The Irish Aviation Authority (IAA) has published the submissions received in response to its Draft Determination on the maximum level of airport charges at Dublin Airport for the 2027 to 2031 regulatory period, providing a detailed insight into how airlines, industry bodies and other stakeholders view the future funding and development of Ireland’s busiest airport. The regulator says all responses will now be carefully assessed before a Final Determination is issued before the end of 2026.
The draft decision, published in July, proposed a significant reduction in airport charges from current levels while still facilitating a major capital investment programme at Dublin Airport over the next five years.
Airlines broadly support lower charges
Ireland’s largest airline, Ryanair, welcomed the IAA’s proposal to reduce airport charges by around 15% but argued that the regulator should go further. In its submission, Ryanair claimed airlines have overpaid more than €200 million in airport charges since 2023 due to traffic forecasts that proved too conservative and capital expenditure allowances that were too generous. The airline also criticised what it described as “gold-plated” investment proposals and warned against approving excessive spending that could ultimately be passed on to passengers through higher charges.
Ryanair linked rising airport charges to its decision to reduce its Summer 2026 Dublin schedule by 10%, resulting in the removal of approximately one million seats from the market. The carrier argued that protecting Ireland’s competitiveness requires both the removal of infrastructure constraints and tighter control of airport costs.
Aer Lingus took a notably more measured approach. The airline said it supports the overall direction of the Draft Determination and described the proposed charge levels and allowed return as “directionally reasonable and appropriately balanced”. However, Aer Lingus called for stronger mechanisms to ensure Dublin Airport delivers promised infrastructure projects efficiently, meets quality-of-service targets and remains accountable for the investments that airport users will ultimately fund.
The airline’s response focused on improving incentives, transparency and accountability rather than fundamentally challenging the regulator’s overall approach. Aer Lingus also submitted a separate technical report examining the IAA’s proposed methodology for calculating the airport’s cost of capital.
Common airline themes emerge
While differing in tone, the responses from Ireland’s major carriers reveal several common themes. Both airlines support maintaining a regulatory framework that pressures Dublin Airport to operate efficiently while ensuring that any capital investment programme delivers tangible benefits for passengers and airlines.
A recurring concern is forecasting accuracy. Airlines have repeatedly argued during the determination process that Dublin Airport has historically underestimated passenger growth, resulting in higher charges than would otherwise have been necessary. Similar concerns were raised previously by IAG, which said conservative traffic forecasts have consistently resulted in additional revenues for the airport beyond those originally anticipated.
Terminal 3 proposal raises strategic questions
Among the more unusual submissions is that of DA Terminal 3 Limited (DAT3), which owns a substantial landholding between Dublin Airport’s runways and continues to advocate for a future third terminal development. DAT3 argues that Dublin Airport’s current expansion plans will not provide sufficient long-term capacity and contends that approving major infrastructure spending without addressing future terminal requirements risks failing future airport users.
The company claims its lands occupy what several historical studies have identified as the optimal location for future terminal development and has urged the IAA to consider the long-term strategic implications of the airport’s expansion plans as part of the determination process. DAT3 argues that Dublin Airport’s currently planned capacity could fall short of future demand, potentially requiring further large-scale investments later.
While DAT3 stops short of opposing the airport’s current capital investment programme outright, it is seeking greater scrutiny of how today’s investment decisions could influence future capacity options at the airport.
Final decision expected before year-end
The publication of consultation responses marks the final major stage in the determination process before the IAA issues its Final Determination. That decision will set the maximum level of airport charges that Dublin Airport can recover from airlines during the 2027 to 2031 regulatory period and will shape how billions of euro of planned airport investment are funded.
With Ryanair pushing for deeper cuts, Aer Lingus seeking stronger accountability measures, and DAT3 challenging the long-term capacity vision for the airport, the IAA now faces the task of balancing affordability, competitiveness and future infrastructure needs as it prepares its final ruling.
