{"url_path":"/sec/ryaay/10-k/2026/item-4","section_key":"item-4","section_title":"Item 4 **Information on the Company","topic":"sec","document":{"doc_type":"20-F","doc_date":"2026-06-22","source_url":"https://www.sec.gov/Archives/edgar/data/1038683/0001104659-26-076131-index.html","accession_number":"0001104659-26-076131","cik":"0001038683","ticker":"RYAAY","issuer_name":"RYANAIR HOLDINGS PLC","edgar_url":"https://www.sec.gov/Archives/edgar/data/1038683/0001104659-26-076131-index.html","primary_entity_key":"0001038683","primary_entity_name":"RYANAIR HOLDINGS PLC"},"word_count":15057,"has_tables":true,"body_markdown":"**Item 4.**Information on the Company\n\nINTRODUCTION\n\n​\n\nRyanair Holdings was incorporated in 1996 as a holding company for Ryanair Designated Activity Company (“DAC”). The latter operates a low-fare, scheduled-passenger airline serving short-haul, point-to-point routes mainly within Europe. In FY19, the Company set up Buzz (a Polish charter and scheduled passenger airline with a Polish AOC), acquired Lauda (a Maltese wet lease provider to the Ryanair Group with a Maltese AOC), and set-up Ryanair UK (with a UK AOC). In FY20, Malta Air became the fifth airline in the Ryanair Group. Each of Buzz, Lauda, Malta Air, Ryanair DAC and Ryanair UK are wholly owned airlines within the Ryanair Group. See “Item 5. Operating and Financial Review and Prospects—History” for detail on the history of the Company.  As of March 31, 2026, the Group had a principal fleet of 621 Boeing 737 aircraft and 26 Airbus A320 aircraft (total short-haul fleet of 647 aircraft). The Group offers over 3,600 short-haul flights per day serving approximately 235 airports across Europe*.* See “—Route System, Scheduling and Fares—Route System and Scheduling” for more details of Ryanair’s route network. See “Item 5. Operating and Financial Review and Prospects—Seasonal Fluctuations” for information about the seasonality of Ryanair’s business.\n\n​\n\nRyanair recorded a profit after taxation of €2.17bn in FY26, as compared with a profit of €1.61bn in FY25. The movement was primarily attributable to 4% traffic growth, 10% higher average fares and fuel hedging, which helped offset higher ATC and environmental costs. Ryanair generated an average booked passenger load factor of approximately 94% in FY26 (FY25: 94%) and total revenue increased by 11% to €15.54bn, up from €13.95bn in FY25.\n\n​\n\nManagement believes that the market’s acceptance of Ryanair’s low-fares service is reflected in the “Ryanair Effect” – Ryanair’s history of stimulating significant annual passenger traffic growth on the routes where it commences service. FY26 total revenue rose 11% to €15.54bn. Scheduled revenue increased 14% to €10.56bn as traffic grew 4% to over 208m passengers while average fares increased 10%. Ancillary revenue increased 6% to €4.99bn. Operating costs increased 6% (2% on a per passenger basis) to €13.17bn.\n\n​\n\nThe address of Ryanair Holdings’ registered office is Dublin Office, Airside Business Park, Swords, County Dublin, K67 NY94, Ireland. The Company’s contact person regarding this Annual Report on Form 20-F is: Neil Sorahan, Group CFO (same address as above). The telephone number is +353-1-945-1212. Under its current Articles, Ryanair Holdings has an unlimited corporate duration.\n\n​\n\nRyanair Holdings files annual reports, special reports, and other information with the SEC. Its SEC filings are available on the SEC’s website at https://www.sec.gov. This site contains reports, proxy and information statements and other information regarding issuers that file electronically with the SEC. Ryanair Holdings also makes available on its website, free of charge, its annual reports on Form 20-F and the text of its reports on Form 6-K, including any amendments to these reports, as well as certain other SEC filings, as soon as reasonably practicable after they are electronically filed with or furnished to the SEC. Ryanair’s investor website address is https://investor.ryanair.com. The information on these websites, and any other website referenced herein, is not part of this report except as specifically incorporated by reference herein.\n\n​\n\n​\n\n25\n\n[Table of Contents](#TOC)\n\nSTRATEGY\n\n​\n\nRyanair’s objective is to establish itself as Europe’s largest scheduled passenger airline group in a disciplined and sustainable manner, through continued improvements and expanded offerings of its low-fares service. Ryanair offers low fares that generate increased passenger traffic while maintaining a continuous focus on cost- containment and operating efficiencies. The key elements of Ryanair’s long-term strategy are:\n\n​\n\n*Low-Fares.* Ryanair’s low fares are designed to stimulate demand, particularly from fare-conscious leisure and business travelers who might otherwise use alternative forms of transportation or choose not to travel at all. Ryanair sells seats on a one-way basis, thus eliminating minimum stay requirements from all travel on Ryanair scheduled services. Ryanair sets fares on the basis of the demand for particular flights and by reference to the period remaining to the date of departure of the flight, with higher fares typically charged on flights with higher levels of demand and for bookings made nearer to the date of departure. Ryanair also periodically runs special promotional fare campaigns. See “—Route System, Scheduling and Fares—Widely Available Low Fares” below.\n\n​\n\n*Customer Service.* Ryanair’s strategy is to deliver industry leading customer service, including best in class on-time performance (“OTP”) and reliability (approximately 80% OTP in FY26, despite significant ATC disruptions). Ryanair achieves this by focusing strongly on the execution of these services. Ryanair conducts a daily conference call with airport personnel at each of its base airports, during which the reasons for each “first wave” flight delay and baggage short shipment are discussed in detail and logged to ensure that the root cause is identified and rectified. Subsequent (consequential) delays and short shipments are investigated by Ryanair ground operations personnel. The Group has an ongoing commitment to improving customer satisfaction (“CSAT”) across the customer journey and this is measured by regular post-flight CSAT surveys and online “mystery passenger” checks. The Group’s FY26 CSAT score was a new record of 89% (FY25: 86%), despite the widespread disruption caused by ATC delays and cancellations due to ATC staff shortages, poor rostering and equipment failures.\n\n​\n\n*Frequent point-to-point flights on short-haul routes.* Ryanair provides frequent point-to-point service on short-haul routes. In FY26, Ryanair flew an average route length of approximately 790 miles and an average flight duration of approximately 2.25 hours. Short-haul routes allow Ryanair to offer its low fares and frequent service, while eliminating the need to provide unnecessary “frills”, like free in-flight meals and movies, typically expected by customers on longer flights. Point-to-point flying (as opposed to hub-and-spoke service) allows Ryanair to offer direct, non-stop routes and avoid the costs of providing “through service” for connecting passengers, including baggage transfer and transit passenger assistance.\n\n​\n\n*Low Operating Costs.* Management believes that the Ryanair Group’s operating costs are among the lowest of any European scheduled-passenger airline group, with the cost gap with competitor airlines widening. Ryanair strives to widen the cost gap through control of the primary expenses involved in running a major scheduled airline group, including: (i) aircraft equipment and finance costs; (ii) personnel costs; (iii) customer service costs; and (iv) airport access and handling costs:\n\n​\n\n(i) Aircraft Equipment and Finance Costs. Ryanair currently operates mainly Boeing 737s. The operation of primarily a single aircraft type enables Ryanair to limit the costs associated with personnel training, maintenance, and the purchase and storage of spare parts while also affording the Company greater flexibility in the scheduling of crews and equipment. Management also believes that the terms of Ryanair’s contracts with Boeing are favorable to Ryanair. The strength of Ryanair’s balance sheet and cash flows also enables the Group to lease aircraft at competitive rates (such as the 26 A320s leased by Lauda). See “—Aircraft” below for additional information on Ryanair’s fleet. The Company has a BBB+ credit rating from both S&P and Fitch Ratings (see “Item 3. Key Information—Risk Factors—Risks Related to the Company—The Company will incur significant costs acquiring new aircraft and any instability in the credit and capital markets could negatively impact\n\n26\n\n[Table of Contents](#TOC)\n\nRyanair’s ability to obtain financing on acceptable terms” above) and can raise inexpensive unsecured debt in the capital markets. The Company also finances aircraft from its strong cash flows.\n\n​\n\n(ii) Personnel Costs. Ryanair endeavors to control its labor costs through incentivizing high productivity. Compensation for personnel emphasizes productivity-based pay incentives. These incentives include sales bonus payments for onboard sales of products for cabin crew and payments based on the number of hours or sectors flown by pilots and cabin crew within strict limits set by regulations fixing maximum working hours.\n\n​\n\n(iii) Customer Service Costs. Ryanair has entered into agreements with external contractors at certain airports for ticketing, passenger and aircraft handling, and other services (including the growing use of self-service kiosks) that management believes can be more cost-efficiently provided by third parties. Ryanair negotiates competitive rates for such services by negotiating fixed-price, multi-year contracts. Through the development of its Direct Distribution Policy Ryanair has eliminated travel agent commissions. As part of its strategic initiatives, the Company has broadened its distribution base by making Ryanair’s fares available to bricks & mortar travel agents and corporate travel booking tools via GDSs Travelport (trading as Galileo and Worldspan), Amadeus and Sabre, as well as Concur and Kyte. Direct sales via the Ryanair website and mobile app (including through referrals from authorized OTAs under ‘Direct Distribution Agreements’ (see “Item 3. Key information—Risk Factors—Risks related to the Company—The Company faces risks related to unauthorized use of information from the Company’s website”) continues to be the main generator of scheduled passenger revenues.\n\n​\n\n(iv) Airport Access and Handling Costs. Ryanair prioritizes airports that offer competitive prices. Ryanair’s record of delivering a consistently high volume of passenger traffic growth at many airports has allowed it to negotiate favorable growth contracts with such airports. Since the launch of the Always Getting Better program (“AGB”) in 2013, and following the Covid-19 pandemic, the Company has accessed more primary airports, which typically have higher airport charges and greater competition along with slot limitations. Secondary and regional airports generally do not have slot requirements or other operating restrictions that can increase operating expenses and limit the number of allowed take-offs and landings. Ryanair endeavors to reduce its airport charges by opting, when practicable, for less expensive gate locations as well as outdoor boarding stairs, rather than jetways, which are more expensive and operationally less efficient to use. Ryanair requires all passengers to check-in on the Internet, which reduces waiting times at airports and speeds a passenger’s journey from arrival at the airport to boarding, as well as significantly reducing airport handling costs. See “Item 3. Key information—Risk Factors—Risks related to the Company—The Company faces risks related to its internet reservations operations, its decision to implement 100% digital boarding passes and its elimination of airport check-in facilities.”\n\n​\n\n*Taking advantage of digital platforms.*Ryanair’s reservation system operates under a hosting agreement with Navitaire which currently extends to 2034. As part of the implementation of the reservation system, Navitaire developed an Internet booking facility. The Ryanair system allows Internet users to access its host reservation system and to make and pay for confirmed reservations in real time through the Ryanair.com website. The Company also has a mobile app which makes it simpler and easier for customers to book Ryanair flights. The website and app also offer customers the ability to add additional discretionary products on day of travel (e.g. checked bags, priority boarding, preferred seating and fast track). Ryanair has continued to invest in its website with the key features being personalization, a “My-Ryanair” account, easier booking flow and more content. These features make Ryanair’s website faster, intuitive and fully responsive for mobile devices. The “MyRyanair” registration service, which allows customers to securely store their personal and payment details, has also significantly quickened the booking process and made it easier for customers to book a flight. Membership of “My-Ryanair” is automatic for all bookings.