EU slot rules forced Lufthansa to fly 18,000 ‘unnecessary’ flights to protect landing rights

ATC Intelligence
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Network carriers like Lufthansa can’t simply sell ghost-flight seats at bargain prices. EU law, while it grants full pricing freedom, doesn’t solve the underlying problem: these flights exist to protect landing rights at congested hubs like Frankfurt, not to carry passengers, so there’s often no real demand to sell into at any price. Ryanair’s Michael O’Leary can suggest discounting because his point-to-point model doesn’t depend on preserving slot pairs across a connecting network the way Lufthansa’s does.

The EU’s use-it-or-lose-it slot rule normally requires flying 80% of allocated slots to keep them next season. During the pandemic’s worst stretch, that was cut to 50%, then eased to 64% for summer 2022 — thresholds that still left carriers flying largely empty aircraft to preserve scheduling rights.

Michael O’Leary doesn’t do subtlety, and his jab at Lufthansa was no exception: if the German carrier didn’t want to run ghost flights, he said, it should simply sell those seats cheap. It’s a clean soundbite. It also sidesteps almost everything that makes the ghost-flight problem structural rather than a matter of willpower.

Lufthansa says it operated roughly 18,000 flights it considered unnecessary during the 2021–22 winter season, flown mainly under its own brand and Brussels Airlines to protect slot pairs at coordinated airports. The airline rejects the ‘ghost flights’ label and argues the flights were needed to preserve those rights. Ryanair, unsurprisingly, sees something else: a slot regime that protects legacy-carrier capacity at hubs and keeps competitors out.

Both things can be true. The more useful question — and the one that actually explains why this keeps happening — is why “just sell the seats cheap” isn’t the easy fix O’Leary makes it sound like.

What “ghost flights” actually means under EU slot rules

The mechanism here is the EU’s use-it-or-lose-it slot rule, formally Council Regulation (EEC) No 95/93. Article 10(2) sets the bar at 80%: a carrier has to use that share of a slot series during a season, or it loses historic precedence — the right to the same slot — in the equivalent season next year. Fall below that, and a coordinator can assign the slot to a rival.

That rule works when demand is normal. It creates a perverse incentive when demand collapses, because airlines fly to protect future slots rather than carry passengers. The Commission waived the standard rate, first through Regulation (EU) 2020/459 and then through Delegated Regulation (EU) 2022/255, setting temporary requirements of 50% for summer 2021 and winter 2021–22 and 64% for summer 2022.

Even a halved threshold, it turns out, is still a threshold. Airlines with weak winter demand on business or long-haul routes still had to fly a meaningful share of their slots empty or near-empty to protect next winter’s schedule — which is exactly the population of flights Lufthansa is describing.

The data gap nobody has closed

Here’s the part that gets lost in the O’Leary-versus-Lufthansa framing: nobody outside Lufthansa has published a neutral, regulator-verified count of how many near-empty flights other major European carriers ran that same winter.

Reported or regulator-recorded near-empty flights (load factor ≤10%) by selected European airlines, winter 2021–22
Airline Reported near-empty / ghost flights, winter 2021–22 Primary source type Notes / load-factor detail
Lufthansa Group 18,000 flights (self-described as unnecessary) Airline statement via media reports Covers Lufthansa and Brussels Airlines brands combined; not independently audited
Air France No data available (unverified) No regulator or airline figure located
KLM No data available (unverified) No disaggregated figure identified
British Airways No airline-level data (UK regulator data only by airport) CAA aggregated airport data UK CAA data confirms 14,472 UK-wide ghost flights March 2020–September 2021, 4,910 from Heathrow, but not by airline or by the 2021–22 winter specifically
Iberia No data available (unverified) No Spanish or EU dataset located
Austrian Airlines Folded into Lufthansa Group narrative only (unverified) No separate figure disclosed
Brussels Airlines Included within the 18,000-flight Lufthansa total Airline group statement via media No standalone count published
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The EU’s use-it-or-lose-it slot rule normally requires flying 80% of allocated slots to keep them next season. During the pandemic’s worst stretch, that was cut to 50%, then eased to 64% for summer 2022 — thresholds that still left carriers flying largely empty aircraft to preserve scheduling rights.”, “datePublished”: “2026-08-23T15:57:20+08:00”, “dateModified”: “2026-08-23T15:57:20+08:00”, “author”: { “@type”: “Person”, “name”: “ATC Intelligence”, “jobTitle”: “Travel Intelligence Team”, “url”: “https://www.airtraveler.club/about/#atc-intelligence”, “worksFor”: { “@type”: “Organization”, “name”: “Air Traveler Club”, “url”: “https://www.airtraveler.club” } }, “publisher”: { “@type”: “Organization”, “name”: “Air Traveler Club”, “url”: “https://www.airtraveler.club”, “logo”: { “@type”: “ImageObject”, “url”: “https://www.airtraveler.club/wp-content/uploads/2024/03/atc-r-logo-blue-1000.png” } }, “mainEntityOfPage”: { “@type”: “WebPage”, “@id”: “https://www.airtraveler.club/insider/slots/eu-slot-rules-forced-lufthansa-fly-18000-unnecessary-flights-protect-landing-rights/” }, “articleSection”: “Air Traveler Club Decoded”, “keywords”: “(empty)”, “mentions”: Ryanair, Lufthansa, }

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