Portugal Tells Ryanair It Cannot Refuse Paper Boarding Passes

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Ryanair’s move to go fully paperless has hit a regulatory roadblock in Portugal. On 11 November 2025 Portugal’s civil-aviation regulator ANAC (Autoridade Nacional da Aviação Civil) formally told Ryanair it must not refuse passengers who present printed (paper) boarding passes and must not charge mandatory fees for issuing or accepting a paper boarding pass — even though Ryanair launched a policy requiring digital boarding passes via its myRyanair app from 12 November.

What ANAC said — the regulator’s core demands

ANAC published Press Release No. 11/2025 after reviewing Ryanair’s website information and the extra clarifications the airline submitted at ANAC’s request. The regulator concluded that, while Ryanair intends to issue digital boarding passes to all passengers who check in online, the carrier must not:

1. Prevent boarded passengers from travelling if they have a confirmed reservation and have already checked in but do not hold a digital boarding pass; and

2. Impose mandatory fees for obtaining or using a physical (paper) boarding pass.

   

ANAC also said it will continue to monitor the situation to ensure passenger rights — including protections for people with disabilities, reduced mobility or those without a smartphone — are respected.

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Why this matters (passenger rights, accessibility and consumer law)

Ryanair’s announcement — part of a wider industry trend toward digitalisation — has provoked debate about accessibility and consumer rights. Critics warned the policy risks disadvantaging groups who lack smartphones, have limited technical ability, or face problems such as a lost battery or device theft at the airport. ANAC’s intervention is a clear reminder that moves to cut costs or force app-adoption must not override existing passenger protections.

Portugal’s stance is also relevant across the EU because national regulators have the mandate to enforce passenger-rights protections and ensure airlines comply with consumer and safety obligations at their airports of operation. ANAC’s public warning sets a practical expectation for how airlines must treat paper boarding passes on Portuguese soil.

Ryanair’s position and operational detail

Ryanair has been explicit that from 12 November 2025 it will move to 100% digital boarding passes, automatically issuing a digital boarding pass in the myRyanair app after online check-in. The airline argues the move reduces costs and paper waste and that most passengers already use mobile passes. Ryanair also says the app stores passes for offline use (after check-in), and in its help pages it notes exceptions for certain destinations that still require printed passes (for regulatory reasons). 

Despite Ryanair’s assurances that gate staff can help when passengers have app issues, ANAC’s direction makes clear carriers must still accept paper passes and cannot charge for them in Portugal — placing the burden on Ryanair to ensure its local operations comply with Portuguese rules.

Early reaction: consumer groups and media

Consumer bodies and media outlets flagged the potential problems ahead of the deadline. In Portugal, consumer organisation DECO labelled a digital-only policy “abusive” and asked for government oversight; ANAC’s intervention addresses those concerns directly by telling Ryanair to uphold passenger rights at Portuguese airports. News outlets across Europe and travel media have reported similar worries about older travellers and passengers in vulnerable situations. 

Practical takeaways for passengers flying via Portugal

• If you have checked in online, ANAC says you should not be prevented from boarding in Portugal just because you do not present the myRyanair app boarding pass. Keep proof of check-in (booking reference) with you. 

  
  

• Ryanair claims its digital pass is usable offline after check-in, but if your phone fails or is lost, ask gate staff for assistance — and do not accept a mandatory reissue fee in Portugal. 

• If an agent attempts to refuse boarding or charge for a paper pass in Portugal, passengers should contact ANAC and keep receipts or photos as evidence for complaints. 

Wider implications for airlines & regulators

This episode illustrates the balancing act regulators face between encouraging digital innovation in aviation and protecting consumer rights. While paperless systems can improve efficiency and cut costs, national authorities can — and will — step in where digital practices risk excluding or penalising passengers. Expect other EU regulators to watch how Ryanair complies in Portugal; similar disputes could emerge in other countries if airlines push digital-only rules without clear, inclusive exceptions.