Aena S.M.E., S.A. (AENA.MC) - Deep Dive Research Report

Prepared 25 June 2026. All figures in euros unless stated. No valuation or price data is included by design.

1. What the Company Does

Aena runs airports. Specifically, it owns and operates the entire network of large commercial airports in Spain - 46 airports plus two heliports - under a single integrated licence, and it has bolted on a growing portfolio of airports abroad. When a passenger flies into Madrid-Barajas, Barcelona-El Prat, Palma de Mallorca, Málaga, Alicante, or any of the Canary and Balearic island airports, they are walking through an Aena building, and almost every euro spent inside it - the landing fee the airline pays, the duty-free perfume, the airport parking, the bottle of water at the gate, the rent the car-rental desk pays - flows back to Aena.

The business has two engines bolted together. The first is a regulated utility: airlines pay Aena a set of charges (per departing passenger, per landing, for aircraft parking, for security) that are capped by a five-year regulatory contract negotiated with the Spanish government. This is a low-risk, inflation-and-traffic-linked annuity. The second is an unregulated real-estate-and-retail landlord: Aena leases terminal floor space and airport land to duty-free operators, restaurants, shops, lounges, advertisers, logistics firms and car parks. The genius of the model is that the regulated engine guarantees the footfall - a captive, affluent, time-rich crowd of travellers - and the unregulated engine monetises it at high margin. Group EBITDA margin sits near 59 percent, among the highest of any large airport operator on earth.

Aena was carved out of Spain's state air-navigation body and floated on the Madrid exchange in February 2015 in what was then the largest IPO in Spanish history. The state never let go: through the holding company ENAIRE, the Spanish government retains 51 percent and therefore control. The remaining 49 percent trades freely and is held by global institutions (BlackRock, Norges Bank, and historically the activist fund TCI). This 51/49 split is the single most important fact about Aena. It is simultaneously a publicly traded, dividend-paying, profit-maximising company and an instrument of Spanish state infrastructure and tourism policy. The same government that collects 51 percent of the dividend also sets, through the CNMC regulator and the Council of Ministers, the airport charges Aena is allowed to levy. That tension runs through everything.

A concrete walk-through. A Ryanair flight from Manchester lands at Palma de Mallorca. Ryanair pays Aena a landing fee based on aircraft weight and a per-passenger charge for every traveller who walked aboard at origin and every one who disembarks. Aena's security staff (a regulated cost) screen them. The passenger then has two hours before a connection: they buy a coffee (Aena's tenant pays Aena a percentage of sales plus a guaranteed minimum rent), browse the duty-free (same structure, Aena's single largest commercial contract category), and if they drove to the airport at the other end, they paid Aena for parking. Multiply that by roughly 320 million passengers a year across the Spanish network and you have the business.

"Uncertainty is, in my opinion, at the highest levels that I have seen in my career." - CFO Ignacio Castejón, Q1 2026 call (29 April 2026), explaining why Aena withdrew its 2026 traffic forecast. The line captures the paradox of the business: an extraordinarily stable cash machine sitting on top of an extraordinarily volatile input - human willingness to fly.

2. Business Segments

Aena reports along four lines: Aeronautical, Commercial, Real Estate Services, and International. The first three describe the Spanish regulated network; the fourth is everything outside Spain.

Aeronautical (~50% of revenue)

This is the regulated core. Revenue comes from charges levied on airlines and passengers: the per-departing-passenger charge (the largest single line), landing fees scaled by aircraft weight, aircraft parking, passenger-boarding-bridge use, security, and handling-related charges. These tariffs are not set by Aena at will. They are governed by the DORA (Documento de Regulación Aeroportuaria), a five-year regulated contract that fixes the maximum allowed revenue per passenger and the investment Aena must make. The current DORA II runs 2022-2026; the 2026 maximum charge is around €11.03 per passenger, with the CNMC having approved a 1.1 percent increase for the year.

The core capability here is not commercial - it is operating one of the world's busiest, safest, most weather-and-tourism-peaked airport systems at scale. Madrid and Barcelona are top-tier European hubs; the island airports absorb enormous summer surges. The segment's economics are a near-pure annuity: traffic times a regulated price, with costs that are largely fixed. Its strategic role is to be the stable, predictable foundation - the part of the business a bond investor would love. Where it loses is on pricing power: by design Aena cannot raise charges freely, and Spanish airport charges are deliberately kept among the lowest in major European countries to support the tourism economy.

