Risks and opportunities report

Risk management system

The Executive Board of FMG and all subsidiaries and affiliated companies is responsible for the early detection and prevention of risks that jeopardize the continuity of Munich Airport and the investments. Group Management has overall responsibility for an effective risk management system and lays the essential foundation for it by communicating and defining corporate strategy and targets. It formulates specifications for the risk management process and the organizational structure of the risk management system.

The goal of the risk management system is to identify events and developments that may have a negative impact on the achievement of strategic and operational targets in good time and develop suitable countermeasures. It takes account of all aspects of entrepreneurial activity – economic as well as environmental and social.

The risk management guideline regulates the general principles of risk management in the Group as well as the tasks and responsibilities of the function holders involved in risk management. This is aligned in accordance with the internationally recognized framework model «COSO ERM» (Committee of Sponsoring Organizations of the Treadway Commission – Enterprise Risk Management).

The Risk Management Committee serves as an additional supporting management, control, and supervisory body within the risk management system. As the highest-ranking body in risk management, it reports directly to the Executive Board and consists of the Managing Director of Finance and Infrastructure, the heads of the Aviation, Commercial Activities and Real Estate business divisions, the heads of the Legal, Corporate Bodies, Compliance and Environment, Group Controlling and Participation Management, Group Security and Corporate Communication & Politics divisions, the head of the IT service division and the risk manager. The head of Compliance is involved in the Risk Management Committee as a guest. The task of the Risk Management Committee is to analyze the risks from a Group perspective and to monitor the effectiveness of countermeasures. It provides support for developing the risk management system and for risk identification, assessment, and control. The Risk Management Committee meets quarterly and issues the risk report, which is subsequently presented to the Executive Board and the shareholders.

The risk management process comprises the following steps. A coordination and communication platform has been established in the system to support this process.

Identification and communication of risks

All divisional managers and Chief Executive Officers of subsidiaries and shareholdings are responsible for the identification and assessment of risks. In the relevant divisions, all risk-relevant information is coordinated, administrated, documented, and passed on by the relevant risk managers. The risk manager checks the divisions’ risk reports for plausibility and compliance with the Group-wide standards for risk assessment. The role involves combining the divisions’ individual reports in a risk report, taking account of materiality for the Group, and reporting quarterly to the Executive Board and shareholders. Risks that jeopardize the Group’s existence that have been identified for the first time must also be reported to the Executive Board on an ad hoc basis.

As a basis for dealing with risks responsibly, each individual employee is involved in managing risks throughout the company. Employees are individually responsible for eliminating risks in their area and for reporting signs of existing risks to their manager without delay.

Assessment of risks

The systematic risk assessment allows the company to determine the extent to which individual risks jeopardize the fulfillment of Munich Airport’s corporate goals and strategies and which risks may possibly threaten its existence. For this purpose, the factors damage amount, and probability of occurrence/frequency, are presented in a two-dimensional risk matrix. The expected loss describes the impact on profits that can be expected if the loss event occurs. In the case of events that recur over time, the company works with the frequency with which they occur. The assessment first takes place without considering measures to limit the risk (gross risks, see the section «Risks»). Subsequently, the risks are assessed after risk-minimizing measures are initiated or implemented (net risks, see section «Risks»).

Dealing with risk

Starting from the risk analysis, appropriate countermeasures for dealing with risk are specified according to corporate strategy and economic aspects. Risk management strategies include: control, insure against, minimize, eliminate, and transfer. The risk officers have the task of specifying and implementing countermeasures to manage risks in the respective division affected.

Risk monitoring

The risk manager monitors the effectiveness of risk management continuously. Risks are also monitored separately by Internal Audit.

Compliance management system

Compliance covers compliance with all Munich Airport-related laws, specifications, and regulations, national and international rules and standards, as well as in-house rules and guidelines. Munich Airport has established a Group-wide compliance management system, which encompasses all organizational provisions ensuring compliance with the aforementioned rules.

The Compliance Department submits reports on the current status of the compliance management system to the Executive Board on a regular basis and to the Supervisory Board on an annual basis.

Compliance risks are also communicated as part of the risk reporting to the Executive Board and shareholders if internal thresholds are exceeded. Regular dialog takes place between Risk Management and Compliance.

Identifying and mitigating compliance risks

The Compliance department prepares the compliance risk analysis with input from the FMG divisions and combines it with the subsidiaries/affiliates compliance risk analyses every year.

Compliance risks are assessed in the same way as the risk management process. Once the compliance risk analysis has been carried out, the Executive Board is notified of the results in a report.

The annual Compliance Report to the Supervisory Board of FMG also includes the results of the compliance risk analysis. If, despite all countermeasures taken, a risk has a high potential for damage and at the same time a high probability of occurrence, then it is examined in more detail in the report.

After consideration of the implemented countermeasures, no significant compliance risks remain for the year 2020. Appropriate protective measures for the health of employees and customers were given the highest priority with respect to the Corona pandemic.

Preventing corruption

The Compliance Principles and the Gift/Invitation Policy support management, executives and employees in behaving lawfully and ethically in the workplace. They are published on the intranet and are therefore available to all employees. In addition, the principles refer to the observance of other internal company guidelines, such as compliance with public procurement law during procurement and procurement processes, data protection organization or information security. These ensure that processes and procedures are transparent and traceable, both internally and externally. In contracting and tendering procedures, Munich Airport requires bidders to submit a declaration of commitment stating that they will undertake everything necessary to preclude corruption. Compliance failures are subject to sanctions, such as exclusion from the contracting process.

The position of anti-corruption officer is exercised by the head of the Compliance department. There are no known confirmed cases of corruption in the Group for 2020. Minor attempts at fraud against Munich Airport could be prevented in advance.