\n\n​\n\n27\n\n[Table of Contents](#TOC)\n\nThe Ryanair app enhances the day-of-travel experience by giving customers live flight information and status updates directly from Ryanair’s operations centre. Features such as 100% digital boarding passes and Order to Seat, which enables customers to order inflight food and drink directly through the app, make travel quicker, easier and more convenient. Ryanair will endeavor to continue to improve its website and mobile app through a series of ongoing upgrades.\n\n​\n\n*Commitment to safety.* Safety is the primary priority of Ryanair. This commitment includes the hiring and training of Ryanair’s pilots, cabin crew, and maintenance personnel and maintenance of its aircraft in accordance with regulatory requirements and the highest European industry standards. Ryanair has not had a single passenger or flight crew fatality as a result of an accident with one of its aircraft in its 41-year operating history. Although Ryanair seeks to maintain its fleet in a cost-effective manner, management does not seek to extend Ryanair’s low-cost operating strategy to the areas of safety, maintenance, training or quality assurance. Routine aircraft maintenance and repair services are performed primarily by Ryanair, at Ryanair’s main bases, but are also performed at other base airports by maintenance contractors approved under the terms of an EASA Part 145 and UK CAA approval. Ryanair currently performs the majority of heavy airframe maintenance in-house, but currently contracts with other parties who perform engine overhaul services and rotable repairs. Ryanair also outsources some heavy maintenance activity. These contractors also provide similar services to a number of other major European airlines.\n\n​\n\n*Enhancement of operating results through ancillary services.* Ryanair distributes various optional products, including travel insurance, airport fast track, parking, airport transfers, car hire and accommodation services through its website and mobile app. Ancillary Revenues accounted for approximately 32% of Ryanair’s total operating revenues in FY26 and approximately 34% in FY25. See “—Ancillary Services” below and “Item 5. Operating and Financial Review and Prospects—Results of Operations—FY26 Compared with FY25—Ancillary Revenues” for additional information.\n\n​\n\n*Focused criteria for growth*. Ryanair believes it will have opportunities for continued growth by: (i) using fare promotions to stimulate demand; (ii) initiating additional routes in the EU; (iii) initiating additional routes in countries party to a European Common Aviation Agreement with the EU that are currently served by higher-cost, higher-fare carriers or where competitor traffic capacity has not fully returned following the Covid-19 pandemic; (iv) increasing the frequency of service on its existing routes; (v) starting new domestic routes within individual EU countries and the UK; (vi) considering acquisition opportunities that may become available in the future; (vii) connecting airports within its existing route network; (viii) establishing new bases; and (ix) initiating new routes not currently served by any carrier.\n\n​\n\n*Responding to market challenges.* In recent periods, Ryanair’s low-fares business model faced substantial pressure due to significantly increased fuel costs and economic contraction in the economies in which it operates (including global market disruptions related to the Covid-19 pandemic outbreak, the war in Ukraine and the conflict in the Middle East). The Company has aimed to meet these challenges by: (i) grounding aircraft during the winter season; (ii) controlling costs and liquidity; (iii) renegotiating contracts with existing suppliers, airports and handling companies and (iv) flexibly reallocating capacity to new markets. There can be no assurance that the Company will be successful in achieving all of the foregoing or taking other similar measures, or that doing so will allow the Company to earn profits in any period. See “Item 3. Key information—Risk Factors—Risks related to the Company—Changes in fuel costs and availability affect the Company’s results” and “— The Company may not be successful in increasing fares to cover rising business costs.” In prior years, in response to an operating environment characterized by high fuel prices, typically lower seasonal yields and higher airport charges and/or taxes, Ryanair adopted a policy of grounding a certain portion of its fleet during the winter months. Ryanair also carries out its scheduled aircraft maintenance at this quieter time of the year. While seasonal grounding does reduce the Company’s operating costs, it also decreases Ryanair’s winter season flight and non-flight revenues. Decreasing the number and frequency of flights may also negatively affect the Company’s labor relations, including its ability to attract flight personnel interested in full-time employment. See “Item 3. Key information—Risk factors—Risks related to the Company—Ryanair has seasonally grounded aircraft.”\n\n28\n\n[Table of Contents](#TOC)\n\nROUTE SYSTEM, SCHEDULING AND FARES\n\nRoute System and Scheduling\n\n​\n\nThe Company offers over 3,600 daily scheduled short-haul flights serving approximately 235 airports largely throughout Europe, the Middle East and North Africa. The following table lists Ryanair’s 95 operating bases:\n\n​\n\n \n\n**Operating Bases**\n\n \n\n \n\n \n\n \n\nAgadir\n\nGdansk\n\nPisa\n\nAlicante\n\nGirona\n\nPorto\n\nAthens\n\nGothenburg\n\nPoznan\n\nBaden-Baden\n\nIbiza\n\nPrague\n\nBarcelona (El Prat)\n\nKatowice\n\nPrestwick\n\nBari\n\nKaunas\n\nRabat\n\nBelfast International\n\nKrakow\n\nReggio\n\nBerlin (Brandenburg)\n\nLamezia\n\nRiga\n\nBirmingham\n\nLanzarote\n\nRome (Ciampino)\n\nBologna\n\nLeeds Bradford\n\nRome (Fiumicino)\n\nBournemouth\n\nLisbon\n\nSeville\n\nBratislava\n\nLiverpool\n\nShannon\n\nBrindisi\n\nLondon (Luton)\n\nSofia\n\nBristol\n\nLondon (Stansted)\n\nStockholm (Arlanda)\n\nBrussels (Charleroi)\n\nMadeira\n\nTangier\n\nBucharest\n\nMadrid\n\nTenerife South\n\nBudapest\n\nMalaga\n\nThessaloniki\n\nCagliari\n\nMalta\n\nTirana\n\nCatania\n\nManchester\n\nToulouse\n\nChania\n\nMarrakesh\n\nTrapani\n\nCologne\n\nMarseille\n\nTrieste\n\nCopenhagen\n\nMemmingen\n\nTurin\n\nCorfu\n\nMilan (Bergamo)\n\nValencia\n\nCork\n\nMilan (Malpensa)\n\nVenice (Marco Polo)\n\nDublin\n\nNaples\n\nVenice (Treviso)\n\nDubrovnik\n\nNewcastle\n\nVienna\n\nDusseldorf (Weeze)\n\nNuremberg\n\nVilnius\n\nEast Midlands\n\nPalermo\n\nWarsaw (Modlin)\n\nEdinburgh\n\nPalma de Mallorca\n\nWroclaw\n\nFaro\n\nPaphos\n\nZadar\n\nFez\n\nParis (Beauvais)\n\nZagreb\n\nFrankfurt (Hahn)\n\nPescara\n\n​\n\n​\n\n​\n\n​\n\n​\n\n29\n\n[Table of Contents](#TOC)\n\n \n\nSee Note 16, “Analysis of operating revenues and segmental analysis” to the consolidated financial statements included in Item 18 for more information regarding the geographical sources of the Company’s revenue.\n\n​\n\nRyanair’s objective is to schedule a sufficient number of flights per day on each of Ryanair’s routes to satisfy demand for Ryanair’s low-fares service. Ryanair schedules departures on its most popular routes at frequent intervals normally between approximately 6:00 a.m. and 12:00 a.m. Management regularly reviews the need for adjustments in the number of flights on all of its routes. In recent years, Ryanair has focused on high frequency and business friendly timings between Europe’s main business centers.\n\n​\n\nDuring FY26, the Ryanair Group opened 3 new bases and over 160 new routes across its network. See “Item 3. Key information—Risk factors— Risks related to the Company—Ryanair’s new routes and expanded operations may have an adverse financial impact on its results.”\n\n​\n\nWidely Available Low Fares\n\n​\n\nRyanair offers low fares, with prices generally varying on the basis of advance booking, seat availability and demand. Ryanair sells seats on a one-way basis, thus removing minimum stay requirements from all travel on Ryanair scheduled services. All tickets can be changed, subject to certain conditions, including fee payment and applicable upgrade charges. However, tickets are generally non-cancellable and non-refundable and must be paid for at the time of reservation.\n\n​\n\nRyanair’s discounted fares are driven by Ryanair’s “load factor active – yield passive” strategy whereby seats are priced to ensure that high load factor targets are achieved.\n\n​\n\nRyanair also periodically runs special promotional fare campaigns, in particular in connection with the opening of new routes, and endeavors to always offer the lowest fare on any route it serves. Promotional fares may have the effect of increasing load factors and reducing Ryanair’s yield and passenger revenues on the relevant routes during the periods they are in effect. Ryanair expects to continue to offer significant fare promotions to stimulate demand in periods of lower activity or during off-peak times for the foreseeable future.\n\n​\n\nMARKETING AND ADVERTISING\n\n​\n\nRyanair’s primary marketing strategy is to emphasize its widely available low fares, route choice and great care. Ryanair does so through online advertising, social media, and its own digital platforms, complemented by radio sponsorships and some TV advertising.\n\n​\n\nIn addition, Ryanair uses creative content to drive awareness of communication campaigns (such as the need for ATC reform), ancillary services and policy information through email marketing, social media and the Ryanair app. Social media alone gives Ryanair free access to a monthly audience of over 150m people.\n\n​\n\nOther marketing activities include co-operative advertising campaigns with other travel-related entities, including local tourist boards. Ryanair also regularly contacts people who have registered in its database to inform them about promotions and special offers.\n\n​\n\nRESERVATIONS ON RYANAIR.COM\n\n​\n\nPassenger airlines generally rely on travel agents (whether traditional or online) for a significant portion of their ticket sales and pay travel agents’ commission for their services, as well as reimbursing them for the fees charged by reservation systems providers. In contrast, Ryanair encourages all passengers to make reservations and purchase\n\n30\n\n[Table of Contents](#TOC)\n\ntickets directly. Due to Ryanair’s long standing online distribution policy, the majority of reservations and purchases are made through the website Ryanair.com, although a significant number of customers are also booking on the Ryanair app and therefore, we are not reliant on travel agents. Ryanair has long campaigned against the anti-consumer practices of OTAs who overcharge customers, apply hidden mark-ups, and provide fake customer contact and payment details. In 2024, several OTAs signed DDAs with Ryanair that allow them to market Ryanair flights to consumers in compliance with the principles of price transparency, ensuring that Ryanair is provided with genuine customer details. These agreements protect OTA consumers from the anti-consumer practices of screenscraping/unauthorized OTAs. Customers who are on bookings that look like they were made by a BOT (not a human) are required to verify their identity on our website to ensure all safety and security protocols during online check-in are adhered to.\n\n​\n\nRyanair’s reservations system is hosted under an agreement with the system provider, Navitaire. Under the agreement, the system serves as Ryanair’s core seating inventory and booking system. In return for access to these system functions, Ryanair pays transaction fees that are generally based on the number of passenger seat journeys booked through the system. Navitaire also retains back-up booking engines to support operations in the event of a breakdown in the main system.\n\n​\n\nThe Company has long-standing agreements with the GDSs Amadeus, Sabre and Travelport. These GDSs provide access to Ryanair fares (except for some promotional fare categories) to traditional bricks & mortar travel agents and corporate travel booking tools. Since 2024 Ryanair has signed numerous agreements with OTA partners, covering 95% of the OTA market. These agreements allow OTA’s to distribute Ryanair’s inventory, subject to abiding by Ryanair’s customer protection requirements such as price transparency and no hidden charges.