Commercial (~31% of revenue)

This is the margin engine and the part management is proudest of. Aena is, functionally, one of the largest retail-and-hospitality landlords in Spain. It tenders concessions for duty-free (its biggest category), food and beverage, specialty shops, car parks, VIP lounges, advertising, car rental and banking/currency. The structure is typically a percentage of the tenant's sales subject to a Minimum Annual Guaranteed (MAG) rent - so Aena captures the upside of booming travel spend while protecting a floor.

The core capability is running competitive tenders that extract rising guaranteed rents from operators desperate for access to a captive, high-spending audience. In Q3 2025 management disclosed that newly awarded specialty-shop tenders locked in minimum guaranteed rents 33 percent and 40 percent higher (for 2025 and 2026) than 2024 levels, with food-and-beverage equivalents up 19 and 20 percent. VIP-lounge revenue jumped 31.5 percent year-on-year in Q1 2026. This segment exists separately because its economics (high-margin, growth-linked, unregulated) and its skill set (retail leasing, not air-traffic operations) are entirely different from aeronautical. It is the cash compounder sitting on top of the regulated annuity.

Real Estate Services (~2-3% of revenue)

The smallest segment, but a long-dated option. Aena leases airport-adjacent land and buildings: cargo terminals, logistics warehouses, hangars, offices and fuel facilities. The flagship effort is the Airport City programme (Ciudad Aeroportuaria) at Madrid and Barcelona, where Aena is developing large land banks into logistics, business and real-estate parks. It is small today but capital-light relative to its potential and gives Aena a way to monetise the vast acreage it controls around its hubs. Strategically it is a slow-burn growth option, not a current driver.

International (~16% of revenue)

Everything outside Spain, run through Aena Internacional and Aena Brasil. The portfolio includes London Luton in the UK; a large and growing Brazilian footprint (the Northeast block, the São Paulo Congonhas / Block group, and the recently won Rio de Janeiro Galeão concession); a stake in Mexico's Grupo Aeroportuario del Pacífico; airports in Colombia (including Cartagena); and Jamaica (Montego Bay, Kingston). In December 2025 Aena agreed to buy 51 percent of a holding company owning 100 percent of Leeds Bradford and 49 percent of Newcastle for £270 million, expanding the UK platform.

The core capability is exporting the integrated aero-plus-commercial operating model into concession markets - winning long-dated concessions at auction and lifting their commercial yield. Brazil is the standout: the ANB (Northeast) block recovered to 116 percent of 2019 traffic, and Luton's EBITDA margin reached 53.6 percent. This segment exists separately because it carries different risk (FX, concession-renewal, country risk) and is the company's primary growth bet now that the Spanish network is mature. Management frames it as the engine that diversifies Aena beyond a single regulated country.

3. Products and Business Detail

Aena's "products" are airports and the services sold inside them. The catalogue runs from the runway to the retail aisle.

The regulated air-side service. Aena provides runway, taxiway, apron, terminal, security screening, boarding bridges and aircraft parking. The network spans 46 Spanish airports and two heliports (Ceuta and Algeciras). It is wildly unequal: a handful of airports (Madrid-Barajas, Barcelona-El Prat, Palma, Málaga, Gran Canaria, Tenerife South, Alicante) carry the overwhelming majority of traffic, while many regional airports are sub-scale and exist partly for territorial-cohesion reasons. Operating the loss-making small airports inside the same regulated network as the cash-gushing big ones is part of the political bargain of the licence - cross-subsidy is built in.

The commercial estate. Inside the terminals Aena runs a retail and hospitality property business: duty-free and travel retail (the largest contract category), food and beverage outlets, specialty fashion and convenience shops, advertising space, banking and currency exchange, and the fast-growing VIP-lounge product. Off the terminal floor it runs car parks (a high-margin product where Q1 2026 revenue rose 9.1 percent even as domestic traffic dipped) and rents space to car-rental firms.

The manufacturing constraint is physical capacity. Aena's binding constraint is concrete: runways, terminal floor area, and gates. Management has repeatedly said many of its airports are "approaching their technical limits," which is the entire rationale for the coming DORA III investment surge - a planned regulated-investment programme of roughly €9,991 million over 2027-2031, the first large-scale expansion cycle in about 25 years, concentrated on roughly a dozen airports led by Madrid, Barcelona and Málaga. Building airport capacity is a multi-year, permit-heavy, environmentally contested process, which is itself a barrier protecting the incumbent.

