modernise and facilitate its use.  

Rail and Air transport 

At the technical level, the Regulation mandates cooperation with the European Union 
Agency  for  Railways  (ERA)  to  review  existing  European  railway  technical  and 
operational rules, identifying changes that can further facilitate the transport of dangerous 
goods and abnormal cargo on the rail network. In particular, the Commission will review 
the Rail Service Facilities Regulation in 2026 to ensure it meets military transport needs.  
The  Regulation  would  ensure  coherence  with  other  relevant  legislative  files  under 
preparation, notably the forthcoming  Rail Capacity Regulation  and the revision of the 
Weights  and  Dimensions  Directive,  thereby  avoiding  conflicting  requirements  between 
civilian and military movements. 

For  military  transport  by  air,  the  Joint  Communication  calls  for  an  evaluation  of  the 
principles of Flexible Use of Airspace adopted in 2005 (Regulation (EC) 2150/2005) in a 
context of increased cross-border operations to ensure efficient dynamic reallocation of the 
airspace,  making  cross-border  operations  more  efficient  and  responsive.  The 
Communication also calls for a series of actions to enhance smooth cross-border operations 
by  air.  Firstly,  a  network  of  dual-use  airports  needs  to  be  established  to  accommodate 
increased military operations. The existing TEN-T network of dual-use airports should be 
evaluated to ensure they have the necessary capacity, equipment, and capabilities to handle 
military operations. Upgrade funding could be provided through the Connecting Europe 
Facility  (CEF).    Furthermore,  in  order  to  facilitate  moving  through  national  sovereign 
airspaces  without  jeopardising  or  being  jeopardised  by  civil  traffic  and  minimising  the 
impact on the flow of civil traffic as well, cross-border connection points will need to be 
identified with the aim of covering the whole of the EU (360° approach) and facilitating 
all possible military cross-border movements.   

55 

 
 
Core measures on rules and procedures 

•  Unified  cross  border  permission  procedures  (standing  and  ad  hoc 
permissions):  Standardised  EU  templates  and  workflows  for  movement 
requests/notifications;  maximum 
clear 
responsibilities and timelines for competent authorities. 

processing 

three-day 

time; 

•  Dangerous  goods  and  abnormal  loads:  Common  EU  rules  for  military 
transport of dangerous goods and oversized/overweight consignments; advanced 
route  planning  based  on  infrastructure  compatibility  and  coordinated  traffic 
management. 

•  Clarified customs procedures: Default use of EU or NATO Form 302 (unless 
otherwise requested by the military authorities when they favour the use of the 
standard customs declaration); prioritised controls; legal clarity already provided 
under the UCC for movements under official military use. 

•  Adaptation  of  civilian  rules  to  military  needs:  exemptions  for  military 
transport from certain rules and restrictions related to traffic bans and cabotage  

European Military Mobility Enhanced Response System (EMERS) 

The preferred policy option laid out throughout the Military Mobility package also entails 
an ambitious approach when it comes to emergency situation requiring effective military 
transport operations.  

Purpose and activation  

The  consultation  revealed  a  strong  consensus  among  Member  States  and  industry 
stakeholders  on  the  importance  of  establishing  a  common  understanding  of  "military 
transport emergency", which should be paired with dedicated rules to facilitate seamless 
military movement and promote a coordinated approach across all Member States. 

The  European  Military  Mobility  Enhanced  Response  System  (EMERS)  proposed 
under the regulation would introduce an emergency framework that could be activated 
by the Council of the European Union, based on a proposal from the Commission. The 
goal  would  be  to  address  scenarios  where  a  significant  surge  in  military  transport 
operations  cannot  be  accommodated  within  the  normal  transport  rules  or  the  existing 
capacity of the Union's transport network. The heightened demand for military transport 
could  result  from  various  factors,  including  the  deterioration  in  the  Union’s  security 
environment,  external  threats,  or  crises  in  neighbouring  countries,  as  well  as  natural 
disasters or man-made catastrophes affecting EU Member States or third countries.  

EMERS would apply  to all Member States,  and  would entail  exceptional,  time-bound 
measures that temporarily override normal rules and procedures. The measures would aim 
to  enable  rapid,  coordinated,  and  adaptable  military  movements  in  response  to  urgent 
situations,  thereby  facilitating  the  swift  and  effective  execution  of  increased  military 
transport operations.  

56 

 
 
 
 
By  facilitating  Member  States’  rapid  deployment  of  military  personnel  and  equipment, 
EMERS would contribute to the credibility of the defence readiness of the Union. In 
practice, the Council could take the decision to activate EMERS to enable swift and large-
scale  military  movement  in  an  effort  to  demonstrate  a  strong  deterrence  posture.  As  a 
result, while the EU and NATO could engage in exchanges of views regarding EMERS 
activation,  Member  States  with  EU  and  NATO  membership  would  bear  primary 
responsibility for ensuring consistency between NATO's military transport efforts and the 
potential EMERS activation.   

EMERS activation and scope 

•  Commission can decide to or can be requested by 2 Member States to assess 
the need to activate EMERS. The assessment is based on a defined criterion 
(increase of military transport operations exceeding normal transport capacity 
and rules) 

•  Activation of EMERS by the Council, based on the Commission’s proposal, 

following its assessment of the Commission.   

•  EMERS applies to the whole EU territory and has a clear time limit of 

activation extension and early termination can be decided by the Council. 

•  EU-NATO exchange of views could take place to ensure consistency and 

synergies 

Enhanced facilitation of military transport  

Once  activated,  EMERS  would  allow  for  the  implementation  of  measures  that  would 
significantly facilitate Member States’ military transport operations:  

-  military transport requests to be automatically accepted by the receiving Member 

State, subject only to a simple notification.  

-  Lead times for coordination and traffic management would be reduced,  
-  military movements across all transport modes would receive priority access to 
transport networks, infrastructure  and services. This proposal was supported 
by nearly 59% of Member States during the consultation. 

-  To reflect operational urgency, Member States would also have to temporarily lift 
national restrictions on cabotage, driving time and rest periods, and restrictions 
based on noise control and air pollution in ports and airports for military transport 
operations, as well as the environmental performance of vehicles for certain road 
sections.  
Infrastructure managers may also authorise rail vehicles to operate beyond their 
specified area of use. 

- 

-  The  protection  of  Strategic  Dual-use  Infrastructures  (see  5.3.2)  would  also  be 
reinforced, to make sure that Member States can access the relevant infrastructures 
to execute their military transports.    

57 

 
 
 
-  Member  States  would  also  benefit  from  a  reinforced  access  to  transport  and 
logistics capabilities registered under the Solidarity Pool (see 5.3.3), if the latter is 
established. 

For  military  movement  entering  the  EU  territory,  EMERS  would  also  include  an 
emergency  customs  mechanism.  The  latter  would  be  developed  by  the  EU  Customs 
Authority  in  consultation  with  the  Commission,  which  enables  accelerated  clearance 
procedures or, where necessary, temporary suspension of the obligation for customs 
declaration  for  military  transport.  Similar  flexibilities  would  apply  to  sanitary  and 
phytosanitary controls for food and feed destined for military use, including supplies for 
service animals, to avoid logistic delays at entry points. The framework ensures that the 
temporary  measures  adopted  under  EMERS  remain  compatible  with  the  EU’s  internal 
market and legal order.  

EMERS Core measures  

•  Notification based system for cross border movement with specific 

conditions for transport where traffic arrangements are needed; accelerated 
coordination for road and rail arrangements. 

•  EU-wide priority access to infrastructure, networks and related services for all 
military modes and operators, including contractors and transport involving 
dangerous goods/abnormal cargo. 

•  Enhanced regulatory flexibilities: temporary exemptions from cabotage, 
driving and/or rest time, traffic limitations; permission for rail vehicles to 
operate outside their specified area of use. 

•  Customs emergency protocols and Sanitary and phytosanitary (SPS) 
facilitation: activation of a dedicated customs crisis protocol; temporary 
waivers for military food supplies (including for service animals) to avoid 
bottlenecks at entry points. 

•  Enhanced protection measures for strategic mobility infrastructure (physical 

and cyber), ensuring coherence with existing regulatory frameworks, in 
particular the CER and NIS2 Directives. 

•  Enhanced access to capabilities through the solidarity pool 

5.3.2  On Infrastructure  

Member  States'  armed  forces  heavily  rely  on  dual-use  infrastructures  to  facilitate  their 
military operations. To ensure the readiness of these infrastructure networks, two sets of 
actions have become crucial: further upgrading and adapting our existing infrastructure, as 
well  as  strengthening  the  resilience  of  the  most  strategic  dual-use  infrastructure  from 
potential threats. Member States' armed forces should also be able to rely on resilient and 
secure  energy  infrastructure  to  guarantee  a  stable  energy  supply,  thereby  ensuring  the 

58 

 
 
 
uninterrupted mobility of their forces. These actions are reflected in the preferred policy 
option. 

Reinforcing the dual use infrastructure network 

The  Regulation  aligns  the  adaptation  of  the  TEN-T  to  military  requirements  with  the 
objectives  of  the  future  CEF  (the  Commission’s  proposal  for  the  next  MFF  2028-2034 
promotes a tenfold increase of the available budget for military mobility, with a proposed 
budget  of  EUR  17.65  billion  under  the  future  CEF  for  investments  in  TEN-T  dual-use 
transport  infrastructure).  Funding  will  focus  on  upgrading  the  four  priority  military 
mobility corridors to standards consistent with the Council’s Military Requirements. 
Approximately  500  “hotspot”  projects  have  already  been  identified  for  urgent 
implementation, addressing key bottlenecks along these corridors. 

In 2026, the Commission will launch a study to reassess the real physical limitations of 
the  rail  infrastructure  on  the  priority  military  mobility  corridors  (working  closely 
with rail infrastructure managers) to identify technical limitations and guide the selection 
of dedicated high-load routes suitable for the heaviest military vehicles. The Commission 
will also work to accelerate ongoing studies on the assessment of the state of rail and road 
bridges and tunnels and on an analysis of port and airport capacities by using satellite data. 
Work with the EU Member States and industry will ensure that the design of future military 
vehicles takes into account the physical constraints of the transport network. Efforts will 
also be taken to re-evaluate the transport infrastructure standards contained in the Council 
Military Requirements.  

Enhancing the resilience of strategic dual-use infrastructure 

Resilience  measures  will  also  address  systemic  vulnerabilities.  The  Joint 
Communication  announces  that  the  Commission will  work  with  ERA  to strengthen  the 
robustness of the rail traffic management system in a harmonised way to ensure continued 
operations in cases of sabotage or other system failure. It will promote absolute safe train 
positioning  technologies  based  on  satellite  signals,  reducing  dependency  on  physical 
trackside equipment. Coordinated stress-testing processes will be put in place by 2029 
to facilitate this.  

Complementing  the  obligations  of  Member  States  under  the  CER  Directive,  the 
Regulation  sets  up  a  process  for  Member  States  to  identify  strategic  dual-use 
infrastructure . Based on a shared toolbox of resilience and protection measures that go 
beyond the instruments of the CER Directive, Member States will be able to ensure that 
this strategic transport, energy and communication infrastructure is resilient against threats 
and  hazards  and  remain  operational  at  all  times.  As  announced  in  the  White  Paper  for 
European  Defence-Readiness  2030,  this  includes  stronger  measures  to  mitigate  risks 
associated with  foreign  ownership and  control of strategic infrastructure, as well as the 
possibility  for  Member  States  to  temporarily  take  control  over  important  infrastructure, 
equipment and assets.  

Cybersecurity is an integral component of resilience. In particular, comprehensive action 
at EU level is needed to enhance the robustness of the radio spectrum that is at the heart 
of  transport  communication  and  navigation.  The  Commission,  ,  will  assess  the  need  to 
update  relevant  EU  legislation  adapt  essential  requirements  for  radio  equipment  and 
accelerate projects for enhanced monitoring of radio frequency interferences.  

