Feedback for the European Commission on rail passenger rights

As mentioned by Jon Worth last month and reminded by Oliver Blanthorn today, the European Commission has put together a call for feedback to improve the current regulation on rail passengers’ rights and obligations (EU 2021/782), to grant more rights when passengers take a journey involving multiple operators. For this specific initiative, the focus is on tickets purchased as a single transaction.

This initiative aims to ensure that passengers are granted their passenger rights when travelling with multiple railway undertakings, with tickets purchased as part of a single transaction from a ticket platform. This is particularly important when connections between rail services are missed due to a delay or cancellation of the previous service. Minimum connection times must be respected.

Here is the feedback I submitted.

The Commission is right that granting passenger rights when travelling with multiple operators is essential for competitivity of the railway sector. Today, passengers using several operators (for example because they cross a border) generally need to add extra buffer time between operators to reduce the chance of missing a connection if the first train is delayed (and losing all rights on the rest of their journey). This additional buffer time makes the whole journey longer even when no delay happens, which is less competitive than other modes of transportation.

However, limiting the scope of this initiative to tickets purchased in a single transaction will limit its effectiveness. Today, there are only few platforms selling tickets for multiple operators, none work across all operators in the EU, and they generally act as resellers that sell a collection of tickets (for the various operators involved) rather than a unified ticket.

Even if the (re)selling landscape improves in the future, there are many valid reasons to split a journey into multiple transactions. A typical example is differing booking horizons: one operator may not sell tickets more than one month in advance, while tickets may already be sold out at that point for another operator (or much more expensive than a 3-month ahead price). Another example is passengers with special needs, such as travelling in a wheelchair, with a bicycle or with a pet: in this case direct booking with each operator is today generally the only way to purchase the required special tickets. (Even if beyond the scope of this specific initiative, improving ticket selling to make sure all cases are covered by reselling platforms without requiring a special treatment would certainly be welcome.)

Setting aside the scope of which tickets grant rights or not, something I’d like to see is unified rules for delay compensation, and if possible a unified platform to make claims. Today, some operators offer monetary compensation based on the ticket price when some delay thresholds are reached, but rules vary widely. Even for a given operator, compensation varies between segments, for example SNCF Voyageurs’ “Billet Direct” grants a 25% refund beyond 30 minutes of delay for the TGV Inoui offering, but only beyond 60 minutes for the TER offering, making the experience less clear for passengers. Besides, SNCF’s reimbursement platform is a chat bot with very frequent reliability issues, making it hard for passengers to even claim their rights. Establishing EU-wide thresholds with a minimum monetary compensation (on top of existing rights such as journey continuation) would make rules clearer for passengers, and incentivize operators to improve the reliability of their services.

Another important component that is missing today is having EU-wide open data about delays. More precisely, the EU should mandate each railway operator to publish an open-data trail of when each train arrived at and left each station (with 1-minute precision), and at which platform. This is essential for several reasons.

Today, delay data is often only available as live data (which is useful during the journey to make alternative plans), but disappears once the train has left. This makes it difficult for passengers to have a proof of delay after the fact.
Some operators don’t even publish live delay data online, making it hard for passengers to know what’s happening and adjust their plans accordingly.
In addition, having unified open-data about delays is useful at planning time, allowing passengers to know how much delay to expect (and whether buffer time is advised). Open-data is essential here to allow third-party tools to use it creatively and improve the experience of all passengers (for examples of tools leveraging the limited existing delay data, see Zugfinder, Carto Tchoo or Chuuchuu).

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