(1)

Pursuant to Article 11 of Regulation (EC) No 549/2004, Member States are to draw up plans, either at national level or at the level of functional airspace blocks (‘FABs’), including performance targets, for each reference period of the performance and charging scheme for air navigation services and network functions. Those plans are to include local performance targets which are consistent with the Union-wide performance targets for the reference period concerned.

(2)

On 12 June 2024, the Commission adopted Union-wide performance targets for the fourth reference period (‘RP4’, 2025-2029). Those Union-wide performance targets were set out in Commission Implementing Decision (EU) 2024/1688 (4).

(3)

On 1 October 2024, Greece submitted to the Commission a draft performance plan for RP4. After the verification of completeness of that draft performance plan by the Commission, Greece submitted an updated draft performance plan (‘the draft performance plan’) on 15 November 2024.

(4)

The Commission found that the capacity targets set by Greece in the draft performance plan do not meet the assessment criteria set out in point 1.3 of Annex IV to Commission Implementing Regulation (EU) 2019/317 and that the cost-efficiency targets for Greece’s en route charging zone do not meet the assessment criteria laid down in point 1.4 of Annex IV to that Implementing Regulation. Accordingly, the Commission concluded that the capacity and cost-efficiency performance targets included in the draft performance plan are not consistent with the Union-wide performance targets for RP4 and, on 16 May 2025, notified Greece thereof through Commission Implementing Decision (EU) 2025/1040 (5). In that Decision, the Commission issued recommendations to Greece in view of ensuring the consistency of its performance targets with the Union-wide performance targets for RP4.

(5)

On 7 August 2025, Greece submitted a revised draft performance plan for RP4 for assessment by the Commission. Following the verification of completeness of that plan, Greece submitted an updated version of the revised draft performance plan (the ‘revised draft performance plan’) on 3 October 2025.

(6)

In accordance with Article 15(1) of Implementing Regulation (EU) 2019/317, the Commission has assessed the consistency of the local performance targets included in the revised draft performance plan on the basis of the assessment criteria laid down in point 1 of Annex IV to that Implementing Regulation, and taking account of local circumstances where relevant.

(7)

The Commission has complemented its assessment of the revised draft performance plan with a review of the elements set out in point 2 of Annex IV to that Implementing Regulation. However, the allocation of costs between en route and terminal services referred to in point 2.1(d)(vii) of Annex IV to Implementing Regulation (EU) 2019/317 is subject to a separate review by the Commission based on additional information received from Greece in December 2025. Therefore, the Commission has not drawn any conclusions, at this stage, in respect of the compliance of that cost allocation methodology with points (e) and (f) of Article 15(2) of Regulation (EC) No 550/2004 of the European Parliament and of the Council (6) and Article 22(5) of Implementing Regulation (EU) 2019/317.

(8)

The Performance Review Board (‘PRB’), assisting the Commission in the implementation of the performance and charging schemes pursuant to Article 13(2) of Regulation (EU) 2024/2803, has submitted to the Commission its opinion on the performance targets included in the revised draft performance plan of Greece with regard to the consistency of those targets with the Union-wide performance targets. The findings set out in this Decision have been informed by the detailed technical assessment set out in the PRB opinion (7).

(9)

As regards the key performance area of safety, the consistency of the targets included in the revised draft performance plan has been assessed in accordance with point 1.1 of Annex IV to Implementing Regulation (EU) 2019/317.

(10)

The performance targets in the key performance area of safety proposed by Greece in respect of the effectiveness of safety management, broken down per safety management objective and expressed as a level of implementation, are as follows:

(11)

The Commission observes that the safety performance targets proposed by Greece for the air navigation service provider ‘HASP’ are equal to the Union-wide safety targets for each calendar year from 2025 to 2029, except for the ‘safety risk management’ objective for which the level of the Union-wide target is planned to be reached in year 2029.

(12)

The Commission notes that the revised draft performance plan sets out measures for HASP for the achievement of the local safety targets, such as organisational restructuring, promoting safety culture, increasing the number of safety training courses, improving the competence assessment scheme for safety experts, rehearsing emergency procedures and reviewing risk criteria.

(13)

On the basis of the findings set out in recitals (10), (11) and (12), the local safety performance targets included in the revised draft performance should be considered consistent with the Union-wide performance targets.

(14)

As regards the key performance area of environment, the consistency of the targets included in the revised draft performance plan regarding the average horizontal en route flight efficiency of the actual trajectory has been assessed based on the criterion laid down in point 1.2 of Annex IV to Implementing Regulation (EU) 2019/317. Accordingly, the proposed environment targets of Greece have been compared with the relevant en route horizontal flight efficiency reference values set out in the European Route Network Improvement Plan (‘ERNIP’), drawn up in accordance with Annex I to Commission Implementing Regulation (EU) 2019/123 (8) and available at the time of adopting the Union-wide performance targets for RP4, that is on 2 July 2024.

