Airports in Spain: a new dispute over fees and investments ahead of the DORA III period
Airlines and their umbrella associations have stepped up pressure on Spain’s state airport operator Aena (AENA) and regulatory bodies over planned airport charges in the next regulatory cycle, known as DORA III. At the heart of the dispute is whether – and under what assumptions – it is possible to finance a major investment wave in infrastructure while maintaining or even lowering the price carriers pay per passenger for basic airport services. The debate is taking place at a sensitive moment: Spain is among Europe’s leading tourist destinations, and air connectivity is considered one of the key pillars of economic growth and regional cohesion.
What is DORA III and why it matters
DORA (Documento de Regulación Aeroportuaria) is a multi-year framework in Spain that defines the combination of investments, service quality targets and the methodology for setting airport charges for the network of airports managed by Aena. The third document, DORA III, covers the period 2027–2031 and, according to Aena, should cover a new phase of modernization and capacity expansion to adapt the system to expected traffic growth, security standards, sustainability and increased passenger requirements.
In practice, DORA III is not just a technical document. It directly affects airlines’ operating costs, route availability, aircraft basing decisions, and the investment cycle in terminals, runways, security systems, as well as digital and energy infrastructure. That is why any change in fee parameters or traffic assumptions becomes a political and economic issue, with consequences that spill over into tourism, the labor market and travel prices.
What airlines want: a 4.9% annual cut
The International Air Transport Association (IATA) and the Spanish Airline Association (ALA) have publicly called for an average annual reduction of airport charges of 4.9% in the 2027–2031 period. Their argument rests on the assessment that lower charges would increase the destination’s competitiveness, facilitate the opening of new routes and stimulate additional demand, which would in turn increase total traffic and system revenues.
Carriers say that lowering charges does not have to be incompatible with investments, but they insist that traffic and cost projections must be based on realistic assumptions and that it is necessary to clearly separate investments essential for safety and maintenance from those that, in their interpretation, are aimed at long-term capacity expansion without sufficiently solid evidence of demand growth at each airport. In the background is also the message that Spain competes with other Mediterranean markets for tourist traffic and that airport charges, although not the only factor in ticket price, can influence carriers’ operational decisions, especially in low-cost models.
Aena’s position: the investment cycle requires higher revenue per passenger
Aena, on the other hand, defends a plan that envisages a gradual increase in regulated charges during the DORA III period. In publicly available releases and media reports, it is stated that the average increase would amount to about 3.8% per year between 2027 and 2031, or approximately 0.43 euros more per passenger per year, depending on the methodology and the year of application. Aena justifies this approach by the need to ensure stable financing of investments, maintenance and operating costs in the airport network, emphasizing that the model must sustain safety, quality and sustainability standards.
A key point of the debate is the investments themselves. According to Aena, it is an investment package of “around 13 billion euros” for Spanish airports in the 2027–2031 period, while some media and analysts refer to an investment plan “of almost 10 billion euros” within the DORA III framework. Differences in amounts mostly arise from the way they are presented (baseline plan, additional components, phasing by year and inclusion of certain investment categories), so Aena emphasizes that it is a technically grounded plan focused on future demand.
The role of the regulator: CNMC between financial sustainability and market competition
The final say on key parameters of charges and revenue per passenger lies with Spain’s regulator, the National Commission on Markets and Competition (CNMC), which, within the applicable legislation, assesses the justification of traffic, cost and investment projections and their reflection in the maximum regulated revenue. In previous decisions, CNMC has stressed the need to balance revenue stability with the costs of providing services and promoting competitiveness. For example, in earlier cycles the regulator maintained or froze certain fee components when it assessed that forecasts were conservative or that there was not enough justification for an increase.
In the current, short-term context of the debate, it is also important that CNMC allowed an increase of the current charge of up to 6.5% from March 2026, which is on average about 0.68 euros, with an upper level of 11.02 euros per passenger. That decision has already become part of the argumentation in the dispute: airlines warn about the cumulative effect, while Aena claims it is a regulated mechanism that must follow investment and operating needs and macroeconomic conditions.