\n\n​\n\nAIRCRAFT\n\n​\n\nBoeing Aircraft\n\n​\n\nAs of March 31, 2026, the Company had a fleet of 621 Boeing 737 aircraft which are currently operated by Buzz, Malta Air, Ryanair DAC and Ryanair UK. The fleet includes 210 Boeing 737-8200 “Gamechanger” aircraft, each having 197 seats, 410 Boeing 737-800 “Next Generation” (“NG”) aircraft, each having 189 seats and 1 Boeing 737-700.\n\n​\n\nUnder the terms of the 2023 Boeing Contract, Ryanair agreed to purchase up to 300 Boeing 737 MAX-10 series aircraft (of which 150 are firm orders and 150 are subject to an option exercisable at Ryanair’s discretion) in the period from calendar 2027 to 2033 inclusive. It is a short-to-medium range aircraft and, for Ryanair’s specified configuration, will seat 228 passengers (39 (21%) more than the Group’s existing Boeing 737NGs). The Boeing 737 MAX-10 also offers significantly improved fuel, carbon and noise efficiencies compared to the Boeing 737NG, with approximately 20% lower fuel and CO2 emissions and up to 50% less noise. The Basic Price (equivalent to a standard list price for an aircraft of this type) for each of the Boeing 737 MAX-10 series aircraft is approximately U.S.$135m. Net of basic credits, the value of the 150 firm Boeing 737 MAX-10 aircraft under the 2023 Boeing Contract is approximately U.S.$10.6bn. Boeing has granted Ryanair certain price concessions as part of the 2023 Boeing Contract. As a result, the \"effective price\" (the purchase price of the New Aircraft net of discounts received from Boeing) of each Boeing 737 MAX-10 will be significantly below the Basic Price mentioned above. The effective price applies to all Boeing 737 MAX-10s due for delivery from calendar 2027.\n\n​\n\nFor additional details on the Boeing contracts, scheduled aircraft deliveries and related expenditures and their financing, see “Item 5. Operating and Financial Review and Prospects—Liquidity and Capital Resources.”\n\n31\n\n[Table of Contents](#TOC)\n\nThe Boeing 737 is the world’s most widely used commercial aircraft and exists in a number of generations, the Boeing 737-8200 being the most recent entering service.\n\n​\n\nThe Boeing 737NGs are fitted with CFM 56-7B engines and have advanced CAT III Autoland capability, advanced traffic collision avoidance systems, and enhanced ground-proximity warning systems. The Boeing 737-8200s are fitted with CFM LEAP-1B engines which, combined with the Advanced Technology winglet and other aerodynamic improvements, should reduce fuel consumption by up to 16% on a per seat basis compared to the Boeing 737NGs in Ryanair’s configuration and reduce operational noise emissions by up to 50%.\n\n​\n\nFor additional information, please see “Item 3—Key information—Risk Factors—Risks related to the Company—A majority of Ryanair’s aircraft and certain parts are sourced from a single supplier; therefore, Ryanair would be materially and adversely affected if such supplier was unable to provide additional equipment or support”.\n\n​\n\nAt March 31, 2026, the average aircraft age of the Company’s Boeing 737 fleet was approximately 10 years.\n\n​\n\nAirbus Aircraft\n\n​\n\nAs of March 31, 2026, the Company had a fleet of 26 leased Airbus A320 aircraft (2025: 26; 2024: 27). These aircraft are operated by Lauda, as a wet lease operator for the Group, and have 180 seats. They are powered by a mix of CFM 56-5B and Pratt & Whitney V2500 engines. At March 31, 2026, the average aircraft age of the Company’s leased Airbus A320 fleet was approximately 19 years.\n\n​\n\nSummary\n\n​\n\nRyanair expects to have approximately 800 narrow-body aircraft in its fleet following delivery of the Boeing 737 MAX-10 aircraft, assuming disposals of some older aircraft (including lease returns) over the period and Boeing’s ability to fulfil the 2023 Boeing Contract.\n\n​\n\nTraining and Regulatory Compliance\n\nAt March 31, 2026, Ryanair owns and operates 9 Boeing 737NG, 13 Boeing 737-8200 and 1 A320 full flight simulators for pilot training. The simulators were purchased from CAE Inc of Quebec, Canada (“CAE”). In addition, Ryanair currently owns and operates 10 state of the art, fixed base simulators from Multi Pilot Simulations (“MPS”) which are used for pilot assessments and pilot training. The Group’s simulators are located at the Group’s training centers in Dublin, East Midlands, Krakow, Madrid and Milan (Bergamo).\n\n​\n\nManagement believes that Ryanair is currently in compliance with all applicable regulations and EU directives concerning its fleet of Boeing 737 and Airbus A320 aircraft and will comply with any regulations or applicable EU and UK directives that may come into effect in the future.****However, there can be no assurance that the FAA, the UK CAA, EASA or any other regulatory authorities will not recommend or require other safety-related undertakings that could adversely impact the Company’s results of operations or financial condition, in particular safety-related undertakings related to the Boeing 737-8200. See “Item 3. Key Information—Risk Factors—Risks Related to the Airline Industry—Safety-related undertakings could affect the Company’s results.”  \n\n​\n\n32\n\n[Table of Contents](#TOC)\n\nANCILLARY SERVICES\n\n​\n\nRyanair provides various ancillary services and engages in other activities connected with its core air passenger service, including non-flight scheduled services (e.g. Priority Boarding and Reserved Seating), internet-related services (e.g. SMS flight confirmation), and the in-flight sale of beverages, food, duty-free and merchandise.\n\n​\n\nRyanair primarily markets car hire, travel insurance and accommodation services through its website and mobile app. Ryanair markets car parking, fast-track, airport transfers and travel insurance on its website and mobile app. Ryanair also sells gift vouchers which are redeemable online.\n\n​\n\nMAINTENANCE AND REPAIRS\n\n​\n\nGeneral\n\n​\n\nAs part of its commitment to safety, Ryanair endeavors to hire qualified maintenance personnel, provide proper training to such personnel, and maintain its aircraft in accordance with EASA and UK Regulations and European industry standards. While Ryanair seeks to maintain its fleet in a cost-effective manner, management does not seek to extend Ryanair’s low-cost operating strategy to the areas of continuing airworthiness management, maintenance, training, or quality assurance.\n\n​\n\nEASA came into being on September 28, 2003, through the adoption of Regulation (EC) No. 1592/2002 of the European Parliament, and its standards superseded the previous Joint Aviation Authority (“JAA”) requirements. See “—Government Regulation—Regulatory Authorities” below. Post Brexit, with the UK leaving EASA, aircraft registered in the UK are managed in accordance with the UK equivalent regulations.\n\n​\n\nRyanair Engineering and the Safety & Compliance department manage the Continuing Airworthiness of the Group fleet in accordance with Commission Regulation (EU) No. 1321/2014 of 26 November 2014 - Continuing Airworthiness and UK Reg. (EU) 1321/2014 - the UK Continuing Airworthiness regulation. Each Group Airline holds applicable approval with their respective National Airworthiness Authority (IAA Ireland, Polish CAA, TMCAD Malta and UK CAA), providing robust oversight of all maintenance activities.\n\n​\n\nMaintenance activities are undertaken in accordance with EASA and UK Part 145 as applicable, by Ryanair DAC under IAA approval and approved contracted providers.\n\n​\n\nDuring FY25, Ryanair established the Ryanair Engineering Academy (the “Academy”) to increase the number of trainees recruited into the Group to align headcount with future aircraft deliveries. The calendar year 2024 engineering intake included approximately 1,000 trainees, which grew to 1,200 trainees in 2025 and a similar target is in place for the calendar year 2026. The Academy is approved to deliver maintenance type training courses under EASA and UK Part-147 approvals, with approved training sites located across the Ryanair network, in Glasgow (Prestwick), Milan (Bergamo), London (Stansted), Seville and Shannon.\n\n​\n\nRyanair is an EASA Part-145 approved maintenance organization and provides its own routine aircraft maintenance and repair services. Ryanair also performs certain line maintenance checks on its aircraft, including pre-flight and daily checks at a number of its bases, as well as A-checks at its Madrid (8 bays),  London Stansted (5 bays), Bergamo (5 bays), Dublin (2 bays), Vienna (2 bays), Nuremberg (2 bays), Malta (1 bay) and Porto (1 bay) facilities to support line maintenance on Boeing 737 and Airbus A320 aircraft.\n\n33\n\n[Table of Contents](#TOC)\n\nRyanair will continue to look for opportunities to invest in additional hangar facilities over the coming years to ensure there is sufficient hangar capacity for the growing fleet. Ryanair recently completed works in a new 8 bay facility in Madrid and commenced the building of new hangars in Porto, Dublin and Berlin to support the upcoming maintenance requirements.\n\n​\n\nMaintenance and repair services that may become necessary while an aircraft is located at other airports served by Ryanair are provided by other EASA Part 145-approved contract maintenance providers. Aircraft return each evening to Ryanair’s bases, where they are examined by either Ryanair’s approved personnel or by local EASA Part 145-approved companies.\n\n​\n\nHeavy Maintenance\n\n​\n\nRyanair performs the majority of its Boeing 737 heavy airframe maintenance utilizing a Ryanair associated Part-145 approval/organization for heavy maintenance. Ryanair has hangar facilities in Prestwick (6 bays), Seville (5 bays), Kaunas (4 bays), Wroclaw (4 bays), Shannon (3 bays) and Hahn (2 bays) which are used for heavy maintenance activities. These hangars have co-located workshops which carry out component repairs on parts commonly used on the Boeing 737 fleet. Ryanair currently has 5 heavy maintenance hangar bays under construction in Kaunas (2) and Wroclaw (3). Ryanair will continue to look for opportunities to invest in additional hangar facilities over the coming years to ensure there is sufficient hangar capacity for the growing fleet.\n\n​\n\nRyanair expects to be dependent on external service contractors for Airbus A320 and Boeing 737 maintenance, particularly for airframe, engine and component maintenance, for the foreseeable future, notwithstanding the capabilities provided by its current maintenance facilities. See “Item 3. Key Information — Risk Factors — Risks Related to the Company — The Group is dependent on external service providers”. Ryanair utilizes MROs which provide a high standard of maintenance.\n\n​\n\nEngine Overhaul\n\n​\n\nRyanair currently contracts out engine overhaul service for its Boeing 737NG aircraft to CFM under a ten-year agreement to 2028, with certain engine overhauls covered until FY29. This comprehensive maintenance contract provides for the repair and overhaul of the CFM56-7B series engines fitted to Ryanair’s Boeing 737NG aircraft, the repair of parts and general technical support for the fleet of engines. CFM uses its EASA Part-145 approved repair facilities in Cardiff (Wales), Celma (Brazil), Petropolis (Brazil), Paris (France), Kuala Lumpur (Malaysia), Queretaro (Mexico) and Casablanca (Morocco). CFM LEAP-1B Engines installed on the Boeing 737-8200 aircraft are subject to warranty by CFM. Any required repairs/overhauls subject to this warranty will be accomplished by CFM at its EASA Part-145 approved repair facilities. Engine maintenance providers are also monitored closely by the national authorities under EASA and national regulations. Ryanair trained engineering staff with both Boeing and CFM in advance of the introduction of the Boeing 737-8200 aircraft to the Ryanair fleet.\n\n​\n\nWith Ryanair’s engine fleet growing to circa 2,000 engines by FY34 leading to increased engine maintenance requirements, Ryanair plans to establish up to two engine MRO facilities, bringing engine maintenance in-house from approximately early 2029. Each facility is expected to have capability for maintenance activities on both CFM56-7B (Boeing 737NG aircraft) engines and LEAP-1B (Boeing 737-8200 and Boeing 737-MAX-10) engines.\n\n34\n\n[Table of Contents](#TOC)\n\nSAFETY RECORD\n\n​\n\nRyanair has not had a single passenger or flight crew fatality in its 41-year operating history. Ryanair demonstrates its commitment to safe operations through its safety policy, training, procedures, its investment in safety-related equipment and enhancements, and its adoption of an internal, open, and confidential reporting system for safety and security matters. The Company’s Board also has a Group Safety and Security Committee to review and discuss air safety and security performance. Members of the Committee include Non-Executive Directors, Eamonn Brennan, Ray Conway (Co-Chair) and Ryanair’s Chief Risk Officer, Carol Sharkey (Co-Chair). The Accountable Managers of each of the Ryanair Group Airlines and nominated persons as applicable are invited to attend. Mr. Conway and Ms. Sharkey report to the Board each quarter.