(15)

The environment performance targets proposed by Greece for RP4 and the corresponding national reference values for RP4 from the ERNIP, expressed as the average horizontal en route flight efficiency of the actual trajectory, are as follows:

(16)

The Commission observes that the environment targets proposed by Greece are equal to the corresponding national reference values for each year of RP4. On that basis, the targets included in the revised draft performance plan should be considered consistent with the Union-wide performance targets in the key performance area of environment.

(17)

In accordance with point 2.1(a) of Annex IV to Implementing Regulation (EU) 2019/317, the Commission has complemented its assessment of the revised draft performance plan of Greece by reviewing the measures for the achievement of the environment targets included in that plan.

(18)

The Commission notes that Greece has presented, in the revised draft performance plan, measures for the achievement of the local environment targets, which include the procurement of a new air traffic management (‘ATM’) system and the implementation of cross-border free route airspace with neighbouring countries.

(19)

In Implementing Decision (EU) 2025/1040, the Commission considered that Greece should improve the measures for the achievement of its environment targets for RP4, including by committing to all the operational measures set out in the ERNIP and expediting the implementation of cross-border free route airspace.

(20)

The Commission observes that in its revised draft performance plan Greece has committed to two more operational measures set out in the ERNIP compared to the draft performance plan submitted in 2024. Those operational measures relate to the implementation of enhanced cross-border free route airspace with neighbouring countries. The Commission welcomes this additional commitment provided by Greece in the revised draft performance plan but also reiterates its view, as set out in Implementing Decision (EU) 2025/1040, that Greece should commit to the implementation of the entirety of the operational measures set out in the ERNIP. The Commission invites Greece to address this observation in connection with the adoption of its final performance plan in accordance with Article 16, point (a) of Implementing Regulation (EU) 2019/317.

(21)

In Implementing Decision (EU) 2025/1040, the Commission concluded that the en route capacity performance targets included in the draft performance plan of Greece submitted in 2024 were inconsistent with the Union-wide performance targets. Greece has proposed revised en route capacity targets in its revised draft performance plan.

(22)

The revised en route capacity targets proposed by Greece for RP4, expressed in minutes of air traffic flow management (‘ATFM’) delay per flight, as well as the corresponding reference values from the Network Operations Plan, are as follows:

(23)

The consistency of the revised capacity targets of Greece has been assessed based on the criterion laid down in point 1.3 of Annex IV to Implementing Regulation (EU) 2019/317. Accordingly, the proposed capacity targets of Greece have been compared to the relevant reference values set out in the Network Operations Plan drawn up in accordance with Article 9 of Implementing Regulation (EU) 2019/123 and available at the time of adopting the Union-wide performance targets for RP4, that is on 2 July 2024.

(24)

The Commission observes that the revised capacity targets proposed by Greece are equal to the corresponding national reference values for each year of RP4.

(25)

In accordance with point 2.1(a) of Annex IV to Implementing Regulation (EU) 2019/317, the Commission has complemented its assessment of the revised draft performance plan of Greece by reviewing the measures for the achievement of the capacity targets included in that plan.

(26)

Greece has presented, in the revised draft performance plan, measures for the achievement of the capacity targets, in particular with regard to the deployment of a new ATM system and the training and recruitment of additional air traffic controllers (‘ATCOs’). The Commission notes that Greece has explained in its revised draft performance plan that it has included all the relevant measures for the achievement of its RP4 capacity targets within that plan. The PRB has however, in its opinion on the assessment of Greece’s revised draft performance plan, raised doubts as to whether those measures presented by Greece are sufficient to enable the capacity performance targets to be effectively reached. Therefore, the PRB indicated that it will closely monitor the achievement of the capacity targets and the timely and the proper implementation by Greece of the planned capacity enhancement measures for RP4.

(27)

The Commission notes that Greece has established, in the revised draft performance plan, an additional key performance indicator (‘KPI’) and associated additional performance targets in the capacity key performance area, in accordance with Articles 8(4) and 10(3) of Commission Implementing Regulation (EU) 2019/317. That additional KPI concerns the timely achievement of the milestones for the realisation of certain new investments in fixed assets which are critical for the purpose of enhancing airspace capacity. Greece has also set up an incentive scheme of a financial nature, in accordance with Article 11(4) of that Implementing Regulation, to support the achievement of the additional capacity performance targets referred to in this recital.

(28)

With reference to recital (27), the Commission views positively the additional capacity performance targets and the related financial incentive scheme established by Greece in the revised draft performance plan. The Commission considers that the financial incentives set for the air navigation service provider in this respect are justified and proportionate in light of the criticality of implementing in a timely and orderly manner the capacity-related investments set out in the revised draft performance plan.

(29)

On balance, on the basis of the findings set out in recitals (22) to (28), the Commission considers that Greece has adequately addressed the recommendations set out in Article 2 of Implementing Decision (EU) 2025/1040 with regard to the revision of its en route capacity performance targets. The Commission therefore concludes that the revised capacity targets included by Greece in the revised draft performance plan and referred to in recital (22) should be considered consistent with the Union-wide performance targets for RP4.