Why the dispute is intensifying: traffic, forecasts and the “risk” model
At the center of the disagreement is the question of traffic forecasts. Airlines claim that Aena underestimates future traffic growth, which in the model would lead to higher charges than necessary, because fixed costs and investments are spread over a smaller number of passengers. Aena, in turn, states that investments are based on technical demand assessments and that the operator in the Spanish regulatory model bears the so-called “traffic risk” – the risk of traffic deviation – which, according to Aena, acts as protection against overinvestment and encourages more realistic planning.
The conflict is also intensifying because DORA III coincides with a new investment cycle at the largest hubs, primarily Madrid-Barajas and Barcelona-El Prat, but also with upgrades and expansions at a number of regional airports. The public debate focuses on priorities: which investments are necessary immediately, which can be phased, and how to ensure that rising charges do not disproportionately affect smaller carriers or market-sensitive routes.
Market consequences: capacity, bases and the price of travel
The debate over charges is not abstract. Low-cost carriers have repeatedly warned that rising operating costs, including airport charges, can lead to capacity cuts in certain markets. As an example, it is stated that increases in charges are linked to decisions to reduce capacity in Spain during the winter flight schedule, including the closure of certain bases. Such decisions most directly affect regional airports that depend on seasonality and a smaller number of key carriers.
For passengers, an increase in airport charges does not automatically mean a price increase for every ticket, because prices depend on competition, fuel, demand and carriers’ business strategies. However, in periods of high demand and limited supply, additional costs are often partially passed on to the final price or offset by reducing frequency and capacity. Tourist regions have a particular interest: any change in the number of flights and seats affects revenues in accommodation, hospitality and local services, and indirectly seasonal employment.
Investments and sustainability: what is financed and how impact is measured
In investment plans for DORA III, Aena highlights several goals: increasing capacity where congestion is expected, modernizing terminals, improving security and operational systems, and projects linked to sustainability, including energy efficiency and emissions reduction. In the broader European context, this fits into pressure for air transport and infrastructure to decarbonize faster while preserving service and safety levels.
At the same time, airlines are calling for clearer criteria. Their position is that investments must have a measurable effect on capacity, quality and efficiency and that costs should be allocated transparently and predictably. Particularly sensitive are investments in commercial content or projects not directly related to the core airport service, because the question arises to what extent such projects may influence regulated charges.
Political framework and public debate: between parliament, the market and regions
Although DORA III is primarily a regulatory document, the debate is spilling over into the political arena. In Spain, the question has periodically been raised whether airport charges should be frozen or capped to protect the destination’s competitiveness and encourage connectivity, especially in island and peripheral regions. At the same time, Aena as an operator with a network of diverse airports warns that a unified financing system enables maintenance and investment even in less profitable airports, thereby preserving territorial accessibility and the public interest.
For local and regional authorities in tourist zones, the key question is whether the planned investment projects will improve the passenger experience and reduce operational bottlenecks without excessive cost increases for carriers. In that sense, DORA III becomes a test of how to align a centrally managed network with different needs: from major international hubs to seasonally burdened island airports.
What comes next: procedure, timelines and possible compromises
The DORA III adoption process includes consultations with system users, regulatory analyses and formal decisions that will determine the parameters of charges and investments for the 2027–2031 period. In the coming months, intensive alignment of traffic forecasts, costs and investment phasing is expected, because these variables determine how maximum revenue per passenger will be calculated and how much room there will be for increasing or reducing charges.
In practice, a compromise can be sought in several directions: more precise traffic modeling, staged introduction of certain investments, stronger efficiency criteria and differentiation of effects on large and small airports. However, as the DORA III period approaches, and at the same time already approved changes to current charges apply from March 2026, it is clear that the dispute over the “per passenger” price will remain one of the key issues of the Spanish aviation market in 2026 as well.
Sources:- Reuters – report on Aena’s proposal to increase charges and airlines’ reaction ahead of the 2027–2031 period (link)
- Aena (press release) – official framework of the investment proposal and explanation of the charges model for Spanish airports (link)
- Business Travel News Europe – information on CNMC’s regulatory decision and the impact on current charges from March 2026 (link)
- Cinco Días (El País) – details on the DORA III proposal, investment framework and projections of revenue per passenger (link)
- Majorca Daily Bulletin – ALA reactions and the context of the debate about more expensive flights to Spain (link)
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