59 

 
 
By  setting  out  cybersecurity  risk-management  requirements  for  essential  and  important 
entities in 18 critical sectors, the NIS2 Directive strengthens the cyber resilience  of EU 
infrastructure.  When  implementing  cybersecurity  protection  measures  for  SDI,  it  is 
necessary to ensure coherence with the measures taken pursuant to the NIS2 Directive and 
other relevant existing legislation. Besides the NIS2 Directive, Union legal acts in fields 
such as energy58 and aviation59 set out further cyber and information security requirements 
for certain types of entities in the relevant sectors.  

Ensuring energy supply 

Energy resilience is equally vital for sustained military mobility. The Regulation foresees 
coordination with the forthcoming reviews of EU energy security legislation, including the 
Oil Stock Directive, to ensure adequate access to critical fuel reserves and to integrate the 
defence dimension into the deployment of sustainable aviation and maritime fuels.  

The  Sustainable  Transport  Investment  Plan  will  be  an  important  milestone  further 
supporting the scale-up of SAF and sustainable marine fuels. Closer cooperation between 
civil and military sectors in the fuel ecosystem can significantly unlock the potential of 
SAF and sustainable marine fuels markets, reinforcing EU energy security while pursuing 
climate  targets.  By  promoting  a  modular,  dispersed  production  model  and  enhancing 
distribution networks, the EU can reduce dependence on foreign fuels and fortify military 
mobility and operational readiness.  

Such  investment  will  present  a  significant  opportunity  to  progressively  enhance  energy 
security and strategic  autonomy for the  armed  forces of Member States.  However, it is 
essential to note that pursuing an ambitious approach to renewable and low-carbon fuels, 
along with investing in the development of a comprehensive network of recharging and 
refuelling  infrastructure,  must  be  balanced  with  the  Union's  objective  of  maintaining 
military mobility. This is due to the fact that the existing transportation and logistical assets 
currently used by Member States’ armed forces will remain in operation for many years to 
come, necessitating the continued availability of supporting infrastructure to provide them 
with the necessary fuel supplies.  

Core measures on infrastructure adaptation 

58 See Commission Delegated Regulation (EU) 2024/1366 supplementing Regulation (EU) 2019/943 of the 
European  Parliament  and  of  the  Council  by  establishing  a  network  code  on  sector-specific  rules  for 
cybersecurity aspects of cross-border electricity flows 
59 See Commission Implementing Regulation (EU) 2023/203 of 27 October 2022 laying down rules for the 
application  of  Regulation  (EU)  2018/1139  of  the  European  Parliament  and  of  the  Council,  as  regards 
requirements for the management of information security risks with a potential impact on aviation safety for 
organisations  covered  by  Commission  Regulations  (EU)  No  1321/2014,  (EU)  No  965/2012,  (EU)  No 
1178/2011, (EU) 2015/340, Commission Implementing Regulations (EU) 2017/373 and (EU) 2021/664, and 
for competent authorities covered by Commission Regulations (EU) No 748/2012, (EU) No 1321/2014, (EU) 
No  965/2012,  (EU)  No  1178/2011,  (EU)  2015/340  and  (EU)  No  139/2014,  Commission  Implementing 
Regulations (EU) 2017/373 and (EU) 2021/664 and amending Commission Regulations (EU) No 1178/2011, 
(EU)  No  748/2012,  (EU)  No  965/2012,  (EU)  No  139/2014,  (EU)  No  1321/2014,  (EU)  2015/340,  and 
Commission  Implementing  Regulations  (EU)  2017/373  and  (EU)  2021/664;  Commission  Delegated 
Regulation  (EU)  2022/1645  of  14  July  2022  laying  down  rules  for  the  application  of  Regulation  (EU) 
2018/1139 of the European Parliament and of the Council, as regards requirements for the management of 
information  security  risks  with  a  potential  impact  on  aviation  safety  for  organisations  covered  by 
Commission Regulations (EU) No 748/2012 and (EU) No 139/2014 and amending Commission Regulations 
(EU) No 748/2012 and (EU) No 139/2014. 

60 

 
 
 
•  The  Commission’s  proposal  for  the  next  MFF  (2028  –  2034)  promotes  a 
tenfold increase of the available budget for military mobility, with a proposed 
budget of EUR 17.65 billion under the future CEF for investments in TEN-
T dual-use transport infrastructure.  

•  500 hotspot projects on military mobility corridors earmarked for near-term 
removal of choke points; regular corridor meetings to synchronise and accelerate 
implementation. 

•  2026 rail study to reassess physical limits (axle loads, gauge, clearances) of rail 
infrastructure;  progressive  identification  and  upgrade  of  dedicated  high-load 
routes. 

•  Review  of  Council  Military  Requirements  with  EUMS;  engagement  with 

industry to optimise asset design against practical constraints. 

Core measures on system robustness and cybersecurity 

•  Strengthening  the  robustness  of  the  rail  traffic  management  system  in  a 

harmonised way to ensure continued operations  

•  Strategic dual-use infrastructure identification by Member States, with an EU 
toolbox of protective measures complementing the CER Directive; mitigation of 
foreign  ownership/control  risks  and  provision  for  temporary  public  control 
where necessary. 

•  Cyber/radio-spectrum  resilience:  coordinated  actions  to  strengthen  the 
resilience  of  the  air  traffic  management  system  and  enhance  monitoring  and 
protection against interference, in particular of the radio spectrum. 

Core measures on energy security for mobility 

•  Revision  tracks  for  energy  security  legislation  (including  the  Oil  Stock 
Directive) to reflect defence demand, sustainable fuels and emergency access to 
critical stocks. 

•  Support  for  Sustainable  Aviation  Fuels  and  Sustainable  Marine  Fuels; 

coordination with NATO on future fuels and infrastructure trajectories. 

5.3.3  On capabilities  

Ensuring the effectiveness of military mobility relies heavily on Member States' access to 
necessary  transport  and  logistics  capabilities.  To  achieve  this,  it  proposed  under  this 
preferred  option  to  ensure  that  Member  States'  armed  forces  can  count  on  enhanced 
cooperation through the sharing and pooling of capabilities, as well as on a robust civil-
military cooperation, to facilitate seamless and efficient operations. 

Pooling and sharing capabilities 

61 

 
 
 
Member States are confronted with significant gaps that are de facto difficult to bridge at 
the  national  level  alone,  either  due  to  the  substantial  investment  required  or  because 
addressing  them  individually  would  result  in  unnecessary  duplication  of  efforts.  To 
overcome  this,  several  Member  States  have  successfully implemented  'pooling  and 
sharing' initiatives for transport and logistical capacities, notably in the field of strategic 
air  lift, inland surface and  sea  transport.  However,  these  initiatives  are  fragmented  and 
limited to certain Member States. The Union also has relevant experience in pooling and 
coordinating  responses  to assistance in  civil  protection  area  through  the  European  Civil 
Protection Pool.   

During the consultation, Member States have expressed broad support for the concept of 
pooling and sharing dual use transport capabilities, with around 70% agreeing that it would 
be  beneficial  for  military  mobility  and  preparedness.  While  there  are  conditions  and 
frameworks that need to be established to ensure the success of such an initiative, many 
see it as a way to increase transparency, boost interoperability, and reduce duplication of 
efforts within the EU. Overall stakeholders consulted also identify the potential for cost 
savings and enhanced readiness but  recommend however the development  of a flexible 
pooling model with clear allocation rules and centralized management.  

make them 

Building  on  this,  the  Regulation  would  entail  the  possibility to establish a  “Solidarity 
Pool”  for  military  mobility.  It  would  cover capabilities  across all transport  modes 
and seek to 
States. The 
Commission would ensure that the solidarity pool can benefit from a 24/7 capacity as well 
as  planning  and  coordination  functions. Under  this  initiative Member  States would  be 
able to  voluntarily  register  their  own  military  transport  capacities  as  well  as  those 
contracted with civilian operators. The registered capacities would be made available to 
all Member States, enhancing their ability to conduct military transport operations.  

accessible 

Member 

all 

to 

and 

sharing 

Additionally,  the  Union  would  be  able  to  register additional capabilities  in  the 
pool and include contracted capabilities. To expand existing capacities, and to incentivise 
should 
the 
also respectively support procurement  of new military  mobility  capabilities  and help 
Member  States  in  sharing  the  burden  of  deployment  costs,  maintenance  expenses,  and 
personnel  training  costs  linked  to  pool. The  proposed European  Competitiveness  Fund 
to 
(ECF) includes  dedicated  provisions 
provide such financial support under the next MFF.  

of capacities, the Commission 

that  would  allow 

the  programme 

pooling 

To complement the financial support, the Commission could also consider introducing a 
credit-based system  while establishing  the Solidarity Pool,  to incentivize the sharing of 
capabilities among participating members. Building on the existence of the Air Transport, 
Air-to-Air  Refuelling,  and  other  Exchange  of  Services (ATARES)  and  the Surface 
Exchange of Services (SEOS), the Commission, may specify the conditions under which 
a credit-based system may be used as a  form of non-financial exchange mechanism for 
capabilities  registered  in  the  Pool. Such  a  system  could  help to guarantee a fair and 
transparent access  to the Pool’s capabilities.  Complementing  this,  a  Strategic  Lift 
Reserve will enable operators to set aside transport capacities (such as airlift or sealift) for 
EU or Member State use in exceptional situations. 

Civilian-military capacity enablement 

Member State’s armed forces must be able to rely on a strong partnership with civilian 
actors. In this perspective increasing the awareness of the logistics and transport dual-use 

62 

 
 
capacities  from  the  civilian  sector  constitute  a  prerequisite  That  the  preferred  option  is 
aiming to achieve. 

This  is  the  reason  why,  the  Commission  and  the  High  Representative  will  explore  the 
possibility  to  create  a  Military  Mobility  Catalogue  to  allow  European  companies  to 
voluntarily list transport assets and services that can support military operations, giving 
Member  States’  armed  forces  greater  visibility  of  available  capacities.  Complementing 
this,  a  Strategic  Lift  Reserve  will  enable  operators  to  set  aside  transport  capacities 
(notably airlift and sealift) for EU or Member State use in exceptional situations.  

Member  States  should  also  be  able  to  access  information  about  existing  dual-use 
capabilities  to  appropriately  plan  future  military  transport  operations  and  identify 
persisting capability gaps. Most civilian rail and road vehicles and aircraft are registered 
in  national  or  European  registers.  Member  States’  visibility  over  existing  capabilities 
should therefore be improved by ensuring that the national services responsible for military 
transport have access to these registers. Large numbers of civilian rail vehicles might be 
considered  dual-use  and  fit  for  military  transport  operations,  or  easily  upgradeable  for 
those purposes. Therefore, the Commission should be allowed to define whether and under 
what conditions entities that own such vehicles, vehicle keepers that are responsible for 
them and vehicle manufacturers that manufacture them assess whether railway vehicles 
have the technical characteristics to be used as part of a military transport. The Commission 
should  also  be  allowed  to  develop  harmonised  technical  parameters  on  which  such 
identification might be based.  

Member States need access to information on existing dual-use capabilities. This could be 
achieved by granting national military transport services access to national and European 
registers  of  civilian  vehicles,  including  rail  and  road  vehicles,  as  well  as  aircraft.  In 
particular,  many  civilian  rail  vehicles  could  be  suitable  for  military  transport  or  easily 
upgradeable for this purpose. To facilitate this, the proposed Regulation could allow the 
Commission  to  establish  criteria  to  help  railway  undertakings,  vehicle  keepers,  and 
manufacturers identifying dual-use railway vehicles.  

As a result of scarce capacities, a Member State may end up pre-contracting those already 
booked by another Member State. To address risks associated with such possible double 
booking,  we  propose  today  that  transport  providers  be  required  to  keep  Member  States 
informed of such cases. In addition, to be ready to face most extreme situations, Member 
States should all have in place a framework for taking temporary control of necessary 
equipment for military transport operations also to assist other Member States. 

