Legal and regulatory factors
The Lufthansa Group is subject to a large number of national, European and international regulations. This regulatory environment influences costs as well as the Company’s international competitiveness. This is particularly the case where regulations only apply in certain countries or regions, which means that competing airlines are not operating on a level playing field.
Legislation at the European level – in particular, relating to climate change mitigation policy and consumer protection – is particularly significant in this regard. Geopolitical risks, tariff conflicts and airspace closures also represent challenges. The high government-induced costs of doing business in Germany have a particularly severe impact on the cost-effectiveness of flights within and departing from Germany. These include air traffic tax as well as aviation security fees and air traffic control charges.
EU climate change mitigation regulations entail competitive disadvantages
With its Fit for 55 programme, by 2030 the EU aims to cut its greenhouse gas emissions by at least 55% relative to their 1990 level. Three dossiers are key from the point of view of aviation: the regulation on sustainable aviation fuels (ReFuelEU Aviation), the reform of EU emissions trading (EU-ETS) and the proposal to introduce a kerosene tax (EU energy tax directive).
Since January 2025, a binding blending quota has applied for sustainable aviation fuels (SAF). Under the ReFuelEU Aviation Regulation, this quota is to gradually increase from the current 2% to 70% in 2050. A sub-quota for synthetic PtL aviation fuels is planned from 2030 and is set to rise from 1.2% to 35% in 2050. In the view of the Lufthansa Group, this quota will lead to strong cost increases for European airlines and considerable competitive disadvantages for intercontinental traffic. Since it only applies for flights departing from EU airports, non-European airlines with transfer airports close to Europe only have to meet the SAF quota on the flight segment from Europe to their hub. Moreover, the availability of SAF will remain limited in the medium term and prices are still not competitive. To date, PtL fuels are only available in laboratory quantities and up to ten times more expensive than conventional kerosene.
The total number of CO2 certificates will be gradually reduced in the EU ETS. The previously free allocations will be phased out starting in 2026. Costs will increase above all due to the discontinuation of free allocations. The regulations will make European airlines’ feeder traffic more expensive and entail the risk of an increasing displacement of long-haul connections to hubs outside Europe. To create an incentive to use SAF, a decision was made to provide a limited contingent of CO2 certificates on a temporary basis to compensate for the additional costs of SAF. However, this does not sufficiently offset the additional expenses nor establish a level playing field with airlines from outside the EU. Moreover, due to the nature of the system for the allocation of CO2 certificates, certain EU network carriers will benefit more strongly than others in terms of the relief they receive on their additional SAF costs. This is distorting competition within Europe.
The introduction of an EU minimum tax on kerosene is currently the subject of political debate. The EU Council recently extended the tax exemption for kerosene until 2035. Any introduction of an EU minimum tax on kerosene, which requires a unanimous resolution by the EU Council, would massively increase the existing global competitive disadvantage.
The Lufthansa Group believes that improvements to EU climate protection regulations are urgently required in order to maintain the competitiveness of the airlines based in the EU and to avoid the transfer of traffic and emissions that is known as the carbon leakage effect. The goal must be to introduce climate change mitigation measures which are effective but also competition-neutral. ↗ Combined non-financial declaration.
More stringent consumer protection policies may have adverse impact
A reform of the Air Passengers Rights Regulation ((EC) No 261/2004) is currently being negotiated at the European level. The European Parliament, the EU Council and the European Commission began trilogue negotiations in October 2025. More stringent regulations in a number of areas are on the agenda. These would mean higher costs for the Lufthansa Group and its customers. They include, in particular, higher compensation amounts, additional carry-on bags free of charge, numerous limitations on exemptions from the obligation to provide compensation and requirements for the compensation procedure. Moreover, increased carry-on luggage quantities would mean slower security checks and boarding processes and thus jeopardise operational stability and punctuality.
Costs of doing business in Germany adversely affect the country’s connectivity
The costs of doing business in Germany imposed by the German government on air traffic departing from Germany – air traffic tax as well as aviation security and air traffic control fees and charges – have more than doubled overall since 2019. The Lufthansa Group has thus been obliged to cancel routes within Germany for economic reasons. This development is having a considerable adverse impact on Germany’s connections to European and global air traffic.
In its November 2025 relief package, among other things, the German government cancelled its 2024 air traffic tax increase, with effect as of 1 July 2026, and reduced air traffic control charges. From the Lufthansa Group’s point of view, these decisions are an important first step in order to maintain the current level of service at German airports.