Geographies. The Spanish network is the home base. Internationally, the UK (Luton, plus the pending Leeds Bradford and Newcastle), Brazil (Northeast block, Congonhas/Block, and Galeão in Rio, with operating rights to 2039), Mexico (via GAP), Colombia and Jamaica. The Brazilian and UK expansions are the active frontier; financial close on the UK deal is expected in Q2 2026 and on Galeão in H2 2026.

Milestones that shaped the business: the 2015 IPO (state retains control); the post-COVID recovery (2020 traffic collapsed roughly 72 percent, then rebuilt past 2019 levels); the Brazilian concession wins that turned International from a token line into a real segment; and now the DORA III investment cycle that will materially expand the regulated asset base for the first time in a generation.

4. Customers

Aena has two fundamentally different customer sets, and a third behind them.

Airlines are the regulated customers. The roster is led by low-cost and Spanish carriers: Ryanair (by far the largest user of the Spanish network), the IAG group (Iberia, Vueling, Iberia Express), easyJet, Air Europa, Jet2, Binter (Canary inter-island), and Wizz. The buying decision is not really a "choice" in the usual sense - if you want to fly commercially to or from a major Spanish city, you use an Aena airport, because Aena owns essentially all of them. The negotiating tension is over charges and over capacity/slots, and it plays out through the regulator rather than at a sales desk. Ryanair in particular publicly fights every proposed charge increase and periodically threatens to cut Spanish capacity. The relationship is part commercial, part political.

Concessionaires and tenants are the commercial customers: duty-free operators (Avolta/Dufry and peers), restaurant and retail chains, car-park and car-rental operators, advertisers. These buy through competitive tenders. The decision-maker is a corporate real-estate or travel-retail executive weighing the value of guaranteed access to millions of captive shoppers against the MAG rent Aena demands. Switching cost is high in a specific sense: there is no alternative venue. If you want to sell perfume to departing passengers at Barcelona, there is exactly one landlord. That scarcity is why Aena has been able to push minimum guaranteed rents up 30-40 percent in recent tenders.

Passengers are the ultimate customers of the commercial business - the people actually buying the coffee and the parking. They do not choose Aena; they are delivered to it by the airlines. Their value to Aena is measured as sales-per-passenger, which rose 1.7 percent in Q1 2026.

Concentration and contract structure. Customer concentration is real but two-sided. On the airline side, Ryanair and IAG dominate volume, which gives them lobbying weight over charges. On the commercial side, revenue is spread across many concessionaires but anchored by MAG floors that lock in years of minimum rent regardless of traffic - giving Aena unusual revenue visibility for a travel-exposed business. The regulated aeronautical revenue, meanwhile, is effectively a five-year contract with the Spanish state via DORA. The blend is a business with far more contracted, predictable revenue than a casual observer would expect from something so tied to tourism.

5. Competitive Landscape

Here is the unusual thing about Aena: within its core market, it has almost no competition. It is a near-complete national airport monopoly granted by licence. The "competition" is therefore of three kinds: other large airport operators it competes against for international concessions and for the affection of capital, airports in other countries competing for the same European tourist, and the regulator who substitutes for market competition on price.

Direct peers (for concessions and as investment comparables):

Why Aena wins. Three structural advantages. First, scale and density: it runs the largest passenger network of any single operator, anchored by a tourism economy (Spain is among the most visited countries on earth, near 100 million annual visitors) that fills its airports for free. Second, margins: at ~59 percent group EBITDA margin it is more profitable than ADP or Fraport, largely because its commercial business is so productive and its regulated capex was, until now, low. Third, the licence itself: nobody can build a competing airport network in Spain.

Where Aena is exposed. Against ADP and Vinci it is less internationally diversified - those two have spent two decades assembling global concession portfolios, while Aena's international push is more recent and more concentrated (Brazil, UK). And uniquely among this peer set, Aena's controlling shareholder is also effectively its price regulator, which can suppress the pricing power its monopoly would otherwise command.

Barriers to entry are about as high as they get in any industry. You cannot build a new major airport in a developed country in under a decade, against entrenched environmental opposition, with the land and capital required, to compete with an incumbent that already owns the catchment. The barrier is not a moat Aena dug - it is a geographic and regulatory fact. The real competitive risk is not entry; it is regulation and politics squeezing the returns on the monopoly.