Furthermore, to promote interoperability, the Commission will task its relevant regulatory 
Agencies  (EASA,  EMSA  and  ERA)  and  the  European  standardisation  organisations  to 
develop  dual-use  standards  for  military  mobility  critical  transport  assets,  ensuring 
consistency  with  NATO  standards  for  transport  assets  and  the  updated  dual-use 
infrastructure requirements. 

The  Package  also  supports  the  use  and  development  of  dual-use  unmanned  aircraft 
systems for military transport. It notably calls for an EU network of civil/defence drone 

63 

 
 
testing centres. Together with the European Union Aviation Safety Agency (EASA), the 
Commission  will  develop  a  joint  framework  for  integrating  drones  into  low-altitude 
airspace and develop a U-Space framework, ensuring civil and military operations through 
common  standards  and  procedures.  It  will  create  a  European  regulatory  framework  for 
Counter-UAS  technologies  and  work  on  establishing  a  methodology  for  assessing  AI-
based drone systems' trustworthiness. Lastly, the Commission and EASA will develop a 
harmonised  certification  framework  for  large,  high-risk  drones  by  amending  the  EASA 
Basic Regulation.  In  close cooperation with  the  EDA, the Commission  and EASA will 
ensure that defence requirements and interoperability aspects are fully integrated into 
these  initiatives.  EDA  will  act  as  the  defence  interface,  linking  national  Ministries  of 
Defence,  facilitating  access  to  military  test  ranges,  and  ensuring  coherence  with  EU 
defence capability priorities and NATO standards.  

Digitalisation of military mobility 

Digitalisation constitutes a key enabler of preparedness. The Regulation therefore would 
envisage the creation of a Military Mobility Digital Information System, a secure, EU-
wide platform for managing cross-border movement requests. This system would also have 
in scope the electronic handling of EU Form 302. 

It would be designed to meet the highest standards of confidentiality and cybersecurity, 
with funding and deployment foreseen under the next Multiannual Financial Framework. 
This reflects a wide perception noted during the stakeholder consultation:  69% of Member 
States supported the establishment of a digital tool for cross-border permissions.  

This  option  of  a  Military  Mobility  Digital  Information  System  would  build  on  the 
experience gained through the EDF’s SDMMS project and could benefit from additional 
EU support under the next MFF, under the proposed ECF, which entails the possibility to 
fund  the  digitalisation  of  Military  Mobility  related  processes.  The  development  and 
deployment  of  the  Military  Mobility  Digital  Information  System  would  also  require  a 
strong involvement of the Military Mobility Transport Group notably to reflect Member 
States views (see 5.3.4). 

Core measures on solidarity mechanisms 

•  Military Mobility Solidarity Pool: sharing and pooling of registered national 

and EU capacities  

• 

Incentives: EU co-funding of operating/maintenance/training costs; co-funded 
capacities  automatically  available  to  the  Pool  under  EMERS;  credit-based 
system to ensure fair use. 

Core measures on civilian-military capacity enablement 

•  Military  Mobility  Catalogue:  voluntary  listing  by  European  operators  of 

assets/services relevant to military mobility. 

•  Access to registries of dual-use road/rail vehicles and identification rules to 

facilitate their military use. 

64 

 
 
 
•  Flexible  and  transport  contracting:  transparency  on  overbooking;  clauses 
enabling other Member States to access contracted services where feasible. 

•  National frameworks for temporary control/right of use: common minimum 

features to enable last-resort mutual support. 

•  Mandates to European standardisation organisations for dual-use standards 

(consistent with NATO). 

•  Drone  ecosystem:  EU  civil-defence  testing  network;  U-Space  integration; 

Counter-UAS framework. 

Core measures on digitalisation 

•  Military Mobility Digital Information System covering: digital workflows for 
movement  authorisations;  the  customs  aspects  of  EU  Form  302;  secure  data 
exchange;  NATO-interoperable 
and 
confidentiality. 

architecture;  high 

cybersecurity 

•  Development  and  deployment  envisaged  under  the  next  MFF,  building  on 
technical 

the  EDF’s  SDMMS); 

previous  achievements  (among  others, 
specifications co-created with Member States. 

5.3.4  On governance  

The preferred policy option establishes a strong governance framework in the context of 
the  proposed  the  Regulation,  ensuring  a  more  cohesive  approach  to  improve  military 
transport in the Union.  

At national level, each Member State will designate a National Coordinator for Military 
Transport, responsible for ensuring interministerial coordination. It would also act as the 
sole contact point in implementing the Regulation, particularly in facilitating timely and 
effective  communication  between  Member  States  regarding  cross-border  permissions, 
where rapidity, efficiency, and clarity are essential. 

At  Union  level,  the  Regulation  establishes  a  Military  Mobility  Transport  Group, 
bringing together representatives of Member States (incl. from Member States’ customs 
authorities),  the  Commission,  the  European  External  Action  Service  (including  the 
European Union Military Staff), and the European Defence Agency. This Group  would 
provide a forum to advice and issue recommendations necessary for the implementation of 
the Regulation. For instance the Group would help identifying the capabilities that should 
be  pooled  and  shared  in  the  context  of  the  possible  Solidarity  Pool  or  would  provide 
recommendations on the technical specifications that should be envisaged for the potential 
Military Mobility Digital Information System. This Group would also play a key role in 
ensuring overall coherence and stimulating the coordination efforts at the Union level in 
certain aspects of the implementation of the proposed regulation. Specifically, the Group 
would encourage the establishment of standing permissions between Member States along 

65 

 
 
 
 
the  same  military  mobility  corridors,  and  promote  discussions  on  pre-planned  traffic 
arrangements and pre-defined routes in the context of these stranding permissions. 

In addition, to maintain operational readiness, each Member State will conduct an annual 
Military  Transport  Readiness  Check,  to  verify  that  it  has  implemented  all  necessary 
measures to facilitate military transport operations on its territory, and that it has shared its 
cross-border military transport permission requests and solidarity pool support requests in 
a timely manner. This will enable Member States to regularly assess that all necessary steps 
are being taken to ensure seamless military transport operations within the Union, with a 
view to maintain the credibility of the Union's defence readiness. In parallel, and as part of 
these preparedness efforts, the Commission and EEAS will organise targeted stress tests 
focusing  on  specific  elements  of  the  Regulation,  such  as  customs  control  or  civilian-
military coordination. 

Core measures on governance and coordination 

•  National  Coordinator  for  Military  Transport  appointed  by  each  Member 
State to ensure whole-of-government coordination and EU interface, including 
during EMERS. 

•  Military Transport Group (Member States, Commission, EEAS/EUMS, EDA) 
to  advice  the  Commission  on  the  implementation  of  certain  aspects  of  the 
Regulation, promote permissions and traffic arrangements, and oversee progress. 

•  Annual Military Transport Readiness Checks by Member States.  

•  Commission-led stress tests on targeted aspects (e.g. customs procedures, civil-

protection/military interfaces). 

66 

 
 
 
 
6 

IMPACTS OF THE PREFERRED POLICY OPTION? 

It should be noted that the feasibility of a comprehensive ex ante assessment of impacts 
in  the  area  of  military  mobility  is  seriously  constrained  in  comparison  with  many 
other  policy  areas.  This  limitation  is  driven  primarily  by  the  lack  of  available  and/or 
reliable data due to the nature of and number of policy areas related to military mobility as 
well as and the security considerations and sensitivities associated with data sharing and 
making  data  publicly  available.  Beyond  sensitivity  of  the  data,  there  are  no  sufficient 
studies conducted in military mobility since the first Action Plan on Military Mobility and 
the newfound interest  in the wake of the changing geopolitical situation. In addition, no 
sufficiently  large-scale  military  transport  movements  have  been  performed  previously. 
There  is,  therefore,  a  lack  of  evidence  of  formalised  analysis  of  lessons  learned  from 
military exercises60. These limitations compound the speculative character of many of the 
assumptions in this chapter. 

The  measures  laid  out  in  the  Military  Mobility  Package  2025  can  be  expected  to  have 
significant  and  multi-dimensional  impacts  on  rules  and  procedures,  infrastructure,  and 
capabilities across the EU. The heterogenous nature (effect will not be uniform across the 
EU) and the conditionality (dependence on uptake) of many of the impacts described in 
this section should be noted. The analysis below considers direct, indirect and spill-over 
effects across the economic, social and environmental dimensions, and identifies (where 
possible) potential negative externalities and (where possible) mitigation measures.  

6.1  Economic impacts 

The Regulation establishes, for the first time at EU level, a  systematic framework for 
identifying and protecting strategic infrastructure for military mobility. In operational 
terms,  the vulnerability to disruption of such infrastructure has been underlined both  in 
recent  EU  risk  assessments61  and  during  NATO’s  multinational  exercises  such  as  
DEFENDER-Europe.62 

The  infrastructure  dimension  represents  the  largest  economic  multiplier  of  the 
initiative, taking into account the proposed  budget of EUR 17.65 billion CEF (2028–
2034) for TEN-T dual-use transport infrastructure upgrades along the corridors. It can be 
expected  that  this  investment  might  enhance  TEN-T  network  efficiency  by  removing 
bottlenecks and enabling interoperability of civil and military transport and increase cross-
border  connectivity  and  cohesion,  especially  for  peripheral  regions  linked  to  those 
upgraded corridors.  

However, this impact can be expected to be unevenly distributed: Member States with 
advanced  project  pipelines  may  absorb  a  disproportionate  share  of  funding,  (with  the 
potential  for  widening  intra-EU  regional  disparities).  In  Member  States  with  extensive 
networks already subject to EU or national resilience measures, the incremental effect may 
be limited, whereas in others the identification of  strategic dual-use infrastructure could 
lead to tangible improvements in preparedness.  

60 ECA Special Report 04/2025, p. 58, p.63.  
61 Directive (EU) 2022/2557 of the European Parliament and of the Council of 14 December 2022 on the 
resilience of critical entities and repealing Council Directive 2008/114/EC 
62 U.S. Army Europe and Africa Public Affairs Office, DEFENDER 25 

 
 
 
 
The foreseeable impacts on infrastructure are likely to materialise gradually and unevenly 
across the EU. The designation of strategic dual-use infrastructure is expected to improve 
prioritisation  of  investment  and  protection  measures  (it  is  to  be  expected  that,  once 
designated  as  such,  this  strategic  dual-use  infrastructure  will  focalise  investment, 
subsequently receiving special attention from Member State governmental bodies when it 
comes to protection measures), but the degree of impact will depend on the consistency 
with which Member States apply the designation criteria.63  Whereas largescale military 
movements may have disruptive effects on civilian life and require societal buy-in, their 
deliverables also benefit society. Investment in transport infrastructure could be of triple 
use,  simultaneously  benefitting  the  EU’s  trade  flows,  the  EU’s  Common  Security  and 
Defence Policy and NATO’s Concept for the Deterrence and Defence of the Euro-Atlantic 
Area64 

As a recent European Parliament Research Service briefing insert states, “looking at the 
impact  on  GDP  of  the  announced  investment  in  dual-use  transport  infrastructure,  it  is 
essential to distinguish what would constitute new investment from what would constitute 
a  shifting  from  the  transport  budgetary  line  to  the  dual-use  military  budgetary  line. 
Budgetary  realignment  is  important  for  flagging  priorities  and  directing  investment 
towards  certain  goals,  but  it  is  unlikely  to  boost  GDP  in  a  significant  way  as  the  total 
amount invested is unchanged.” 65 

The  mentioned  briefing  estimates  the  “potential  impact  of  additional  investment  of 
between EUR 75 billion and EUR 100 billion until 2035 to inprove the current state of 
infrastructure  [...]  the  added  value  associated  with  a  larger  amount  of  funds  invested 
collectively leads to benefits that are almost three times higher (EUR 21 billion additional 
GDP per year in 2035) than when Member States invest separately and in an uncoordinated 
way.” As a comparative exercise, the impact assesment on the completion of the TEN-T  
network  sheds  light  on  the  following  (building  on  the  projects  along  the  core  network 
corridors to be implemented between 2017 and 2030):  

•  An additional 800 000 European people will be employed in 2030 through the 

completion of the TEN-T core network,  

•  7.5 million person-years of jobs will be generated cumulatively during the period 

2017 - 2030, The impact of TEN-T completion - Synthesis 10  

•  Additional GDP growth of 1.6 % will be realised in 2030,  

Since there is a 94 % overlap between the EU military mobility network and the TEN-T 
network66, it can only be assumed that infrastructure improvements on the TEN-T network 
would also benefit military mobility, creating significant returns and positive impacts.67  

The results of the EPRS projection “confirm the largely beneficial impact of coordinated 
EU  action  when  it  comes  to  investment  in  infrastructure.  The  larger  amount  of  funds 

63  European  Association  for  Forwarding,  Transport,  Logistics  and  Customs  Services,  Position  Paper  on 
Military Mobility and Dual-Use Transport Infrastructure, July 2025. 
. 
64 NATO’s “deter and defend” concept. 
65  European  Parliament  Research  Service,  European  Added  Value  in  Action  briefing  “Towards  a 
comprehensive and beneficial approach to military mobility”, September 2025, p. 11. 
66 ECA Special Report 04/2025, p 10. 
67  European  Parliament  Research  Service,  European  Added  Value  in  Action  briefing  “Towards  a 
comprehensive and beneficial approach to military mobility”, September 2025, p. 3. 

