Please find attached Lufthansa Group's contribution to the EU Aviation Strategy Call for Evidence. In short, it is our view that a renewed Aviation Strategy must prioritize competitiveness and fair competition, guided by five principles: 1. Safeguard the EUs strategic autonomy: strong EU network airlines and hubs are essential to maintaining independent European connectivity and to reduce reliance on nonEU carriers.
Lufthansa Group
Company · Germany · EU Transparency Register 0714344663-32
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 925 companies & groups on this site, they rank #210 by legislative files engaged — a count of participation, not a measure of influence.
Declares membership of
- IATA - The International Air Transport Association
- A4E - Airlines for Europe
- ENAA - European Network Airlines Association
- E4FC - Europeans for Fair Competition
- BDI - Bundesverband der Deutschen Industrie
- BDL - Bundesverband der Deutschen Luftverkehrwirtschaft
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026).
- Register category
- Companies & groups
- Head office
- Köln, Germany
- EU office
- Brüssel
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Lufthansa Group filed 4 positions between 10 Mar 2026 and 14 Aug 2026, across 4 of the 326 legislative files tracked here, attaching a full position paper 3 times.
What they argued
The existing digital rulebook provides a common regulatory framework, yet its practical impact is limited by overly complex, interpretation-heavy legislation that at times generates more uncertainty than clarity. Key regulationsmost notably the EU AI Actare drafted in broad and abstract terms, leaving businesses without the operational guidance needed for consistent and efficient implementation.
Lufthansa Group welcomes the publication of the European Commission´s Passenger Mobility Package and the opportunity to comment on the proposals. The Package aims to facilitate passengers ability to search for, compare, and book multimodal travel options through digital platforms while also addressing long-standing barriers in rail passenger transport.
The draft raises issues of critical concern for the European aviation industry. Commercial airlines have been strictly regulated under the well-established EU ETS1 system (Annex I of the Directive) since 2012. The introduction of ETS2 for the transport sector must not - under any circumstances - result in uncoordinated carbon cost pass-through by fuel suppliers, market fragmentation, or severe administrative…
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
- IDEE ECONOMICHE www.idee-economiche.it · 4 files in common
- BDI - Federation of German Industries · 2 files in common
- Verbraucherzentrale Bundesverband (vzbv) · 2 files in common
- Ibec · 2 files in common
- Germanwatch · 2 files in common
Showing 5 of 8.
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Everything on this page comes from Lufthansa Group’s own submissions to the European Commission — we have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.