Communication and training

A key task of the Compliance department is to train and advise employees, managers, and the FMG Executive Board in compliance matters as a preventative measure to stop compliance breaches from occurring.

Group compliance regularly provides training and publishes information to ensure that all employees and managers are familiar with the guidelines and any updates or amendments to them. As a result of the effects of the Corona pandemic, compliance training for employees in 2020 was conducted in a flexible manner, both in person and digitally. Participation in the training was documented.

Training courses under the Leadership Excellence Program had to be canceled due to the Corona pandemic and will be resumed in a modified form in 2021 in accordance with current developments.

The Executive Board addresses the issue of compliance in an ongoing process at frequent intervals, and the Supervisory Board is informed at regularly scheduled intervals.

Electronic whistle-blower system

Through an electronic whistle-blower system, the Business Keeper Monitoring System (BKMS®), Group employees, business partners, and customers can report behavior potentially damaging to our organization. As part of the advancing globalization and internationalization of business activities, the whistleblower system will also be offered in English from now on. Furthermore, documents can now also be forwarded electronically in anonymized form. People inside the Group and outside can also contact the Compliance department by other means of communication (telephone, e-mail, face-to-face discussions) if they wish to draw attention to compliance infringements and need advice. Tender documents inform potential bidders of the possibility of using the BKMS® should compliance infringements be suspected.

Data protection

Munich Airport has taken comprehensive measures to comply with the General Data Protection Regulation (GDPR) and the revised Federal Data Protection Act (BDSG). The subsidiaries and associated companies have appointed data protection officers to perform advisory and oversight duties in accordance with the GDPR. Data protection coordinators have also been established in FMG’s specialist departments in order to identify and address the issues and risks faced by the departments. They are continuously trained, informed and advised by the Corporate Compliance unit in cooperation with the Data Protection Officer. This has also been handled in a flexible manner on short notice through various media since the outbreak of the Corona pandemic.

Responsibility for data protection compliance in their respective processing operations is decentralized among the individual FMG departments and subsidiaries/affiliates.

FMG’s data protection officer is responsible for advising and supporting the departments and is appointed directly as data protection officer in most subsidiaries/affiliates. The data protection officer of FMG is assigned organizationally to the Compliance department and reports directly and independently to the Executive Board.

Due to the impact of the Corona pandemic, training measures for Group employees and managers to further raise awareness of data protection and data security took place almost exclusively on a digital basis in 2020. In addition, awareness was continuously raised via the intranet. In individual cases, professional and individual advice was also provided to support security in handling personal data.


Risks that could have a material influence on the business activity or on the net assets, financial position, and results of operations as well as the reputation of Munich Airport are explained below. In each case, the risks are shown before (overview of gross risks) and after consideration of suitable countermeasures (overview of net risks).

The risk assessment relates to the economic impact in the assessment period quoted. As of December 31, 2020, the following material gross risks were identified for Munich Airport:

Overview of gross risks

Overview of gross risks (matrix)

As already described in detail in the Course of business section, the Corona pandemic at Munich Airport led to a significant reduction in passenger traffic compared with the previous year. Future traffic development depends in particular on international travel restrictions and warnings. Due to the high numbers of infections, it is currently very likely that the measures to contain the Corona pandemic will continue for some time. Due to the ongoing uncertainty among passengers, changes in travel behavior to the detriment of air travel are to be expected in the medium term. Cost-cutting measures in many companies and digital media will, at least for the time being, result in restrictive travel policies for business travel and therefore fewer business trips.

The current level of uncertainty surrounding the further course of the Corona pandemic and its impact on the aviation industry has a major effect on the assessment of the risks «Loss of/adverse impact on hub/discontinuation/reduction airlines», «Economic cycle» and «Market slump from epidemic/disease». The latter two risks were set to «very high» in the previous year’s report after December 31, 2019. The risk «Loss/impairment hub, discontinuation/reduction airlines» was reassessed in the current 2020 fiscal year and upgraded from a «very low» to a «low» probability of occurrence. The financing requirements at Munich Airport are also reviewed continuously, which is reflected in the liquidity risk. In addition, the risk «Personnel situation» has gained in importance.

Risks resulting from force majeure



Description and analysis



Natural disasters


Persistent and intensive rainfall together with melting snow and ground saturation to the south of Munich as far as the Alps could cause flood run-off in the Isar. A resulting breach of the Isar dams and flood protection dike in Freising could lead to the terminals being flooded.


Gradual upgrading of the Isar dams by the water authority. They have already been partially renovated. In addition, the Free State of Bavaria is planning to shift the flood protection dike further back. Munich Airport also monitors the waste water discharge situation on a permanent basis and carries out maintenance and repair work. A study of the flood protection system conducted in 2019 also showed that it is adequate even in the event of intense precipitation and flash flooding, which can occur under certain weather conditions. Countermeasures are being intensified at an operational level by means of crisis and risk management procedures at Munich Airport. Insurance to cover earthquakes, storms, hail, and flooding has been arranged.

Attack on air traffic


The risk of terrorist attacks on air traffic remains unchanged. In addition to bodily injury and property damage, this would result, at least temporarily, in a decrease in the number of aircraft movements and passengers.


To avert a terrorist attack, Group security is taking strategic, operative, as well as technical and organizational measures: provision of sufficient and well-trained personnel resources, construction measures to guarantee modern and approved security technology and infrastructure, monitoring of service quality through sustainable quality measures, and constant exchange with the responsible security authorities. Bodily injury and property damage as well as interruptions of operations are insured.

Terror at the airport


Terrorist acts on the airport campus pose a risk of personal injury and property damage. A further consequence of such events would be, at least temporarily, a decrease in the number of aircraft movements and passengers.