68 

 
 
 
invested collectively, and the efficiency gains associated with sharing best practices and 
further harmonisation, leads to benefits which are almost three times higher (€21 billion 
additional GDP per year in 2035) than when Member States invest on their own (around 
€7 billion additional GDP per year in 2035).”68  

Figure 7 : European Parliamentary Research Service’s estimation of GDP impact per year 
by 2035, p.11.  

Hence, upgrading of selected assets to dual-use standards may generate efficiency gains 
for both civilian and military traffic (although speculative, these could range from time 
savings, to cost reductions or capacity increases69 70), but the scope of such benefits will 
vary  depending  on  national  uptake.  Reinforced  bridges  and  upgraded  railheads  are 
expected  to  ease  bottlenecks  for  heavy  military  convoys  and  could  also  facilitate  the 
movement of oversized civilian freight, though such civilian spillovers will likely not be 
universal.71 

The  earmarked  near-term  removal  of  choke  points  in  the  500  hotspot  projects,  can  be 
expected to reduce the vulnerability of key assets to disruption, particularly in relation 
to  hybrid  threats.  However,  the  impact  will  depend  on  the  adequacy  of  resources 
allocated to  upgrading  measures, as  well as on the ability of operators to integrate new 
standards  into  existing  systems.  Some  operators,  especially  in  ports  and  rail,  may  face 
significant costs in meeting the new requirements 

The revision tracks  for  energy security legislation (including the Oil Stock Directive), 
support for SAF and sustainable marine fuels, and coordination with NATO on future fuels 
and infrastructure trajectories is likely to improve security of supply for military transport, 
especially on the EU’s eastern flank where refining capacity is more limited. Nevertheless, 
the effect may be constrained by structural trends in the energy market, such as declining 
refining  capacity  in  the  EU.  Access  to  emergency  oil  stocks  in  crises  may  improve 
operational  readiness,  though this may come at the cost  of temporary strain  on civilian 
markets if not adequately managed.72 73 

The military mobility package is also expected to yield gradual yet significant changes to  
military mobility within when it comes to rules and procedures in the EU. Even though 

68  European  Parliament  Research  Service,  European  Added  Value  in  Action  briefing  “Towards  a 
comprehensive and beneficial approach to military mobility”, September 2025, p. 11. 
69  European  Parliament,  Implementation  Appraisal  Briefing,  European  critical  infrastructure  Revision  of 
Directive 2008/114/EC, February 2021.  
70 European Commission: Directorate-General for Research and Innovation, Making the most of EU research 
and innovation investments – Rethinking dual use, Publications Office of the European Union, 2025. 
71 European Parliament Research Service, Increasing European added value in an age of global challenges 
Mapping the cost of non-Europe in 2022-2032, February 2023. 
72  European  Commission  Staff  Working  Document  on  the  Mid-term  evaluation  of  Council  Directive 
2009/119/EC  imposing  an  obligation  on  Member  States  to  maintain  minimum  stocks  of crude  oil  and/or 
petroleum products {SWD(2017) 439 final}, dated 24.11.2017. 
73  European  Commission:  Directorate-General  for  Energy  and  Trinomics,  Impact  assessment  "Measures 
resulting from the mid-term evaluation of the Oil Stocks Directive 2009/119", Publications Office, 2019. 

69 

 
 
 
 
difficult to quantify, the foreseeable impact is expected to positively affect the time and 
uncertainty associated with cross-border movement permissions and customs.  

For example, according to the ECA Special Report 04/2025, some Member State requires 
45  days  advance  notice  for  cross-border  movement  of  military  equipment  during 
peacetime.74 75  Brig. Gen. Fabrice Feola, who commands France’s Centre for Operations 
and Transport Support, affirmed that “obtaining approval to cross neighbouring countries 
by military convoy today takes much longer than a European Union target of five days – 
more like tens of days”.76  

In the consultation, Member States’s respondents underlined that a binding framework for 
TAs  could  drive  standardisation  and  simplification,  thereby  accelerating  the  cross-
border transport of troops and military equipment. At the same time, concerns were raised 
that some Member States may be reluctant to abandon established national procedures and 
requirements. Nevertheless, to achieve efficiency and interoperability, uniform technical 
standards  are  required  across  all  corridors  intended  for  military  mobility.  A  commonly 
accessible  digital  platform  was  suggested  as  a  practical  tool  to  support  this  objective. 
Member  States  also  recalled  the  importance  of  EDA’s  Category  A  programme  on 
“Optimising  cross-border  movement  permission  procedures  in  Europe”  (CBMP)  and 
stressed the importance of its full implementation. 

Industry stakeholders echoed these points, noting that while full harmonisation is feasible 
in  certain  Member  States,  practical  challenges  may  persist  elsewhere  even  under  a 
harmonised legal regime. Such challenges include digitalisation gaps, language barriers, 
and coordination difficulties with civilian authorities. Industry therefore stressed that EU-
level  harmonisation  must  be  operationally  viable  and  more  practical  than  existing 
arrangements,  while  allowing  for  some  flexibility  to  accommodate  specific  national 
circumstances. Despite these caveats, harmonisation was broadly recognised as a means to 
reduce  bureaucratic  burdens  and  create  standardised  procedures  for  cross-border 
movement. 

By introducing common timelines and standardised templates for movement permissions, 
and ensuring that all the customs facilitations related to Form 302 are used , routine military 
transport is likely to become more predictable, which in turn should facilitate more precise 
operational planning. However, the actual scale of this reduction will be largely dependent 
on the capacity of national administrations to adapt, the level of uptake, and the degree to 
which Member States enforce compliance internally.  

The harmonisation of authorisation procedures across the EU can also be expected to create 
a  more  stable  environment  for  operators  engaged  in  defence-related  transport.  At 
present,  divergent  national  approaches  expose  operators  to  different  levels  of  scrutiny, 
liability, and delay. The Regulation is expected to reduce this variability over time, thereby 
improving  legal  certainty.  Easening  the  administrative  burden  and  the  need  for 
intermediaries  to  handle  permits  and  clearances,  would  allow  coordination  centres  and 
logistics operators to focus on optimizing routes, capacity, and timing - activities that add 

74 Rapid mobility of troops and equipment across the EU still 'problematic', say auditors | Euronews 
75 Red tape and underfunding slow down EU ‘military Schengen’ 
76 EU rail push to eastern flank still snarled by rules: French general 

70 

 
 
 
real efficiency rather than procedural compliance. The result would be faster, more cost-
effective, and more competitive transport services supporting both defence and industry. 

Digitalisation  would  represent  a  considerable  shift  in  how  military  mobility  is 
administered. The foreseeable impact at operational level may result in fewer errors, faster 
processing, and better situational awareness of traffic flows. At strategic level, this impact 
might translate into higher availability of aggregate data on movements, which may help 
the EU identify systemic bottlenecks and to refine policy responses. At the same time, risks 
are inherent: cybersecurity concerns are likely to remain (or increase, if parts of the process 
move to digital space), and processes to increase cooperation with NATO/the respective 
national systems will be likely technically complex. Furthermore, it is worth pointing that 
the  benefits  of  digitalisation  will  only  materialise  if  data  is  consistently  and  accurately 
input.  

The codification of a common definition of a “transport emergency” and, especially, the 
activation  of  extraordinary  derogations  under  EMERS  are  likely  to  shorten  the  time 
needed to implement crisis measures, compared with the current situation where national 
authorities rely on divergent, siloed procedures. The foreseeable impact is a more rapid 
synchronisation  of  responses  across  the  EU,  particularly  in  high-tempo  reinforcement 
scenarios. However, this beneficial impact must be weighed against the risk that divergent 
national interpretations of when a “transport emergency” exists could persist, particularly 
in  the  first  year  of  implementation.  A  further  impact  to  take  into  consideration  is  the 
balance between derogations and safety/environmental  standards: too  broad or frequent 
use of derogations could undermine public confidence or civilian traffic safety. 

The  introduction  of  priority  access  rules  across  all  transport  modes  is  likely  to  have 
different  impacts.  For  military  transport,  improved  planning  of  convoy  movement 
during  “transport  emergencies”  for  military  planners  and  civilian  operators  is 
foreseeable, as operators would no longer face uncertainty about whether civilian flows 
take precedence. For civilian users, the impact is likely to be more mixed. In most cases, 
disruptions  would  be  temporary  and  limited  to  periods  of  emergency.  However,  in 
congested transport systems (like major ports or key rail hubs), the diversion of capacities 
could produce noticeable domino effects. 77 

Coordination  with  NATO  when  it  comes  to  documentation  standards,  is  expected  to 
reduce  duplication  and  ease  the  transit  of  Allied  forces  through  EU  territory.  The 
impact here will be most visible in  large-scale deployments, where procedural bottlenecks 
currently  create  significant  delays.  The  impact  here  will  be  most  visible  in  large-scale 
deployments, where procedural bottlenecks currently create significant delays. However, 
the degree of improvement will depend  on the consistent application of the harmonised 
standards in practice and on the level of EU-NATO coordination achieved. 

The regulatory impacts of the package are expected to be positive in terms of reducing 
fragmentation, increasing predictability, and improving coordination with NATO; all seen 
as major concerns for Member States and industry alike in the stakeholder consultation. 
The  impact  will  depend  on  the  speed  of  national  transposition,  the  adequacy  of 

77  Community  of  European  Railway  and  Infrastructure  Companies,  Position  paper  “Rail's  Vital  Role  in 
Enabling the Future of EU Defence”, Ibid. 

71 

 
 
 
administrative resources, and the willingness of all parties to align their practices with the 
new harmonised framework. 

The  harmonisation  of  cross-border  authorisation  or  the  implementation  of  simplified 
customs formalities may increase efficiency, legal certainty and predictability for both 
military and civilian logistics operators. Uniform templates and the three-day processing 
target  will  cut  waiting  times  and  remove  the  need  for  multiple,  duplicative  national 
authorisations. 

Standardised procedures are expected to reduce admninistrative costs for operators and 
authorities,  likely  generating  costs  savings.  Based  on  comparative  evidence  from  the 
new  Union  Customs  Code  Regulation,  administrative  time  savings  are  plausible78  The 
digitalisation of EU Form 302 is expected to lead to a reduction in the documentary errors 
that may be expected in terms of market efficiency. In terms of increasing certainty for 
investments,  predictable  and  harmonised  rules  make  military  mobility  projects  more 
bankable, which may encourage private investment in dual-use infrastructure projects. 