\n\nRyanair’s flight crew training is oriented towards accident prevention and integrates with the Safety Management System to cover all aspects of flight operations. Threat and Error Management (“TEM”) is at the core of all flight crew training programs. Ryanair maintains full control of the content and delivery of all flight crew training, including initial, recurrent, and upgrade phases. All training programs are approved/accepted by the relevant National Competent Aviation Authority, (including the IAA, the Polish CAA, TMCAD Malta and the UK CAA) which regularly audits operations standards and flight crew training standards for compliance with EU and UK legislation (as applicable). All Boeing 737s that Ryanair has bought are certified for Category IIIA landings (automatic landings with minimum horizontal visibility of 200 meters and a 50 feet decision height).\n\n​\n\nRyanair has a comprehensive and documented Safety Management System. Management actively encourages frontline personnel to report any safety-related issues through the Safety Reporting System, which is available online. Also available is Ryanair’s Confidential Reporting System (“RCRS”) which affords personnel the opportunity to report directly to Safety Officers any event, error, or discrepancy in operations that does not fall into the category of a mandatory report required by regulation, and they do not wish to report through standard reporting channels. Management uses the de-identified information reported through all reporting channels to enhance training, procedures and performance as necessary. Additionally, Ryanair promotes the use of CHIRP, a confidential reporting system that is endorsed by the UK CAA as an alternative confidential reporting channel.\n\n​\n\nRyanair has installed an automatic data capturing system on each of its Boeing 737 and Airbus A320 aircraft. This system captures and downloads aircraft performance information for use as part of Operational Flight Data Monitoring (“OFDM”) which automatically provides a confidential report on exceedances from normal operating limitations detected during the course of each flight. The purpose of this system is to monitor operational performance and trends and identify instances of an operational limit being exceeded. By analyzing this information, management can identify undesirable trends and potential areas of operational risk, so as to take steps to rectify such deviations, thereby ensuring adherence to Ryanair’s flight safety standards.\n\n​\n\nAIRPORT OPERATIONS\n\n​\n\nAirport Handling Services\n\n​\n\nThe majority of Ryanair flights are handled through the airport authorities, either directly through sub-contractors or the airport themselves. The Ground Operations team work to obtain the most competitive service rates for ground, aircraft, and passenger services across the network by negotiating long-term agreements, often across multiple stations with growth incentives (where possible) with fixed or capped rates to gain certainty over costs. These contracts are generally scheduled to expire in two to seven years, unless renewed, and part of the rates are contingent on performance by the providers to ensure compliance and punctuality. Ryanair provides its own ground services, aircraft handling and passenger services either directly or through partners at Dublin, London (Stansted), various Polish airports, Portugal and Spain. Ryanair has the option under European regulations to handle its own aircraft and passenger services where it\n\n35\n\n[Table of Contents](#TOC)\n\ncannot obtain competitive rates or quality handling services at each airport. See “Item 3. Key Information—Risk Factors—Risks Related to the Company—The Group is dependent on external service providers.”\n\n​\n\nAirport Charges\n\n​\n\nAs with other airlines, Ryanair must pay airport charges each time it lands and accesses facilities at the airports it serves. Depending on the policy of the individual airport, such charges can include landing fees, passenger loading fees, security fees and parking fees. Ryanair attempts to negotiate discounted fees by delivering annual increases in passenger traffic and/or access to new destinations, and opts, when practicable, for less expensive facilities, such as less convenient gates and the use of outdoor boarding stairs rather than more expensive jetways. Nevertheless, there can be no assurance that the airports Ryanair uses will not impose higher airport charges in the future and that any such increases would not adversely affect the Company’s operations.\n\n​\n\nSee “Item 3. Key Information—Risk Factors—Risks Related to the Company—Ryanair’s continued growth is dependent on access to suitable airports; charges for airport access are subject to increase.” See also “Item 8. Financial Information—Other Financial Information—Legal Proceedings—EU State Aid-Related Proceedings” for information regarding legal proceedings in which Ryanair’s economic arrangements with several publicly owned airports are being contested.\n\n​\n\nFUEL\n\n​\n\nThe cost of jet fuel (including carbon and de-icing costs) accounted for approximately 41% and 42% of Ryanair’s total operating expenses in FY26 and FY25 respectively. In each case, this accounts for costs after giving effect to the Company’s hedging activities. The future availability and cost of jet fuel cannot be predicted with any degree of certainty, and Ryanair’s low-fares policy limits its ability to pass on increased fuel costs to passengers through increased fares. Jet fuel prices are dependent on crude oil prices, which are quoted in U.S. dollars. If the value of the U.S. dollar strengthens against the euro, Ryanair’s fuel costs, expressed in euro, may increase even in absence of any increase in the U.S. dollar price of jet fuel. Ryanair has also entered into foreign currency forward contracts to hedge against some currency fluctuations. See “Item 11. Quantitative and Qualitative Disclosures About Market Risk— Foreign Currency Exposure and Hedging.”\n\n​\n\nRyanair typically enters into arrangements providing for significant protection against fluctuations in fuel prices, through both forward swap contracts and/or call options covering periods of up to 12 to 18 months of anticipated jet fuel requirements. If capacity is significantly reduced, as was the case in FY21 due to European Governments response to the spread of Covid-19, forward contracts may become ineffective for hedge accounting purposes. See “Item 3. Key Information—Risk Factors—Risks Related to the Company—Changes in fuel costs and availability affect the Company’s results” and “Item 11. Quantitative and Qualitative Disclosures About Market Risk—Fuel Price Exposure and Hedging” for additional information on recent trends in fuel costs and the Company’s related hedging activities, as well as certain associated risks. See also “Item 5. Operating and Financial Review and Prospects—FY26 Compared with FY25—Fuel and Oil.”\n\n36\n\n[Table of Contents](#TOC)\n\nINSURANCE\n\n​\n\nRyanair is exposed to potential catastrophic losses that may be incurred in the event of an aircraft accident or terrorist incident. Any such accident or incident could involve costs related to the repair or replacement of a damaged aircraft and its consequent temporary or permanent loss from service. In addition, an accident or incident could result in significant legal claims against the Company from injured passengers and others who experienced injury or property damage as a result of the accident or incident, including ground victims. Ryanair maintains aviation third-party liability insurance, passenger liability insurance, employer liability insurance, directors’ and officers’ liability insurance, aircraft insurance for aircraft loss or damage, and other business insurance in amounts per occurrence consistent with industry standards. Ryanair believes its insurance coverage is adequate, although not comprehensive. There can be no assurance that the amount of such coverage will not need to be increased, that insurance premiums will not increase significantly or that Ryanair will not be forced to bear substantial losses from accidents. Ryanair’s insurance does not cover claims for losses incurred when, due to unforeseen events, airspace is closed and aircraft are grounded such as the airspace closures described in “Item 3. Key Information—Risk Factors—Risks Related to the Airline Industry—Extreme weather events could affect the Company and have a material adverse effect on the Company’s results of operations.” The cost of insurance coverage for certain third-party liabilities arising from “acts of war” or terrorism increased dramatically as a result of the September 11, 2001 terrorist attacks and the war in Ukraine. Ryanair’s insurers have indicated that the scope of the Company’s current war-related insurance coverage may exclude certain types of catastrophic incidents, which may result in the Company seeking alternative coverage.\n\n​\n\nRyanair has established Aviation Insurance Limited (“AIL”), a wholly owned captive insurance company subsidiary based in Malta, to provide the Company with self-insurance as part of its ongoing risk-management strategy. AIL underwrites a portion of the Company’s aviation insurance program, which covers not only the Company’s aircraft but also its liability to passengers and to third parties. AIL reinsures virtually all of the aviation insurance risk it underwrites with recognized third parties in the aviation reinsurance market, with the amount of AIL’s maximum aggregate exposure not currently subject to such reinsurance agreements being equal to approximately U.S.$16m.\n\n​\n\nCouncil Regulation (EC) No. 2027/97, as amended by Council Regulation (EC) No. 889/2002, governs air carrier liability. This legislation provides for unlimited liability of an air carrier in the event of death or bodily injuries suffered by passengers, implementing the Warsaw Convention of 1929 for the Unification of Certain Rules Relating to Transportation by Air, as amended by the Montreal Convention of 1999. Ryanair has extended its liability insurance to meet the appropriate requirements of the legislation. See “Item 3. Key Information—Risk Factors—Risks Related to the Airline Industry—The Company faces the risk of loss and liability” for information on the Company’s risks of loss and liability.\n\n37\n\n[Table of Contents](#TOC)\n\nFACILITIES\n\n​\n\nThe following are the principal facilities owned or leased by the Ryanair Group:\n\n​\n\n​\n\n​\n\n​\n\n​\n\n​\n\n​\n\n​\n\n​\n\n​\n\n​\n\n**Site Area**\n\n​\n\n**Floor Space**\n\n​\n\n​\n\n​\n\n​\n\n**Location**\n\n**  ​ ​ ​**\n\n**(Sq. Meters)**\n\n**  ​ ​ ​**\n\n**(Sq. Meters)**\n\n**  ​ ​ ​**\n\n**Tenure**\n\n**  ​ ​ ​**\n\n**Activity**\n\nAirside Business Park, Dublin\n\n \n\n48,174\n\n \n\n36,517\n\n \n\nFreehold\n\n \n\nOffices, Travel Labs Dublin, Training Center, OCC & Engineering\n\nBergamo Airport\n\n \n\n16,647\n\n \n\n9,563\n\n \n\nLeasehold\n\n \n\nAircraft Maintenance & Training Center\n\nDublin Airport (Hangar)\n\n \n\n8,190\n\n \n\n8,269\n\n \n\nLeasehold\n\n \n\nAircraft Maintenance\n\nEast Midlands Airport\n\n \n\n5,935\n\n \n\n3,435\n\n \n\nFreehold\n\n \n\nSimulator Training Center\n\nFrankfurt (Hahn) Airport (Hangar)\n\n \n\n5,064\n\n \n\n5,064\n\n \n\nLeasehold\n\n \n\nAircraft Maintenance & Simulator Training Center\n\nKrakow, Poland\n\n​\n\n17,370\n\n​\n\n4,159\n\n​\n\nFreehold\n\n​\n\nSimulatorTraining Centre\n\nMadrid Airport (Hangar)\n\n​\n\n22,606\n\n​\n\n16,378\n\n​\n\nLeasehold\n\n​\n\nAircraft Maintenance\n\nMadrid, Spain\n\n​\n\n3,828\n\n​\n\n3,828\n\n​\n\nLeasehold\n\n​\n\nTravel Labs Madrid\n\nMadrid, Spain\n\n​\n\n4,873\n\n​\n\n3,985\n\n​\n\nFreehold\n\n​\n\nSimulatorTraining Centre\n\nMalta Airport (Hangar)\n\n​\n\n6,729\n\n​\n\n3,696\n\n​\n\nLeasehold\n\n​\n\nAircraft Maintenance\n\nPieta, Malta\n\n​\n\n480\n\n​\n\n940\n\n​\n\nLeasehold\n\n​\n\nAdministrative Offices\n\nPorto Airport (Hangar)\n\n​\n\n8,424\n\n​\n\n5,103\n\n​\n\nLeasehold\n\n​\n\nAircraft Maintenance\n\nPrestwick Airport (Hangar)\n\n \n\n16,022\n\n \n\n14,295\n\n \n\nLeasehold\n\n \n\nAircraft Maintenance\n\nSeville, Spain (Hangar)\n\n \n\n9,800\n\n \n\n8,000\n\n \n\nLeasehold\n\n \n\nAircraft Maintenance\n\nStansted Airport (Hangar)\n\n \n\n17,262\n\n \n\n14,302\n\n \n\nFreehold\n\n \n\nAircraft Maintenance & Simulator Training Center\n\nVienna Airport (Hangar)\n\n​\n\n12,591\n\n​\n\n7,720\n\n​\n\nLeasehold\n\n​\n\nAircraft Maintenance\n\nVienna, Austria\n\n​\n\n1,325\n\n​\n\n1,325\n\n​\n\nLeasehold\n\n​\n\nAdministrative Offices\n\nWarsaw, Poland\n\n​\n\n5,920\n\n​\n\n7,800\n\n​\n\nLeasehold\n\n​\n\nAdministrative Offices\n\nWroclaw Airport, Poland (Hangar)\n\n \n\n8,701\n\n \n\n7,484\n\n \n\nLeasehold\n\n \n\nAircraft Maintenance\n\nWroclaw, Poland\n\n​\n\n1,935\n\n​\n\n1,935\n\n​\n\nLeasehold\n\n​\n\nTravel Labs Wroclaw\n\n​\n\n​\n\nTRADEMARKS\n\n​\n\nRyanair’s name, logo, certain other names and logos, as well as certain slogans, are registered as:\n\n​\n\n(1)European Union Trademarks – registrations which afford uniform protection in all 27 EU member states.