To avert a terrorist attack, Group security is taking strategic, operative, as well as technical and organizational measures: provision of sufficient and well-trained personnel resources, construction measures to guarantee modern and approved security technology and infrastructure, monitoring of service quality through sustainable quality measures, and constant exchange with the responsible security authorities. Bodily injury and property damage as well as interruptions of operations are insured.

Fulfillment of security tasks


The airline companies are responsible for security tasks in transferred areas. In these areas, airline companies fulfill the same task as airport operators, but are not subject to the same supervisory authority. For Munich Airport, there is a risk that inspections will reveal defects in transferred areas and the airport as a whole will lose its security status as a result.
Defective controls could lead to property damage and bodily injury as well as reputational damage.


At present, a subsidiary of FMG is responsible for operational security tasks in the transferred areas; its services rendered are subject to regular monitoring by FMG. Furthermore, a mutual, intensive exchange takes place with the responsible government and supervisory authorities.

Market slump from epidemics/illness


Munich Airport is an arrival, departure, and transfer location for millions of air passengers and therefore a potential source of bacteria and viruses from all over the world. Epidemic/sickness outbreaks can result in market downturns with reduced aircraft movements and passenger numbers. As a result of the Corona pandemic, this risk is becoming particularly important. It is currently evident that the pandemic at Munich Airport is creating enormous economic burdens, which in 2020 caused a very high drop in earnings. The effects on future years cannot be reliably estimated at this time due to the high degree of uncertainty.


Munich Airport is subject to the Act Implementing the International Health Regulations (IGV-DG) and employs a subsidiary to fulfill the necessary functions. Similarly, the rules prescribed by the European Aviation Safety Agency (EASA) on the topic of «emergency response planning» are also fulfilled. This includes, among other things, the responsibility of the Airport Medical Service for managing operations, and compliance with laws and regulations (e.g., the German Infection Protection Act).
A number of measures are currently being planned or have already been implemented to prevent infections. These include protective walls, contact-free access points and fixtures, regular hygiene inspection tests for ventilation systems, adjustment of cleaning quality/intervals, and the «Touchless Travel» project with two «eGates» for contact-free identification using facial recognition.
Recommendations have been issued by EASA as well as by the European Public Health Agency (ECDC) to ensure safe travel in times of the Corona pandemic. These recommendations were taken into account and implemented in a «Hygiene Protection Concept.»
For explanations of the economic countermeasures, please refer to the «Economic cycle» risk.

Large fire


In the event of damage to or destruction of terminals or infrastructure systems caused by a large fire, property damage and bodily injury as well as long-term interruptions of operations are to be expected.


To minimize the risk of a large fire, Munich Airport takes all required preventive and defensive fire protection measures, and has its own Airport Rescue and Firefighting unit. The risk of a major fire is additionally minimized by a fire insurance policy (property and interruption of operations insurance) and public liability insurance (liability claims of third parties). After taking the countermeasures into consideration, the net risk is below the risk tolerance limit.

Aviation accidents


Aviation accidents or damage to aircraft can result in bodily injury and property damage, as well as interruptions of operations and secondary damage.


To minimize the risk, Munich Airport maintains an Airport Rescue and Firefighting service, a medical service, and a counseling team. The risk of aviation accidents is minimized through liability insurance and fully comprehensive insurance. After taking the countermeasures into consideration, the net risk is below the risk tolerance limit.

Market risks



Description and analysis



Loss of/adverse impact hub, discontinuation/
reduction airlines


Since the beginning of the year, the global Corona pandemic has had an unprecedented impact on air traffic, requiring appropriate government support measures for airlines. Above all, different international quarantine and entry regulations and contact restrictions in numerous destinations are leading to less and less mobility and slowing down a normalization of air traffic. The pandemic will inevitably lead to serious reductions in supply (routes, frequencies of aircraft) and demand. In the current winter flight schedule, Deutsche Lufthansa is concentrating most of its heavily reduced intercontinental services at Frankfurt, thereby significantly reducing services in Munich.
This temporary measure is not a precedent for a decision detrimental to hub traffic in Munich in the post-pandemic period. At present, Deutsche Lufthansa’s planning scenarios do not foresee any impairment of hub operations. Lufthansa continues to adhere to its strategy of operating Munich Airport as a hub.
The future is uncertain for other airlines, which were already struggling with financial problems before the pandemic.
The risk of losing the hub in the short-term is therefore rated as «low.»


Munich Airport’s collaboration with Deutsche Lufthansa is based on joint investments and long-term cooperation agreements. The widespread use of rapid tests as well as «Tested Flights» is intended to create framework conditions for the resumption of intercontinental air traffic.
Despite the Corona pandemic and its impact on air traffic, the cooperation between Munich Airport and Deutsche Lufthansa will continue. In this context, the letter of intent signed between the two parties on December 16, 2019 was expanded to include a side letter in October 2020.
In addition, Munich Airport was again awarded the top rating of «5-Star Airport» by the Skytrax institute in 2020. This is the best foundation for a successful new start after the Corona pandemic.

Economic cycle


As a result of a weak economy, the growth parameters assumed in the planning process cannot be achieved, which has a negative impact on earnings development.
During more significant economic crises, a collapse in loan finance markets may occur.
Increasing protectionist tendencies could put a strain on global trade in general, but especially on European-American trade and consequently on the transatlantic aviation market. This could result in growth-inhibiting effects for Munich Airport.
In addition to the above explanations, the outbreak of the pandemic is putting a heavy strain on the global economy. The economy in countries like the USA or Great Britain has been particularly hard hit.
Since the further course of the pandemic is uncertain, all forecasts are subject to a very high level of uncertainty. At present, it is not possible to make a reliable estimate of the economic impact this will have on Munich Airport in the years to come.