Transitional  costs  that  can  be  expected  to  have  to  do  with  necessary  investments  by 
Member States  and operators in  potential  IT adaptation  or compliance monitoring. The 
expected  positive  impact  that  the  Regulation’s  measures  may  have  on  interoperability 
standards might serve as a mitigating factor of these possible transitional costs.  

The foreseeable economic impacts on capabilities are likely to be gradual but significant 
in scope, particularly as the Regulation creates mechanisms for transparency, pooling, 
and burden-sharing that have so far been absent. The establishment of national and EU-
level  registries  of  dual-use  transport  assets  may  provide  a  clearer  picture  of  available 
capacities. The expected impact can be expected to be an improvement in planning and 
allocation  of  resources:  planners  will  be  able  to  better  match  demand  with  available 
assets,  better  identify  critical  shortfalls,  and  better  develop  the  appropriate  contingency 
measures. However, the effectiveness of the registries will be impacted by the accuracy 
and completeness of the data provided by operators, as well as on the degree to which the 
information is kept up to date.  

The solidarity mechanism is expected to strengthen collective resilience. For Member 
States  with  limited  national  transport  capacity,  the  impact  could  be  particularly 
meaningful, as they could gain structured access to assets otherwise unavailable to them. 
Member States with larger national transport capacities may benefit from burden-sharing 
arrangements that reduce the risk of overstretching their assets during crises. Nonetheless, 
the functioning of the solidarity pool will be impacted by depending heavily on voluntary 
contributions,  clarity of allocation rules, and the governance structure ensuring fair and 
rapid access. Stakeholder survey input also reinforces the foreseeable risk that in situations 
of high civilian demand, the willingness of operators to release assets into the pool may be 
constrained. 

The more structured integration of private carriers into the military mobility framework 
will likely  expand the volume of transport capacity available, particularly  in  sectors 

78 Commission Staff Working Document, Impact Assessment Report accompanying the document Proposal 
for a Regulation of the European Parliament and of the Council establishing the Union Customs Code and 
the  European  Union  Customs  Authority,  and  repealing  Regulation  (EU)  No  952/2013,  {SWD/2023/140 
final}. 

72 

 
 
 
such as road and rail freight where military-owned assets are limited. Clearer liability rules 
and  pre-negotiated  framework  contracts  should  reduce  the  reluctance  of  companies  to 
participate. The likely impact is that, during crises, reliance on private carriers will be more 
predictable  and  less  vulnerable  to  last-minute  refusals.  However,  this  dependence  also 
creates new vulnerabilities: private operators may still prioritise commercial commitments 
or be reluctant to operate in high-risk areas, even under a more robust legal framework. 
The Regulation reduces but does not eliminate these uncertainties. 

The  harmonisation  of  standards  for  dual-use  equipment  is  expected  to  encourage 
interoperability and reduce inefficiencies in procurement. Over time, this may lower 
costs and simplify the use of civilian equipment for military purposes. The impact is likely 
to  be  gradual,  given  the  long  lifecycle  of  rolling  stock  and  other  transport  equipment. 
However, industrial adaptation will depend not only on regulatory alignment but also on 
the strength of demand signals from both civilian and defence customers. 

The capabilities pillar will increase the availability of transport assets (especially for 
Member States with limited capacities in this regard), being expected to lower overall costs 
and  improving  utilisation  rates.  Harmonised  dual-use  standards  and  certification 
frameworks for drones, vehicles and logistics systems may create larger, EU markets for 
dual-use  equipment,  with  an  increased  level  of  predictability.  These  changes  may 
impose  adjustment  costs  on  SMEs  that  must  align  with  these  new  standards  or 
interoperability requirements.   

6.2  Societal impacts 

Measures  foreseen  under  the  package  will  have  both  direct  and  indirect  impacts  on 
different societal aspects. It can only be expected that improved infrastructure will enhance 
mobility, safety and accessibility for both military and civilian users, benefiting citizens 
beyond  the  defencedomain.  The  process  of  identifying  strategic  dual-use  infrastructure 
may further strengthen  resilience in crisis times and public safety.  Public perception 
risks  may  include  concerns  about  disruptions  of  public  space,  especially  during 
construction.  

The introduction of priority rules under EMERS could, when activated, create short-term 
disruption to civilian transport flows. Such impacts are expected to be temporary and 
proportionate but will need to be closely monitored to avoid unintended consequences for 
supply  chains.  The  activation  of  EMERS  prioritisation  protocols  may  also  temporarily 
disrupt civilian transport and impose economic costs on operators, particularly if activated 
for extended periods. These risks to infrastructure underline the importance of adequate 
EU co-financing and coordinated monitoring. 

In terms of governance, the establishment of the National Coordinators and the Military 
Transport  Group  will  serve  to  strengthen  inter-ministerial  coordination.  Stakeholder 
consultation responses revealed that the absence of uniform procedures currently causes a 
high degree of legal uncertainty.  

The new governance mechanisms laid out in the Regulation promotes accountability of 
the  different  bodies  and  agencies.  Potential  downsides  include  an  initial  increase  in 
administrative workload (including for Union agenies) particularly for Member States with 
less populous administrative bodies. 

73 

 
 
The Regulation is likely to have a moderate but discernible effect on labour, particularly 
in the transport and logistics sectors. The increased reliance on dual-use infrastructure and 
private operators for military transport will likely require a workforce with the necessary 
clearances, technical skills, and familiarity with military standards. A foreseeable impact 
may  not  be  the  creation  of  large  numbers  of  new  jobs,  but  rather  the  reskilling  and 
upskilling of existing staff to ensure compliance with harmonised rules and procedures. 
This may be expected to, over time, reduce errors in handling dangerous goods or improve 
digital  competence  where  new  tools  are  introduced.  The  immediate  impacts  may  be 
modest,  as  training  systems  take  time  to  establish  and  absorb,  but  cumulative 
improvements in preparedness are likely in the medium to long term.  

Labour  shortages  in  key  sectors  (road  haulage,  rail  freight)  are  likely  to  condition  the 
Regulation’s  effectiveness.  Stakeholder  input  highlighted  that  many  truck  drivers 
operating in Member States are nationals of other EU or third countries, which may present 
challenges  in  times  of  crisis  if  mobility  is  restricted  or  labour  protections  limit 
redeployment. This structural vulnerability means that the Regulation’s reliance on private 
carriers  could  be  constrained  by  availability  of  personnel,  particularly  during  surges  in 
demand.  Overall,  the  Regulation  is  expected  to  have  limited  quantitative  impact  on 
employment  levels,  but  qualitative  impacts  on  skills,  training  requirements,  or  working 
conditions are foreseeable. 

It  can be expected that  enhanced capabilities  contribute to preparedness,  solidarity, 
and  governance  coherence.  This  may  be  the  case  with  National  Coordinators  and  the 
Transport Military Group when it comes to the first steps of institutionalised cross-sectoral 
coordination at national  and EU-level and the improved interinstitutional accountability 
that might be a consequence of this. The aforementioned readiness checks and stress tests 
can be expected to build trust and an operational culture across the bodies involved that 
may elevate the level of trust between them.  

Nevertheless,  the  measures  may  introduce  potential  governance  complexity  with  the 
emergence of new coordination nodes. The mitigation of this risk may potentially stem 
from  the  clear  division  of  competences,  reporting  practices  and  peer-review  informal 
processes (i.e. in the Military Transport Group)  

6.3  Environmental impacts 

Measures  foreseen  under  the  package  will  have  both  direct  and  indirect  environmental 
implications.79  At  immediate  level,  facilitating  more  frequent  and  large-scale  military 
transport  may  result  in  a  marginal  increase  in  emissions  associated  with  transport 
activities,  particularly  in  the  road  and  rail  domains.  Although  military  transport 
represents a relatively small share of overall transport flows in the EU, the movement of 
heavy,  outsized  cargo  and  the  use  of  older  platforms  are  likely  to  generate  higher  per-
movement emissions. The long-term environmental impact will therefore depend on 
the scale of utilisation of the framework, which will mainly depend on the evolution of 
the EU’s security environment. 

79 Joint  Communication  to  the  European  Parliament  and  the  Council:  a  new  outlook  on  the  climate  and 
security nexus: addressing the impact of climate change and environmental degradation on peace, security 
and defence, dated 28.6.2023. 

74 

 
 
 
localised  environmental 
Infrastructure  adaptation  measures  may  also  have 
consequences. Works could generate temporary increases in noise, emissions, and land-
use pressure, depending on the scale of projects. Indirectly, the Regulation may contribute 
to improved resilience of transport and energy supply chain infrastructure, with positive 
spillover  effects  for  the  environment.  Enhanced  resilience  measures,  including  those 
related  to  strategic  dual-use  infrastructure,  are  expected  to  reduce  the  vulnerability  of 
critical infrastructure to  disruptions, thereby potentially limiting inefficient fuel use and 
unnecessary emissions.  

From  an  environmental  perspective,  the  Regulation’s  reliance  on  existing  TEN-T 
alignments  minimises  new  land  take,  consistently  with  the  “do  not  significant  harm” 
principle  laid  out  in  Regulation  (EU)  2020/85280.  Positive  impacts  may  range  from 
reduced overall vehicle mileage for heavy transports to updated design standards. 
Negative externalities, however, may include potential localised increases in noise levels, 
or natural habitat disruption during construction periods. At EU level, there is no recent 
comprehensive  estimate  of  adaptation  costs  available.  Extrapolating  from  national 
assessment studies, the World Bank (2024) estimates a range of EUR 15 billion to EUR 
64 billion for the annual aggregate (climate) adaptation costs for the EU27 countries until 
2030.81  

The impact assesment on the completion of the TEN-T network assessed that 26 million 
tons of carbon dioxide emissions will be saved between 2017 and 2030 in the transport 
sector. This is expected to be complemented by noticeable additional savings of carbon 
dioxide emission which will be enabled by further roll out of alternative fuel infrastructure 
(electricity,  natural  gas,  hydrogen)  and  their  use  by  cleaner  vehicles.  Given  the  94  % 
overlap between the EU military mobility network and the TEN-T network82, it can only 
be  assumed  that  infrastructure  improvements  on  the  TEN-T  network  would  also  create 
similar returns.83  

Smoother and shorter transport procedures can be expected to reduce congestion and idle 
times at border crossings, leading to (marginal) reductions in fuel consumption and air 
pollution. Harmonised route planning may prevent unnecessary detours (although subject 
to  the  needs  of  military  planning),  contributing  to  (marginally)  better  environmental 
outcomes. 

Nevertheless, the possibility of increased overall traffic flows, especially during EMERS 
activation, could locally raise emissions and/or noise. This is  offset by the Regulation’s 
integration of sustainability considerations (i.e. focus on Sustainable Aviation Fuel) and 
its  encouragement  of  exploring  multimodal  transport  options,  consistent  with  Better 
Regulation’s enphasis on creating synergies with the European Gren Deal.  

Another area of environmental impact concerns fuel supply: stakeholders highlighted the 
continuing dependence of armed forces on fossil fuels, which will persist even as civilian 
transport undergoes a gradual transition to low-carbon alternatives. In the medium term, 

80 Regulation (EU) 2020/852 
81 Johannes Pfeiffer and Karen Pittel, ”To adapt or not to adapt: Costs, Benefits, and Financing of Adaptation 
in the EU”, Ifo Institute, Policy Debate of the Hour series, p. 8. 
82 ECA Special Report 04/2025, p 10. 
83  European  Parliament  Research  Service,  European  Added  Value  in  Action  briefing  “Towards  a 
comprehensive and beneficial approach to military mobility”, September 2025, p. 3. 

