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No—Heathrow has not been forced to tender its expansion work. As of 26 October 2026, the UK Civil Aviation Authority (CAA) is designing a regulatory framework that could require Heathrow Airport Limited (HAL) to run competitive procurements for selected expansion and major-capital assets. The CAA is also examining whether a separately promoted terminal or other facility could compete with Heathrow, but that route would require a third party to obtain a Development Consent Order (DCO). Both options remain subject to further evidence, consultation and legal testing under the Civil Aviation Act 2012.
What is the CAA proposing for Heathrow?
The CAA is moving from a choice between isolated regulatory models to an integrated package covering capital governance, cost incentives, longer-term financing certainty, procurement oversight and possible direct competition. Its stated objective is better value for passengers while supporting the Government’s timetable for airport expansion.
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The proposal is not an implemented compulsory-tender regime. The CAA is still testing the legal basis, governance arrangements and practical safeguards, and Tim Johnson told Parliament that changes would face further consultation before implementation.
Why is the regulator considering a new approach?
Heathrow’s expansion proposal is estimated by Steer at £33–£52 billion in 2024 prices, excluding other capacity works. Heathrow West Limited’s alternative is estimated at £27–£43 billion on the same basis. At that scale, the CAA is assessing whether conventional regulation gives consumers enough protection against cost escalation, delay and weak procurement discipline.
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The policy question is a trade-off: competition may sharpen prices and risk allocation, while multiple delivery or operating parties can create interfaces across terminals, baggage, passengers, airfield systems, information technology and disruption management.
Could the CAA make Heathrow tender expansion work?
The CAA is considering licence requirements and backstop powers that could require competitive procurement where it would further consumers’ interests. It has not decided that every project must be tendered, and HAL would probably continue to run procurements under independent oversight.
Which contracts are being considered?
- Design and build: competing suppliers would develop and construct an asset, with competition aimed at innovation and efficient capital delivery.
- Design, build and operate: a third party would also operate the asset, adding lifecycle and performance incentives where operational separation is workable.
Each asset would be assessed separately. The CAA lists separability, interfaces, construction-risk allocation, programme integration, testing and commissioning, handover, resilience, operational accountability, financeability, termination, re-tendering and hand-back as relevant tests. HAL would need clear evidence when arguing that its own procurement route better serves consumers.
How would the requirement be tested?
The CAA plans to identify one or more near-term test projects before wider use. A strengthened capital committee, independent technical assurance and escalation routes would scrutinise major schemes. The committee would influence decisions in a timely and meaningful way, although the CAA does not currently expect it necessarily to hold a veto over HAL’s capital expenditure.
Can another company build and operate a Heathrow terminal?
Possibly, but only after a planning trigger. Under the CAA’s direct-competition concept, a non-HAL promoter would first need a DCO for all or part of the expansion or a major redevelopment. The regulatory framework could then accommodate that promoter competing with HAL for infrastructure or airport-operation services.
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The CAA currently sees little consumer benefit in contractually separating operation of existing assets without that planning trigger. It wants more evidence on spare capacity, access for smaller airlines, financing costs, coordination and whether a second operator would create effective competition rather than a regulated duopoly.
What would direct competition cost?
HAL advisers, as reported by the CAA in CAP3313, estimate that a standalone terminal under direct competition could raise the cost of capital by 100–150 basis points. Their scenario estimates an additional £250–£290 million a year in financing costs over 20 years and an average passenger-charge increase of at least £2.73. These are HAL-adviser estimates, not CAA forecasts or a final impact assessment.
Which regulatory models performed best?
Steer assessed models against capacity-delivery and delay risk, expansion-cost efficiency and service quality. After proposed mitigations, no model led on every criterion.
| Model | Main concept | Assessment signal |
|---|---|---|
| 1a | Changes to capital-expenditure governance | Positive on delivery, cost and service quality; HAL retains responsibility. |
| 2 | Targeted incentive adjustments | Positive across all three criteria without major structural change. |
| 4b | Mandated design-and-build contract | Strong cost-efficiency performance among competitive models. |
| 5b | Design, build and operate | Strongest delivery performance and strong cost performance, but requires interface safeguards. |
| 7a | Wholesale supplier model | Strong cost pressure, with structural and coordination risks. |
| 7b | Direct competition for airport-operation services | Strongest cost-efficiency performance, but a negative delivery score because of fragmentation and interfaces. |
| 9a/9c | Price benchmarking or lighter-touch regulation | Negative on cost control because leverage over baselines and escalation is weaker. |
The technical work therefore does not select Model 7b or any other winner. Models 1a and 2 were positive across the three criteria, while Model 5b was strongest for delivery and Model 7b for cost efficiency. The CAA says the final choice must balance consumer value, schedule, integration, financeability, legal feasibility, competition and resilience.