\n\n(2)National trademarks (in, for example, the UK, Jordan and Lebanon) – registrations which afford protection in the state of registration.\n\n(3)International trademarks – registrations designating relevant countries, which in turn operate as national trademark registrations.\n\n​\n\nRegistered trademarks give Ryanair an exclusive monopoly over the use of the particular mark in the relevant jurisdiction and the right to sue for trademark infringement should another party use an identical or similar mark in relation to identical or similar services.\n\n​\n\n38\n\n[Table of Contents](#TOC)\n\nTHE ENVIRONMENT\n\n​\n\nRyanair’s Environmental Policy commits the Group to what the Board and management believe are ambitious future environmental targets, building on impressive achievements to date, including commitments to address climate change, and the priorities and policies which will allow the Group to continue to lower CO2 emission intensity and noise pollution.\n\n​\n\nRyanair’s Environmental Strategy illustrates Ryanair’s commitment to managing its impact on the environment, with key targets and achievements including:\n\n​\n\nTargets\n\n●Achieving net carbon zero by 2050, as set out below;\n\n●Reduce CO2 per passenger/kilometer to c.50 grams by 2031, with this target conforming with the Science Based Targets Initiative’s (“SBTi”) aviation decarbonization pathway;\n\n●Power 12.5% of our flights with Sustainable Aviation Fuel (SAF) by 2030; and\n\n●Retain, or improve, the Group’s strong CDP climate protection rating (currently “A“).\n\n​\n\nAchievements\n\n●Becoming the first Airline Group to publish its CO2 statistics monthly in FY19;\n\n●Investing billions of euro in new fuel and noise efficient aircraft;\n\n●Commercial SAF partnerships with Enilive, Neste, OMV, Repsol and Shell;\n\n●Industry leading MSCI ‘A’ rating and CDP ‘A‘ rating;\n\n●Rated No.1 Large Cap global airline for ESG by Sustainalytics;\n\n●Extended our Sustainable Aviation Research Centre partnership with Trinity College Dublin to 2030; and\n\n●At least quarterly reporting to the Audit Committee and Board, to oversee delivery of ambitious environmental goals.\n\n​\n\nRyanair manages its impact on the environment and lowers CO2 emissions by operating a young fleet, achieving high load factors and efficient fuel burn. These enable Ryanair to minimize fuel and energy consumption and reduce noise pollution.\n\n​\n\nClimate Governance and Strategy\n\n​\n\nRyanair’s Board has ultimate oversight and responsibility of the Group’s climate transition plan, strategy in achieving sustainability goals and climate-related risks and opportunities. The Board and Audit Committee receive quarterly updates on Ryanair’s climate related risks and performance from the Chief Sustainability Officer and Group CFO.\n\n​\n\nClimate-related risks and opportunities are incorporated into the Ryanair Group's environmental policy. The Board reviews the environmental policy annually and receives quarterly updates on performance. Environmental opportunities and threats are factored into our financial and operational planning, including operational fuel efficiencies and regulatory impacts.\n\n​\n\nThese risks are identified through scenario analysis, horizon scanning and ongoing industry scrutiny. Key transitional risks are assessed and managed across the organization primarily through the enterprise risk management\n\n39\n\n[Table of Contents](#TOC)\n\nregister with upstream climate risks also raised to the Sustainability Committee. These risks include Market and Technology Shifts, Reputation, Policy, Legal and Physical Risks.\n\n​\n\nRyanair’s long-term strategy identifies climate change as a key area that will impact the business in coming years. Short and medium-term risks and opportunities are addressed on an ongoing basis by the Ryanair Sustainability Committee and Sustainability team who, ultimately, report back to the Board.\n\n​\n\nIn recent years, geopolitical events have disrupted existing supply and demand patterns of the energy market. Despite this disruption, movements towards a cleaner energy system have continued through advancements in European Union policies, including the “Fit for 55 package” and “REPowerEU”. High fossil fuel prices, as seen since the war in Ukraine began and the escalation of the conflict in the Middle East, present an opportunity to operate more efficiently and build momentum in energy transition to sustainable aviation fuels and fleet renewal through the Group’s 210 Boeing 737-8200 aircraft and the Group’s 300 Boeing 737 MAX-10 aircraft (150 firm and 150 options) order under the 2023 Boeing Agreement.\n\n​\n\nIn FY22, the Ryanair Group published its Pathway to Net Zero – a detailed plan on how the Group aims to achieve its emissions reductions. This pathway forms a key pillar of our ongoing Group strategy. Emission reductions will come from:\n\n●32% technological and operational improvements;\n\n●34% Sustainable Aviation Fuel;\n\n●10% Single European Sky initiative; and\n\n●24% carbon offsetting.\n\n​\n\nThe aviation industry conducted a feasibility study (“Destination 2050”) of reaching Net Zero emissions by 2050. This study demonstrates that reaching net zero emissions in aviation is possible. Key challenges are recognized in reaching these long-term goals (as detailed further in the below “Material transition risk related to climate change and consequences” section) most notably around the inability to obtain sufficient quantities of SAF.\n\n​\n\nRyanair recognizes that transition risk costs will arise in connection with the climate change transition. The Group has a history, as demonstrated through its recent aircraft orders, in maintaining a young, fuel efficient fleet and any breakthrough in new technology engines, will be procured as part of ongoing fleet renewal. Additionally, while sustainable aviation fuels currently trade at a premium of approximately 3x – 4x compared to normal jet kerosene, the long-term outlook is for price convergence and there are a number of policymaker decisions which are currently being reviewed which will aim to reduce the existing price divergence (e.g. government incentives to procure SAF, Emission Trading System reform legislation, etc.).\n\n​\n\nAny and all firm commitments regarding climate change transition are recognized within respective going concern or impairment assessments. There are no material litigation risks related to climate change currently identified.\n\n​\n\nCertain material transition risks related to climate change and consequences\n\n​\n\n●Inability to meet mandated SAF blending – could lead to increased cost for SAF or potential non-compliance penalties resulting in lower earnings.\n\n​\n\nRyanair has bi-lateral agreements in place with a number of SAF suppliers. These agreements allow Ryanair access to SAF at key airport locations. These agreements are in place with Enilive, OMV, Repsol and Shell. By using SAF, Greenhouse Gas (“GHG”) emissions will decrease which will reduce Emissions Trading System (“ETS”) and Carbon Offsetting and Reduction Scheme for International Aviation (“CORSIA”) compliance costs.\n\n40\n\n[Table of Contents](#TOC)\n\n●Increased consumer concern about climate change could lead to a reluctance to fly.\n\n​\n\nBy Ryanair positioning itself as a leader in the climate change agenda for aviation, there is an opportunity that passengers will switch to flying with Ryanair. There is an opportunity to enhance the Group reputation and brand value as a carbon efficient airline.\n\n​\n\n●Costs to transition to lower emissions technology could result in higher capital expenditure and lower earnings.\n\n​\n\nRyanair has had a long-standing strategy for fleet modernization supported with strong cash flows and access to capital markets. New technologies will be more fuel efficient, delivering ongoing operational cost savings, an example of which is Ryanair’s decision to retrofit its Boeing 737NG aircraft with split scimitar winglets, which provide an emission reduction benefit of approximately 1.5% and lower noise by approximately 6%.\n\n​\n\nCertain material physical risks related to climate change and consequences\n\n​\n\n●Increased severity of extreme weather events such as wild-fires, cyclones and floods could lead to operational disruption and potential revenue loss.\n\n​\n\nGroup assets are highly mobile and can be moved and are therefore not subject to acute risks associated with coastal flooding or tropical cyclones.\n\n​\n\n●Rising temperature and sea levels could potentially lead to lower revenue due to cancelled flights.\n\n​\n\nWeather conditions are closely monitored, with the Group flying predominantly intra-European routes which would be less affected by physical risks.\n\n​\n\nGOVERNMENT REGULATION\n\n​\n\nRegulatory Authorities\n\n​\n\nEU air carriers such as the Company and the Group Airlines are generally able to provide passenger services on domestic routes within any EU member state outside their home country, as well as between EU member states without restriction, subject to applicable EU and national regulations implemented by competent authorities, including the European Commission and EASA, as well as oversight by the European Organization for the Safety of Air Navigation (“Eurocontrol”). The Group Airlines are also subject to national regulation in their home countries, which is implemented primarily by (i) in Ireland, the Irish Aviation Authority (“IAA”) and the Department of Transport (“DoT”) in the case of Ryanair DAC, (ii) in Poland, the Polish Civil Aviation Authority (“Polish CAA”) in the case of Buzz, (iii) in Malta, Transport Malta and the Civil Aviation Directorate (“Maltese CAD”) in the case of Lauda Europe and Malta Air, and (iv) in the United Kingdom, the Civil Aviation Authority and the Department for Transport (“UK DfT”) in the case of Ryanair UK.\n\n​\n\nManagement believes that the present regulatory environment in the EU and in other markets the Company operates in is generally characterized by high sensitivity to safety and security issues, which is demonstrated by intensive reviews of safety-related procedures, training and equipment by the national and EU regulatory authorities. During the Covid-19 pandemic, various public health measures were imposed on airlines, including requirements in certain countries to verify passenger’s health documentation and, in certain cases, restrictions on the freedom to operate flights.\n\n41\n\n[Table of Contents](#TOC)\n\nIreland\n\n​\n\n*Irish Aviation Authority.*The IAA is primarily responsible for regulating the safety, security and technical aspects of aviation in Ireland. The IAA has broad regulatory and enforcement powers, including the authority to require reports and investigate and institute enforcement proceedings.\n\n​\n\nTo operate in the EU, an Irish air carrier is required to hold an AOC granted by the IAA attesting to the air carrier’s operational and technical competence to conduct airline services with specified types of aircraft. The IAA has broad authority to amend or revoke an AOC, with Ryanair’s ability to continue to hold its AOC being subject to ongoing compliance with current and future applicable statutes, rules and regulations pertaining to the airline industry. Ryanair DAC’s current AOC (No. IE 07/94) was issued by the IAA in January 2022.\n\n​\n\nEach aircraft operated by Ryanair DAC is required to have a Certificate of Airworthiness issued by the IAA. The validity of each Certificate of Airworthiness, and the Company’s Flight Operations Department, flight personnel, flight and emergency procedures, aircraft, and maintenance facilities are each subject to periodic review and inspections by the IAA.\n\n​\n\nUnder Ireland’s Air Navigation and Transport Act 2022, the air navigation service provision function of the IAA was transferred into a new corporate entity, AirNav Ireland, in May 2023, while the safety and security regulation functions of the IAA were retained within the IAA. The Act further provided for the dissolution of the Commission for Aviation Regulation (“CAR”) and the merger of its functions and responsibilities with the IAA, creating a single regulator for the civil aviation sector in Ireland, covering safety, security, economic and consumer regulation.