75 

 
 
 
this divergence could slow the uptake of renewable fuels in certain corridors if military 
requirements necessitate the maintenance of conventional fuel infrastructure. However, the 
Regulation  also  creates  opportunities  for  incentivising  dual-mode  or  dual-fuel  assets, 
which  could  mitigate  the  impact  over  time  if  adequately  supported  by  EU  funding 
instruments.  While  the  Regulation  might  generate  some  localised  and  short-term 
negative  environmental  effects,  particularly 
transport 
activity/infrastructure  upgrades,  it  also  has  the  potential  to  deliver  indirect  efficiency 
gains and synergies with EU sustainable transport objectives.  

to  additional 

linked 

Capability  pooling  and  emphasis  on  dual-use  of  the  measures  set  out  in  the  Military 
Mobility Package will, foreseeably, reduce resource duplication, with potential impact 
on  the  reduction  of  emissions  stemming  from  this.  The  drone  and  counter-UAS 
frameworks  introduced  may  have  the  long-term  effect  of  promoting  safer  and  more 
efficient low-altitude logistics, with potential civilian applications in disaster relief and 
environmental monitoring. Negative impacts could include increased energy use during 
high-readiness  operations  (or  during  EMERS  activation)  and  challenges  in  the 
environmental management of retired or requisitioned assets.  

76 

 
 
 
 
ANNEX: STAKEHOLDER CONSULTATION (SYNOPSIS 
REPORT)  

CONSULTATION STRATEGY  

A  targeted  stakeholder  consultation  for  the  Military  Mobility  package  aimed  to  collect 
qualitative  and  quantitative  data  and  feedback  on  key  issues  that  ought  to  be 
addressed  in  the  Military  Mobility  Package  2025.  The  targeted  consultation  was 
launched on 12 June 2025 by a Joint Press Release by the European Commission and the 
EU’s High Representative. It addressed Member States and all relevant actors including 
NATO, relevant PESCO projects, military mobility areas, industry, transport infrastructure 
and  assets  managers,  customs  and  energy  sector  stakeholders  and  the  financial  sector 
among others.  

This  targeted  stakeholder  consultation  encompassed  a  dedicated  online  survey  and 
possibility  to  submit  position  papers  and  written  contributions  from  12  June  until 
31 July 2025. The EEAS and the European Commission were also conducting a dedicated 
consultation of Member States until 30 September 2025. 

Finally, EDA has gathered expertise through its military mobility network and working 
groups and informed these about the consultation. 

Given the specificities of the field of military mobility, requiring technical expertise and 
handling of non-public information, the targeted consultation strategy was selected instead 
of a public consultation. A call for evidence was open for public feedback on the Have 
your say portal for 24 October 2025. 

In  total,  the  Commission  received  108  contributions  to  the  survey,  of  which  39  from 
Member States and 2 from Norway, 36 from companies, 12 from industry associations, 4 
from other organisations. Other contributions included 12 from port authorities, 1 from rail 
authority  and  1  representing  workers  and  a  contribution  from  NATO.  With  regards  to 
sectors represented, where possible to provide a specific allocation, 6 originated from air 
sector, 3 representing customs authorities, 1 from energy sector, 21 from rail sector, 2 from 
road  sector  and  18  from  sea  domain.  76  position  papers  were  also  received  in  the 
consultation,  7  from  Member  States  and  69  from  industry,  think  tanks,  and  other 
organisations. Input was also received from NATO. 

The bilateral meetings with the Member States who responded positively to the invitation 
provided  an  opportunity  to  further  discuss  and  deepen  the  understanding  of  the  written 
contributions  provided  and  present  the  aggregate  results  of  the  stakeholder  survey  to 
Member  States.  In  addition  to  the  structured  consultation  process,  Commission  met 
bilaterally  with  those  Member  States  who  wished  to  avail  of  the  opportunity  to  further 
discuss each of the thematic areas.  

For the purposes of this document, given the minimal differences in perspectives between 
Industry  Associations  and  Companies,  we  have  grouped  them  into  a  single  category 
labelled ‘Industry.’ Consequently, the analysis will focus on comparing findings between 
Member States and the Industry sector, unless there are differences.   

77 

 
 
Figure 8: Number of contributions received by stakeholder group 

The questionnaire was built around the following areas of interest: regulatory bottlenecks, 
transport capabilities, resilience of infrastructure and access to energy. Participants were 
asked specific questions allowing for quantitative assessment of responses and open 
text  boxes  providing  them  with  a  possibility  to  justify  their  answer  or  provide  more 
information. A summary of the latter is presented together with further inputs from written 
contributions.  

To present the results in an aggregated manner, but underlining differences between the 
different respondent groups, sections presented below refer to views of respondents from 
Member States and industrial stakeholders. Responses of other stakeholders from the less 
numerous  groups  are  provided  in  general  sections  providing  general  views  of  all 
respondents to avoid the possibility of identification of a specific entity.  

1.  Identified obstacles in military mobility  

In discussions on the main obstacles and causes of delays in military mobility that would 
have  to  be  addressed  as  a  matter  of  priority,  there  has  been  a  broad  consensus  among 
stakeholders. The highest-ranking “invoked” causes were the infrastructure problems or 
bottlenecks,  with  70.83%  for  Industry  and  64.1%  for  Member  States,  and  current 
paperwork,  consisting  of  cross-border  movement  permissions  and  formalities,  with 
76.92% for Member States and 58.33% for Industry.  

Many  noted  that  the  insufficient  capabilities  and  transport  assets  (Member  States 
66.67%,  Industry  45.83%),  and  interoperability  issues  between  civil  and  military 
systems (Member States 48.72%, Industry 45.83%), also cause delays.  

When  asked  about  the  areas  that  cause  the  biggest  delays  among  these  Member  States 
consider  diplomatic  clearances  and  time  to  obtain  permissions  for  the  transport  of 
dangerous goods. Industry similarly highlighted the time to obtain permission for the 
transport  of  dangerous  goods  and  permission  for  oversized  or  overweight  cargo. 
Generally,  the  transport  of  dangerous  goods  was  found  as  cause  of  biggest  delays  to 

78 

 
 
 
obtaining  specific  clearances  for  both  –  annual  movement  permissions  and  ad  hoc 
movement permissions. 

Member States noted that the submission of incomplete or wrongly completed forms, along 
with the differing rules and restrictions for the transport of oversized and overweight cargo 
for  various  modes  of  transport  causes  further  delays.  Respondents  mentioned  that  the 
present  fragmentation  causes  preventable  delays.  As  solutions  to  the  above  identified 
issues, respondents noted the need for a robust legal framework, harmonising requirements 
(i.e.,  pertaining  to  required  diplomatic  clearances,  rules  governing  cross-border 
movements,  information  sharing)  on  EU  level  as  much  as  possible.  In  line  with  this, 
suggestions were made for EU-NATO interoperability efforts to be enhanced, aligning the 
procedures,  to  ensure efficient  cooperation between EU and non-EU NATO allies (i.e., 
rapid  movement  of  military  personnel  arriving  in  EU  from  non-EU  allied  countries). 
Further digitalisation and electronic information sharing would have the potential to further 
reduce the delays caused by manual handling of the documentation. Some Member States 
would welcome the establishment of a Host Nation Movement Coordination centre at the 
MoD, as well as further investment into the infrastructure (including dual-use projects) and 
creating connections from hotspots, military bases, or storage areas to the nearest transport 
network node.   

In their submissions, industry stakeholders have raised that in some cases the last-minute 
changes to routes, escorting of military transports, lack of digitalisation and automation in 
military transport, and lack of interoperability cause delays. When discussing solutions, 
industry  stakeholders  focused  on  the  necessity  of  further  investment  (through  Member 
States  and  available  EU  instruments  such  as  CEF,  SAFE,  the  next  MFF  cycle)  and 
upgrading infrastructural facilities which have not been constructed with military use in 
mind  to  dual  use  standard,  granting  priority  to  military  transport,  strengthening  the 
resilience of the supply chain and infrastructure security, introducing uniform signalling 
system  for  rail  transport,  and  further  digitalisation.  The  latter  mostly  pertains  to  cross-
border permissions and customs formalities and reducing the differences in interpretation 
of  the  different  rules  and  procedures  among  Member  States  customs  authorities.  Other 
areas were signalled as having a potential to limit delays: real-time route planning, tracking 
and communication (e.g. the creation of a digital twin for the corridors and routes has been 
suggested  for  rapid  comparison  of  route  options,  impact  assessment,  infrastructural 
disruption or for identifying  an alternative route in  cases of external  disruption). It  was 
noted that issuance of permits for oversized military transportation should be prioritised.  

With regards to information sharing, respondents found it fundamental to ensure a secure 
communication  channel  and  governance  structures  to  ensure  coordination  between 
Member  States,  military  authorities  and  relevant  stakeholders.  It  was  also  raised  that 
exception  for  holiday  and  weekend  traffic  as  well  as  for  working  hours  for  military 
transport would increase the speed of movements, as well as a greater number of trained 
personnel to operate the infrastructure.  

2.  Regulatory bottlenecks  

2.1.Common definition of Transport Emergency 

In  discussions  regarding  the  usefulness  of  developing  a  definition  of  a  ‘transport  
emergency’,  the  majority  of  both  Member  States  and  Industry  agreed  that  a  common 
definition would be useful (Q5: Member States 61.1% and Industry 50%) or useful under 

79 

 
 
certain conditions (Q5: Member States 33.33% and Industry 39.58%) and that it should be 
accompanied by a set of specific rules facilitating military movement applicable in such a 
case (Q6: Member States 87.81% and Industry 87.5%). Providing such definition at EU 
level was seen as important.  

Overall, Member States were welcoming a common definition of a transport emergency, 
as it would help reduce bureaucracy and legislative overlaps. It would ensure that a state 
of emergency in one Member State is equivalent to that in other Member States and would 
avoid  differing  interpretations  (n.b.,  if  the  concepts  are  interpreted  identically  with  a 
unified emergency standard, then a unified response can also be adopted). Some Member 
States only welcomed this for times of security crisis or in escalation of events, noting that 
the exact wording is crucial in order to avoid an overly broad definition. Others noted that 
there might be a movement of larger formations already in peacetime, therefore transport 
emergency shall be developed as a tool to facilitate such movement, rather than become a 
new  emergency  state.  Certain  level  of  flexibility  for  unforeseen  circumstances  shall  be 
maintained, however too broad of a definition might become redundant; national context 
should be considered. Some Member States further noted that specific rules applicable in 
transport  emergency  would  be  useful,  as  they  would  help  accelerate  military  mobility. 
Such  a  set  of  common  rules  could  provide  legal  certainty,  reduce  bureaucratic  burden, 
legislative  overlaps  and  contribute  to  faster  reaction  times.  Ideally,  it  would  promote 
further  harmonisation  among  the  Member  States,  as  they  would  have  a  common 
framework based on which emergency measures  would be taken. Some Member States 
were in favour of these rules being applicable also in peacetime, to facilitate the large-scale 
military movements (e.g., during environmental disasters). However, it was also noted that 
some Member States already have rules which can be used in case of an emergency, while 
others  underlined  that  a  country  should  be  aware  of  the  goods  entering,  transiting,  and 
exiting its territory at any time.  

Industry stakeholders likewise welcomed the common definition, for reasons that it would 
facilitate  decision-making,  reduce  administrative  burdens,  improve  the  overall 
coordination,  and  offer  more  legal  certainty  to  operators,  highlighting  the  need  of  a 
precise  wording  to  avoid  misconceptions.  A  common  set  of  rules  would  make  certain 
operational  situations  easier  to  comply  with  and  ensure  that  the  response  is  more 
effectively  coordinated,  however,  the  infrastructure  limitations  must  be  taken  into 
consideration. It would ensure efficient and timely movement of large quantities of troops 
and equipment across borders (n.b., through pre-established military corridors). The added 
value  would  allow  for  a  seamless  coordination  with  other  organisations  including  with 
NATO,  more  efficient  use  of  civilian  and  dual-use  infrastructure,  as  well  as  allow  for 
enhanced readiness and training (e.g., the pre-defined rules can be incorporated into the 
training exercises, simulations and readiness assessments).  