Reducing expenses through cost monitoring, if necessary reducing staff numbers in a socially responsible manner, short-time work benefits plus a short-term cut in the investment budget in non-critical divisions aim to mitigate the consequences of economic slowdowns.
To ensure solvency, revolving credit lines exist or loans can be taken out on the capital market.
In the wake of the Corona pandemic, Munich Airport initiated these countermeasures at an early stage to reduce the economic impact. The aim is to safeguard earnings and liquidity.
On December 24, 2020, the EU and the United Kingdom agreed on a trade deal that provides for a comprehensive economic partnership. As a result, serious trade barriers could be averted. Nevertheless, there are changes in air traffic laws. On the other hand, traffic between the individual EU countries and Great Britain will remain unaffected by the changes.

Operating risks



Description and analysis



IT failure


Damage to the IT system can result from fire, water ingress, and sabotage.
Constant new technological developments and the increasing threat of cyber attacks worldwide also lead to risks in relation to the security of IT systems and networks as well as data security. In the area of cybercrime, there is an increasing, abstract potential risk that requires constant monitoring and assessment.
Failure of IT for traffic operations can lead to interruptions in operations. This would result in financial losses and reputational damage.


Critical corporate IT systems are fully redundant with systems located in physically separate locations. Property damage and interruptions of operations are insured.
To avert a cybercrime attack at Munich Airport, there is a central information security management system that specifies and controls strategic, technical and organizational measures to defend against cyber attacks. Awareness of cyber risks is reinforced among managers and employees through training. In the competence center against cyber crime (Information Security Hub), IT specialists at the airport work together with experienced IT security companies to test and search for new methods to combat cyber crime. In addition, Munich Airport is working with German air traffic control and other airports to develop measures to defend against cyber attacks.
The risk is minimized through insurance. After taking the countermeasures into consideration, the net risk is below the risk tolerance limit.

Water damage


Water damage caused by a break in the main drinking water or fire extinguishing water pipelines could lead to the failure of infrastructure systems important for air traffic.


Remotely controlled emergency shut-off equipment and additional protective devices in the pipeline connections limit the possible damage. Property damage and interruptions of operations are insured. After taking the countermeasures into consideration, the net risk is below the risk tolerance limit.

Change in national and EU-wide security requirements


Munich Airport is subject to national and EU-wide aviation security requirements, encompassing the topics of airport security, air passenger and hand luggage checks, airfreight, airmail, and goods control, among others. Security requirements are adjusted continuously to the current circumstances. This can give rise to procedural and also infrastructural changes for Munich Airport. Corresponding financial burdens would then follow.


Munich Airport attempts to minimize these consequences through work in associations and on committees. Early information relating to ongoing legislative procedures ensures the timely implementation of security regulations.
Additional expenses incurred as a result of infrastructural changes are used as the basis for the master agreement on charges.

Failure to pass an EU safety inspection


The EU’s aviation authorities are conducting safety inspections at airports. Should it fail to comply with a safety standard and subsequently fail the follow-up audit, Munich Airport can lose its «Clean» status. The consequences would be a heightening of the safety regulations, considerable obstruction with operational processes, competitive disadvantages, and a loss of image.


Munich Airport conducts thorough and strict quality controls to manage the quality of all safety aspects at the airport.
The quality controls implemented have shown that the countermeasures taken as well as the consistent monitoring are effective and that – in theory and practice – very well trained personnel are employed.
Therefore, the probability of occurrence of the risk is reduced to «low.»

Utilities and waste disposal facilities


The inadequate availability of substances necessary for operating activities, such as electricity, heat, cooling energy, drinking and extinguishing water, waste water, and waste, may result in property damage and interruptions of operations.


The service and maintenance programs, network redundancies, and storage reduce the risk of gaps in supply. Property damage and interruptions of operations are insured.
After taking the countermeasures into consideration, the net risk is below the risk tolerance limit.

Reorganization of ground handling


The success of the reorganization of the former Ground Handling business unit could be put at risk by the following uncertainties and circumstances: sustained reductions in traffic from existing customers, ground handling losses due to the transfer of part fleets to third parties, aggressive pricing policies of competitors, and increasing price decline at Munich Airport.
Due to the Corona pandemic, this risk is becoming increasingly important because of the high declines in traffic.


During the negotiations to extend the long-term contract with an important customer of AE Munich, a new contract was concluded at the end of 2016. As a result, associated collective restructuring agreements could be extended.
To compensate for declining ground handling volumes, talks with potential new customers are ongoing. In the event of a loss of ground handling, capacities and associated costs will fall. Constant monitoring and reporting of the renovation progress and renovation path is carried out.
In response to the significant drop in handling volumes caused by the pandemic, the «Restart» change program, which also includes ground handling, was launched in the fiscal year. The program is designed to position the company for the future. In addition to measures to adjust personnel capacity, organizational changes will also be developed as part of the program.

Personnel situation (previous year: Personnel procurement/


Munich Airport is in crisis mode given the situation created by the Corona pandemic. Due to the massive drop in air traffic, the Group is expecting significantly lower staffing levels in the future.
The issue from the previous year regarding recruitment/staffing is of secondary importance.
Munich Airport is concentrating on overcoming the crisis and taking measures that are intended to ensure the health of employees on the one hand and to mitigate the economic consequences on the other.
Personnel management measures can lead to a loss of know-how. Despite the countermeasures that have been introduced, Munich Airport is committed to retaining existing skilled employees.


The countermeasures initiated are aimed at securing liquidity and limiting the negative impact on earnings. To achieve this, personnel capacity is adjusted to the decreasing workload. These measures include in particular the reduction in time-off credits and the short-time work benefits introduced in April 2020, which have been extended until the end of 2021.
In addition, the FMG-wide «Restart» change program was initiated, as described under the «Ground Handling Restructuring» risk. This involves developing organizational and efficiency-enhancing measures and focusing on adjusting personnel capacity.
In addition, the emergency collective agreement will come into force on January 1, 2021, which was concluded at the federal level between the Association of Municipal Employers’ Associations (VKA) and Verdi/Beamtenbund dbb for Flughafen München GmbH.



