Earlier this year, Ishka SAVi took note of emerging disparities on EU Taxonomy eligibility and alignment across the first set of European airline financial disclosures to include them. The EU Taxonomy, a classification system for economic activities aligned with environmental objectives, came into force in 2020, but a delegated act introducing criteria for aviation (among other sectors) was only officially published in November 2023. Further clarifications on its application were then issued throughout 2024.
In February 2025, proposed amendments to the EU Corporate Sustainability Reporting Directive (CSRD) removed EU Taxonomy reporting requirements for small and medium-sized enterprises (SMEs), including lessors, which qualify as SMEs as they have fewer than 1,000 employees. Pending final agreement on these changes across the EU’s three legislative bodies, attention on the application of the aviation criteria has focused almost entirely on airlines. To provide context on how these criteria are being applied, Ishka SAVi collected EU Taxonomy disclosure data from 11 airlines.
Note: The following charts are presented for informational and contextual purposes. EU Taxonomy reporting remains a complex area, with significant variation in how companies interpret and disclose their data. Reporting teams at each airline as well as external auditors may differ in their interpretation of what qualifies as eligible or aligned revenue, CaPex, and OpEx. As such, the figures shown here should not be viewed as directly comparable across companies, but rather as illustrative of current reporting practices.
Scope of the analysis
The charts below are based on disclosures by a sample of some of Europe’s largest airlines. Ishka SAVi examined the 2024 annual report of 15 airlines: Aegean, Air Baltic, Air France-KLM, EasyJet, Finnair, IAG, Icelandair, Lufthansa, Norse Atlantic Airways, Norwegian, Ryanair, SAS, TAP Air Portugal, TUI, and Wizz Air.
Of these 15 airlines, four did not provide EU Taxonomy disclosures:
- EasyJet: The airline is headquartered in the UK, outside of the EU. Its latest annual report did not include references to the EU Taxonomy.
- SAS: Following SAS’s delisting and transition to private ownership, the airline noted that its regulatory obligations have changed. “As a private entity, SAS is no longer mandated to report under the EU Taxonomy. This shift in obligations reflects the regulatory framework’s focus on publicly listed companies.”
- TAP Air Portugal: The airline noted that it would include EU Taxonomy information in its sustainability report. Ishka SAVi was unable to find a recently issued sustainability report containing this information.
- Wizz Air: The airline noted that due “to ongoing regulatory developments and uncertainties surrounding the implementation of the EU Taxonomy framework, especially the application of the “Do No Significant Harm” criteria, it “opted not to include the EU Taxonomy disclosure” in its annual report.
The upcoming charts cover the remaining 11 airlines’ EU Taxonomy turnover, CapEx, and OpEx eligibility across the four sets of aviation technical screening criteria (TSC). Below each chart, the proportion of EU Taxonomy-eligible revenue that qualifies as aligned is displayed. For more details on the EU Taxonomy aviation criteria, see this explainer.
A note on auditors: With the exception of Norse Atlantic Airways, the external auditors for the analysed airlines are all Big Four accounting firms.
3.21 Manufacturing of Aircraft
Note: Only airlines with reported eligibility are included out of the 11 analysed.
In most cases, revenue in this category typically includes MRO services provided to other airlines, with CapEx covering investments in maintenance infrastructure, and OpEx covering maintenance and repair costs. As a result, airline groups with in-house MRO business feature more prominently.
6.18 Leasing of Aircraft
Note: Only airlines with reported eligibility are included out of the 11 analysed.
Only two airlines reported revenue/CapEx/OpEx related to aircraft leasing. Norse Atlantic Airways attributed the turnover to “lease income” while Icelandair noted that it financial streams relating to leasing of aircraft through its leasing business, Loftleidir Icelandic.
6.19 Passenger and freight air transport
Note: Only airlines with reported eligibility are included out of the 11 analysed.
This is the core area of activity of the analysed airlines and therefore all with EU Taxonomy disclosures are represented. In most cases, turnover covers total passenger revenue across airfare and ancillary, cargo revenue, and, in some cases, charter revenue. CapEx includes activities like spending on aircraft and reserve engines, rights-of-use to aircraft and reserve engines. OpEx comprises direct expenses incurred to ensure the operational readiness of aircraft and engines.
6.20 Air transport ground handling operations
Note: Only airlines with reported eligibility are included out of the 11 analysed.
Revenue in this category may include handling operations performed for other carriers. CapEx may include the leasing or purchase of ground vehicles to carry out handling activities. OpEx are not described, but is understood to cover costs associated with ground operations and handling leases.
Non-aviation activities
Note: Only airlines with reported eligibility are included out of the 11 analysed.
In addition to EU Taxonomy alignment across the aviation criteria, many of the analysed also reported eligibility and alignment across other sectors and activities that, in most cases, are not core to their business. The clear exception is TUI, a travel and hospitality group with significant revenue and activities outside of aviation.
The Ishka View
The purpose of this overview is to highlight the disparities in EU Taxonomy aviation criteria reporting across its first reporting period. The central objective of the EU Taxonomy is to become a guiding framework for investors to identify companies whose operations favour economically sustainable activities. Enabling comparability is at the heart of that mission but, as the charts above show, it remains challenging to contrast the approaches of individual airlines. The percentage of aviation EU Taxonomy alignment has always been expected to be low due to the limitations of the replacement ratio (which caps alignment of new aircraft through an industry-wide replacement factor), older aircraft phase-out requirements, and SAF blending percentages significantly above the EU mandate.
This overview does not fully address the differences in alignment across airlines. While most of the disclosures reviewed provide some indication of estimated alignment – or lack thereof – the majority stop short of explaining how the criteria are interpreted, either by the airline itself or by the auditor.