6. Industry

Demand drivers. Airport revenue is driven by passenger volume, which is driven by GDP, disposable income, the price of flying, and tourism flows. For Aena specifically, inbound tourism to Spain is the dominant variable - Spain competes with Italy, Greece, Turkey and others for European and intercontinental leisure travel, and the weather, the cost of a holiday, and the relative strength of the euro all move the dial. A secondary, newer driver flagged repeatedly by management is modal shift: as Spain's high-speed rail faces capacity limits and as short-haul flying remains cheap, some travellers shift toward air, and parking and ancillary revenues benefit.

Size and trajectory. The Aena Spanish network alone handles north of 300 million passengers a year; including Luton and the Brazilian and other international assets, the group footprint is materially larger. Global air travel has structurally grown faster than GDP for decades, interrupted only by shocks (9/11, the financial crisis, COVID). Post-COVID, Spanish traffic has fully recovered and pushed to record highs, and management now describes the business as entering "a more normal phase" of low-single-digit annual growth after the recovery bounce - hence the modest 1.3 percent Spanish growth pencilled in for 2026 (since withdrawn amid macro uncertainty).

Where Aena sits in the chain. Airports are the toll booths of aviation. They sit between airlines (who own the planes) and passengers (who want to travel), and they monetise both the airlines (charges) and the passengers (retail). They are infrastructure assets with utility-like regulated returns plus a property-and-retail overlay - a hybrid the market values somewhere between a utility and a consumer landlord.

Regulation. This is the defining feature. In Spain the CNMC and the DORA framework cap the maximum revenue per passenger and dictate required investment over five-year windows. DORA I (2017-2021) and DORA II (2022-2026) held charges essentially flat to slightly down in real terms; DORA III (2027-2031) is the pivotal upcoming negotiation, in which Aena proposes a roughly €10 billion investment programme funded by a gentle tariff path (maximum revenue per passenger rising from €10.92 in 2027 to €12.69 in 2031, an average increase management characterised as about €0.43 a year). Beyond price regulation, the industry faces tightening climate policy: EU Emissions Trading System costs, sustainable-aviation-fuel mandates and national aviation taxes all raise the cost of flying and could dampen demand.

Cyclicality. Severe. Airport traffic is highly cyclical and acutely vulnerable to shocks - pandemics, oil-price spikes, terrorism, recessions and geopolitical conflict all hit travel demand fast and hard. COVID was the extreme case, cutting Aena's traffic by roughly three-quarters in 2020 and forcing the dividend to zero. The offset is that the regulated annuity and the MAG rent floors give the business more downside protection than a pure leisure-travel stock.

Tailwinds and headwinds. Tailwinds: durable Spanish tourism appeal, long-run air-travel growth, modal shift from rail, and the coming investment cycle that expands the regulated asset base. Headwinds: regulatory price suppression, climate policy raising airfares, growing local backlash against over-tourism in the Canaries and Balearics, and the ever-present risk of a demand shock.

7. Growth Triggers

Drawn directly from the six most recent earnings calls.

• DORA III investment cycle (€9,991m regulated investment, 2027-2031; regulated asset base expanding by more than €5.5 billion). The first large network-expansion cycle in roughly 25 years, concentrated on Madrid, Barcelona, Málaga and about a dozen airports approaching capacity limits. (FY2025 call, 25 Feb 2026; reiterated Q1 2026 call, 29 Apr 2026 - repeated)

  "Many of Aena's airports are approaching their technical limits." - FY2025 call, framing the rationale for the expansion.

• DORA III tariff path: maximum revenue per passenger rising from €10.92 (2027) to €12.69 (2031). A modest, multi-year step-up in regulated pricing that, if approved, lifts aeronautical revenue per passenger after years of flat charges. (H1 2025 call, 30 Jul 2025; Q3 2025 call, 29 Oct 2025 - repeated)

• Commercial tender re-pricing. Newly awarded specialty-shop concessions locked in minimum annual guaranteed rents 33% (2025) and 40% (2026) above 2024 levels, with food-and-beverage equivalents up 19% and 20%. These contracted floors feed revenue growth regardless of traffic. (Q3 2025 call, 29 Oct 2025)