\n\n​\n\nFollowing the dissolution of CAR and the merger of its functions with the IAA (which took place on April 30, 2023), the IAA is responsible for issuing operating licenses to air carriers registered in Ireland under EU Regulation 1008/2008. The criteria for granting an operating license include, inter alia, an air carrier’s financial fitness, the adequacy of its insurance and the fitness of its management. In addition, EU regulations require that (i) the air carrier must be owned, for the purposes of EU Regulation 1008/2008, and continue to be owned (directly or through majority ownership) by EU member states and/or EU nationals and (ii) the air carrier must at all times be effectively controlled by such EU member states or EU nationals. The IAA has broad authority to revoke an operating license. See “Item 10. Additional Information—Limitations on Share Ownership by Non-EU Nationals.” See also “Item 3. Key Information—Risk Factors—Risks Related to Ownership of the Company’s Ordinary Shares or ADSs—EU Rules impose restrictions on the ownership of Ryanair Holdings’ Ordinary Shares by Non-EU nationals” above.\n\n​\n\nRyanair’s current operating license (No 12/25) was issued by the IAA on October 23, 2025 and is subject to periodic review.\n\n​\n\n*Department of Transport*. The DoT is responsible for implementation of certain EU and Irish legislation and international standards relating to air transport.\n\n​\n\nMalta\n\n​\n\n*Maltese Civil Aviation Directorate*. The Maltese CAD is Malta's aviation regulator, assisting the Maltese Director General for Civil Aviation in fostering the development of civil aviation in Malta within a safety oversight system. The Maltese CAD is responsible for: the safety of aircraft, aircraft and aerodrome operators, air navigation service providers, licensing of aeronautical personnel and the conclusion of international air services agreements. To operate in the EU, a Maltese air carrier is required to hold an AOC granted by the Maltese CAD attesting to the air carrier’s operational and technical competence to conduct airline services with specified types of aircraft. The Maltese CAD has authority to amend or revoke the AOC, with Lauda Europe’s and Malta Air’s ability to continue to hold their respective AOCs being\n\n42\n\n[Table of Contents](#TOC)\n\nsubject to ongoing compliance with applicable statutes. Lauda Europe’s and Malta Air’s flight operations, aircraft, maintenance facilities and air crew are subject to ongoing review and inspections by the Maltese CAD.\n\n​\n\nThe Company’s subsidiary, Malta Air, obtained an AOC (No. MT-57) and operating license (No. (CAD/MT-57) from the Maltese CAD in June 2019.\n\n​\n\nThe Company’s subsidiary, Lauda Europe, obtained an AOC (No. MT-62) and operating license (No. (CAD/MT-62) from the Maltese CAD in September 2020.\n\n​\n\n*Transport Malta.* Transport Malta is a government body overseeing transport in Malta, including the work of the Maltese CAD. It is responsible for implementation of certain EU and Maltese legislation and international standards relating to air transport.\n\n​\n\nPoland\n\n​\n\n*Polish Civil Aviation Authority*. The Polish CAA is a government body and the civil aviation supervisory authority in Poland. Apart from certification and licensing of airlines, the Polish CAA performs operational and regulatory functions in all matters relating to qualifications of personnel, safety, security, as well as maintaining registers of aircraft, personnel and training entities, amongst others.\n\n​\n\nThe Company’s subsidiary Ryanair Sun S.A., operating as Buzz, obtained an AOC (No. PL-066) and operating license (No. ULC-LER-1/4000-0156/06/17) from the Polish CAA in April 2018.\n\n​\n\nUK\n\n​\n\n*UK Civil Aviation Authority*. The UK CAA is primarily responsible for ensuring safety standards, consumer protection, efficient use of airspace and security risks. A UK air carrier is required to hold an AOC granted by the UK CAA attesting to the air carrier’s operational and technical competence to conduct airline services with specified types of aircraft. The UK CAA has an authority to amend or revoke the AOC, with Ryanair UK’s ability to continue to hold its AOC being subject to ongoing compliance with applicable statutes. Ryanair UK’s flight operations, aircraft, maintenance facilities and air crew are subject to ongoing review and inspections by the UK CAA.\n\n​\n\nThe Company’s subsidiary, Ryanair UK, obtained an AOC (No. GB 2451) and an operating license (OL/A/624) from the UK CAA in December 2018.\n\n​\n\n*UK Department for Transport*. The UK DfT is responsible for implementation of certain UK legislation and international standards relating to air transport.\n\n​\n\nEuropean Union\n\n​\n\n*The European Union Aviation Safety Agency*. EASA is an agency of the EU that has been given specific regulatory and executive tasks in the field of aviation safety. The purpose of EASA is to draw-up common standards to ensure the highest levels of safety, oversee their uniform application across Europe and promote them at the global level.\n\n​\n\n*The European Organization for the Safety of Air Navigation*. Eurocontrol is an autonomous international organization established under the Eurocontrol Convention of December 13, 1960. Eurocontrol is responsible for, inter alia, the safety of air navigation and the collection of charges for air navigation services throughout Europe.\n\n​\n\n43\n\n[Table of Contents](#TOC)\n\nInternational agreements concerning Eurocontrol provide for the payment of charges to Eurocontrol in respect of air navigation services for aircraft in airspace under the control of Eurocontrol. The relevant legislation imposes liability for the payment of any charges upon the operators of the aircraft in respect of which services are provided and upon the owners of such aircraft or the managers of airports used by such aircraft. The Company’s airline subsidiaries, as aircraft operators, are primarily responsible for the payment to Eurocontrol of charges incurred in relation to their aircraft. The legislation also authorizes the detention of aircraft in the case of default in the payment of any charge for air navigation services by the aircraft operator or the aircraft owner, as the case may be. This power of detention extends to any equipment, stores or documents, which may be onboard the aircraft when it is detained and may result in the possible sale of the aircraft.\n\n​\n\n*European Commission.*The European Commission is the EU body with primary responsibility for the preparation of legislative proposals (for adoption by the European Parliament and the Council of the EU) and for the monitoring of the implementation of EU legislation by member states of the EU. The European Commission is also responsible for the enforcement of EU competition law and certain other laws.\n\n​\n\nThe European Commission has published guidelines on the financing of airports and start-up aid to airlines by regional airports that place restrictions on the incentives public airports can offer to airlines delivering traffic, when compared with the commercial freedom available to private airports.\n\n​\n\nThe European Union has adopted several legislative acts aimed at modernizing the EU’s air traffic control system, including the legislative package known as the “single European sky”, and its subsequent amendments “SES2” and “SES2+”. For example, EU Regulation 1070/09 (under “SES2”) focused on air traffic control performance, and extended the authority of EASA to include airports and air traffic management. The objective of the EU’s policy in this area is to enhance safety standards and the overall efficiency of air traffic control in Europe, as well as to reduce the cost of air traffic control services.\n\n​\n\nThe European Union has also adopted legislation on airport charges (EU Directive 2009/12), which was originally intended to address abusive pricing at monopoly airports. However, the legislation includes all European airports with over five million passengers per year. Management believes that the scope that exists within this Directive to address abuses of their dominant positions by Europe’s larger airports is very limited. See “Item 8. Financial Information—Other Financial Information—Legal Proceedings—EU State Aid-Related Proceedings.”\n\n​\n\nEU Regulation 1008/2008 grants EU airlines the freedom to set prices, reinforcing a principle that has underpinned the liberalized EU air transport market since the 1980s. However, in 2020 certain politicians in Austria and Italy called for the introduction of minimum prices on airline tickets, while the Italian government in 2023 passed a decree attempting to introduce a price cap on certain flights to Sicily and Sardinia, and in 2024 the Spanish government proposed a price cap on two routes from mainland Spain to Spanish islands. While none of these measures were ultimately implemented, it cannot be guaranteed that some form of government intervention in airline fares will not be introduced at a national or European level. If allowed to stand following judicial review, any such restriction would severely impact the Company’s ability to attract the most price sensitive consumers. EU Regulation 1008/2008 also sets out rules in respect of transparency of airline fares, requiring the inclusion of all mandatory taxes, fees, and charges in advertised prices. Ryanair includes this information in its advertised fares in all markets where it operates. While consumer benefits of the unbundling of airline services are widely acknowledged, some consumer law enforcement authorities have argued that certain optional price components should be included in advertised prices and/or that certain optional services should be considered mandatory, which, if implemented, would limit the Company’s commercial freedom.\n\n​\n\nThe European Union has also passed legislation governing the allocation and use of airport slots, a directive governing access to the ground handling market at EU airports, a directive on the terms of airlines’ participation in the\n\n44\n\n[Table of Contents](#TOC)\n\nEU Emissions Trading System, regulations on passenger rights and the rights of passengers with reduced mobility, and several other legislative acts affecting air transport, including matters of aviation security, noise, social security and sustainable aviation fuel.\n\n​\n\nRegistration of Aircraft\n\n​\n\nPursuant to the Irish Aviation Authority (Nationality and Registration of Aircraft) Order 2015 (the “Order”), the IAA regulates the registration of aircraft in Ireland. In order to be registered or continue to be registered in Ireland, an aircraft must be wholly owned by either (i) a citizen of Ireland or a citizen of another member state of the EU having a place of residence or business in Ireland or (ii) a company registered in and having a place of business in Ireland and having its principal place of business in Ireland or another member state of the EU and not less than two-thirds of the Directors of which are citizens of Ireland or of another member state of the EU. As of the date of this report, 10 out of 12 Directors of Ryanair Holdings are citizens of a member state of the EU.\n\n​\n\nThe Company’s aircraft operated by Lauda Europe and Malta Air are registered in Malta, the aircraft operated by Buzz are registered in Poland and the aircraft operated by Ryanair UK are registered in the UK. In each of these countries similar regulations apply to the registration of aircraft as those described above in relation to aircraft operated by Ryanair DAC, which are registered in Ireland.\n\n​\n\nRegulation of Competition\n\n​\n\n*Competition/Antitrust Law.*It is a general principle of EU competition law that no agreement may be concluded between two or more separate economic undertakings that prevents, restricts, or distorts competition in the common market or any part of the common market. Such an arrangement may nevertheless be exempted by the European Commission, on either an individual or category basis. The second general principle of EU competition law is that any business or businesses having a dominant position in the EU common market or any substantial part of the common market may not abuse such dominant position. Similar competition laws apply at national level in EU member states, as well as in the UK and other non-EU countries where the Company operates. Ryanair is subject to the application of the general rules of competition law as well as specific rules on competition in the airline sector.