(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, Denmark submitted to the Commission a draft performance plan for RP4. After the verification of completeness of that draft performance plan by the Commission, Denmark submitted an updated draft performance plan (‘the draft performance plan’) on 13 December 2024.

(4)

The Commission found that the cost-efficiency performance targets set by Denmark in the draft performance plan in respect of its en route charging zone do not meet the assessment criteria laid down in point 1.4 of Annex IV of Commission Implementing Regulation (EU) 2019/317 and thus are not consistent with the Union-wide performance targets for RP4.

(5)

On 16 May 2025, the Commission therefore notified Denmark of the findings regarding the inconsistency of the performance targets referred to in recital 4 through Commission Implementing Decision (EU) 2025/1040 (5). In that Decision, the Commission issued recommendations to Denmark in view of ensuring the consistency of their performance targets with the Union-wide performance targets for RP4.

(6)

On 15 August 2025, Denmark submitted a revised draft performance plan for RP4 for assessment by the Commission. Following the verification of completeness of that plan, Denmark submitted an updated version of the revised draft performance plan (the ‘revised draft performance plan’) on 6 October 2025.

(7)

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.

(8)

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 Denmark 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.

(9)

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) No 2024/2803, has submitted to the Commission its opinion on the performance targets included in the revised draft performance plan 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).

(10)

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.

(11)

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

(12)

The Commission has found that the safety performance targets proposed by Denmark for the air navigation service provider ‘NAVIAIR’ are equal to the Union-wide safety targets in respect of calendar year 2029.

(13)

The Commission notes that the revised draft performance plan sets out measures for NAVIAIR for the achievement of the local safety targets, such as data-driven means of monitoring and managing fatigue-related risk, regular assessment of risks, an improvement program in respect to safety culture, definition of safety policies and standards, enhancement of a system to manage responsibilities and authorisations, as well as internal and external audits and surveys.

(14)

On the basis of the findings set out in recitals 11, 12 and 13 considering that the Union-wide safety performance targets set in Implementing Decision (EU) 2024/1688 are to be achieved by the final year of RP4, that is, 2029, the local safety performance targets included in the revised draft performance plan should be considered consistent with the Union-wide performance targets.

(15)

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 Denmark have been compared to 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.

(16)

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

(17)

The Commission observes that the environment targets proposed by Denmark are equal to the corresponding national reference values for each calendar year of RP4.

(18)

The Commission notes that Denmark has presented, in the revised draft performance plan, measures for the achievement of the local environment targets which include the implementation of enhanced cross-border free route airspace with five neighbouring countries.

(19)

On the basis of the findings set out in recitals 16, 17 and 18, the targets in the key performance area of environment included in the revised draft performance plan of Denmark should be considered consistent with the Union-wide performance targets for RP4.

(20)

As regards the key performance area of capacity, the consistency of the targets included in the revised draft performance plan regarding the average en route air traffic flow management (‘ATFM’) delay per flight 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 Denmark 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.

(21)

The en route capacity targets proposed by Denmark for RP4, expressed in minutes of ATFM delay per flight, and the corresponding reference values from the Network Operations Plan, are as follows:

(22)

The Commission observes that the capacity targets proposed by Denmark are either equal to or lower than the corresponding national reference values for each calendar year of RP4.

(23)

The Commission notes that Denmark has presented, in the revised draft performance plan, measures for the achievement of the local en route capacity targets which include the continuous recruitment and training of air traffic controllers, sector optimization, the implementation of advanced air traffic flow and capacity management measures and improved arrangements regarding military training areas.

(24)

On the basis of the findings set out in recitals 21, 22 and 23, the targets in the key performance area of capacity included in the revised draft performance plan of Denmark should be considered consistent with the Union-wide performance targets for RP4.

(25)

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 Denmark 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.

(26)

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

(27)

The table below shows the revised performance targets contained in the revised draft performance plan.

(28)

The Commission notes that the cost-efficiency performance targets of Denmark were revised downwards for each year of the reference period, thus leading to a lower annual determined unit cost (‘DUC’) in comparison with the draft performance plan submitted in 2024. That improvement resulted both from the revised traffic assumptions, in line with the Eurocontrol STATFOR base forecast of February 2025, and from a reduction of the determined costs for RP4.

(29)

The revised determined costs expressed in EUR in real terms in 2022 prices (‘EUR2022’) and the updated traffic forecast for the charging zone, as presented in the revised draft performance plan, are shown in the table below:

(30)

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

(31)

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 -2,1 % over RP4 outperforms the Union-wide trend of -1,2 % over the same period.

(32)

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 (‘RP3’) and RP4 of +0,4 % underperforms the long-term Union-wide trend of -1,0 % over the same period.

(33)

Denmark has requested the Commission to consider the impact of the traffic changes resulting from Russia’s war of aggression against Ukraine as part of the calculation of the long-term en route DUC trend. According to Denmark, the changes in traffic resulting from the war in Ukraine have led to a structural reduction of overflights in the Danish airspace. Denmark has provided additional information, in the revised draft performance plan, to substantiate its claim regarding the significance of these traffic changes.

(34)

Based on the additional information submitted by Denmark as part of the revised draft performance plan, the loss of overflights due to the impact of the war in Ukraine is estimated by the PRB to represent 12 % of the total service units of the en route charging zone of Denmark. The PRB noted that Denmark is indeed in the geographical area affected by these traffic changes and that the resulting impact constitutes a structural traffic reduction continuing to impact the cost-efficiency of air navigation services in RP4 in the Danish airspace.

(35)

It is therefore necessary and appropriate to examine, for the purpose of the assessment criterion referred to in recital 32, whether Denmark would meet the Union-wide long-term DUC trend in absence of the circumstances referred to in recital 33 and 34.

(36)

To this end, the Commission has recalculated the long-term DUC trend of Denmark in light of the estimated structural loss of traffic for Denmark as a consequence of the war in Ukraine, measured in en route service units. That recalculation results in an adjusted long-term DUC trend for Denmark of -1,0 %, which is in line with the long-term Union-wide DUC trend of -1,0 %. Therefore, it is concluded that Denmark fulfils the assessment criterion referred to in (32) after considering the effect of the significant traffic reduction resulting from the war in Ukraine.

(37)

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 of EUR 72,32 of Denmark in EUR2022 is 18,7 % higher than the average baseline value of EUR 60,92 in EUR2022 of the relevant comparator group set out in Article 7, point (f), of Implementing Decision (EU) 2024/1688.

(38)

As outlined in recital 31, it is clear that the DUC trend of Denmark over RP4 outperforms the corresponding Union-wide trend by a significant margin. Furthermore, as shown in recitals 33 to 36, when excluding the negative impact of the traffic changes resulting from Russia’s war of aggression against Ukraine, Denmark meets the Union-wide long-term DUC trend. Therefore, the Commission considers that the deviation from the average DUC baseline value for 2024 referred to in recital (37) does not preclude Denmark’s cost-efficiency performance targets from being consistent with the Union-wide cost-efficiency performance targets.

(39)

On the basis of the findings set out in recitals 27 to 38, the Commission considers that Denmark 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 Denmark in the revised draft performance plan should be considered consistent with the Union-wide performance targets for RP4.

(40)

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 draft performance plan of Denmark 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.

(41)

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