2.2.Transport of dangerous goods, and oversized and overweight cargo 

While  cross-border  permissions  and  rules  for  the  transport  of  dangerous  goods  and 
oversized  and  overweight  cargo  are  needed,  their  number  at  different  levels  should  be 
limited to reduce redundancy to avoid causing unnecessary delays to military transport. 
The  relaxation  of  the  rules  for  the  transport  of  dangerous  goods,  oversized  and 
overweight cargo by the armed forces was welcomed by the majority of both Member 
States and Industry, (with 64.1% of Member States and 47.92% of Industry and 58.92% 
of  Member  States  and  43,75%  of  Industry  respectively  in  favour).  However,  such  a 

80 

 
 
relaxation should be done in  cases pertaining to crisis or wartime on the premises of 
speedy transport, rather than become a standard.  

Member  States  highlighted  that  the  relaxation  of  rules  should  come  under  specific 
conditions (e.g., having a declared state of emergency or a crisis), and should ideally align 
across the entire conflict spectrum, considering that the boundaries between peacetime, 
crisis and war time are not always clear. Others noted that a distinction should be made 
between dangerous goods and then ammunition and weapons – the latter two should be 
subject to notification. Some noted that armed forces should be able to transport the cargo 
in all situations, as having two or more sets of rules could negatively impact readiness, as 
forces would have to wait until the decision on the status of the situation would be made 
before being able to move. However, it was also raised that a minimum standard must be 
established and respected, considering the physical constraints of road infrastructure (e.g., 
bridges, tunnels, roads), as while the relaxation certain rules in times of crisis may be useful 
to enhance flexibility and responsiveness, it should never come at the expense of safety 
(i.e., consideration should be given to European Agreement concerning the International 
Carriage of Dangerous Goods by Inland Waterways (ADN) and Agreement concerning the 
International Carriage of Dangerous Goods by Road (ADR)). This was also raised by those 
Member States that were against such a relaxation, citing protection of population and fear 
of losing control over the goods entering the country.  

Likewise, industry stakeholders in general welcomed the relaxation of the rules in crisis or 
wartime to offer more operational flexibility, to act quickly and appropriately. It was 
highlighted  that  the  rules  should  be  defined  in  advance,  guarantee  the  necessary  safety 
level, be harmonised on EU level, pre-tested and not leave space for interpretation or cause 
ambiguity,  as  that  could  delay  or  reduce  the  security  of  a  cross-border  transport.  Clear 
distinction  according  to  context  should  be  maintained  –  during  peacetime  stricter  rules 
should  remain  applicable.  However,  there  may  be  structural  restraints  (e.g.,  bearing 
capacities  of  the  bridges  and  quays)  that  should  be  respected  in  all  circumstances. 
Additionally,  there  should  be  compensation  for  the  wear  and  tear  of  the  infrastructure 
caused  by  overweight  and  oversized  cargo.  Those  that  were  against  have  raised  the 
necessity  to  respect  and  maintain  the  rules  intended  to  guarantee  safety,  environmental 
compliance, infrastructural integrity to mitigate possible risks. Instead of relaxing the rules, 
they have suggested to focus on the process.  

2.3.Private carriers 

Presently, there is a broad reliance on private carriers for military transport, due to 
the limited capacities within the armed forces, which underlines the need for a streamlined 
treatment  to  achieve  operational  continuity.  The  majority  of  Member  States  who  had 
experience with military transports have stated that  that transport by private carriers 
for the armed forces are treated less favourably than ordinary military transports 
(51.28%),  while  the  majority  of  Industry  stated  that  they  don’t  have  practical 
experience with military transports (45.83%), (and only about 20% of both categories 
of respondents reported that transport by private carriers for the armed forces are treated 
the same as ordinary military transports).  

However, in some Members States more controls need to validate the transport done by 
private carriers, and that the movement of cargo by civilian means is treated as civilian 
movement. It was noted that there is a deviation between NATO, EU and national rules on 

81 

 
 
how the status of a civilian “contractor” is seen (it was suggested that if the contractor is 
delivering goods for armed forces, he should be treated as an operator of the armed forces). 
On the other hand, it was also raised by a Member State that civilian freight should not be 
treated the same as a military freight, upholding the obligation to comply with the stricter 
rules.  

Some  industry  stakeholders  raised  that  military  transport  should  not  be  carried  out  by 
private  companies,  but  rather  public  authorities,  due  to  the  very  nature  of  the  goods 
transported. This was mirrored in the claim that solely state-owned railway companies are 
suitable for such a task. However, more broadly it was noted that structured partnerships 
between Member States and private carriers should be established and operated on a “trust-
and-check” basis mechanism, which would allow for a rapid activation of private carriers 
without jeopardising security of the transport.  

2.4.Codification of Technical Arrangements and Priority Access 

Member  States  recalled  the  EDA’s  Cat  A  programme  on  “Optimising  cross-border 
movement  permission  procedures  in  Europe”  (CBMP)  and  highlighted  the  need  for  its 
implementation.  According 
to  Member  States,  codification  of  the  Technical 
Arrangements into EU law would be a way to speed up implementation. The most 
common expected result of the codification of Technical Arrangements into EU law would 
be the full harmonisation of the procedures to obtain diplomatic clearances for cross-
border movement permissions, as put forward by 61.54% of the Member States. More 
than  half  (52.0%)  of  Industry  responses,  however,  stated  that  they  don’t  have  practical 
experience with military transport, and only 27.08% agreed with Member States.  

Member  States  highlighted  that  mandatory  rules  and  procedures  could  facilitate 
standardisation and simplification, which would in turn accelerate the transport of troops 
and military equipment. Nevertheless, to ensure efficiency and interoperability, uniform 
technical standards are needed across all corridors designed for military mobility. A secure 
digital platform could / should be envisaged along with the harmonisation of rules to ensure 
that these are treated digitally in the future.  

Industry stakeholders noted that a full harmonisation would be attainable, some additional 
operational rules may be necessary at national level. Harmonisation would lead to reducing 
bureaucratic burden, resulting in standardised and uniform procedure to facilitate cross-
border movement.   

With regards to priority access rules similar to those contained in the Rail Capacity 
Regulation for other transport modes, networks, and assets were welcome by 58.97% 
of the Member States and 39.58% of Industry, with 30.77% and 50% of the Member States 
and Industry respectively expressing their lack of knowledge on the issue. Member States 
agreed  that  it  would  be  useful  to  apply  similar  rules  to  all  transport  modes,  however  it 
should be in balance with the civilian needs and transport flow. In principle, it was stated 
that  in  times  of  crisis  or  wartime  it  could  be  supported  as  means  to  enhance  military 
mobility,  as  multimodal  priority  is  crucial  to  ensure  rapid  response  and  uninterrupted 
logistical chains.  

Industry stakeholders likewise agreed with the need of priority access in times of crisis, as 
harmonised  priority  access  across  all  modes  ensures  a  synchronised  and  coherent 

82 

 
 
movement  of  forces  and  equipment.  Having  priority  for  one  mode  of  transport  would 
simply shift the bottlenecks to other modes. Having a clear legal framework overriding 
civilian traffic would enhance EU rapid deployment and ensure that the civilian-operated 
transport  assets  can  be  swiftly  repurposed  for  military  needs,  while  remaining  in  close 
alignment with NATO. 

2.5.Digitalisation and creation of a digital tool 

The added value of development and deployment of a digital tool was recognised by 
69% of Member States and 47% of industry stakeholders. The question of the entity taking 
responsibility for management of the tool was voiced as central and needed to ensure 
necessary coordination among the Member States to effectively use the tool  

Generally,  Member  States  were  welcoming  to  digitalisation  of  cross  border  movement 
permissions.  The  main  benefits  raised  by  Member  States  are:  limiting  administrative 
burden, achieving efficiency and clarity in the process, allowing real-time data exchange 
are all important to minimise the delays caused by incomplete or incorrectly filled in forms 
and manual handling of the documentation. It was flagged that harmonisation of the rules 
is  a  pre-requisite,  as  the  digital  tool  cannot  be  launched  without  pre-agreed  uniform 
requirements, but that digitalisation should not be delayed. Handling sensitive information, 
cybersecurity  resilience  and  ensuring  compatibility  with  existing  systems,  including 
especially those of NATO, were mentioned as key features of the digital tool  

2.6.Cooperation  with  NATO  and  other  bilateral  and  multilateral 

agreements 

Member  States  called  for  a  stronger  cooperation  with  NATO  to  avoid duplication  of 
efforts. Some Member States voiced the need for military mobility training and simulation 
exercises. The majority of Member States and Industry stated that they see the added value 
of having a common data set for the single electronic form 302 compatible between 
EU 302 and NATO 302. Member States would also welcome the harmonisation between 
the two 302 forms in a single electronic form. Industry stakeholders were welcoming 
towards the unification of the forms, as it would strengthen the operational readiness and 
interoperability. Likewise, use of a digital harmonised form would be welcome, however, 
concerns pertaining to cybersecurity and data management were raised.  

61.54%  of  Member  States  reported  participating  in  bilateral  and/or  multilateral 
agreements in  place that  simplify such procedures, while the vast  majority of  Industry 
reported that the inquiry was not relevant. The most common frameworks for participations 
were: Permanent Structured Cooperation (PESCO), EDA Military Requirements related to 
Customs,  “Secure  Digital  Military  Mobility  System”  (SDMMS),  and  CBMP, 
NORDERFO and NATO’s Joint Support Enabling Command (JSEC). 

2.7.Member States’ Coordination and role of the EU 

On  coordination  between  the  relevant  ministers  in  the  area  of  military  mobility, 
majority  of  Member  States  for  whom  the  question  was  of  relevance  claimed  that  the 
coordination  is  adequate  (33.33%),  or  good  to  excellent  (48.72%).  The  majority  of 
Industry,  however, stated that the question was  not  relevant,  with  some  referencing  the 
current state of coordination as poor to very poor (39.58%). The most common means of 

83 

 
 
coordination for Member States was an ad hoc coordination on a case-by-case basis with 
76.92%,  closely  followed  by  coordination  through  a  designated  liaison  or  point  of 
contact with 58.97%. The coordination at national level was deemed to be sufficient and 
effective by Member States, but slightly insufficient  by Industry, with a perception gap 
that was not overly wide for the latter.  

Member States noted that the need for coordination across the ministers has significantly 
grown,  expressing  a  need  for  or  establishment  of  an  inter-ministerial  group,  due  to  the 
necessity  of  a  whole-of-government  approach  in  planning  process  on  strategic  and 
operational level.  

Many  industry  stakeholders  emphasised  the  need  to  involve  civilian  parties  and  the 
necessity to have a designated liaison or point of contact on national level, responsible for 
coordinating the logistical process. They have further noted, that despite the EU efforts to 
harmonise the process, the national procedures still differ, highlighting the lack of real-
time  coordination  tools,  lack  of  digital  platforms  that  would  allow  real-time  tracking, 
clearance and coordination across ministries and transport operators.  It  was visible that 
while  some  industry  operators  are  in  close  contact  with  the  national  ministries  and 
cooperate  on  matters  pertaining  to  military  mobility,  in  other  cases  need  for  deeper 
cooperation was expressed. 

When addressing how the EU could support Member States in fulfilling their commitments 
under  the  Military  Mobility  Pledge,  Member  States  deemed  harmonisation  and 
simplification  of  existing  EU  law  and  procedures,  uniform  legal  framework,  financial 
support, clear information exchange and overview of existing initiatives as the main areas 
of support the EU could provide. The development of a digital tool, further investment into 
infrastructure  and  more  possibilities  of  joint  procurement  of  transport  capabilities 
complying with dual-use criteria was also deemed important. Industry stakeholders saw 
the greatest added value in the financial support, coordination, and funding that could be 
used  for  funding  dual-use  projects.  Uniformity  of  the  legal  framework,  regulatory 
harmonisation, streamlining and simplifying the procedures to support military mobility.  

2.8.Protection and resilience 

In discussions on the present level of protection and resilience in military mobility, of those 
who answered, 56.41% of Member States and 60.42% of Industry deemed the existing EU 
legislation  insufficient  in  providing  protection  and  resilience  in  military  mobility. 
There has been a broad agreement (64.1% for Member States and 75% for Industry) among 
stakeholders that there is a need to further enhance the protection in the different areas 
of military mobility in the EU.  