• UK portfolio expansion: 51% of a holding owning 100% of Leeds Bradford and 49% of Newcastle, for £270m, financial close expected Q2 2026. Adds roughly 9.5 million passengers, lifting the UK platform (with Luton) toward ~26.5 million. (FY2025 call, 25 Feb 2026; Q1 2026 call, 29 Apr 2026 - repeated)

• Rio de Janeiro Galeão concession, financial close expected H2 2026, operating rights to 2039. Deepens the Brazilian platform, backed by a BRL 5.7 billion financing package. (Q1 2026 call, 29 Apr 2026)

• VIP-lounge and premium-services ramp (+31.5% in Q1 2026), plus parking (+9.1%). High-margin commercial products growing well ahead of traffic. (Q1 2026 call, 29 Apr 2026)

• COVID-tenant settlement cash inflow of about €30 million. Resolution of pandemic-era commercial-rent disputes converting to cash. (Q1 2026 call, 29 Apr 2026)

8. Key Risks

Regulatory and political control (the master risk). The Spanish state owns 51 percent of Aena and, through the CNMC and the Council of Ministers, sets the charges Aena can levy. These two roles conflict. As shareholder the state wants high dividends; as policymaker it wants low airport charges to protect tourism, low airfares, and regional airports kept open regardless of profitability. DORA III is where this plays out: management has proposed a roughly €10 billion investment programme on a gentle tariff path, and the government must approve it (a Council-of-Ministers decision targeted before the regulatory deadline). A harsher-than-expected outcome - lower allowed tariffs, or investment obligations without commensurate return - would directly compress the regulated annuity. This is a moderate-probability, high-impact risk, and it is structural, not one-off.

"The sooner we have a resolution, the better." - management on DORA III, Q1 2026 call, acknowledging that the regulatory overhang is itself a drag.

Traffic-demand shocks. The entire model rests on people flying. Fuel-price spikes, geopolitical conflict, recession, pandemics or terrorism can cut traffic fast. The vividness of this risk was on display in Q1 2026 when management withdrew its 1.3 percent traffic guidance entirely, citing jet-fuel volatility and airline cancellations, with the CFO calling uncertainty the highest of his career. High-probability that some volatility appears; the catastrophic version (a COVID-scale collapse) is low-probability but devastating, as 2020 proved when the dividend went to zero.

Cost inflation outrunning revenue. Management has flagged structural, not temporary, cost pressure: Spanish-network staff costs up 12.4 percent in Q1 2026 (collective bargaining, +400 headcount, salary reviews), maintenance up 20 percent, security up 8.5 percent, with "double-digit" staff-cost growth guided for the whole of 2026. Because aeronautical pricing is capped by the regulator, Aena cannot simply pass rising costs through - margins can erode if cost growth outpaces the regulated revenue path. Moderate-probability, moderate-drag.

Climate and aviation policy. EU ETS costs, sustainable-aviation-fuel mandates and national flight taxes raise the cost of flying, which over time can suppress the leisure demand that fills Aena's airports. Slow-moving but directionally negative, and partly outside management's control.

International execution and country risk. The growth story now leans on Brazil and the UK. Brazilian concessions carry currency risk (BRL), construction obligations and a longer payback; the Galeão and UK deals must close and then deliver. A misjudged concession price or a Brazilian macro shock would dent the segment management is selling as its diversification engine.

Over-tourism backlash. Anti-tourism sentiment in the Canary and Balearic islands has become politically visible. Measures that cap visitor numbers or constrain airport expansion in those high-margin island markets would hit a particularly profitable slice of the network.

9. Walk the Talk

The six calls underpinning this assessment: FY2024 (26 Feb 2025), Q1 2025 (~29 Apr 2025), H1 2025 (30 Jul 2025), 9M/Q3 2025 (29 Oct 2025), FY2025 (25 Feb 2026), and Q1 2026 (29 Apr 2026). The most recent is within 90 days of today.

The through-line is a management team that is consistent, conservative on the things it controls, and refreshingly willing to admit when it cannot forecast.

Start with traffic guidance for 2025. Through 2025 management held a full-year Spanish-network growth target of roughly 3.4 percent. At H1 (30 Jul 2025) and again at Q3 (29 Oct 2025) they reaffirmed it. The outcome: group traffic grew 4.1 percent and Spain 3.9 percent for the nine months, with the year finishing ahead of the 3.4 percent guide. They guided conservatively and modestly beat - the most credible pattern there is.