Arising from the increasing number of drones in the sky, there is a risk that drones can enter into the controlled space of Munich Airport without authorization and endanger or disrupt flight operations.
In 2017, with the regulation concerning the operation of unmanned aircraft, the Federal Government adopted tightened rules for the use of drones, including an obligation to register aircraft and a ban on operation within the controlled space of airports. In addition, the EU Commission adopted a provision on May 24, 2019 to make the increasing drone traffic safer for people on the ground and in the sky. At national level, legal responsibility for the implementation of drone detection, identification and verification was regulated in mid-2019. At all German commercial airports, the German Air Traffic Control (DFS) is responsible for this. Implementation in the member states took place in December 2020 and is expected to be completed after two years. This provides a binding legal framework for the operation of drones in Europe based on risk assessments.
The required legislative changes necessitated by the EU Implementing Regulations (IRs) have not yet entered into force as of December 31, 2020.


Although national responsibilities and competencies with regard to detection and protection against drones do not lie with the airport operator, an exchange between relevant stakeholders on the current status of detection and protection technology has taken place in an expert meeting initiated by FMG. Together with the airport associations ADV, Airport’s Council International (ACI) and the German Air Transport Association (BDL), Munich Airport is working toward uniform regulation of drone traffic at national and European level.
In addition, a realistic technical evaluation of detection systems was carried out at Munich Airport in the third and fourth quarters of 2020 by DFS in cooperation with the Group and other partners. The findings from the test project will provide a basis for deciding which technology appears suitable for future drone detection at and around German commercial airports.
After taking the countermeasures into consideration, the net risk is below the risk tolerance limit.

Legal risks



Description and analysis



Third runway


Due to the postponement of the decision to realize the third runway, all planning and land acquisition costs incurred to date must be examined for recoverability on an ongoing basis and written off if necessary.
Effects from the moratorium agreement reached in 2018 and the Corona pandemic were accounted for in the balance sheet.
Without an increase in capacity brought about by the construction of the third runway, there could be a significant loss of company value in the medium and long-term. This will be influenced primarily by a stagnation or decline in the traffic volume and the associated lower revenues in the Aviation and Non-Aviation divisions.
The further development of the Corona pandemic and its impact on the aviation industry are subject to a high degree of uncertainty at this time and depend heavily on international travel restrictions and warnings. Based on current vaccination activity, the risk will be reassessed in 2021 and the classification revised.


The confirmation of the planning approval decision by the Bavarian Administrative Court (BayVGH) on February 19, 2014 and in the following year by the Federal Administrative Court limited the legal risks for project implementation.
Diversification of the product range and expansion of foreign business were planned as countermeasures to the significant loss of company value. In previous years, the «LabCampus» project was launched, with which Munich Airport intends to create a unique location for innovation and cross-industry cooperation. The expansion in the USA continues.
The third runway remains a key long-term strategic project for the future of the Munich Airport.

Products used for de-icing


Formates in the airfield deicing agent currently in use are believed to accelerate the oxidation of aircraft brakes. Discussions about banning these formate de-icing products are ongoing at the SAE (Society of Automobile Engineers) international standardization committee. As an alternative, there are currently only glycol-based de-icers on the market, the use of which is not permitted at Munich Airport by the Ministry of the Environment. If they were banned, substantial sums would have to be invested in waste water systems to comply with the requirements of water management legislation.


The German passenger airports within the ADV and BDL associations are jointly opposing the ban on formate-based de-icers. The intention is to continue to influence SAE through ACI Europe.
In discussions with the Bavarian water management authorities, ACI Europe, and the responsible SAE working group, it was shown that as little de-icer as possible is used in order to minimize the environmental impact. In addition, the surface deicing agents used for airfields are published by Munich Airport in the Notice to Airmen (NOTAM).
The manufacturers of the de-icer are to be involved in the future in order to find a solution to this problem.

EU General Data Protection Regulation


In addition to the legal risks listed in the risk matrix, there are risks in connection with the EU General Data Protection Regulation (GDPR). The GDPR expands the existing obligations arising from the Federal Data Protection Act (BDSG) and increases the legal, operational, and technical/organizational requirements for data protection. An infringement of these rights and obligations could incur high fines, claims for damages, reprimands, and reputational damage.
Currently, Munich Airport is considering issues related to the use of closed circuit television (CCTV) video surveillance.


At Munich Airport, the project to implement the requirements of the GDPR has been successfully completed. As part of this, organizational structures and processes as well as their documentation were adjusted and awareness of data protection was heightened within the Group.
In particular, the following measures were taken as countermeasures for data protection risks arising from CCTV: Role usage concept, re-signage to indicate video surveillance, renegotiation of the company agreement on CCTV, consolidation of the legal basis, implementation of a data protection consequence assessment.
Munich Airport has also appointed data protection officers and data privacy coordinators who receive awareness training and other types of training on a regular basis from the Group’s Compliance unit.
The gross risk here is below the risk tolerance limit set by FMG and is therefore not represented in the risk matrix.

Munich Airport is confronted with various legal disputes during the normal course of business. These can lead, in particular, to the payment of compensation claims or, in the case of construction projects, to changes in the remuneration of services. Moreover, other legal disputes can be initiated or existing legal disputes can be expanded. Apart from matters for which provisions have already been made in the balance sheet, Munich Airport is not currently anticipating any material negative impacts for the net assets, financial position, and results of operations from other known cases at the present time.