Member States noted that it is not only about protection, but about resilience, therefore 
continuous improvements in this area must be made. The procedures must be standardised 
and  digitalised,  improvements  must  be  made  in  the  protection  of  critical  infrastructure 
(e.g., further investment into the protection of sensitive areas), as presently critical entities 
are  often  insufficiently  protected.  Generally,  an  increase  in  capabilities  for  surveillance 
and security is needed. Protection should be enhanced throughout the entire supply chain, 
however, the  work done should be coordinated across sectors, to  avoid  duplication and 
redundancies. The importance of energy security has been raised.  

84 

 
 
Industry  stakeholders  also  emphasised  the  necessity  to  enhance  protection  on  transport 
infrastructure (mostly railway networks against espionage and sabotage, bridges, tunnels, 
ports,  airports  and  corridors),  critical  entities  (potential  targets  for  cyber-attacks  or 
sabotage),  and  of  data  and  digital  systems  (as  military  mobility  increasingly  relies  on 
digital  systems).  Further  monitoring,  drone  scanning,  and  integrated  security  protocols 
would be welcome. It was noted that the EU should also consider the availability of fall-
back scenarios to further enhance resilience and ensure preparedness.  

3.  Assets and capabilities  
3.1.Asset availability 

The  issue  availability  of  transport  assets  for  military  mobility  has  been  thoroughly 
discussed, with 66.67% of Member States considering it to be a problem, with a divide 
between those who found it to be a major problem (41.03% of the respondents) and those 
who found it to be a somewhat problem (25.64% of the respondents). Regarding Industry, 
the  majority  (45.83%)  thinks  it  is  a  somewhat  problem,  27.08%  finding  it  a  major 
problem, and 18.75% of them stating that the question is not relevant for them. It was noted 
that the military mobility policy should focus not only on the infrastructure, but also 
on the assets and equipment necessary for the efficient use of the infrastructure and 
for the provision of the transport services.  

Looking at specific transport assets needed for military mobility in the EU, the Member 
States and the Industry mentioned in the consultation some of those that are most needed. 
Examples  include  rail  wagon  flatbeds,  medical  rail  wagons,  ADR  trucks,  HET  trucks, 
specialised  vehicles  (e.g.,  vehicles  for  multimodal  transport,  heavy  armour  vehicles), 
strategic and tactical airlift dual-use ferries and tankers. Member States noted that for many 
of the mentioned capabilities, the EU is experiencing supply shortages, however for some 
of them increasing availability through production or contracting is easier than for other. 
Some such as ADR trucks are easier to replace than those where the production capacity 
in the EU is low such as rail wagon flatbeds. 

It  was  once  more  noted  that  for  each  of  the  mentioned  assets,  the  EU  is  experiencing 
shortages, production delays, or insufficient production. In connection with this, the labour 
shortages  experienced  across  sectors  were  raised,  often  contributing  to  delays  in 
production.  When  it  came  to  which  assets  could  be  produced  within  the  EU  and  made 
available for military mobility, the most listed assets were: rail wagons, heavy-duty loading 
ramps, availability of port facilities and inland vessels (i.e., vessels for inland waterways), 
road transport assets (e.g., heavy duty vehicles and ADR-certified vehicles), and transport 
ships.  

Furthermore, lack of pre-negotiated framework contracts, rapid activation protocols and 
common interoperability standards is deemed problematic by Member States and Industry. 
In this regard the importance of translating military scenarios into service-level agreements 
was raised.   

3.2.Procurement and production scale-up 

Industry stakeholders raised in the consultation that in case procurement is based solely on 
national requirements (without EU requirements), there is a high risk that procured assets 
will not be interoperable. In this regard, coordination across the EU and with NATO would 

85 

 
 
be beneficial, especially in terms of adequate and targeted financing into dual-use projects 
and technologies.  

In addressing manufacturing during a crisis or contingency situation, of those asked 
and  for  whom  the  question  was  of  relevance,  23.08%  of  Member  States  and  50%  of 
Industry responded that they could scale up operations or manufacturing during a crisis 
or a contingency situation. Member States and Industry noted, that for the scale up to be 
possible, there is a need for financial support to enhanced demand signal, an updated legal 
framework. Some raised the issue of personnel shortage. It was deemed necessary to have 
common clearly defined dual-use standards to ensure interoperability of the assets.  

In discussions on strengthening the preparedness of military mobility, the idea of sharing 
and pooling of strategic dual-use transport assets was presented. When gathering input, of 
those asked and for whom the question was of relevance, there has been a consensus of 
69.23% Member States and 62.5% Industry on sharing and pooling of strategic dual-use 
transport assets among Member States as beneficial to military mobility and preparedness. 
Of those, majority was welcoming under specific conditions and frameworks, to ensure 
legal clarity. 

Member States noted that a creation of such a pool would need to be strictly controlled, 
lawful, and carried out according to a pre-determined procedure (i.e., have a precise set of 
rules governing the creation and use of the pool), perhaps requiring a coordinated entity to 
prioritise the use of the limited assets. Such an instrument could make the availability of 
transport  assets  within  the  EU  more  transparent  (e.g.,  boost  interoperability  and  reduce 
duplication) and serve as a basis for bilateral or EU led arrangements.  However, it was 
also raised that this would require further coordination and therefore might hinder the rapid 
movement  of  equipment.  A  Member  State  also  flagged  the  necessity  to  keep  sufficient 
assets available for to meet internal needs,  while another raised that pooling could be a 
solution in peacetime for efficiency reasons, but not in a crisis where a great number of 
assets is required. Those Member States that had experience in the area, referenced the 
following: ATARES, SEOS, MCCE, MRTT, NORDEFCO, EATC.  

Industry stakeholders, while in favour of such a mechanism, pointed out the necessity of 
strict, clear allocation rules accompanied by a centralised management on the EU level, 
possibly in cooperation with NATO. A coordination system should be present for cross 
border deployment of the assets. It was recommended that a flexible model of pooling is 
developed to avoid that certain assets or capabilities are available only in specific countries 
and regions. Further sharing of transport capacities would be welcome, as it would be cost-
effective and enhance the readiness. A point of concern was the feasibility of such a project 
due to logistical and political constraints. As their experience in the area, they referenced 
the  rental  of  transport  capabilities,  leasing  solutions  already  in  place,  and  the  rescEU 
initiative under the umbrella of the EU Civil Protection Mechanism (UCPM). However, it 
was also noted that seizing various assets from civilian use can have consequences for the 
functioning  of  the  businesses  and  industries  which  would  negatively  impact  the 
competitiveness of the EU – this outcome shall be prevented.  

3.3.Labour  

Regarding the matter of reskilling of labour, the majority of Member States stated that 
the  question  wasn’t  relevant  (48.72%),  and  38.46%  that  they  saw  areas  where  it  could 

86 

 
 
benefit military mobility, but it would need to be improved. This last response reflected 
the majority opinion among Industry (41.67%).  

Member States highlighted that retraining civilian personnel in military mobility enhances 
preparedness, speeds up movements and enhances EU-NATO interoperability in times of 
crisis.  Focus  has  been  mostly  on  customs  officers,  road  and  rail  authorities,  military 
personnel, and staff of ministries of transport and defence. It has been further raised, that 
majority of truck drivers operating in a Member State are not nationals of that Member 
State, being citizens of other Member States or a third state, which could be problematic 
in times of a crisis (i.e., due to availability of the workers, labour law protection of the 
workers).  

Industry  stakeholders  on  the  other  hand  noted  that  nowadays  it  is  necessary  to  design 
equipment and infrastructure for dual use purposes, therefore familiarity with the military 
standards would be useful (e.g., knowledge of EU and NATO protocols for handling of 
sensitive  or  hazardous  materials),  and  reskilling  of  labour  would  be  beneficial. 
Additionally, during commercial transport of military equipment across countries, it would 
be  useful  to  have  a  national  liaison  officer  overseeing  the  logistics  process.  In  case  of 
further digitalisation of the process, it would be necessary to improve digital competences 
among personnel as well as provide further training pertaining to military mobility (mostly 
on  safety  and  applicable  rules  and  protocols).  An  underlying  issue  of  labour  shortage 
among several sectors (rail and road transport, cybersecurity) was noted. 

4.  Infrastructure  

4.1.Fuel infrastructure and availability of civilian oil stocks  

When asked whether there are challenges in access to fuel supply when armed forces 
are  moving in  the  EU, 61.54%  of  Member  States  responded  positively.  Meanwhile, 
among  Industry,  the  proportions  were  nearly  identical  between  those  who  deemed  it 
problematic,  those  who  did  not,  and  those  who  did  not  respond,  with  a  slight  majority 
leaning toward the first. 

Member States noted that while all countries are dependent on petrol deliveries for both, 
civilian and military purposes, the availability in EU eastern flank might be worse than 
elsewhere, highlighting the necessity to expand the NATO fuel pipeline east and create 
linkage with critical transport infrastructure. It was noted that the availability of fuel differs 
in peacetime and times of crises, as well as on the proximity to the frontline. There should 
be  a  reliable  supply  chain  and  sufficient  storage  capacities  along  strategic  transport 
corridors, which are essential for ensuring uninterrupted mobility during crises. The notion 
of green transition has been raised in connection with the decrease in fuel refineries.  

Industry side raised that while there are sufficient diesel fuelling facilities this is not the 
case for renewable fuels. There should be an overall increase in the numbers and capacities 
of the supply points, highlighting that some ports have insufficient fuel storage for a naval 
fleet. It has been raised once more that there is worse fuel availability in the eastern flank, 
as majority of the refining capacity is concentrated in western Europe. Additionally, there 
are  rising  concerns  surrounding  the  shrinking  refining  capacity  driven  by  the  lack  of 
competitiveness  in  the  global  market  and  the  anticipated  decline  from  the  commercial 
sector due to energy transition. It has been highlighter that while fossil fuels are slowly 
being  phased  out,  they  will  remain  important  for  military  operations,  therefore  it  is 

87 

 
 
essential to manage the transition without restraining the EU and NATO military readiness. 
In light of the transition, it was noted that the EU and Member States should focus on dual-
mode assets (i.e., diesel-electric or battery-electric assets), and ensure that military forces 
are provided with fuels required for the operationalisation of their equipment, which may 
not necessarily follow the de-carbonisation path.  

Generally, there has been a broad consensus that the armed forces should be allowed to 
use (civilian) emergency oil stocks in the case of an emergency or war, with more Member 
States  responding  affirmatively  than  Industry  (76.92%  compared  to  56.25%).  Member 
States highlighted that it is fundamental for the military to be able to function and carry 
out their tasks in times of crisis or wartime to ensure operational readiness. However, this 
must be well-coordinated and prioritised alongside the needs of the civilian population and 
sufficient compensation should be provided to the company or entity storing the oil stocks. 
In some cases, such a use shall be subjected to governmental approval and be governed by 
national legislation. Those against, raised the risk of disrupting national production and the 
economy,  which  could  lead  to  harm  the  civilian  population,  and  instead  suggested  the 
establishment of separate military stocks.  

Industry  sector  likewise  agreed  that  in  times  of  crisis,  war  or  emergency  armed  forces 
should  have  access  to  critical  resources,  as  it  is  essential  for  the  defence  and  survival, 
therefore civilian discomfort must be weighed against the greater risks. It was highlighted 
that due to the confidentiality, the information of usage of fuel in times of crisis is rarely 
shared with other states or civilian sector. In line with this, it is often unclear under which 
conditions the stocks may be requisitioned or require the state of emergency. It was also 
raised that this should be arranged with the owners of such stocks, as they might require 
compensation. In this aspect several bottlenecks were raised, as in some cases even with 
civilian stocks, the oil reserves may not be sufficient, or the reserves may be located on a 
territory of another country. 

88 

 
 
 
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