We are working closely with the Department for Transport and the industry on the expansion of capacity at Heathrow airport. We need to ensure that we develop regulatory arrangements that deal with the associated challenges, and supports capacity expansion in a timely and efficient and effective way, which furthers the interests of consumers.
Early costs of capacity expansion
CAP3201 Proposals on regulatory treatment, December 2025
This consultation (CAP3201) sets out our proposals for the recovery of early costs associated with capacity expansion. These are costs incurred by potential promoters before the Government takes a decision on whether to grant a Development Consent Order for capacity expansion at Heathrow airport. These proposals aim to provide an appropriate level of clarity and certainty for HAL on the recovery of early costs incurred in 2025 and 2026. It also further clarifies our position on other potential promoters that provided credible and appropriately mature proposals in response to the Government’s July 2025 deadline.
Supporting documents:
- Letter from Yann Cambier, IAG, to Stewart Carter, CAA, 26 September 2025 - "Update on the regulatory treatment of the early costs of capacity expansion at Heathrow airport"
- Letter from Heathrow Airport Limited (HAL) to Selina Chadha, CAA, 17 October 2025 - "Heathrow Response to CAP3173 - Update on the regulatory treatment of early costs of capacity expansion at Heathrow Airport"
- Document: "Response to the CAA on Property", 29 October 2025
- Letter from Raghbir S. Pattar, IAG, to Seline Chadha, CAA, 28 November 2025 - "Opposition to Request for Early Expansion Cost Recovery"
- Letter from Mike King, HAL, to Stewart Carter, CAA, 9 December 2025 - "...updates to the view of early costs we set out in our submission in July"
CAP3173 Update on regulatory treatment, September 2025
This document (CAP3173) provides an update on the regulatory policy on the recovery of early expansion costs incurred by potential promoters before the Government takes a decision on whether to grant a Development Consent Order for capacity expansion at Heathrow airport
CAP3149 Consultation on regulatory policy, August 2025
In CAP3149, we are consulting interested parties on the regulatory policy on the recovery of early expansion costs incurred by potential developers before the Government takes a decision on whether to grant a Development Consent Order for capacity expansion at Heathrow airport.
The following documents and letters provide supporting information that we have used in the consultation. HAL and the Arora Group have provided their consent for us to publish these documents.
- Letter from Carlton Brown to Selina Chadha, 4 July 2025 – “Third runway expansion plan at London Heathrow Airport – cost recovery”
- Letter from Andrew Walker to Carlton Brown, 21 July 2025 – “Re: Third runway expansion plan at London Heathrow Airport – cost recovery”
- Letter from Ross Baker to Selina Chadha, 26 June 2025 – “Early costs for expanding Heathrow”
- Letter from Selina Chadha to Ross Baker, 14 July 2025 – “Re: Early costs for expanding Heathrow”
- Letter from Ross Baker to Selina Chadha, 17 July 2025 – “Early costs for expanding Heathrow”
- Letter from Andrew Walker to Ross Baker, 22 July 2025 – “Early costs for expanding Heathrow”
- Letter from Mike King to Andrew Walker, 31 July 2025 – “Heathrow application to increase the H7 capex allowance”
Responses to CAP3149
- Airlines for America
- Arora
- British Airways
- Council for the Independent Scrutiny of Heathrow Airport
- Heathrow Airport Limited
- Heathrow AOC Limited
- Heathrow Strategic Planning Group
- International Airlines Group
Regulatory models
CAP3195 Working paper, November 2025
This document (CAP3195) is a working paper for consultation on our review of regulatory models and sets out:
- the case for changing the current regulatory framework at Heathrow airport;
- a framework for evaluating whether different regulatory models would be likely to further the interest of consumers; and
- a “long-list” of possible alternative regulatory models and how these models might, in principle, apply to capacity expansion at Heathrow airport.
Supporting documents:
- CAP3195A - Data for charts presented in CAP3195 document
- CAP3195B - Steer - Capex Benchmark of terminal building projects
- CAP3195C - Fundamental reform of Heathrow: Securing the right long-term model for passengers, airlines and the UK economy
- CAP3195D - Jacobs - Review of Airport Charges Bespoke Analysis
- CAP3195E - Fundamental reform of Heathrow: To comprehensively address the failings with the current model of economic regulation at Heathrow
- CAP3195F - Fundamental reform of Heathrow: Discussion about examples of potential reform options
- CAP3195G - Fundamental reform of Heathrow: Case for change - Presentation of why HAL’s claims, arguments and commissioned reports should be disregarded
- CAP3195H - Final Lotus Report. Note: Notwithstanding the confidential classification of the document, the CAA has received consent from Heathrow Airport Limited and the authors of the report to publish the report in its current form.
Responses
- Aer Lingus
- Air Canada
- Airline Community
- Airlines UK
- Airlines for America UK
- AFKL
- British Airways
- BusinessLDN
- CISHA HPF
- easyJet
- Emirates
- Green Impact Heathrow Airport’s Expanding Capital Expenditure Plans
- Heathrow Airport response
- 01. Megaproject outcome drivers Benchmarking fact base
- 02. Financeability Analysis of CAA Regulatory Models - Santander Freshfields
- 03. Case study evaluation of regulatory models and criteria set out in CAP3195
- 05. Capex Benchmark of Terminal Building projects - Steer
- 07. H7 Capex Delivery Obligations Framework - Lessons Learnt
- 07.1. H7 Capex Delivery Obligations Framework - Lessons Learnt - KPMG_Transmittal Letter
- 08. Cost of Capex Delivery
- 08.1. Cost of Capex Delivery - KPMG _ Transmittal Letter
- 10. Funding and Expanded Heathrow - Santander & Freshfields
- 12. Data Annex
- 14. Heathrow Expansion Capital Governance
- 15. Multi-Operator Airports - Mott MacDonald
- Heathrow Reimagined response to the CAA’s November 2025 Working Paper
- Heathrow Southern Railway
- HWL
- IATA
- IAG response
- Japan Airlines
- KM Malta airlines
- LCCI
- LH Group
- Logistics UK
- Make UK
- OGP Heathrow Critique Report
- OCP Heathrow Benchmark Report
- QF
- Star Alliance
- Singapore Airlines
- TfL
Scope and process
CAP3144 Statement on scope and process, July 2025
We published CAP3144 to set out the scope and process for our review of the regulatory approach to capacity expansion at Heathrow airport.