In addition, further risks can arise in construction projects from increases in construction prices, supplier defaults, planning delays and external influences from the public, the environment, politics, changes in technology, engineering rules or other requirements, including the postponement of construction projects. The investment projects are planned appropriately in terms of their commercial viability, their financial feasibility and the risks associated with the investments, and are monitored continuously during implementation.

During the course of establishing foreign subsidiaries as part of operating and advising other airports and terminals, risks may arise in particular from assuming operational responsibility in other countries for the first time. Airport operating projects, like the Munich location itself, are subject to general economic and company-specific risks. To minimize risk, Munich Airport therefore works with local partners who have experience with respect to the specific country regulations and conditions. In order to counter liability risks in particular, local companies with limited liability were founded in the previous year. Risks can arise, in particular, with what are typically long-term airport operator projects, when it comes to assessing future aviation development and consumer behavior on the part of passengers. This risk became increasingly visible, particularly as a result of the Corona pandemic. A possible lack of growth and/or a possible decline in air traffic, including delayed expansion projects, could have a material adverse effect on the earnings performance of the foreign companies, which would consequently result in risks for the invested capital. In 2021, Munich Airport will attempt to establish a compensation mechanism with appropriate contractual provisions vis-à-vis the franchisor. Risks may also arise from unforeseen regulatory intervention in the tariff, tax and levy structure of airports or from contractual breaches to the detriment of airport operators.

Tax (operational) audits by the tax authorities are also considered a general risk.

Financial risks

The expected financial liability for the gross financial risks listed below were under the reporting limit as at December 31, 2020. Therefore they were not included in the risk reporting. The monitoring and management of these risks are the responsibility of central finance and cash management.

Financial risks



Description and analysis



Currency risks


Currency risks arise insofar as planned sales in foreign currencies are not balanced by any corresponding expenses or outgoings in the same currency.


Munich Airport hedges currency risks using forward exchange transactions.

Credit and reliability risks


Credit and credit rating risks primarily arise from short-term deposits as well as trade receivables.


Deposits are (generally) only made with (German) banks with deposit protection.
The management of credit risks includes the constant monitoring of debtors’ creditworthiness, overdue invoices, and stringent collections management. Dependent on the credit rating, certain services are only performed against prepayment or provision of collateral in the form of guarantees.

Interest rate risks


Interest rate risks largely arise from floating-rate financial liabilities with respect to loans and financial liabilities to shareholders.


Interest rate risks from floating-rate financial liabilities from loans are countered by Munich Airport by hedging with interest rate swaps.

Liquidity risk


Munich Airport monitors risk as part of its long-term business planning and short and medium-term financial planning. In order to ensure solvency at all times, long-term credit lines and liquid funds are made available based on a rolling liquidity plan.
This risk is becoming increasingly important in the context of the Corona pandemic.
Risks to the net assets, financial position and operating results may arise from banks’ lending practices and changes in the general conditions on the capital market.


Munich Airport has set up a separate liquidity management system to safeguard liquidity during the pandemic. Liquidity planning takes into account ongoing business, capital expenditure and financing aspects for the entire Group.
In addition to cost reductions, as described under the risks «Economic situation» and «Personnel situation», the goal is to postpone or avoid capital expenditure projects.
In addition, Munich Airport raised a promissory note loan with a total volume of EUR 380 million in November 2020 to secure liquidity. In addition, there are revolving lines of credit.

After considering countermeasures, the following net risks remain:

Overview of net risks

Overview of net risks (matrix)


As an international aviation hub, Munich Airport competes with other major commercial airports. Functional and targeted opportunity management is of central importance for maintaining and expanding the airport’s market position. This is an integral part of the strategy and planning processes at Munich Airport. Opportunities are future developments and events that may lead to a positive deviation from planning or strategic targets. Both external (for example, changes in the market environment) and internal opportunities (for example, programs to increase efficiency) are considered.

All divisional heads and managing directors of the subsidiaries and associated companies are responsible for developing and implementing measures to take advantage of opportunities. They are supported by the Group Controlling and Investment Management department. In addition, all employees of Flughafen München GmbH and its subsidiaries are required as a matter of principle to identify opportunities during the course of their daily work and report them to their supervisors. In order to make the best possible use of the company’s own resources, Munich Airport operates a professional and tool-supported innovation management system in addition to a traditional ideas management system (for more information, see the section on innovation and ideas management).

As a basic principle, Munich Airport strives to strike a balance between opportunities and risks. Where opportunities are likely to occur, they have already been included in the 2021 forecast or the medium and long-term planning. The opportunities presented therefore focus on future developments or events that could lead to a positive deviation for Munich Airport from the forecast and the medium and long-term planning.

The evaluation of opportunities is based on the risk assessment system. The economic benefit resulting from the opportunities and the probability of occurrence are divided into the following categories analogous to the risks under consideration:

Economic advantage


Amount in €



1-5 million



5-30 million



30-150 million

Very high


>150 million

Probability of occurrence


Percentage intervals

Very low












In contrast to the risks, the probability of occurrence and financial impact (economic benefit) are not shown separately, but are combined in the «high relevance» and «low relevance» opportunity categories.

Since Munich Airport is confronted in some cases with very long planning periods, the opportunities are also indicated as to when they will occur in the short, medium or long-term.






<2 years



2–5 years



>5 years

Compared to the previous year, the current situation as of December 31, 2020 resulted in changes in the opportunities identified.

These mainly concern the naming and grouping of opportunities by subject. Prior year opportunities «Consumption», «Economic Cycle», «Transportation», «Hub Development», and «Off-Campus» are included in the opportunities «Corona Pandemic Development», «Economic Development», and «Market Development». The opportunity «CO2 strategy» has been renamed «Implementation of climate protection measures (CO2 strategy)». In addition, the opportunities «Regulation and legislation», «Interest rate and exchange rate developments», and «Internal process and efficiency improvements» were recently included.

