Most ANSPs know the date. Far fewer have mapped what has to happen before it.
31 December 2027 is the hard deadline under European Commission Implementing Regulation No. 2021/116 (Common Project 1) by which all ANSPs operating in European airspace must support ATS-B2 applications. The regulation carries infringement procedures for non-compliance. There is no grace period built in, and the European Commission has already signalled it will not repeat the precedent of extending PCP timelines.
What tends to catch organisations out is not the CP1 compliance deadline itself. It is the distance between signing a contract and achieving operational acceptance. A data link system can be procured, integrated, and still fail acceptance testing because the interoperability environment (adjacent ANSPs, CSP network, aircraft fleet equipage) was not validated end-to-end before go-live. That last mile, routinely underestimated, is where CP1 compliance deadline pressure is now being felt most acutely across the sector.
What CP1 Actually Requires of ANSPs
Meeting the CP1 compliance deadline requires ANSPs to support two capabilities under ATM Functionality 6 (AF6): Data Link Services.
The first is CPDLC (Controller‑Pilot Data Link Communications), the digital messaging system used between controllers and pilots to exchange non‑time‑critical ATC clearances, routine communications, and related service messages. ANSPs must support the full suite of CPDLC data link services—Data Link Initiation Capability (DLIC), ATC Communications Management (ACM), ATC Clearances and Information (ACL), and ATC Microphone Check (AMC) as defined in EUROCAE ED‑110B and the applicable ATN standards.
The second is ADS-C with Extended Projected Profile (EPP), the mechanism by which aircraft transmit four-dimensional trajectory data to ground systems. EPP goes beyond the basic ADS-C contract: it gives the ANSP access to the aircraft’s full predicted trajectory, not just its current position. For ANSPs that have not previously operated ADS-C infrastructure, this is not an add-on to an existing system. It requires dedicated CM Server and ADS-C Server capability, connected to the ATN network and validated against the aircraft systems that will use it.
AF6 also carries a dependency many ANSPs are still working through. B2 common services must connect via SWIM (System Wide Information Management), which draws in elements of AF5. Where an ANSP’s SWIM infrastructure is not yet in place, this dependency adds scope and time to the compliance picture.
Why the CP1 Compliance Deadline Is Closer Than ANSPs Think
The challenge is not finding solutions. Several mature, proven options exist for each component of the required infrastructure. The challenge is the sequence of work that has to happen before a system can be declared operationally compliant, and how long each step actually takes in practice.
A public tender for operational ATM software typically runs twelve to eighteen months from specification to contract award. That is before a line of integration work begins. System integration, site acceptance testing, and interoperability validation with adjacent ANSPs and CSP networks add further months, with the precise duration depending on the complexity of the existing environment and how many bilateral agreements need to be established or updated.
ANSPs that have not yet completed procurement are not simply behind on a project plan. They are working in a window where, even with a capable vendor and a clean integration, operational acceptance before December 2027 is genuinely at risk.
The European Commission has already noted that infringement procedures remain on the table for non-compliant member states. Beyond that regulatory exposure, there is an operational reality that will arrive regardless of enforcement: as B2-equipped aircraft become the norm across European routes, ANSPs without compliant ground infrastructure will face an increasingly unworkable mixed environment, managing voice and digital communications with systems that were not designed to handle both at scale.
Four Things ANSPs Should Be Doing Now
With the CP1 compliance deadline now within a single procurement cycle, these are the four actions that determine whether December 2027 is achievable.
Get a specific gap assessment, not a general readiness review
A readiness review that concludes “further investment is required” is not useful at this stage. What an ANSP needs now is a component-level gap assessment: which specific functions within DLIC, ACL, ACM, AMC, and ADS-C EPP are currently supported; which require upgrade or replacement; what the interoperability dependencies are with adjacent ANSPs and the CSP network; and whether existing test infrastructure can validate the upgraded system before go-live. The answers to those questions determine whether a December 2027 deadline is achievable and what the programme looks like to get there.
Prioritise the ADS-C EPP and CM Server stack
For most ANSPs, the ADS-C EPP capability is the longest lead-time item. It requires CM Server and ADS-C Server infrastructure that may not exist in the current environment, connected via ATN to the relevant CSP network, and validated against equipped aircraft. Centralised service models such as a shared Logon and ADS-C Common Service (LACS) can reduce the per-ANSP deployment burden significantly, particularly for smaller ANSPs where the cost and complexity of standalone infrastructure is disproportionate to the traffic handled. This is worth exploring early, as it changes the scope and timeline of what needs to be procured and integrated.
