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Common Project 2: Achieving Regulatory Excellence Before the Funding Battle Commences

Published on November 6th, 2025
5 Minute Read
Common Project 2: Achieving Regulatory Excellence Before the Funding Battle Commences

In October 2025, the SESAR Joint Undertaking (SJU) initiated the creation of the Common Project (CP) 2 implementing regulation. The announcement of the CP2 workshop, to be held on 23-24 March 2026 in Brussels, marks the formal beginning of intensive stakeholder consultation to shape the next decade of air traffic management (ATM) transformation. The scene has been set by the SJU: “Focusing on what is essential, transformative and requires coordination on an EU level”.

The workshop will define technical content, priorities and standards governing European ATM modernisation through 2035, exploring the new service delivery model, future air-ground connectivity and Trajectory-Based Operations – all technological pillars of the Digital European Sky. CP2 is planned to be submitted to the European Commission before summer 2026, with entry into force scheduled for 2027.

Stakeholders face a delicate challenge. They must craft a comprehensive technical implementing regulation while navigating uncertainty about whether adequate public funding will materialise for its application.

A Common Project is defined as a deployment instrument established under Commission Implementing Regulation (EU) No 409/2013, which provides the legal framework for the coordinated and timely implementation of essential ATM functionalities, as defined in the European ATM Master Plan. Initially a public co-funding of up to euro 2.5 billion had been announced for CP1. To date, the SESAR Deployment Manager (SDM), tasked with the implementation of CPs, has mobilised euro 3 billion in industry investments with a further euro 1.3 billion in EU support across 350+ projects. 91% of these projects are either operational or under implementation.

Yet CP2 unfolds against a challenging backdrop: the Multi-Annual Financial Plan (MFF) 2028-2034 negotiations face competing priorities, spanning defence to climate action, and the open question of final public co-funding envelopes for ATM innovation and its critical infrastructure.

An uncomfortable paradox 

CP2 stakeholders must develop a detailed implementing regulation defining functionalities, timelines and synchronisation requirements without knowing how much public funding will be in place for implementation. It is worth noting that co-funding has been in the past – and will remain in the future – a crucial factor for stakeholder commitment.

SESAR has delivered tangible benefits. “The operational use of these technologies has enabled industry savings of almost euro 17 billion, a figure set to double by 2035,” states the SESAR Deployment Industry Partnership (SDIP) in its recent declaration on the future of SESAR deployment. SDM notes that, “on this basis, there’s general consensus on the need to extend and renovate the ambition of SESAR, as the industry and Europe still need a competitive, future-proof and efficient ATM sector.”

As with CP1, the SJU holds CP2 development ownership. “We are expected to have a critical role in the Common Project 2 proposal, as requested by both the European Commission and the operational stakeholders’ community,” SDM explains. “We will support the SESAR JU in defining a proposal which builds on the lessons learned from over a decade of coordinating SESAR deployment and that truly reflects the implementation priorities of the industry.” SDM is engaged from the drafting team to the expert layers, up to the Steering Group. “We’ll work with all relevant parties in the first half of the year using our well-known inclusive consultation approach: the target is to produce a consolidated version to be sent to the EC in summer.”

This compressed timeline means stakeholders have roughly six months to achieve consensus on a regulation governing ATM investments for the next decade, while fundamental funding questions remain unanswered.

Unity cannot wait

Only a unified, compelling technical proposal stands a chance of securing adequate funding for our sector in the competitive MFF negotiations, against defence, space and climate initiatives, notwithstanding the traditionally dominant agriculture and regional budgets fighting for their shares.

CP1 demonstrated that public co-funding serves as essential glue for coordinated deployment. Public funding has facilitated the SDM partnership and synchronised investments across ANSPs, airports, civil and military airspace users and the Network Manager. 

Yet no public funding commitment exists for CP2. This battle comes later, contingent on the technical proposal’s strength. This creates a dilemma: strong regulation is necessary to justify funding requests, while stakeholders may hesitate with their commitments without confidence in public co-funding.

The guidance for CP2 is set

The baseline of CP2 is established through the 2025 European ATM Master Plan and the Aviation Research and Innovation Strategy (ARIS), complementing the SES2+ regulation.

The Master Plan describes tomorrow’s digital sky enablers: the new service delivery model, future air-ground connectivity, and Trajectory-Based Operations. CP2 is intrinsically linked to ARIS, which calls for euro 22.5 billion in EU funding between 2028-2034 to maintain Europe’s aviation leadership. The Master Plan provides the technology roadmap and deployment objectives, while ARIS provides the strategic foundation, and CP2 will pave the way for the detailed deployment plan. Together they strive to secure Europe’s position in global aviation.

The advocacy imperative: Building whilst lobbying

Dwelling on uncertainty risks a self-fulfilling prophecy. A cautious, minimalist CP2 proposal virtually guarantees insufficient funding and it will not justify the investment scale needed for meaningful ATM transformation.

Stakeholders must define genuinely essential functionalities delivering measurable benefits, demonstrate clear value for competitiveness and sustainability goals, achieve consensus, and link CP2 to broader EU objectives like the Green Deal and strategic autonomy.

Creating the technical regulation is only half the challenge. Simultaneously, the ATM community must continue the intensive advocacy for CP2 funding within MFF 2028-2034 negotiations. As detailed in our earlier MFF analysis, the proposed transport budget has doubled from euro 25.8 billion to euro 51.5 billion for the Connecting Europe Facility, but aviation and ATM must compete against genuine defence and space programmes, as well as numerous other priorities in a fiercely contested euro 2 trillion budget framework.

Setting Europe’s ATM trajectory through 2035

The next six months will set European ATM modernisation trajectory through 2035. If CP2 fails to secure adequate funding, subsequent ATM investments become harder to justify, Single European Sky momentum weakens, and the Digital European Sky vision slips away.

Without CP2 success, European ATM risks fragmenting into national initiatives that undermine the focus on network-level performance and see Europe fall behind in next-generation capabilities.

Call for action

The SJU March workshop is the prime opportunity for for the ATM community – ANSPs, airlines, airports, industry, associations, the Network Manager, institutional partners and Member States – to demonstrate that they can unite behind a shared vision and create a comprehensive, ambitious CP2 regulation, including implementation commitments, despite profound uncertainty about implementation funding.The SESAR stakeholders have to deliver now to enable the future of SESAR.

CP2’s success depends on stakeholders’ willingness to build the strongest possible technical foundation whilst simultaneously fighting for implementation resources. Both must happen in parallel. 

Only a strong, unified, compelling CP2 proposal will justify the intensive funding advocacy. The technical regulation and funding advocacy are interdependent prerequisites. A weak proposal guarantees inadequate funding. A strong proposal doesn’t guarantee adequate funding but makes it possible. 

Can the stakeholders deliver? I believe that they want to. And I believe that they can. 

Marita Lintener
With 35 years of management experience, Marita has a proven track record in the aviation & aerospace sector in Europe and globally. Her journey has been about pioneering strategic initiatives and nurturing stakeholder partnerships in the global transportation sector. Her cross-industry experience includes ANSP, airline and industry body roles.
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