Overview of opportunities at Munich Airport





Time of occurrence


Summary of the measures

Development of the Corona pandemic


high relevance


short- and medium-term


  • Systematic monitoring of pandemic development and identification of measures
  • Close cooperation with relevant stakeholders (especially airlines)

Economic development


high relevance


short- and medium-term


  • Continuous monitoring of global economic developments
  • Identification of measures to exploit opportunities in all relevant business units

Market development


high relevance


short-, medium-, and long-term


  • Intensive airline acquisition
  • Quality management
  • Close cooperation with system partner DLH

Regulation and legislation


low relevance




  • Association work
  • Use of expertise in the area of Corporate Communication & Politics

Rail access


high relevance




  • Intensive contact with political decision-makers and the Deutsche Bahn (German Railways)
  • In-house expertise in the field of rail connectivity

Interest and exchange rate trends


low relevance




  • Adjustment of product and service portfolio in the retail sector

Implementation of climate protection measures (CO2 strategy)


low relevance




  • Ongoing trend monitoring with regard to efficiency improvements in low-emission technologies

Internal process and efficiency improvements


low relevance




  • Intensive use of the expertise available in the company (among other things, see «Restart» change program)
  • Efficient alignment as well as organizational changes



low relevance


medium- to long-term


  • Observation of foreign business and further development

Real Estate


low relevance




  • Successive implementation of innovative real estate concepts on campus

Development of the Corona pandemic

The travel and tourism industry is particularly affected by the Corona pandemic due to severely restricted mobility worldwide. Further developments, specifically with regard to mobility restrictions, are therefore extremely important for the recovery of global air traffic and for the economic success of Munich Airport as well. At present, it is generally assumed that the aviation industry will take several years to return to pre-crisis levels. If, for example, medical advances were to result in better-than-expected performance or opportunities in other business sectors within the Group, this would have a very positive impact on Munich Airport’s EBT. Corona aid for Munich Airport, which is not included in the planning, could also have a positive impact. The Group is systematically monitoring further developments and is in close contact with airlines as part of its acquisition activities. The goal is to participate at an above average level in a possible recovery.

Although the probability of an early recovery is presently rated as low, the resulting opportunity is rated as «highly relevant» due to its high earnings effect.

Economic development

There is a strong correlation between national and global economic growth and growth in air traffic. At the moment, economic development both in the Federal Republic of Germany and worldwide is being negatively impacted to a considerable extent by the Corona pandemic. A significant recovery is expected for the following years assuming that the prevailing measures can bring the subsequent course of the pandemic under control. Although the downside risks are predominant, there is still a chance of a faster recovery in the economy and accompanying growth in air traffic.

Protectionist trade policy tendencies have been observed in various countries in recent years. Prominent examples of this are the trade disputes between the United States and China and the United Kingdom’s exit from the European Union (Brexit). Since the volume of air traffic depends heavily on the degree of economic globalization, protectionist measures generally have a restraining effect on worldwide air traffic. If these trends reverse in the following years and there is a renewed political focus on the global distribution of labor, it could boost economic and air traffic growth.

Furthermore, Munich Airport closely monitors all of the world’s relevant economies in various corporate divisions. In this way, potential for the various business units (e.g. Aviation, Commercial, International Business) is identified and appropriate measures are initiated to exploit opportunities on a decentralized basis.

Since economic development is one of the key factors influencing air traffic, the associated opportunities must be rated as «highly relevant» in the short and medium term.

Market development

Airline industry trends are of particular importance for traffic volumes at airports. The airline industry is currently facing historically unprecedented challenges. The current situation involves significant losses for the airlines due to the considerable reduction in traffic. Since a clear trend towards a consolidation of the European airline market could be observed before the outbreak of the pandemic, a continuation or even an intensification of this trend can now be expected due to the effects of the crisis. At present, demand for air travel is expected to remain below pre-crisis levels for an extended period in the wake of the pandemic and its aftermath. In the event of a wide-scale airline consolidation, however, the remaining demand would be spread among fewer providers. In addition, it appears possible that the remaining network carriers will emerge from the crisis downsized and concentrating on fewer hub locations in order to bundle their traffic efficiently.

Munich Airport has been pursuing intensive quality management for some time and is just one of a small number of airports worldwide to hold the status of a 5-Star Airport. It also has an extremely attractive catchment area, both in terms of business and private travel, and has been operating a professional airline acquisition service for years. Deutsche Lufthansa is an important customer for Munich Airport. They operate a hub at the Munich location and intend to maintain it in the future. In addition, cooperation is based on joint investments and long-term cooperation agreements.

If there is a large-scale consolidation of the airline market, Munich Airport could benefit disproportionately from the recovery in the aviation market in the medium term, which could lead to earnings growth well above plan.

Although such a development is uncertain due to the current situation, the resulting opportunity must be rated as «highly relevant» due to its impact on the subsequent development of the company in the medium and long-term.

Regulation and legislation

Air transport has historically been a highly regulated market. Accordingly, laws, ordinances and international agreements are still a decisive factor influencing air traffic today. The introduction of new regulations as well as changes to existing ones may involve risks, but also present opportunities for market participants.

In 2011, the German government introduced a ticket tax in the form of the German aviation surcharge, which was increased on April 1, 2020. The surcharge is used to implement climate policy objectives. The goal of the increase is to achieve a volume shift to rail. Due to its national character, the German air traffic surcharge has competition-distorting effects in the European air traffic market. As a result, passengers from areas close to the border are increasingly choosing airports in other countries as their departure point. If the aviation tax were to be replaced by more effective international or supranational climate policy instruments, this could reduce the competition-distorting effects. And this could lead to an increase in traffic at Munich Airport.

