AEAT and AESA update fiscal data exchange: what changes for the aviation sector

Key data

If you operate in the aviation sector in Spain, your fiscal data held by AEAT can be consulted by the State Aviation Safety Agency (AESA). This is not new, but it has just changed: the Resolution of May 4, 2026 (BOE-A-2026-10304), published on May 12, 2026, contains the amendment that modifies the agreement between both organizations, updating the technical conditions and scope of information exchange.

The message is clear: coordination between the tax administration and the aviation regulator is being strengthened. For companies in the sector, this means greater exposure to information cross-checks between their fiscal data and their operational activity supervised by AESA.

What does this regulation establish?

The original agreement between AEAT and AESA allowed AESA to access certain fiscal data managed by AEAT for the exercise of its supervision and control functions in the aviation sector. The amendment published now modifies that agreement in two main dimensions:

• Technical conditions of data supply: The mechanisms or protocols through which AEAT transfers data to AESA are updated.
• Scope of data supply: The type or volume of information that can be consulted is adapted, in response to new operational or regulatory needs of AESA.

The regulation does not detail in its publication the specific data fields or the technical systems involved. To know the full content of the amendment, it is necessary to consult the complete text in the official Official Gazette.

This type of inter-administrative agreements are covered by the regulations on information exchange between public bodies and by tax legislation, which allows sharing fiscal data when there is a legally authorized supervision or control purpose.

Economic and operational impact

This agreement does not generate direct costs for companies in the sector. There are no new fees, sanctions or additional reporting obligations arising from this amendment. However, it has operational and risk implications that should not be ignored:

• Greater capacity to detect irregularities: By cross-referencing fiscal data with operational information from the aviation sector, AESA and AEAT can identify inconsistencies between declared and actual activity. This increases the risk of inspection for companies with discrepancies.
• Strengthening the fight against fraud in the sector: This is the stated objective of the amendment. Companies with irregular fiscal situations or with activity not properly declared to AEAT have greater exposure.
• Impact on due diligence processes: For transactions or financing in the aeronautical sector, the existence of this information channel reinforces the importance of having the fiscal situation in order before any review process.

There is no data on the volume of affected companies or fraud detection figures in previous years with the previous agreement, so it is not possible to offer a quantitative comparison.

Who does it affect?

The amendment directly affects the following groups:

• Air operators: Airlines, charter flight companies, general aviation operators and any entity with an air operator certificate issued or supervised by AESA.
• Companies in the aeronautical sector: Manufacturers, maintenance providers, air navigation service providers, private airports and other entities within AESA's supervision scope.
• Involved administrations: AEAT and AESA, which must adapt their systems and protocols to the new technical framework established in the amendment.

It does not affect companies outside the aeronautical sector or individuals.

Practical example

A Spanish low-cost airline with operations based in Madrid is subject to AESA supervision for its operational activity and ordinary tax obligations to AEAT (VAT, Corporate Income Tax, withholdings, etc.).

With the updated new agreement, if AESA detects during an operational inspection that the airline has significantly expanded its fleet or number of flights, it can cross-check that information with fiscal data available at AEAT: declared invoicing, taxable bases, withholdings made to crew members, etc.

If there is a relevant discrepancy between the operational activity supervised by AESA and the fiscal data declared to AEAT, that cross-check can lead to coordinated inspection action. The company receives no prior notification that this cross-check is taking place: it operates automatically between administrations.

This scenario reinforces the importance of companies in the sector maintaining consistency between their operational activity and their declared fiscal situation.

What should companies do now?

1. Review the fiscal situation with AEAT: Ensure that all declarations submitted are consistent with the company's actual activity. Any discrepancy is now more easily detectable by AESA.
2. Inform the compliance team: The legal department, tax advisor and compliance officer should be aware that AESA has updated access to the company's fiscal data.
3. Review contracts and sector structures: If the company has complex corporate structures in the aeronautical sector, it is advisable to verify that the fiscal information of all group entities is consistent with the activity supervised by AESA.
4. Consult the full text of the amendment: To know exactly what data is subject to the new supply, access the complete text in the Official Gazette or request specialized advice.
5. Anticipate possible cross-checks: If there is any fiscal situation pending regularization, now is the time to do it before an inter-administrative information cross-check brings it to light.