How would the wider framework protect passengers?
Capital governance and assurance
The proposed capital committee would initially focus on expansion, Terminal 5 optimisation phase 2 and replacement of existing terminals, with possible extension to business-as-usual capital expenditure. Independent technical assurance and escalation would provide challenge before projects become difficult to change.
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Cost-efficiency incentives
The CAA is developing project-specific cost-sharing mechanisms, delivery obligations and monitoring. Thresholds could trigger stronger sharing of overruns or greater intervention in programme scope and management, with the intensity matched to each project’s risks and controllability.
Longer-term financing certainty
The regulator is examining whether greater certainty over the cost of capital could reduce financing costs for consumers. It also warns that locking in allowed returns could transfer excessive risk to passengers. Possible safeguards include risk sharing, transparent cost allocation, reporting and a separate expansion regulatory asset base.
What do Heathrow, airlines and passenger groups say?
- HAL supports stronger scrutiny and an independent capital committee but wants to retain procurement and delivery accountability. It warns that design-build-operate competition for integrated or critical-path assets could increase financing and interface risks, and seeks a clear legal basis and intervention threshold.
- Heathrow Reimagined supports active CAA involvement in requiring and overseeing tenders, wider use of design-build-operate models and stronger consequences for non-compliance. Its view that sections 18 and 21 of the Civil Aviation Act 2012 support specified tenders is an advocacy position, not a final CAA ruling.
- Airlines generally favour stronger competition and procurement oversight. Some prefer design-and-build only, arguing that multiple operators may not create effective competition. They also emphasise affordability and access for smaller and low-cost carriers.
- Passenger groups, including the Civil Society for Heathrow and the Heathrow Passenger Forum, caution that structural separation could complicate operations and require robust system-wide oversight.
When will Heathrow’s new model be decided?
The review began with a working paper on 25 November 2025. CAP3251, published on 15 May 2026, set out four broad directions and closed consultation on 15 June. The CAA updated its approach in CAP3286 on 16 July and invited comments by 13 August. CAP3313, dated 9 October 2026, is the current detailed framework update.
The CAA expects further evidence, expert advice and consultation through 2027 and beyond. Development of key capital-governance arrangements is targeted by the end of 2027, but that is a programme milestone rather than a guarantee that compulsory tendering or direct competition will then be operating.
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Scan for outdated or missing drivers - takes under a minuteDriver Scan →Clear out junk files and repair common Windows errorsFree Scan →Parliamentary evidence on 21 October 2026 recorded more than 27,000 consultation responses. Aviation Minister Keir Mather cited Department for Transport analysis estimating £39–£52 billion in cumulative benefits for UK passengers and the wider economy if expansion proceeds; that estimate concerns expansion benefits, not the outcome of the CAA’s competitive-delivery review.
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Frequently Asked Questions
Does Heathrow already have to use competitive tendering for every major project?
No. The CAA is considering asset-by-asset requirements and possible backstop powers, not a blanket rule covering every contract. HAL is expected to remain responsible for procurement unless a future licence requirement or intervention is applied.
What is a DCO and why does it matter here?
A Development Consent Order is the planning consent used for nationally significant infrastructure projects in England. In this proposal, it is the gateway that could allow a separate promoter to develop and compete with Heathrow; without that consent, the direct-competition route would not be available.
Would competition automatically reduce Heathrow passenger charges?
No. Competitive procurement is intended to improve cost discipline, but financing, integration and risk-allocation effects could offset savings. The CAA has not guaranteed lower charges, and the published financing figures for a rival terminal come from HAL advisers rather than the regulator.
Has the Government approved a third Heathrow runway under this framework?
The competitive-delivery work does not itself grant planning consent or settle the expansion scheme. The CAA says its final approach will depend in part on the Government’s Heathrow Expansion National Policy Statement, alongside further legal and economic evidence.
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