\n\n​\n\nAn aggrieved person may sue for breach of competition law in the courts of a member state and/or petition the European Commission or a national competition authority for an order to put an end to the breach of competition law. The European Commission and national competition authorities also may impose fines and daily penalties on businesses and the courts may award damages and other remedies (such as injunctions) in appropriate circumstances.\n\n​\n\nCompetition law in Ireland is primarily embodied in the Competition Acts 2002 to 2022. This legislation is modelled on the EU competition law system. The Irish rules generally prohibit anti-competitive arrangements among businesses and prohibit the abuse of a dominant position. These rules are enforced either by public enforcement (primarily by the Competition and Consumer Protection Commission) through both criminal and civil sanctions or by private action in the courts. These rules apply to the airline sector but are subject to EU rules that override any contrary provisions of Irish competition law.\n\n​\n\nIn December 2022, the AGCM launched an investigation into alleged illegal price coordination between airlines, including Ryanair, on routes between mainland Italy and Sicily during the Christmas period. The investigation was closed in late 2023 with no finding of infringement. The AGCM subsequently launched a review of the use of pricing algorithms by airlines on certain domestic Italian routes. The AGCM issued a final decision in December 2025, which found no specific issues on these routes related to the use of algorithms.  \n\n​\n\n45\n\n[Table of Contents](#TOC)\n\nIn September 2023, the AGCM launched an investigation into alleged abuse of dominance by Ryanair in its dealings with online and offline “bricks and mortar” travel agents in Italy. In the context of this investigation, in April 2024 the AGCM started interim proceedings to determine whether there exists a risk of irreparable damage to competition during the time required for completing the main investigation, unless interim measures are imposed on Ryanair. The AGCM closed these interim proceedings in May 2024, concluding that there was no basis for the adoption of precautionary measures pending the outcome of the main investigation. In February 2025, the AGCM alleged that certain of Ryanair’s responses to the AGCM’s questions have been incomplete. While Ryanair disagrees strongly with this allegation, the AGCM in July 2025 imposed a fine of approximately €1.3m on Ryanair, which Ryanair has appealed to the Administrative Tribunal of Lazio. The AGCM issued a Statement of Objections to Ryanair in October 2025 outlining the case team’s theory on why it believed Ryanair was in breach of competition law, following which Ryanair responded in writing and attended a hearing of the AGCM Board in December 2025. The AGCM Board issued a decision in December 2025 finding that Ryanair had abused a dominant position in its dealings with OTAs and bricks & mortar travel agents between April 2023 and April 2025, and fining Ryanair €256m. Ryanair believes there is no merit in this decision and has filed an appeal to the Administrative Tribunal of Lazio with reference to, amongst others, case law supporting its current distribution model, including January 2024 rulings of the Court of Appeal of Milan in cases brought by OTAs Lastminute and Viaggiare, which found that Ryanair’s direct distribution model benefited consumers and did not entail an abuse of a dominant position. The Italian court appeals will likely take up to three years to be resolved. Ryanair intends to bring to the attention of the courts the May 2026 ruling by the Italian Council of State on Ryanair’s appeal of the AGCM’s decision concerning refunds to passengers and a promotion during Covid, in which the Council of State found that the AGCM had discriminated against Ryanair (relative to other airlines) during the investigation, and which overturned the €4.2m fine imposed by the AGCM on Ryanair.\n\n​\n\nCertain operators of screenscraping websites have alleged in court proceedings that Ryanair’s objection to the unauthorized selling of its flight tickets by online travel agents to consumers is an attempt to restrict competition. Ryanair is vigorously defending such claims and welcomed the withdrawal by On the Beach of its action in UK courts and Lastminute’s withdrawal of its action in Italian courts in 2024. See “Item 3. Key Information—Risk Factors—Risks Related to the Company—The Company faces risks related to unauthorized use of information from the Company’s website”. See also “Item 3. Key Information—Risk Factors—Risks Related to the Company—The Company faces risks related to allegations of non-compliance with competition law”.\n\n​\n\n*State Aid.*EU law sets conditions on which State aid may be granted by EU member states to businesses. The EU Treaty prevents member states from granting such aid unless approved in advance by the EU. Any such grant of State aid to an airline is subject to challenge before the European Commission or, in certain circumstances, national courts. If aid is held to have been unlawfully granted it may have to be repaid by the airline to the granting member state, together with interest thereon. Under the terms of the EU—UK TCA, the UK has introduced a new subsidy control regime to prevent distortions of competition between the UK and the EU. See “Item 3. Key Information—Risk Factors—Risks Related to the Company—The Company is subject to legal proceedings alleging State aid at certain airports” and “Item 8. Financial Information—Other Financial Information—Legal Proceedings.”\n\n​\n\nData Protection\n\n​\n\nRyanair’s processing of personal data is subject to increasingly complex data protection laws including the EU’s GDPR as well as relevant national implementing legislation (Irish Data Protection Act 2018). The GDPR is directly applicable across the member states of the EU and an equivalent data protection regime operates in the UK post-Brexit (the European Commission has considered the UK regime to be adequate by way of the ‘adequacy decision’ adopted on June 28, 2021). The GDPR imposes strict obligations on companies which process personal data, including requirements to implement appropriate security measures to ensure that processing, storing, and transferring of personal data is done in accordance with the key data protection principles contained in the GDPR. There is an obligation to report data breaches which are likely to result in a risk to the rights and freedoms of natural persons (and in some\n\n46\n\n[Table of Contents](#TOC)\n\ninstances an obligation to inform the data subjects) within stipulated timeframes. The GDPR also provides data subjects with enhanced rights in respect of their personal data, such as the “right to be forgotten” (to be erased from the databases of organizations holding their personal data, including erased from third party providers’ databases, provided there are no legitimate grounds for retaining the personal data) and the right to “data portability” (the right to receive the personal data concerning the data subject in a structured and commonly used and machine-readable format and to transmit that data to a nominated third party).\n\n​\n\nA breach of the GDPR may result in the imposition of fines by supervisory authorities up to €20m or 4% of annual group-wide turnover (whichever is higher). Supervisory authorities also have the power to audit businesses and require measures to be taken by businesses to rectify any non-compliance (which can include orders to suspend data processing activities). Additionally, data subjects are entitled to seek compensation for any damage (including non-material damage) suffered in the event that the processing of their personal data is in breach of the GDPR’s requirements. See “Item 3. Key Information—Risk Factors—Risks Related to the Company—Ryanair is subject to increasingly complex data protection laws and regulations” and “Item 8. Financial Information—Other Financial Information—Legal Proceedings—Data Protection Commission Inquiry”.\n\n​\n\nConsumer Protection\n\n​\n\nRyanair operates under stringent consumer protection laws. Despite diligent efforts to ensure full compliance, there is a possibility that government bodies or other entities might claim non-compliance with these laws by Ryanair. Certain authorities across Ryanair’s network have the power to conduct audits and demand corrective actions for any non-compliance. A significant breach by Ryanair of consumer laws could lead to authorities imposing fines of up to 10% of the annual group-wide turnover, or the issuing of strict compliance orders. Furthermore, consumers have the right to seek damages for any harm caused by a breach of their consumer rights and may also be represented in collective redress or class actions. Such cases, whether individually or collectively, could materially and adversely affect the Company's financial condition and operational results. See “Item 3. Key Information—Risk Factors—Risks Related to the Company—The Company is subject to increasingly strict sanctions for non-compliance with consumer protection laws”.\n\n​\n\nEnvironmental Regulation\n\n​\n\n*Aircraft Noise Regulations.*Ryanair is subject to international, national and, in some cases, local noise regulation standards. EU and Irish regulations have required that all aircraft operated by Ryanair comply with Stage 3 noise requirements. All of Ryanair’s aircraft currently comply with these regulations. Many airports in Ryanair’s network (including Amsterdam, Dublin, London Gatwick, London Stansted and Rome Ciampino) have established local noise restrictions, including limits on the number of hourly or daily operations or the time of such operations.\n\n​\n\n*Company Facilities.*The Company maintains facilities across its network, including engineering facilities at the airports in Bergamo, Dublin, Frankfurt (Hahn), Glasgow (Prestwick), Kaunas, London (Stansted), Madrid, Malta, Nuremberg, Porto, Seville, Shannon, Vienna and Wroclaw. Planning permissions for Company facilities have been obtained in accordance with local requirements and management of noxious or potentially toxic substances as well as of waste removal is conducted in adherence to applicable local, national and EU regulations.\n\n​\n\n*Ryanair’s Policy on Noise and Emissions.*Ryanair is committed to reducing emissions and noise through investments in new, efficient aircraft and engine technologies and the implementation of certain operational and commercial decisions to minimize the environmental impact of its operations. The Company is constantly working towards improving its environmental performance and in December 2025, its Leadership Level ‘A-’ rating was upgraded to ‘A’ by CDP – an international non-profit that helps organizations to disclose their environmental impact.\n\n​\n\n47\n\n[Table of Contents](#TOC)\n\nIn December 2005, Ryanair completed the fleet replacement program it commenced in 1999. All of Ryanair’s older Boeing 737-200A aircraft were replaced with Boeing 737-800 “Next Generation” (“NG”) aircraft. The design of these aircraft is aimed at minimizing drag, thereby reducing the rate of fuel burn and noise levels. The engines are also quieter and more fuel-efficient. The Boeing 737NG aircraft have a significantly superior fuel-burn to passenger-kilometer ratio than Ryanair’s former fleet of Boeing 737-200A aircraft. Ryanair has installed winglets on all of its Boeing 737NG aircraft. Winglets reduce both the rate of fuel burn and carbon dioxide emissions by approximately 4%, and also reduce noise emissions. In FY23, Ryanair began to retro-fit scimitar winglets on the Boeing 737NG fleet. This retro-fit program (which is expected to be completed in FY27) further reduces fuel burn of these aircraft by approximately 1.5% and noise by approximately 6%.\n\n​\n\nIn September 2014, Ryanair entered into an agreement with Boeing to purchase up to 200 Boeing 737-8200 “Gamechanger” aircraft (including 100 firm orders and 100 aircraft subject to option). The contract was approved by the shareholders of the Company at an extraordinary general meeting (“EGM”) in November 2014. In June 2017, the Group agreed to purchase an additional 10 Boeing 737-8200 aircraft. In April 2018, the Company announced that it had converted 25 Boeing 737-8200 options into firm orders. In December 2020, the Company announced that it had converted the remaining 75 options to firm orders. This brought the Company’s firm order to 210 Boeing 737-8200s with a total contract value of approximately U.S.$9.6bn at standard list price of U.S.$102.5m per aircraft (net of basic credits and reflective of price escalation over the originally scheduled delivery timeframe). These aircraft have 197 seats and are fitted with CFM-LEAP-1B engines which, combined with the Advanced Technology winglet and other aerodynamic improvements, reduce fuel consumption by up to approximately 16% on a per seat basis compared to the Boeing 737NGs in Ryanair’s configuration and reduce operational noise emissions by up to 50%. All of these aircraft were delivered at March 31, 2026. See “—Aircraft” above for details on Ryanair’s fleet plan.