On financial delivery, the record is clean. FY2025 produced revenue of €6,379.2 million (+9.5%), EBITDA of €3,785.0 million (+7.8%), and net profit of €2,136.7 million (+10.5%), with EBITDA margin holding near 59 percent - exactly the high-margin, steadily-growing profile management has described call after call. Commercial and real-estate revenue crossed €2 billion for the first time, matching the "commercial as growth engine" narrative they have pushed consistently.

On capital returns, they have done precisely what they said. The stated policy is an 80 percent payout, and the dividend has climbed every year of the recovery: €7.66 (FY2023), €9.76 (FY2024, +27.4%), and a proposed €10.90 for FY2025 (+11.7%). Four consecutive years of increases, no surprises.

On strategy, the promises are being executed on schedule. DORA III was promised and the proposal was submitted on time in mid-February 2026. The UK acquisition was announced (December 2025) and is closing on the Q2 2026 timeline management gave. The Galeão concession was won and is progressing to its stated H2 2026 close. There is no gap here between word and deed.

The most telling episode is the 2026 traffic guidance. At FY2025 (25 Feb 2026) management set a 1.3 percent Spanish-growth expectation, explicitly framing it as a return to "a more normal phase." Just two months later, at Q1 2026 (29 Apr 2026), they withdrew it.

"The assumptions behind the earlier 1.3% forecast have been materially affected by changing conditions, so it is too early to confirm the outlook." - Q1 2026.

A weaker management would have quietly left a stale number standing. Aena pulled it and said so plainly, with the CFO admitting unprecedented uncertainty. That is the opposite of overpromising.

Assessment: this is management that does what it says. It guides conservatively, delivers on financial and strategic commitments, raises the dividend on a stated policy, and - crucially - retracts a forecast honestly rather than defending a number it no longer believes. The credibility bar is met.

10. Shareholder Friendliness Index

Dividends. Aena pays a single annual dividend under a stated policy of distributing about 80 percent of net profit, and the trend has been steadily upward through the post-COVID recovery: €4.75 for FY2022, €7.66 for FY2023, €9.76 for FY2024 (+27.4%), and a proposed €10.90 for FY2025 (+11.7%, paid April 2026). That is four consecutive annual increases. The dividend was cut to zero in 2020-2021 during COVID, which is the relevant context for why the recovery-era increases look so steep: management is rebuilding the distribution off a pandemic-zeroed base while keeping the payout ratio disciplined at roughly 80 percent rather than chasing a higher headline number.

Buybacks and dilution. Aena does not run share-repurchase programmes. As a state-controlled company in which ENAIRE must retain 51 percent, buybacks are structurally awkward - repurchasing and cancelling stock would mechanically alter the control arithmetic and the free float - so capital return is delivered entirely through dividends, not buybacks. (No MoatMap database block was supplied for this venue, so no last-90-day figure is asserted; the three-year record from annual reports and exchange filings shows no buyback programme in any of FY2023, FY2024 or FY2025.) The share count has been stable at 150,000,000 shares with negligible treasury stock and no meaningful option-dilution, so there is neither creation nor retirement of stock - the count is flat.

Verdict: Returns Capital. A disciplined ~80 percent payout and four straight years of dividend growth, with no dilution; the only caveat is that the majority owner is the state, so the dividend policy is as much fiscal as financial.

11. Insider Activities

Aena is a state-controlled company, and this fundamentally shapes what "insider activity" means here. The decisive holding is ENAIRE's 51 percent stake on behalf of the Spanish State, which has been held constant since the 2015 IPO and is not traded for investment-signal reasons - it is a control stake. The board is dominated by state appointees and independent directors who, in the Spanish state-enterprise tradition, generally do not hold or trade large personal positions in the company. There is no founder-CEO with a large personal stake whose buying or selling would carry a conviction signal.

A direct search of the CNMV "otra información relevante" register for Aena (issuer NIF A86212420) over the trailing twelve months surfaced corporate disclosures - results, the UK and Galeão transactions, AGM resolutions, the DORA III proposal - but no material PDMR ("comunicaciones de directivos") open-market purchase or sale by a director or senior manager was located within the search budget. The dedicated CNMV "notification by senior managers and related parties" sub-register is the authoritative source and did not return a material director dealing in the period reviewed.

On the substantial-shareholder side, the free float is held by global institutions - BlackRock and Norges Bank are long-standing significant holders, and the activist fund TCI has historically appeared on the register. Movements by these holders are portfolio-allocation decisions by index and active managers, not insider-conviction signals.