Choose partners based on operational track record in this environment
The ATN/FANS environment is not generic telecommunications infrastructure. The interoperability requirements, the validation standards, and the specific failure modes that arise during integration are only understood through direct deployment experience. An ANSP evaluating vendors should be asking not just whether a product is standards-compliant, but which other ANSPs that vendor has integrated with, what the acceptance testing process looked like, and what the support arrangement covers once the system is live. References from comparable deployments in the European ATM environment are the most reliable signal of whether a vendor can deliver within the constraints of this timeline.
Treat testing as a phase, not a sign-off
Validation of a data link system is not a final step. End-to-end testing across ATN and FANS networks, interoperability testing with CSPs and adjacent ANSPs, and acceptance testing of all mandated service functions needs to be scoped, scheduled, and resourced as a distinct programme phase rather than compressed into the final weeks before a go-live date. Interoperability testing alone, when it involves coordination with multiple adjacent ANSPs, can add additional time to a programme. That has to be in the plan from the start.
What a Compliant ANSP Infrastructure Looks Like
By December 2027, a CP1-compliant ANSP ground environment needs to demonstrate support for the following components.
AGDLS is an Air/Ground Data Link Server handling CPDLC across both ATN and FANS networks, supporting the full mandated service function set. ANSP ATN Router provides standards-compliant connectivity to the ATN network via the CSP, with current RHEL-compatible system foundations. ADS-C EPP is a CM Server and ADS-C Server stack capable of receiving and processing four-dimensional trajectory data from B2-equipped aircraft. SWIM connectivity supports B2 common services via a SWIM interface, satisfying the AF5/AF6 dependency. A validated test environment confirms end-to-end performance against operational standards before and after go-live.
Each component has to be integrated and operationally accepted, not simply installed. Procurement is the start of the programme, not the end of it.
A Note on the Cost Picture
The SESAR Deployment Manager’s 2024 Cost-Benefit Analysis estimates the total cost of CP1 deployment across all stakeholder categories at €4.8 billion, with an estimated €1.6 billion remaining to be invested before the end of 2027. For ANSPs specifically, the data link component of that investment is material, and the cost of a compressed or repeat implementation if a first attempt fails acceptance is substantially higher than a well-planned programme done once.
ANSPs that have not yet committed to a procurement path are also facing a narrowing supplier market. Vendors with proven ATN deployment experience are not unlimited, and those with strong European ANSP references are already carrying significant programme commitments ahead of the 2027 deadline.
How Airtel ATN Works With ANSPs on CP1
Airtel has been deploying operational and test data link solutions to ANSPs since the early years of ATN. Sixty percent of European ANSPs use Airtel software in their data link environment. Airtel’s test equipment is used by 24 ANSPs across Europe to validate ATN implementations, making it the most widely used testing platform in the sector.
That footprint matters for the CP1 compliance deadline specifically because it means Airtel has direct experience of the interoperability environment most European ANSPs are working within. When an ANSP’s integration needs to be validated against adjacent systems, Airtel has typically already worked with those adjacent systems.
For the CP1 programme, Airtel offers the following. AGDLS is an operational Air/Ground Data Link Server supporting ATN and FANS with full ATS-B2 application capability. The ANSP ATN Router is cost-effective, RHEL-compatible, and straightforward to integrate with existing data link infrastructure. LACS (Logon and ADS-C Common Service) is already CP1/AF6 compliant and built for rapid deployment, including for ANSPs accessing B2 common services via a shared model. Test and validation equipment is used across the European ATN environment to verify compliance at every stage of deployment.
Airtel works directly with ANSPs and as a component within wider ATM system integration programmes. The products are designed to integrate with existing infrastructure rather than require wholesale replacement.
Where to Start
If your ANSP does not yet have a clear CP1 compliance deadline implementation plan with programme dates attached, the first conversation should be a component-level technical assessment rather than a sales presentation. Airtel’s team can work through the specific gap between where your current infrastructure sits and what operational acceptance requires, and give you an honest view of what the timeline looks like from that starting point.
Talk to the Airtel ATN team about your CP1 programme.
Airtel ATN provides data link communication software and test equipment to Air Navigation Service Providers, Communication Service Providers, Avionics Manufacturers, and MRO organisations worldwide. Based in Dun Laoghaire, Ireland, Airtel’s solutions are active in more than 35 countries and enable over 13,000 aircraft to connect to the ATC network.