(30)

However, in light of the PRB observations referred to in recital (26), as well as the non-realisation of planned investments included in the RP3 performance plan of Greece as referred to in recital (87) of Commission Implementing Decision (EU) 2025/1040, the Commission considers that Greece should put in place additional measures for the achievement of its en route capacity targets for RP4. Furthermore, the Commission urges Greece to expedite the implementation of all the capacity-enhancement measures already set out the revised draft performance plan and to monitor closely and regularly the timely implementation of those measures. The Commission considers that Greece should address, through this monitoring process, any risks of delays in the implementation of the capacity-enhancement measures set in the revised draft performance plan.

Review of the capacity targets for terminal air navigation services

(31)

In accordance with point 2.1(b) of Annex IV to Implementing Regulation (EU) 2019/317, the Commission has reviewed the capacity performance targets for terminal air navigation services set in the revised draft performance plan of Greece in respect of the airports referred to in Articles 1(3) and (4) of that Implementing Regulation. It was found that those targets do not give rise to concerns.

Assessment of the cost-efficiency targets

(32)

The Commission concluded in Implementing Decision (EU) 2025/1040 that the proposed en route cost-efficiency targets included in the draft performance plan of Greece submitted in 2024 were inconsistent with the Union-wide performance targets. Greece has proposed revised en route cost-efficiency targets in its revised draft performance plan.

(33)

The table below shows the revised cost-efficiency performance targets proposed by Greece in the revised draft performance plan.

(34)

The Commission observes that Greece has revised its local cost-efficiency targets for each year of RP4, which results, in comparison with the draft performance plan submitted in 2024, in a reduction of the determined unit cost (‘DUC’) for each year of RP4. Furthermore, Greece has also updated the DUC baseline values for years 2019 and 2024. The Commission notes that the revision by Greece of its baseline value for 2019 addresses the finding raised by the Commission in recital 92 of Implementing Decision (EU) 2025/1040 concerning identified unjustified adjustments of that baseline value. The Commission thus considers that the revised baseline value for 2019 set out in the revised draft performance plan is correctly calculated and adequately justified.

(35)

The decrease of the DUC referred to in recital (34) results mainly from the updated traffic assumptions for RP4 applied by Greece in line with the Eurocontrol STATFOR February 2025 base traffic forecast. The numbers of en route service units forecasted in the revised draft performance plan for each year of RP4 are presented in the table below.

(36)

The revised determined costs of Greece for RP4, expressed in real terms in 2022 prices (‘EUR2022’), are shown in the table below.

(37)

The Commission has assessed the consistency of the revised cost-efficiency targets proposed by Greece based on the criteria laid down in points 1.4(a), (b) and (c) of Annex IV to Implementing Regulation (EU) 2019/317.

(38)

Concerning the criterion laid down in point 1.4(a) of Annex IV to Implementing Regulation (EU) 2019/317, the Commission observes that the en route DUC trend at charging zone level of +1,6 % over RP4 underperforms the Union-wide trend of – 1,2 % over the same period.

(39)

Concerning the criterion laid down in point 1.4(b) of Annex IV to Implementing Regulation (EU) 2019/317, the Commission observes that the long-term en route DUC trend at charging zone level over the third reference period and RP4 of – 1,2 % outperforms the long-term Union-wide trend of – 1,0 % over the same period.

(40)

Concerning the criterion laid down in point 1.4(c) of Annex IV to Implementing Regulation (EU) 2019/317, the Commission observes that the baseline value for the DUC at the level of the charging zone of Greece of EUR 22,28 in EUR2022 is 45,0 % lower than the average baseline value of EUR 40,54 in EUR2022 of the relevant comparator group set out in Article 7, point (c), of Implementing Decision (EU) 2024/1688.

(41)

As outlined in recitals (39) and (40) , it is clear that the long-term DUC trend of Greece outperforms the corresponding Union-wide trend and that Greece’s baseline value for 2024 is significantly lower than the average baseline value of the relevant comparator group. Therefore, the Commission considers that the deviation from the Union-wide DUC trend for RP4 referred to in recital (38) does not preclude Greece’s cost-efficiency performance targets from being consistent with the Union-wide cost-efficiency performance targets.

(42)

On the basis of the findings set out in recitals (33) to (41), the Commission considers that Greece has adequately addressed the recommendations set out in Article 3 of Implementing Decision (EU) 2025/1040 with regard to the revision of its local cost-efficiency performance targets. The Commission therefore concludes that the revised cost-efficiency targets included by Greece in the revised draft performance plan should be considered consistent with the Union-wide performance targets for RP4.

(43)

In accordance with point 2.1(c) of Annex IV to Implementing Regulation (EU) 2019/317, the Commission has reviewed the cost-efficiency performance targets for terminal air navigation services set in the revised draft performance plan of Greece in respect of the airports referred to in Articles 1(3) and (4) of that Implementing Regulation. It was found that those targets do not give rise to concerns.

(44)

In the light of all the foregoing, the Commission has found that the performance targets included in the revised draft performance plan of Greece are consistent with the Union-wide performance targets for RP4,