Net assessment: neutral, by structure rather than by sentiment. The absence of insider buying or selling here should not be read as a bearish or bullish signal the way it would be at a founder-led company. With a 51 percent state control block that never trades and a board of state and independent appointees who do not run large personal books, Aena simply does not generate the open-market insider flow that makes this section informative elsewhere. There is no cluster buying to flag and no concerning selling to explain. Investors looking for an alignment signal should look instead to the state's dual role as owner and regulator, which is covered in the risk and shareholder-friendliness sections. If a primary PDMR filing emerges, the CNMV senior-managers register is the place it would appear.

12. Scenarios

Bull case. DORA III is approved close to Aena's proposal: roughly €10 billion of regulated investment with a gentle tariff path that lifts maximum revenue per passenger toward €12.69 by 2031. The expansion of the regulated asset base, after a quarter-century of underinvestment, gives Aena its first real regulated-revenue growth lever in a generation - it is finally allowed to earn a return on a much bigger book of airport infrastructure. Spanish tourism stays structurally strong, traffic resumes low-single-digit growth, and the modal shift from constrained rail keeps parking and ancillary revenues humming. The commercial engine keeps re-pricing tenders 30-40 percent higher on renewal, pushing sales-per-passenger up and lifting group margin even further. The UK deal closes cleanly and Galeão completes, turning International from a side-show into a genuine second growth pillar with Brazilian traffic already above pre-COVID levels. The dividend, on an 80 percent payout of a rising profit base, keeps compounding. Aena looks like an inflation-protected infrastructure annuity with a growth kicker.

Base case. DORA III is approved but trimmed - the government, balancing its tourism and consumer interests against its shareholder interest, lands on a tariff path slightly below Aena's ask, with the investment obligations broadly intact. Traffic grows in the low single digits, roughly the "normal phase" management has described, with the occasional soft quarter from fuel or geopolitics that makes precise guidance hard (as in early 2026). Commercial revenue continues to outgrow aeronautical, cushioning the regulated side, while structural cost inflation in staff and maintenance nibbles at margins but does not break them. The UK and Brazil deals close and contribute, though execution and FX keep International's reported numbers lumpy. The dividend rises along the 80 percent payout policy. Aena remains what it is: a high-margin, slow-growing, regulated cash machine whose ceiling is set by its own regulator-owner.

Bear case. The state's regulator hat wins. DORA III comes back materially tougher than proposed - lower allowed tariffs, or heavy investment obligations without commensurate return - because the government prioritises cheap airfares, tourism competitiveness and regional-airport politics over its dividend. The regulated annuity, the foundation of the whole equity story, gets repriced downward just as Aena is committing to a multi-billion-euro capex cycle, so returns on the new asset base disappoint. Simultaneously a demand shock - a fuel spike, a recession, a renewed geopolitical crisis, or worse a pandemic-style event - cuts traffic, and the 2020 playbook repeats: profits fall, the dividend is pared or suspended, and the cyclicality the market tends to forget reasserts itself. Cost inflation that management has already flagged as structural compresses margins from the other side. Over-tourism caps in the Canaries and Balearics constrain the most profitable islands, and a Brazilian misstep turns the growth bet into a write-down. In this world Aena is revealed as a politically captive utility with travel-cycle beta, not a compounder.

Sources: Aena Q1 2026 press release; Aena Q1 2026 Interim Management Report; Aena Q1 2026 earnings call transcript (Investing.com); Aena Q1 2026 net profit (The Corner); Aena FY2025 results presentation; Aena FY2025 earnings call (Investing.com); Aena 2025 results (AeroMorning); Aena Q3/9M 2025 transcript (MLQ.ai); Aena 9M 2025 commercial revenue (DFNI); Aena H1 2025 presentation (Investing.com); Aena Q1 2025 / DORA III (ad-hoc-news); Aena shareholders & investors; Aena significant holdings & treasury stock; CNMV other relevant information - Aena; Aena dividend history (DividendMax); Aena segments overview (PortersFiveForce); Aena wins Galeão concession (Travel Daily News); Aena UK expansion - Leeds Bradford & Newcastle (Aviation Week); ADP & Vinci market cap (Yahoo Finance ADP); Fraport market cap (Yahoo Finance); Flughafen Zürich (Morningstar)