\n\n​\n\nIn May 2023, Ryanair signed an agreement with Boeing to purchase up to 300 Boeing 737 MAX-10 aircraft (including 150 firm orders and 150 aircraft subject to option) for delivery between 2027 and 2033. This agreement was approved by Shareholders at the Company’s 2023 AGM. These aircraft have 228 seats and are fitted with CFM-LEAP-1B engines, which reduce fuel consumption by up to approximately 20% compared to the Boeing 737NG and reduce noise emissions by approximately 50%. It is expected that up to 50% of this order will replace older aircraft in the fleet (including lease handbacks), while the remainder will facilitate disciplined traffic growth to approximately 300m passengers per annum by FY34.\n\n​\n\nIn addition, Ryanair has distinctive operational characteristics that management believes help reduce the Company’s impact on the environment. In particular, Ryanair:\n\n​\n\n●operates with a high seat density of 189 seats on the Boeing 737NG and 197 seats on the Boeing 737-8200 aircraft. This is in contrast to the 162 seats and two-class configuration of the Boeing 737-800 aircraft used by traditional network airlines, reducing fuel burn and emissions per passenger-kilometer. The Lauda A320 fleet has a high density of 180 seats;\n\n●has reduced per passenger-kilometer emissions through high load factors (94% in FY26);\n\n●achieves quick turn-around times, thus reducing fuel burn and emissions when aircraft are on the ground;\n\n●provides direct services as opposed to connecting flights, in order to limit the need for passengers to transfer at main hubs and thus reduces the number of take-offs and landings per journey from four to two, reducing fuel burn and emissions per journey; and\n\n●has minimal scheduled late-night departures of aircraft, reducing the impact of noise emissions.\n\n​\n\nIn 2021, a law was passed in France prohibiting domestic flights where an alternative direct train service operates in under 2.5 hours, with an exception made for connecting flights. The European Commission found this distorted competition between point-to-point carriers and network operators. Consequently, France amended the law to remove this exemption for connecting flights. The new formulation of the law de facto means that only 3 routes to Paris\n\n48\n\n[Table of Contents](#TOC)\n\nOrly airport (where the Company does not operate) are affected. The European Commission approved this law in December 2022. It entered into force in May 2023 for a period of three years. Ryanair does not believe that any such measures can in fact make a significant contribution to reducing aviation’s environmental impact given that over half of all emissions from European aviation come from long-haul flights (which account for just a few percent of total European flights) and has argued that policy-makers should instead focus on measures that discourage connecting flights, the most environmentally inefficient form of air travel. A widespread introduction of bans on short-haul flights could have a negative impact on the Company’s results and operations.\n\n​\n\n*“Fit for 55”.* The Company engages with European decision makers to support a fair green transition of the aviation sector. Among the measures included in the “Fit for 55” package, we welcome the legislation to increase the use of SAF and engaged relevant stakeholders to stress the importance of using sustainable fuels to cut the sector’s carbon footprint. We have highlighted the limited environmental benefit and the harmful consequences for the EU economy and connectivity resulting from other elements of the package, e.g., a kerosene tax that applies only to intra-EU flights. In May 2023, the revision of the EU ETS Directive for aviation, as agreed by the European Parliament and the Council of the European Union, was published in the EU Official Journal, and applies the ETS exclusively to intra-EEA flights until at least 2027. It is expected that by July 2026, the European Commission will have assessed and reviewed the geographic scope of the ETS with the view potentially to including long-haul flights within the scope.\n\n​\n\n*Emissions Trading.* In November 2008, the European Union adopted legislation to add aviation to the EU ETS as of 2012. This scheme, which had previously applied mainly to energy producers, is a cap-and-trade system for CO2 emissions to encourage industries to improve their CO2 efficiency. Under the legislation, airlines were granted initial free CO2 allowances based on historical “revenue tonne kilometres” and a CO2 efficiency benchmark. Any shortage of allowances has to be purchased in the open market and/or at government auctions. Management believes that this legislation has a negative impact on the European airline industry as it does not sufficiently promote environmentally efficient growth. The free CO2 allowances were phased out between 2024 and early 2026, which significantly increased the cost of compliance by the Company with the ETS.\n\n​\n\nIn January 2021, a UK ETS replaced the UK’s participation in the EU ETS (in principle covering UK domestic flights and flights from the UK to the EU, while EU ETS still applies on flights from the EU to the UK, regardless of the nationality of the operating carrier). This scheme contains many consistent features with the concurrent EU ETS. Airlines have been granted allowances under the scheme with a subsequent deduction in allocated free EU ETS allowances. These were distributed in proportion to UK ETS activity based on historical “revenue tonne kilometres”. The UK has announced it plans to phase out the free CO2 allowances from 2026.\n\n​\n\n*Carbon Offsetting.*In October 2016, the CORSIA (Carbon Offsetting and Reduction Scheme for International Aviation) agreement was agreed between 191 ICAO countries. The CORSIA scheme uses market-based environmental policy instruments (carbon credits) to offset CO2 emissions above the 2019 levels, starting from 2021 to 2023, and above 85% of 2019 levels from 2024 to 2035. The scheme is voluntary for ICAO countries until 2026. As of May 2026, 130 out of 191 countries decided to participate.\n\n​\n\n*Aviation Taxes.* Ryanair is fundamentally opposed to the introduction of additional aviation taxes, including new environmental taxes, fuel taxes or emissions levies. Ryanair has offered, and continues to offer, among the lowest fares in Europe, to make passenger air travel affordable and accessible to European consumers. Ryanair remitted over €1.6bn in various environmental taxes in FY26 up from over €1.5bn in FY25 (and approximately €1.2bn in FY24). Ryanair believes that the imposition of additional taxes on airlines will not only increase airfares, but will discourage new entrants into the market, resulting in less choice for consumers. Ryanair believes this would ultimately have adverse effects on the European economy in general.\n\n​\n\n49\n\n[Table of Contents](#TOC)\n\nAs a company, Ryanair believes in free market competition and that aviation taxation distorts competition by favoring the less efficient flag carriers which generally have smaller and older aircraft, lower load factors, which offer connecting flights and operate primarily into congested airports, and which, as a result, have a much higher fuel burn per passenger. Furthermore, the introduction of a tax at a European level only, such as that proposed under the Energy Taxation Directive (“ETD”), would distort competition between airlines operating solely within Europe and those operating also long-haul flights to and from Europe.\n\n​\n\nAirport charges\n\n​\n\nThe EU Airport Charges Directive of March 2009 sets forth general principles that are to be followed by airports with more than 5m passengers per annum and airports with the highest passenger movement in each Member State, when setting airport charges, and provides for an appeals procedure for airlines in the event that they are not satisfied with the level of charges. However, Ryanair does not believe that this procedure is effective or that it constrains those airports that are currently abusing their dominant position, in part because the legislation was transposed improperly in certain countries, such as Ireland and Spain, thereby depriving airlines of even the basic safeguards provided for in the Directive. This legislation may in fact lead to higher airport charges, depending on how its provisions are applied by EU member states and subsequently by the courts.\n\n​\n\nSlots\n\n​\n\nCurrently, many of Ryanair Group’s airports have no “slot” allocation restrictions; however, a substantial number of the airports the Ryanair Group airlines serve, including its primary bases, are regulated by means of “slot” allocations, which represent authorizations to take off or land at a particular airport within a specified time period. EU law regulates the acquisition, transfer and loss of slots. Under EU Regulation No. 793/2004, slots may be transferred from one route to another by the same carrier, transferred within a group or as part of a change of control of a carrier, or swapped between carriers. In April 2008, the European Commission issued a communication on the application of the slot regulation, signaling the acceptance of secondary trading of airport slots between airlines. This was intended to allow more flexibility and mobility in the use of slots and further enhance possibilities for market entry at slot constrained airports. Any future legislation that might create an official secondary market for slots could create a potential source of revenue for certain of Ryanair’s current and potential competitors, many of which have many more slots allocated at primary airports at present than Ryanair. The European Commission proposed a revision to the slots legislation reflecting the principle of secondary trading. This revision has been negotiated by the EU institutions since 2014 and is currently stalled. Slot values depend on several factors, including the airport, time of day covered, the availability of slots and the class of aircraft. Ryanair’s ability to gain access to and develop its operations at slot-controlled airports will be affected by the availability of slots for takeoffs and landings at these specific airports. New entrants to an airport are currently given certain privileges in terms of obtaining slots, but such privileges are subject to the grandfathered rights of existing operators that are utilizing their slots. In March 2020, the European Union suspended the “80/20 use it or lose it” rule for the IATA summer season 2020 due to the Covid-19 pandemic. The “80/20” rule provides that an airline is entitled to the same slot in the next equivalent scheduling period if it has used the allocated slot 80% of the time. The suspension of the “80/20” rule had been phased out and the rule was fully restored from the IATA summer season 2023. In May 2026, citing potential fuel cost increases related to the blockade of the Strait of Hormuz, the UK government introduced an alleviation of the “80/20” rule for the IATA summer and winter seasons 2026, which enables airlines to protect historic rights over up to 10% of their slots even if the “80/20” rule is not met, provided that certain other conditions are satisfied. There is no assurance that the Ryanair Group will be able to obtain a sufficient number of slots at the slot-controlled airports that it desires to serve in the future at the time it needs them or on acceptable terms.\n\n​\n\n​\n\n50\n\n[Table of Contents](#TOC)\n\nPublic Procurement\n\n​\n\nThe Company is subject to public procurement laws. Despite diligent efforts to ensure full compliance, there is a possibility that government bodies or other entities might claim non-compliance with these laws by Ryanair. A significant breach by Ryanair of public procurement laws could lead to authorities imposing substantial fines or other orders, including criminal sanctions. Such cases, whether individually or collectively, could materially and adversely affect the Company's financial condition and operational results.\n\n​\n\nOther\n\n​\n\nThe Company now operates under local employment law in all major markets, crew are employed under local contracts of employment and the Company complies with all local legislation and regulations in the applicable jurisdiction, including occupational health and safety.\n\n​\n\nDESCRIPTION OF PROPERTY\n\n​\n\nFor certain information about each of the Company’s key facilities, see “—Facilities” above. Management believes that the Company’s facilities are suitable for its needs and are well maintained.\n\n​"}