With the publication of EASA Opinion No. 02/2025 on the regular updating of rules for air traffic management and air navigation services, EASA has provided further significant impetus for the further development of the European ATM/ANS regulatory framework and thus for the EU legal framework. Even though it is not yet formally applicable EU law, this Opinion is of considerable practical relevance for airports, ATS and AIS providers, and national aviation authorities in Germany and the DACH region. The opinion forms the technical basis for upcoming amendments to several key EU regulations and thus influences operational procedures, processes, responsibilities, and interfaces between air traffic system operators in the medium to long term.
Why this opinion piece is more than a routine update
Dealing with Opinion 02/2025 quickly proves to be challenging. The content is technically and organizationally demanding, closely linked to existing regulations, including those of the ICAO, and requires a deep understanding of both the regulatory architecture and the actual operational processes at the airport. However, it is precisely this complexity that makes it clear that this is not a purely formal update of existing rules. Rather, the Opinion aims to sharpen and clarify the content of key requirements. Organizations that engage with the content early on and in depth will be able to realistically assess the implications and prepare the necessary measures in a structured manner, rather than having to react later under considerable time and implementation pressure.
Where EASA is tightening up and why this is relevant to operations In terms of content, Opinion 02/2025 is designed as a regular update of the ATM/ANS rules, with a clear focus on amendments to Regulation (EU) 2017/373. The areas of air traffic services and aeronautical information services are particularly affected, flanked by subsequent amendments to Aerodrome Regulation (EU) 139/2014 and SERA Regulation (EU) 923/2012. A central focus is on further clarifying the handling of aeronautical data and information. Requirements for the Aeronautical Data Catalogue and aeronautical charts are specified in more detail, while responsibilities for the collection, processing, and exchange of aeronautical data, e.g., for the ADV-ADQ process for creating the AIP or for obstacle management or the application of reference systems, are partially reassigned. At the same time, the Opinion addresses operational aspects of airport operations, in particular intersection take-offs and multiple line-ups on the same runway, with a clear focus on coordinated and comprehensively documented coordination between airport operators and ATS providers.
Interfaces as a risk zone: Who should take a closer look now
The opinion directly affects ATS and AIS providers as well as aerodrome operators, but it also has an impact on national and regional aviation authorities. For many organizations, this means a critical reassessment of existing procedures, rules on responsibilities, and formal agreements. Particularly at the interfaces between aerodromes, AIS, and ATS, it is often apparent in practice that processes are established but not always clearly documented or consistently implemented. With the opinion, quality-assured data delivery, clearly defined responsibilities, and reliable evidence are becoming even more of a focus for regulators and are thus gaining additional regulatory significance.
Time is the decisive factor, not the date of application.
Even though the opinion itself does not yet have any immediate legal effect and the amended EU regulations are currently expected to come into force at the end of 2026, there is already a need for relevant action today. Experience from previous regulatory adjustments shows that the greatest pressure does not arise when the regulations formally come into force, but during the transition phase, when ongoing operations, project implementation, and regulatory compliance must be managed in parallel. From an aviation project management perspective, the opinion should therefore be seen as a clear trigger for complex implementation projects. Organizations that prepare early on ensure planning security, reduce operational risks, and position themselves much more confidently vis-à-vis regulatory authorities. AviaCert supports its customers in analyzing these developments in a structured manner and translating them into customer-specific, audit-proof solutions. Continuous monitoring, well-founded compliance and gap analyses, and support in adapting procedures and documentation ensure that regulatory requirements are not only formally met, but also sensibly integrated into everyday operations.
If you would like to take a structured approach to the regulatory challenges posed by EASA Opinion 02/2025 and set the operational course at an early stage, please feel free to contact our experienced experts:
André Wattler
+49 38854 628192 | a.wattler(@)aviacert.de