In the wake of the current crisis, the discussion on the creation of a Single European Sky gained momentum. The European Commission launched the Single European Sky program back in 1999. In addition to the introduction of uniformly high safety standards, the goal is to expand airspace capacity and achieve more economical supranational cooperation between the individual national air traffic control organizations. In concrete terms, the goal is, among other things, to enable airlines to operate more economical flight routes (direct air route), since there is still considerable potential for improvement in this area. More efficient flight routes could significantly save kerosene and thus reduce CO2 emissions (by up to 10 percent). While the latter could bring a positive image boost for air travel as a whole, the former would have a positive impact on demand for air travel due to lower costs. However, Single European Sky is an extremely complex issue, since it involves questions of national sovereignty of the individual European states. Accordingly, the formulation of solutions must take place in cooperation with all national and European players and in dialog with industry.

In order to properly utilize opportunities arising from regulation and legislation, Munich Airport maintains a Policy & Region department and is involved in various aviation associations, such as the BDL. The central objective here is to help shape important regulations for the aviation sector and counteract competition-distorting effects.

In summary, the opportunities arising from regulation and legislation are currently rated as «low relevance» due to the low probability of occurrence.

Interest and exchange rate trends

Favorable interest rate and exchange rate trends may have a positive impact on the Group’s financial result. Thus, currency effects from the conversion of earnings not denominated in euros into the Group’s functional currency (euros) may have a positive impact on the financial results.

In the retail business at Munich Airport, international customers (outside the eurozone) play a special role due to retail spending, some of which is significantly above average. Internal analyses have shown that fluctuations in the exchange rate (euro versus foreign currency) have a significant impact on retail revenues. A depreciation of the euro against key foreign currencies therefore offers the potential for earnings that exceed targets. However, due to the very low passenger numbers as a result of the crisis and the corresponding drop in retail sales, this effect is significantly weaker than in previous years.

In general, Munich Airport expects to be able to benefit from favorable conditions on the financial markets.

Altogether, the opportunity arising from interest rate and exchange rate trends must be rated as «low relevance» in the short-term due to the current crisis situation.

Implementation of climate protection measures

Munich Airport is pursuing the climate target of «C02-neutrality by 2030». It will reduce the C02 footprint it can control to zero through a combination of reduction and offsetting measures. The implementation of this CO2 strategy is associated with costs. In the field of energy generation and conservation as well as renewable energies, a progressive increase in efficiency can generally be observed. If this development continues at an accelerated rate, the cost of CO2 neutrality at Munich Airport could fall below the expected level thanks to a better price-performance ratio for low-emission energy generation. The environment, technology, and strategic sustainability management departments at the airport monitor trends in this direction.

In the long-term, this could lead to higher than expected earnings. However, the resulting opportunity must be rated as «low relevance» due to the comparatively low earnings effect.

Internal process and efficiency improvements

The impact of the Corona pandemic prompted Munich Airport to launch the «Restart» change program. The program is designed to make the company viable and efficient for the future. In addition to measures to adjust personnel capacity, organizational changes will also be developed as part of the program. The management structures and the interfaces between departments are under scrutiny, as are the company strategy and the Group structure. Initial estimates of the program’s earnings-improving effects are part of the medium-term plan presented to FMG’s governing bodies at the end of 2020. The program’s measures will be finalized during 2021 and then implemented. Since the economic effects of the «Restart» change program have already been taken into account in Munich Airport’s medium-term planning and ambitious targets have been assumed, the likelihood of a significantly greater than planned performance can be classified as low. The resulting opportunity is therefore currently rated as «low relevance».


Munich Airport’s off-campus business (services and retail) may perform better than expected.

In the medium and long-term, this could lead to higher than expected earnings. However, the resulting opportunity must be rated as «low relevance» due to the comparatively low earnings effect.

Real Estate

The innovative real estate concepts being implemented within the framework of LabCampus could lead to a greater demand for real estate in the long term than assumed in the plan. This would result in an increase in revenue in this and, potentially, in other business units.

The probability of growth significantly in excess of plan is currently rated as low. Consequently, the resulting opportunity was rated as «low relevance».

Overall assessment of the opportunities and risk situation

As the second-largest commercial airport in Germany and one of the largest airports in Europe, it is important for Munich Airport to actively seize opportunities as they arise in order to secure and further improve its position in the market through steady growth. However, it is also a key objective of Munich Airport to recognize risks in good time and to counter them systematically.

Therefore, the actual expected impact of possible events and developments is already taken into account in the business planning every year. The reported opportunities and risks are defined as potential deviations going beyond the forecast corporate result. Munich Airport consolidates and aggregates the risks reported by the corporate divisions and Group companies, and reports quarterly to the Executive Board and shareholders. Opportunities are identified and managed with the participation of the Group Controlling and Investment Management departments.

The spread of the Corona virus and its impact on global air traffic had a significant negative impact on Munich Airport’s risk situation compared with the previous year. Taking this current situation into account, the risks were reviewed or reclassified. The Executive Board expects that the economic impact of the Corona pandemic will continue to affect earnings. However, the further course of the pandemic is not foreseeable, so that a conclusive risk assessment is not possible at the present time.

No risks were foreseeable from the Group-wide risk management system or in the assessment of the Executive Board during the current forecast period, which individually or in their entirety could jeopardize the continued existence of Munich Airport. As in the previous year, management is confident that access to liquidity to meet financing needs will be available to overcome the challenges posed by the Corona pandemic. With its diversified business units, Munich Airport’s fundamental earnings power forms a solid basis for exploiting opportunities for future business development and for providing the necessary resources to accomplish this.

Munich Airport would like to point out that various known and unknown risks, uncertainties and other factors could lead to material differences between the actual events, financial situation, development or performance of the company and the estimates given here.

Munich, April 15, 2021

Jost Lammers

Andrea Gebbeken

Thomas Weyer

Share this report on social media: