Ettepanek - SWD(2026) 233, COM(2026) 233

EN EN

EUROPEAN COMMISSION

Brussels, 13.5.2026

COM(2026) 233 final

2026/0114 (COD)

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

amending Regulation (EU) 2021/782 as regards the protection of passengers with single

tickets

{SWD(2026) 233 final}

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EXPLANATORY MEMORANDUM

1. CONTEXT OF THE PROPOSAL

• Reasons for and objectives of the proposal

The European Union has long upheld a commitment to ensuring a high level of passenger

protection in transport, which is a cornerstone of EU transport and consumer policy. The EU

stands out globally for the comprehensive passenger rights it provides across all modes of

transport, including rail. At the same time, its legal framework has progressively adapted to

evolving mobility patterns and passenger expectations. Rail occupies a particularly important

position in this framework, due to its role in boosting connectivity and competitiveness, in

supporting the internal market and in contributing to the EU’s climate objectives. Rail

transport is among the most sustainable modes of travel and is increasingly promoted as an

alternative to road and air transport, especially for long-distance and cross-border journeys.

Nevertheless, the Single European Railway Area remains incomplete, despite decades of

market opening. Seamless cross-border rail travel continues to be held back by market

fragmentation, persisting monopolistic structures, and technical and organisational barriers.

This has a negative effect on passenger experience.

A key problem that this proposal seeks to address is the insufficient protection of passengers

travelling on multi-operator rail journeys. In practice, many rail journeys – particularly those

involving cross-border or long-distance travel – require passengers to use the services of

several railway undertakings. Even when passengers purchase their journey in a single

transaction on one booking platform, the resulting ticket(s) often do not qualify as through-

tickets under current EU law. As a result, passengers who miss a connection due to delays or

cancellations may be left without rights to assistance, re-routing, reimbursement or

compensation, despite their reasonable expectation of being protected for the entire journey.

Although Regulation (EU) 2021/782 of the European Parliament and of the Council1

strengthened rail passenger rights and introduced some obligations to offer through-tickets,

these obligations remain very limited in scope. Some voluntary cooperation agreements

between railway undertakings are in place, such as the Agreement on Journey Continuation

(AJC)2 and ‘Hop on the next available train’ (HOTNAT)3. However, these provide only

partial and non-binding solutions and do not ensure uniform protection to passengers across

the Union. This leads to unequal treatment of passengers depending on the operators involved

and the Member States concerned. This in turn undermines confidence in rail travel and

reduces its attractiveness compared with other modes of transport, notably air travel.

1 Regulation (EU) 2021/782 of the European Parliament and of the Council of 29 April 2021 on rail

passengers’ rights and obligations (recast) (OJ L 172, 17.5.2021, p. 1). 2 The AJC is a voluntary agreement among European rail operators allowing passengers to continue

disrupted international journeys on the next available train at no extra cost

https://www.cer.be/cer-eu-projects-initiatives/agreement-on-journey-continuation-ajc. 3 HOTNAT is a Railteam alliance service allowing passengers to board the next available high-speed

train at no extra cost if a delay or cancellation causes a missed connection between member operators

https://www.railteam.eu/en/services-on-your-journey/hop-on-the-next-available-train-hotnat/.

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The Political Guidelines for the European Commission 2024-2029 contain a clear objective to

ensure that Europeans can buy a single ticket on a single booking platform and enjoy

passengers’ rights for the whole trip. Stakeholder consultations show strong support from

consumer and passenger organisations for closing these protection gaps. This support was

voiced in the call for evidence held by the Commission between July and September 2025. In

contrast, railway undertakings express reservations about the initiative, warning of the

increased costs of rail tickets.

The proposal is therefore grounded in the need to close existing gaps in passenger protection

and adapt the legal framework to current booking practices, where multi-leg multi-operator

journeys are increasingly purchased as a single transaction on a single booking platform.

Under the proposal, holders of single tickets for multi-operator journeys will receive

protection (assistance, reimbursement, re-routing, compensation) if a delay or cancellation of

an earlier service causes a missed connection. To this end, the proposal introduces the notion

of a single ticket defined as valid evidence, regardless of its form, of a through-ticket or of the

conclusion of two or more transport contracts for a single journey purchased in a single

commercial transaction from a railway undertaking, ticket vendor or tour operator.

To enable passengers to buy these single tickets, railway undertakings, ticket vendors and tour

operators should be prevented from segmenting or selling as separate tickets any journeys

they can sell under a single ticket. At the same time, for journeys under a single ticket

exceeding 12 hours, the right to compensation should arise only in relation to the delay

affecting the specific individual leg (or through-ticket). This should not apply where the

journey under the single ticket involves a night train service or where the single ticket only

consists of one through-ticket. In addition, railway undertakings should not be liable for the

rights under this Regulation where a ticket vendor or tour operator combines its services in a

single ticket without respecting the applicable minimum connection times.

Generally, while railway undertakings remain liable for passenger rights, they may entrust

another railway undertaking, ticket vendor or tour operator with the processing of the rights to

reimbursement, rerouting, assistance and compensation. Passengers should be clearly

informed before purchase of the single ticket about this transfer of tasks. This transfer should

not affect the liability of the transferring railway undertaking.

The proposal is based on EU’s competence in the field of transport under Article 91 of the

Treaty on the Functioning of the European Union (TFEU). It complements the proposals for

Regulations on Multimodal Booking (RMB) and on Rail Ticketing (RTR), adopted together

with this proposal4. By strengthening passenger rights for multi-operator journeys, the

proposal aims to:

• ensure a high and uniform level of protection across the Union;

• support the shift towards more sustainable transport;

4 COM(2026) 231 and COM(2026) 232.

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• contribute to completing a genuinely integrated and competitive European rail

system.

The initiative is not part of the Regulatory Fitness programme (REFIT).

• Consistency with existing policy provisions in the policy area

The EU has put in place a comprehensive and evolving framework for passenger rights across

all modes of transport, including rail. In the rail sector, this framework was primarily set out

in Regulation (EU) No 1371/2007 of the European Parliament and of the Council5. This was

replaced by the recast Regulation (EU) 2021/782, which strengthened and harmonised rail

passenger rights throughout the Union. The improvements introduced by Regulation (EU)

2021/782 included improved information requirements, enhanced enforcement mechanisms,

and stronger protection for persons with disabilities and persons with reduced mobility.

Furthermore, it strengthened standardised compensation and reimbursement procedures,

including by the introduction of a common form for such requests, the use of which should be

further encouraged6.

This proposal is consistent with, and complementary to the existing legal framework. Rather

than replacing the current rules, it builds on Regulation (EU) 2021/782 by addressing a

specific gap identified in its application. The gap in question is the limited protection afforded

to passengers travelling on multi-operator journeys when tickets are purchased in a single

transaction on a single booking platform but do not qualify as through-tickets. While the

current Regulation encourages railway undertakings to offer through-tickets and imposes a

limited obligation to do so, the proposal extends passenger protection in situations which fall

outside the existing provisions.

In this way, the proposal strengthens the objectives of the existing policy framework. It will

ensure more uniform and effective protection for rail passengers, particularly on cross-border

and connecting journeys. It also complements the related MTBR and RTR proposals. Those

proposals aim to improve access to integrated ticketing and travel information, but do not in

themselves regulate passenger rights in the event of missed connections.

This proposal is also consistent with the Enforcement Omnibus (COM(2023) 753) and

Multimodal passenger rights proposals (COM(2023) 752). All three share the high-level

objective of strengthening passenger protection during disruptions like missed connections

across operators or modes. They all aim to ensure full rights to assistance, re-routing, and

enforcement without gaps.

5 Regulation (EC) No 1371/2007 of the European Parliament and of the Council of 23 October 2007 on

rail passengers’ rights and obligations (OJ L 315, 3.12.2007, p. 14). 6 Commission Implementing Regulation (EU) 2024/949 of 27 March 2024 establishing a common form

for rail passengers’ reimbursement and compensation requests for delays, missed connections and

cancellations of rail services in accordance with Regulation (EU) 2021/782 of the European Parliament

and of the Council (OJ L, 2024/949, 2.4.2024). The common form can be found on the Commission

website and is adapted to the needs of persons with visual disabilities:

https://transport.ec.europa.eu/reimbursement-and-compensation-requests-form_en .

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• Consistency with other Union policies

In its Sustainable and Smart Mobility Strategy7, the Commission committed to improving the

implementation of EU passenger rights. This involves making the rights clearer for both

carriers and passengers, ensuring adequate assistance and reimbursement in the event of

disruptions, and applying appropriate sanctions when the rules are not properly observed. The

strategy also highlights the potential benefits of extending passenger rights within a

multimodal framework (see Action 63 of the strategy). The current proposal is fully aligned

with these objectives, strengthening the EU’s passenger rights policy and complementing

existing legislative measures. This initiative also aligns with the EU’s 2021-2030 Strategy for

the Rights of Persons with Disabilities8 by ensuring that all passengers, including those with

reduced mobility, receive seamless protection and assistance throughout their entire journey,

including when connections are missed between different rail operators. In addition, the

initiative supports the EU High-Speed Rail Plan’s9 objective to expand reliable, accessible

cross-border rail connectivity by minimising disruptions from missed connections. Lastly, the

initiative is also in line with the European Green Deal objectives and the European Climate

Law10. No significant harm is expected on the environment due to the policy intervention. The

initiative contributes towards Sustainable Development Goal (SDG) #13 (“Climate action”).

The current proposal is deemed to have no digital relevance. It does not introduce, modify, or

affect the use of digital means, data aspects, or provision of digital-public services. The scope

of the proposal is limited to introducing rights for passengers having single tickets for multi-

operator journeys and therefore falls outside the application of the digital-by-default principle.

2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY

• Legal basis

The legal basis for adopting EU legislation in the field of a common transport policy is Article

91(1) of the Treaty on the Functioning of the European Union (TFEU). This underpins the

passenger rights Regulations currently in force.

• Subsidiarity (for non-exclusive competence)

Rail travel within the EU increasingly involves cross-border and long-distance journeys

operated by multiple railway undertakings. Such situations cannot be adequately addressed by

national measures alone, as passengers’ rights and operators’ obligations frequently extend

beyond the territorial competence of individual Member States. Different national rules

regarding scope and enforcement would create inconsistencies and legal uncertainty. In

contrast, the proposal will ensure similar levels of passenger protection across the EU.

Existing voluntary cooperation agreements lack binding force and do not provide sufficiently

comprehensive coverage or legal certainty for passengers. As many railway undertakings

increasingly operate across several Member States, ensuring uniform rights and safeguarding

7 https://eur-lex.europa.eu/resource.html?uri=cellar:5e601657-3b06-11eb-b27b-

01aa75ed71a1.0001.02/DOC_1&format=PDF. 8 https://commission.europa.eu/strategy-and-policy/policies/justice-and-fundamental-

rights/disability/union-equality-strategy-rights-persons-disabilities-2021-2030_en. 9 https://transport.ec.europa.eu/transport-modes/rail/high-speed-rail-plan_en. 10 Regulation (EU) 2021/1119 establishing the framework for achieving climate neutrality.

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passengers in cases of missed connections can only be achieved at Union level. EU-level

action would ensure harmonised and enforceable rights for reimbursement, re-routing,

compensation and assistance for journeys involving multiple railway undertakings. This

supports the proper functioning of the internal market, guarantees equal conditions for

operators and provides passengers with the same level of protection wherever they travel

within the Union. Harmonised rights also make rail transport more attractive and support

broader EU objectives such as environmental and transport policy goals.

• Proportionality

The policy choices set out in this proposal do not exceed what is necessary to address the

identified shortcomings in the protection of rail passengers, particularly in cases involving

multiple railway undertakings under a single ticket purchase. As demonstrated in the staff

working document accompanying this initiative, the selected measures provide an appropriate

balance between enhancing passenger rights and avoiding unnecessary burdens on railway

undertakings, intermediaries and national administrations. The proposed amendments extend

existing rights (information, reimbursement, re-routing, assistance and compensation) in a

targeted manner to ensure they are applied effectively in cases of missed connections. These

measures are strictly limited to what is necessary to guarantee legal certainty and uniform

protection for passengers throughout the Union. At the same time, they do not impose

disproportionate administrative or financial obligations on operators or national enforcement

bodies. The proposal represents the most suitable instrument for: (i) achieving the desired

level of passenger protection; (ii) ensuring that rights are applied consistently in cross-border

and multi-operator contexts; and (iii) supporting the proper functioning of the internal market.

It aligns with the principle of proportionality as laid down in Article 5 of the Treaty on

European Union (TEU). More detailed explanation is provided in the accompanying staff

working document, which demonstrates that the chosen measures are effective and efficient,

and do not go beyond what is necessary to attain the policy objectives.

• Choice of the instrument

Since the proposal concerns a revision of an existing regulation (Regulation (EU) 2021/782

on rail passengers’ rights and obligations), the chosen instrument is also a regulation.

3. RESULTS OF EX POST EVALUATIONS, STAKEHOLDER

CONSULTATIONS AND IMPACT ASSESSMENTS

• Stakeholder consultations

Strong support for strengthening EU rail passenger rights, particularly for multi-operator and

cross-border journeys, was evident from the responses to the Commission’s call for evidence

in connection with this proposal. At the same time, the responses revealed differing

perspectives on the scope of passenger rights, the allocation of liability, and potential impacts

on the rail sector. There was consistent support for extending passenger rights among

members of the public, consumer organisations and NGOs, who highlighted that passengers

currently bear most of the risk in cases of delays, cancellations and missed connections. They

also pointed to fragmented ticketing systems, unclear responsibility and inconsistent

compensation practices, and many of them called for a journey-based approach to passenger

rights. The proposal reflects these views by strengthening protection for journeys purchased in

a single transaction, by clarifying responsibilities and by offering legal certainty for

passengers.

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Business stakeholders expressed more mixed views. Large incumbent railway undertakings

and their associations supported stronger passenger protection in principle but favoured

voluntary schemes such as the AJC and HOTNAT. They also warned against over-regulation

and negative impacts on service supply. New rail entrants, intermediaries and other business

stakeholders were generally more supportive of the initiative, while underlining the need for

realistic minimum connection times and a clear and workable allocation of liability. The

proposal reflects these considerations through a targeted approach that seeks to strengthen

passenger protection while ensuring operational feasibility and proportionality.

Public authorities broadly supported strengthening passenger rights and clarifying the rules on

through-tickets, but differed on the appropriate scope of obligations. They also emphasised

the need for consistency with existing legislation and effective enforcement, which provided

input for the proposal’s focus on legal clarity and consistent application across Member

States.

• Collection and use of expertise

Two external contractors, Milieu Consulting and Transport & Mobility Leuven, contributed to

preparing the support study. The study is publicly available, together with this proposal.

• Impact assessment

The proposal is supported by a Commission staff working document on the costs and benefits

of the proposal. The assessment updates and builds on the impact assessment accompanying

the proposal for a Regulation on rail passengers’ rights and obligations11 in two main areas.

The first of these is the policy measure requiring single journeys which are sold in a single

purchase, under a single transport contract with multiple tickets, to be always considered as a

through-ticket by railway undertakings and ticket vendors. This grants the passenger rights

under the Regulation (i.e. on information, assistance, reimbursement, re-routing and

compensation) for the whole journey. The second area is the measure clarifying that the

possibility to purchase through-tickets has to be offered wherever this is technically possible.

This should not, however, oblige railway undertakings to conclude agreements with each

other, as this would interfere in their business conduct and commercial freedom. Since this

cost and benefit analysis updates a previous impact assessment, a new impact assessment was

not necessary.

Since passengers will be granted additional rights, they are the main beneficiaries of the

proposal. They would also benefit from cost savings in terms of time and effort. Total benefits

for passengers, expressed as present value over 2028-2050 relative to the baseline, are

estimated at EUR 7.78 billion at EU level.

The assessment indicates that railway undertakings would face total costs of EUR 2.14

billion, expressed as present value over 2028-2050 relative to the baseline. This would result

from the action they would need to take in areas such as: (i) defining the extent of their

financial liability; (ii) coordinate disruption agreements with other railway undertakings; (iii)

updating technical request-handling processes; (iv) revising terms and passenger information;

(v) training sales and support staff; (vi) reviewing legal and financial implications; (vii)

provide assistance, reimbursement, re-routing and compensation of passengers, including

11 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52017SC0318.

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administrative costs12 resulting from having to deal with additional requests from passengers

who miss connections during multi-operator journeys. On the other hand, railway

undertakings are expected to benefit from higher demand for rail travel due to increased

consumer confidence. Intermediaries are expected to face some one-off adjustment costs

(EUR 12.84 million) resulting from IT adjustments and contract revisions, but they would

benefit from higher volumes of tickets sold.

National enforcement bodies are expected to incur one-off adjustment costs of EUR 0.03

million at EU level, linked to understanding the amendments, assessing legal implications and

adapting complaint-handling. While the number of complaints may increase due to more

single tickets, greater legal clarity will simplify enforcement. Overall, additional enforcement

costs for national enforcement bodies and other complaint bodies are expected to remain very

limited.

Overall, the assessment demonstrates that the proposal would result in net benefits estimated

at EUR 5.63 billion expressed as present value over 2028-2050 relative to the baseline. The

benefit to cost ratio is estimated at 3.6.

The climate consistency check has been performed. As shown in the Commission staff

working document, the proposal is consistent with the environmental objectives of the

European Green Deal and the European Climate Law.

• Fundamental rights

Article 38 of the Charter of Fundamental Rights requires that Union policies ensure a high

level of consumer protection. Strengthening the rights of rail passengers travelling on multi-

operator services in the EU will further raise the overall high level of consumer protection.

4. BUDGETARY IMPLICATIONS

The proposal has no implications for the EU budget.

5. OTHER ELEMENTS

• Implementation plans and monitoring, evaluation and reporting arrangements

The Commission will monitor the implementation and effectiveness of this initiative. Progress

indicators will include the number of single tickets sold, the number of through-tickets sold,

and the number of complaints and compensation payments. The Commission will gather this

information from periodic reports prepared by the national enforcement bodies under

Regulation (EU) 2021/782.

• Detailed explanation of the specific provisions of the proposal

The proposal complements the current regulatory framework on rail passenger rights through

limited and targeted amendments to Regulation (EU) 2021/782.

Article 1: Amendments to Regulation (EU) 2021/782

12 The annual average recurrent administrative costs for railway undertakings over a ten-year period are

estimated at EUR 96.1 million relative to the baseline.

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This article introduces the notion of a ‘single ticket’, spells out the passenger protection

regime for such tickets, including on the right to compensation for rail journeys under a single

ticket exceeding 12 hours, and adds the requirement for those selling such tickets to respect

minimum connection times.

Article 2 contains the common provisions of the Regulation with regard to entry into force.

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2026/0114 (COD)

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

amending Regulation (EU) 2021/782 as regards the protection of passengers with single

tickets

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,

Having regard to the Treaty on the Functioning of the European Union, and in particular

Article 91(1) thereof,

Having regard to the proposal from the European Commission,

After transmission of the draft legislative act to the national parliaments,

Having regard to the opinion of the European Economic and Social Committee13,

Having regard to the opinion of the Committee of the Regions14,

Acting in accordance with the ordinary legislative procedure,

Whereas:

(1) Effective rail passenger rights should encourage an increase in travel by train. This is

an objective set by the Sustainable and Smart Mobility Strategy adopted by the

Commission in December 202015.

(2) Regulation (EU) 2021/782 of the European Parliament and of the Council16 aims to

ensure that passengers are protected when travelling within the Union. Passengers

should enjoy uniform rights and high standards of protection throughout their journey.

However, passengers who book a journey with multiple railway undertakings in a

single commercial transaction with a single ticket vendor currently often lack such

protection, risking disruption to their journey and unforeseen costs for travel,

accommodation and refreshments.

(3) At present, there is a limited number of voluntary agreements to facilitate cooperation

in this field between the relevant railway undertakings. Such agreements are intended

to provide journey continuation for passengers making a single journey with multiple

tickets on services of different railway undertakings. However, those agreements are

often non-binding, of limited scope and unknown to passengers, leading to

inconsistencies in their application.

13 OJ C , , p. . 14 OJ C , , p. . 15 Communication from the Commission to the European Parliament, the Council, the European

Economic and Social Committee and the Committee of the Regions ‘Sustainable and Smart Mobility

Strategy – putting European transport on track for the future’, 9.12.2020, COM(2020) 789 final. 16 Regulation (EU) 2021/782 of the European Parliament and of the Council of 29 April 2021 on rail

passengers’ rights and obligations (OJ L 172, 17.5.2021, p. 1, ELI:

http://data.europa.eu/eli/reg/2021/782/oj).

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(4) To address the shortcomings in current practice, the rights to reimbursement, re-

routing, compensation and assistance laid down in Regulation (EU) 2021/782 should

be extended to all trips involving several train services operated by multiple railway

undertakings which are sold for one journey under a single ticket. Extending those

rights to all trips under a single ticket would enhance passenger welfare and provide

comprehensive protection throughout the entire journey, especially in cases of missed

connections between services operated by different railway undertakings.

(5) In particular, the right to compensation should apply to the entire journey under the

single ticket, except where the single ticket covers a combination of several transport

contracts and the scheduled journey time under the single ticket exceeds 12 hours, in

which case compensation should be determined per individual transport contract. This

limitation is justified by the potential financial risks associated with the possibly

significant compensation cost for a journey of such a length, both for the

compensation payable and the administrative costs linked to its processing and

payment. At the same time, this limitation should not apply to a single ticket

corresponding to a through-ticket, as a through ticket constitutes a single transport

contract that is either offered by a sole railway undertaking or by several cooperating

railway undertakings. That limitation should also not apply where the journey under

the single ticket includes a night train service, in light of the specific operational

characteristics of such services, including their frequencies and duration, which places

the passenger in a particularly vulnerable position in the event of missed connections

during rail journeys under the single ticket which include night train services, and also

given the need to promote night trains as a sustainable and reliable alternative for

long-distance travel.

(6) To ensure the effective exercise of those rights, passengers should be able to purchase

single tickets. Therefore, railway undertakings, ticket vendors and tour operators

should be prevented from segmenting or selling under separate commercial

transactions any journeys which can be sold as a single ticket.

(7) When offering single tickets, realistic and applicable minimum connection times

should be taken into account to reduce the risk of missed connections.

(8) Claiming reimbursement and compensation under Regulation (EU) 2021/782 should

be easy for passengers. Railway undertakings are required to inform passengers about

their rights and passengers have the right to submit their request using the common

form adopted under Commission Regulation (EU) 2024/94917.

(9) Minimum connection times aim to limit the risk of missed connections at the stage of

booking and should therefore be applied when a passenger buys a single ticket from a

ticket vendor or tour operator who combines services of different railway

undertakings. Where a ticket vendor or tour operator fails to comply with this

requirement when offering a single ticket, and the passenger misses one or more

connections during the journey, they should be liable to protect the passenger by

offering the choice to the passenger between reimbursement of the re-routing costs

incurred by the passenger or full reimbursement of the single ticket. Furthermore, they

should be liable to pay an additional compensation based on the amount paid for the

17 Commission Implementing Regulation (EU) 2024/949 of 27 March 2024 establishing a common form

for rail passengers’ reimbursement and compensation requests for delays, missed connections and

cancellations of rail services in accordance with Regulation (EU) 2021/782 of the European Parliament

and of the Council (OJ L, 2024/949, 2.4.2024, ELI: http://data.europa.eu/eli/reg_impl/2024/949/oj).

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single ticket. This liability of ticket vendors and tour operators aims to ensure that the

minimum connection times are respected. In addition, where a railway undertaking

sells a single ticket including at least one of its own services and fails to respect

minimum connection times, the passenger should remain entitled to comprehensive

protection.

(10) Railway undertakings, ticket vendors and tour operators should be encouraged to

cooperate for the benefit of passengers travelling under a single ticket. Therefore,

while railway undertakings should remain liable in the event of missed connections

occurring in the course of a railway journey under a single ticket, they should be

allowed to entrust another railway undertaking, ticket vendor or tour operator with the

processing of any rights to reimbursement, rerouting, assistance and compensation.

Passengers should be clearly informed before purchasing a single ticket about such

transfer of tasks. That transfer should not affect the liability of the transferring railway

undertaking.

(11) The European Data Protection Supervisor was consulted in accordance with

Article 42(1) of Regulation (EU) 2018/1725 of the European Parliament and of the

Council18 and delivered an opinion on [],

HAVE ADOPTED THIS REGULATION:

Article 1

Regulation (EU) 2021/782 is amended as follows:

(1) Article 3 is amended as follows:

(a) point (9) is replaced by the following:

‘(9) ‘through-ticket’ means a ticket or tickets representing a transport contract

for successive railway services operated by one or more railway

undertakings;’;

(b) the following point (9a) is inserted:

‘(9a) ‘single ticket’ means valid evidence, regardless of its form, of a through-

ticket or of the conclusion of two or more transport contracts for a

journey purchased in a single commercial transaction from a railway

undertaking, ticket vendor or tour operator;’;

(c) point (20) is replaced by the following:

‘(20) ‘missed connection’ means a situation where a passenger misses one or

more services in the course of a rail journey sold in the form of a single

ticket, as a result of the delay or cancellation of one or more previous

services, or of the departure of a service before the scheduled departure

time;’;

(d) the following point (23) is added:

18 Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the

protection of natural persons with regard to the processing of personal data by the Union institutions,

bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC)

No 45/2001 and Decision No 1247/2002/EC (OJ L 295, 21.11.2018, p. 39, ELI:

http://data.europa.eu/eli/reg/2018/1725/oj).

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(e) ‘(23) ‘night train service’ means a rail passenger service which is scheduled to

run predominantly during nighttime hours and which is composed entirely or in

part of rolling stock equipped with dedicated sleeping accommodation, such as

berths, couchettes or sleeping cabins.’;

(2) Article 12 is amended as follows:

(a) the title is replaced by the following:

‘Tickets for journeys including one or more connections’;

(b) in paragraph 1, first subparagraph, the second sentence is deleted;

(c) paragraphs 2 to 7 are replaced by the following:

‘2. For journeys involving long-distance or regional rail passenger services

under a single ticket, the railway undertaking whose delayed or cancelled

or early departed service causes a missed connection with one or more

services under that same single ticket shall be liable in accordance with

Articles 18, 19 and 20 for all relevant disruption occurring during the

entire journey if the passenger misses one or more connections. Railway

undertakings whose services under a single ticket are missed due to a

missed connection shall allow the passenger to continue the journey on

their next service, subject to the availability of seats.

3. When offering tickets, railway undertakings, ticket vendors and tour

operators shall not segment or sell under separate commercial

transactions any journey which can be sold under a single ticket.

4. When offering single tickets, railway undertakings, ticket vendors and

tour operators shall adhere at least to the applicable minimum connection

times laid down in accordance with Commission Regulation (EU)

2026/253*.

5. Where a railway undertaking, ticket vendor or tour operator sells a single

ticket for a journey which does not adhere to the minimum connection

times referred to in paragraph 4 and the passenger misses one or more

connections:

(a) the railway undertaking shall not be liable in accordance with

paragraph 2, unless it sold the single ticket and operates at least one

of the services under that ticket;

(b) the ticket vendor or tour operator shall be liable to pay

compensation equivalent to 75 % of the total amount paid for the

single ticket and to offer the choice between a reimbursement of

the total amount paid for the single ticket or of the necessary,

appropriate and reasonable costs for re-routing incurred by the

passenger.

6. The railway undertaking liable in accordance with paragraph 2 may

entrust another railway undertaking, ticket vendor or tour operator with

the processing of the rights under this Regulation, provided that the

passenger is informed about this transfer of tasks prior to purchasing the

single ticket. The transfer of tasks shall not affect the liability of the

transferring railway undertaking.

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7. Paragraphs 3 to 5 shall not apply to single tickets which consist of only

one through-ticket.’

_____________

* Commission Implementing Regulation (EU) 2026/253 of 6 February 2026 on a technical

specification relating to the telematics subsystem of the rail system in the European Union for

interoperability of data sharing in rail transport (TEL TSI) and repealing Regulations (EU)

No 454/2011 (TAP TSI) and (EU) No 1305/2014 (TAF TSI) (OJ L, 2026/253, 10.2.2026,

ELI: http://data.europa.eu/eli/reg_impl/2026/253/oj).’;

(d)

(3) in Article 19, paragraph 1 is replaced by the following:

‘1. Without losing the right of transport, a passenger is entitled to compensation for

delays from the railway undertaking if he or she is facing a delay between the places

of departure and final destination stated in the ticket or single ticket for which the

cost has not been reimbursed in accordance with Article 18. The minimum

compensation for delays shall be as follows:

(a) 25 % of the ticket price for a delay of 60 to 119 minutes;

(b) 50 % of the ticket price for a delay of 120 minutes or more.

Where a passenger has a single ticket for a scheduled journey of 12 hours or more

between the places of departure and final destination as stated in the single ticket the

passenger shall only be entitled to compensation under the first subparagraph in

relation to delays affecting the individual transport contracts in the execution of

which the delays occurred. Where applicable, passengers shall be informed of that

limitation prior to purchasing the single ticket.

The second subparagraph shall not apply to single tickets which include a night train

service or to single tickets which consist of only one through-ticket.’.

Article 2

This Regulation shall enter into force on the twentieth day following that of its publication in

the Official Journal of the European Union.

This Regulation shall be binding in its entirety and directly applicable in all Member States.

Done at Brussels,

For the European Parliament For the Council

The President The President

EN EN

EUROPEAN COMMISSION

Brussels, 13.5.2026

SWD(2026) 233 final

COMMISSION STAFF WORKING DOCUMENT

Accompanying the document

Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND THE

COUNCIL

amending Regulation (EU) 2021/782 as regards the protection of passengers with single

tickets

{COM(2026) 233 final}

TABLE OF CONTENTS

1. POLITICAL AND LEGAL CONTEXT .............................................................................. 1

2. INSUFFICIENT PROTECTION UNDER MULTI-OPERATOR JOURNEYS ................. 4

2.1. LOW AVAILABILITY OF THROUGH-TICKETS ........................................................... 4

2.2. MULTILATERAL SECTOR AGREEMENTS OFFER LIMITED RELIEF ...................... 8

3. NECESSITY AND ADDED VALUE OF EU ACTION ................................................... 10

4. OBJECTIVES ..................................................................................................................... 10

5. POLICY INTERVENTION ............................................................................................... 11

5.1. BASELINE SCENARIO .................................................................................................... 11

5.2. DESCRIPTION OF THE POLICY INTERVENTION ..................................................... 13

6. IMPACTS OF THE POLICY INTERVENTION .............................................................. 14

6.1. ECONOMIC IMPACTS..................................................................................................... 15

6.2. SOCIAL IMPACTS ........................................................................................................... 26

6.3. ENVIRONMENTAL IMPACTS ....................................................................................... 26

6.4. COST BENEFIT ANALYSIS ............................................................................................ 27

6.5. SENSITIVITY ANALYSIS ............................................................................................... 28

7. STAKEHOLDERS’ VIEWS ON THE PROPOSED INTERVENTION ........................... 31

ANNEX 1: SELECTION OF CROSS-BORDER JOURNEYS ................................................. 33

ANNEX 2: CALL FOR EVIDENCE .......................................................................................... 38

ANNEX 3: ANALYTICAL METHODS .................................................................................... 44

Glossary

Term or acronym Meaning or definition

AJC Agreement on Journey Continuation

ERA European Union Agency for Railways

GCC-CIV/PRR General Conditions of Carriage for Rail Passengers

HOTNAT Hop On the Next Available Train

MDMS Multimodal Digital Mobility Services

PRM Persons with disabilities and persons with reduced

mobility

RPRR Regulation (EU) 2021/782 on rail passengers’ rights and

obligations

RMB Regulation on Multimodal Booking

RTR Rail Ticketing Regulation

1

1. POLITICAL AND LEGAL CONTEXT

Passenger rights form the cornerstone of the EU transport and consumer policy. The EU is

the only region in the world to provide passengers with comprehensive protection across

all modes of transport: air, rail, bus and coach, and waterway. Since 2004, this framework

has been underpinned by four core Regulations covering each mode1, plus a fifth dedicated

to passengers with reduced mobility travelling by air2. It continues to evolve, most recently

with the relaunch, in October 2025, of the interinstitutional negotiations relating to the

Commission’s proposal to amend the Regulation on air passenger rights3, along with the

ongoing negotiations on the 2023 proposals on passenger rights for multimodal journeys4

and on the enforcement of passenger rights5.

Within this framework, the rail sector plays a central role in achieving the EU’s transport,

connectivity, competitiveness, and climate ambitions. In his report on the Single Market6,

Enrico Letta emphasises that the railway sector is essential to its success, serving as a

backbone for EU connectivity. By linking regions and Member States, railways foster

economic cohesion and contribute to the EU’s climate objectives, accounting for only 0.3%

of transport-related greenhouse gas emissions and offering a sustainable alternative to road

and air travel.7 However, as highlighted by Mario Draghi in his report on the Future of

European Competitiveness, the Single European Railway Area remains incomplete.

Twenty-five years of market opening have been undermined by fragmentation,

monopolies, and technical barriers, leaving passengers with limited high-speed options,

complex bookings, and weaker consumer passenger rights8.

In 2023, rail represented 8.4% of overall land passenger transport, and it was the third most

used mode after cars and air travel. From 2000 to 2023, the number of passenger-

kilometres travelled by rail grew by 29.2%, reflecting a 1.1% average increase per year9.

1 Regulation (EC) No 261/2004 establishing common rules on compensation and assistance to passengers in

the event of denied boarding and of cancellation or long delay of flights, Regulation (EU) 2021/782 on rail

passengers’ rights and obligations, Regulation (EU) No 1177/2010 concerning the rights of passengers when

travelling by sea and inland waterway, Regulation (EU) No 181/2011 concerning the rights of passengers in

bus and coach transport, and Regulation (EC) No 1107/2006 concerning the rights of disabled persons and

persons with reduced mobility when travelling by air. 2 Regulation (EC) No 1107/2006 concerning the rights of disabled persons and persons with reduced mobility

when travelling by air. 3 COM(2013) 130 final 4 COM(2023) 752 final 5 COM(2023) 753 final 6 Enrico Letta (2024), “Much More Than A Market” 7 Ninth monitoring report on the development of the rail market under Article 15(4) of Directive

2012/34/EU of the European Parliament and of the Council, p. 2. eur-lex.europa.eu/legal-

content/EN/TXT/PDF/?uri=CELEX:52025DC0439 8 Mario Draghi (2024), “The Future of European Competitiveness”. See, in particular, the in-depth analysis

of transport policies in Part B of the report. 9 European Commission (2025), Statistical pocketbook 2025. Statistical pocketbook 2025 - Mobility and

Transport - European Commission

2

The combined share of regional, long-distance and international rail journeys is on average

57% of all rail journeys in the EU10.

In 2017, the European Commission proposed a revision of Regulation (EC) No 1371/2007

on rail passengers’ rights and obligations11. This proposal led to the adoption of Regulation

(EU) 2021/782 on rail passengers’ rights and obligations (hereafter “Regulation (EU)

2021/782” or “RPRR”), which entered into application on 7 June 2023 and replaced and

repealed Regulation (EC) No 1371/200712. The RPRR applies to both international and

domestic rail journeys (suburban, urban, regional and long-distance) throughout the Union

provided by one or more railway undertakings licensed in accordance with Directive

2012/34/EU.13 Key elements of the revision included real-time dynamic travel

information, a common EU-wide compensation and reimbursement form14, and stronger

tools for national enforcement bodies (NEBs). It also enhanced the protection for persons

with disabilities and persons with reduced mobility (PRM), required dedicated spaces for

assembled bicycles on new or upgraded trains, introduced a right to self‑rerouting, and

obliged railway undertakings to cooperate with station managers on contingency planning.

For the first time, it established, albeit limited, obligations for sole railway undertakings to

offer through‑tickets for their respective long-distance or regional services (with the

obligation to make all reasonable efforts to offer through-tickets for other services)15,

strengthening passenger protection on connecting journeys. This revised framework

reinforced the commitment to standardised and fair railway operations across Member

States.

This analytical Staff Working Document (SWD) builds on and updates the analysis in the

Impact Assessment accompanying the 2017 proposal to revise Regulation (EC) No

1371/2007 (hereafter the “2017 IA SWD”)16. The 2017 IA SWD presented two policy

measures as part of two broader policy scenarios: policy scenario A under which all single

journeys sold in a single purchase would have to be considered a through-ticket and hence

10 Milieu consulting and Transport & Mobility Leuven (2026), Support study for a targeted revision of

Regulation (EU) 2021/782 on rail passengers’ rights and obligations. 11 Regulation (EC) No 1371/2007 of the European Parliament and of the Council of 23 October 2007 on rail

passengers’ rights and obligations (OJ L 315, 3.12.2007, p. 14). 12 Regulation (EU) 2021/782 of the European Parliament and of the Council of 29 April 2021 on rail

passengers’ rights and obligations (recast), (OJ L 172, 17.5.2021, p. 1) 13 Directive 2012/34/EU of the European Parliament and of the Council of 21 November 2012 establishing

a single European railway area (OJ L 343, 14.12.2012, p. 32). Railway undertakings are defined as any public

or private undertaking that is licensed under the Single European Railway Area Directive, whose principle

business is the provision of services for the transport of goods and/or passengers by rail, and which is required

to ensure traction. This definition also covers undertakings which provide traction only. 14 Available in all EU official languages on https://transport.ec.europa.eu/reimbursement-and-compensation-

requests-form_en. See also Commission Implementing Regulation (EU) 2024/949 of 27 March 2024

establishing a common form for rail passengers’ reimbursement and compensation requests for delays,

missed connections and cancellations of rail services in accordance with Regulation (EU) 2021/782 of the

European Parliament and of the Council, ELI: http://data.europa.eu/eli/reg_impl/2024/949/oj . 15 A through-ticket provides passengers with comprehensive, unified rights across successive rail services

operated by one or more railway undertakings, equivalent to a single journey. It is defined as a ticket or

tickets representing a transport contract for successive railway services operated by one or more railway

undertakings, as defined in Article 3(35) of Directive 2012/34/EU of the European Parliament and of the

Council of 21 November 2012 establishing a single European railway area. See section 2.1. 16 SWD(2017)318 final

3

come with a full set of passenger rights17; and policy scenario B which adds to scenario A

that through-tickets would have to be offered where technically possible, while railway

undertakings would not be obliged to conclude agreements between them. Under scenario

B, railway undertakings and ticket vendors would also have the burden of proof towards

passengers that no through-ticket was sold18. In its proposal, the Commission opted for

policy scenario B as it was considered at the time that this would better serve passengers

who ask to obtain through-tickets, while ensuring alignment with the 4th Railway Package

where the Commission clarifies certain aspects related to through-tickets and their

availability and declares its intention to monitor rail market developments in the Member

States in this respect. The co-legislators built on this policy option during negotiations on

the proposal. In particular, they specified that ‘sole railway undertakings’ have to offer

their long-distance and regional rail passenger services as a through-ticket. The concept of

a ‘sole railway undertaking’ does not only concern a rail operator’s own services but also

services of several rail operators that are entirely owned by the same entity. The co-

legislators also agreed that for other services, railway undertakings have to make ‘all

reasonable efforts’ to offer through-tickets and cooperate to that end among themselves.

This analytical SWD also describes how the market and the problem of the insufficient

protection under multi-operator journeys have evolved since the adoption of Regulation

(EU) 2021/782. It also provides an updated assessment of the expected impacts of the

intervention by means of a cost-benefit analysis.

Recognising the importance of seamless and sustainable travel, President von der Leyen

stressed in the Political Guidelines 2024-202919 that it should be made easier for people to

shift to more sustainable travel options, in particular to cross-border rail. This is key to

achieving the European Union’s climate objectives. In this regard, the Political Guidelines

say: ‘[…] Cross-border train travel is still too difficult for many citizens. People should be

able to use open booking systems to purchase trans-European journeys with several

providers, without losing their right to reimbursement or compensatory travel. To this end

we will propose a Single Digital Booking and Ticketing Regulation, to ensure that

Europeans can buy one single ticket on one single platform and get passengers’ rights for

their whole trip’.

This initiative complements the initiative for a Rail Tiketing Regulation (RTR), which

contains rail-specific measures enabling comprehensive comparability and availability of

rail tickets, including single tickets for multi-operator journeys. It also complements the

17 This was outlined as follows: “This measure would define that single journeys which are sold in a single

purchase, under a single transport contract with multiple tickets have always to be considered as a ‘through

ticket’ by railway undertakings and ticket vendors. As a result, the rights under the Regulation e.g. to

assistance, reimbursement, rerouting or compensation apply to the whole journey.” 18 Policy scenario B added the following measure to Policy scenario A: “This measure makes it clear, as

already pointed out in the Interpretative Guidelines, that the possibility to purchase through tickets has to

be offered wherever this is technically possible. The measure would, however not oblige railway

undertakings to conclude agreements with each other, as this would interfere in their business conduct and

commercial freedom. Railway undertakings and tickets vendors would, in addition, have the burden of proof

if no through-ticket was sold, i.e. that the obligations under the Regulation to e.g. assistance, reimbursement,

rerouting or compensation do not apply to the whole journey but only to the different segments of the

journey“. 19 “Europe’s choice, Political Guidelines for the next European Commission 2024-2029”, 18 July 2024,

available at https://commission.europa.eu/document/e6cd4328-673c-4e7a-8683-f63ffb2cf648_en.

4

initiative for a Regulation on Multimodal Booking (RMB) that contains horizontal, mode

agnostic rules ensuring a level playing field between MDMS platforms20 and transport

operators21. Together, these initiatives aim to make rail travel more attractive, integrated,

accessible, and fair, reinforcing both the EU’s climate goals and the creation of a

seamlessly connected and competitive European transport network.

2. INSUFFICIENT PROTECTION UNDER MULTI-OPERATOR JOURNEYS

Rail journeys within the European Union, particularly cross-border, often require

passengers to combine different rail services (regional, long-distance or cross-border) from

more than one railway undertaking in a single journey. However, the level of protection

afforded to passengers in the event of missed connections between these rail services

currently varies, even where the tickets for the journey are purchased in a single transaction

on a single platform. At present, EU law grants protection in such cases only to passengers

holding ‘through-tickets’.

2.1. LOW AVAILABILITY OF THROUGH-TICKETS

A through-ticket is a ticket, representing one (single) transport contract, covering

successive railway services operated by one or more railway undertakings for a given rail

journey.22 Such a ticket gives rise to a full set of rail passenger rights in the event of missed

connections between those services, in particular the rights to reimbursement or re-routing,

to assistance and to compensation23.

Under Regulation (EU) 2021/782, the issuance of a through-ticket can be the result of one

of the following cases:

1. The obligation to offer through-tickets for successive railway services from ‘sole

railway undertakings’ under Article 12(1) of Regulation (EU) 2021/782;

2. A cooperation between railway undertakings for other services than those under point

one above, to offer through-tickets for particular journeys;

3. Where a railway undertaking, on its own initiative, sells a combination of tickets for a

journey involving operators that are not part of the same sole railway undertaking, and

does so in a single commercial transaction.

However, the obligation to offer through-tickets is rather narrow. First, the obligation to

offer through-tickets under the first case above is restricted to long-distance or regional

services from a ‘sole railway undertaking’, i.e. a rail operator’s own services or services

of several rail operators that are wholly owned by the same entity. Second, the requirement

for railway undertakings to cooperate among themselves to offer through-tickets for other

services under the second case above is limited to ‘all reasonable efforts’. Such bilateral

20 Multimodal Digital Mobility Services (MDMS) are platforms providing traffic and travel information (e.g.,

schedules, tariffs and availability of services) and enabling the distribution of tickets, directly or via re-

linking, for two or more transport operators, operating in one or more transport modes. 21 EU rules on multimodal digital mobility services and single digital booking & ticketing 22 See Article 3(9) of Regulation (EU) 2021/782, read together with Article 3(35) of Directive 2012/34/EU. 23 Article 12(3) of Regulation (EU) 2021/782.

5

cooperations take place on a case-by-case basis, , as showcased below. Third, ticket

combinations sold by railway undertakings under the third case above are presumed to

constitute through-tickets. However, this presumption does not apply if the undertaking

clearly informs the passenger, prior to purchase, that the tickets represent separate transport

contracts. It should also be noted that ticket combinations offered by third-party ticket

vendors on their own initiative in a single commercial transaction do not qualify as

through-tickets under the RPRR. Nonetheless, to avoid any misunderstanding that this

single booking does not offer the same level of protection as through-tickets, the third-

party ticket vendor has to inform passengers clearly and prior to purchase about the fact

that it does not sell a through-ticket24.

As explained further below, and also highlighted in the Report on the implementation and

results of Regulation (EU) 2021/782 on rail passengers' rights and obligations, the offer of

through-tickets covering services of more than one sole railway undertaking remains

limited and is not consistently available across the EU, especially for cross-border

journeys.

As regards domestic rail travel, it has to be pointed out first that all incumbent railway

undertakings (except in PL, see Figure 1) have Significant Market Presence (SMP) in the

overall national rail transport service market, i.e. a market share above 50% in terms of

passenger kilometres25. Consequently, in Member States with a dominant incumbent

railway undertaking, a substantial share of domestic rail journeys may already be operated

under through-tickets, as this protection is legally mandated (Article 12(1) RPRR) for long-

distance and regional services provided by a sole undertaking.26 However, such higher

domestic availability of through-tickets is a mere consequence of the overall SMP of

incumbent railway undertakings within their domestic market. Without effective rules on

passenger rights protection in case of missed connections between different railway

undertakings a level playing field amongst all market participants is not ensured, going

against Union objectives for enhanced market opening and for interoperability under the

Single European Rail Area.

24 Under Art. 12(4) of Regulation (EU) 2021/782, where a ticket or tickets are purchased in a single

commercial transaction and the ticket vendor or tour operator has combined the tickets on its own initiative,

the ticket vendor or tour operator that sold the ticket or tickets shall be liable to reimburse the total amount

paid for that transaction for the ticket or tickets and, moreover, to pay compensation equivalent to 75 % of

that amount in the event that the passenger misses one or more connections. It follows from Art. 12(7) of

that same Regulation that this liability shall not apply if it is mentioned on the tickets, or on another document

or electronically in such a manner that allows the passenger to reproduce the information for future reference,

that the tickets represent separate transport contracts, and the passenger was informed of this prior to the

purchase. 25 It needs to be noted however that market shares relating to particular type of passenger rail service (long-

distance, regional, cross-border) may be different. 26 Furthermore, in some Member States some particularities have been identified. For example, in

Luxembourg, second-class rail travel on passenger services operated by the main railway undertaking is free

of charge and does not require a (through-)ticket.°(26) In the Netherlands, a national check-in and check-out

system is in place. Passengers’ journeys start when they check in at the station of departure and end when

they check out at the station of the final destination, regardless of any transfers, the type of rail services used

or changes of operator. In practice, this appears to function as a through-ticketing system. See

Communication - Report on the implementation and results of Regulation (EU) 2021/782 on rail passengers'

rights and obligations, COM(2026) 228

6

Figure 1: Incumbent market share (in terms of pkm) in the passenger service market per Member

State (2022)

Source: Rail market monitoring (RMMS), July 2025

Evidence suggests that domestic through-ticketing schemes covering several railway

undertakings in a single Member State are available only in a limited number of Member

States. In 2021, a study commissioned by the European Commission identified instances

of extensive through-ticketing in some Member States and limited availability of through-

ticketing in others.27 The list below includes schemes quoted in the 2021 study, along with

additional cases found through desktop research:

- In Czechia, under the Oneticket system, regardless of the number of operators, the

entire domestic journey is considered as a single transport contract when it is done

within the railway network of the country. Passenger’s rights for travel disruptions

apply28.

- In Germany, railway undertakings participate in a common fare system under the

Deutschlandtarif. Tickets issued for a journey consisting of directly adjacent rail

services of undertakings participating in the Deutschlandtarif, including temporary

passes like the monthly Deutschlandticket, are considered to be a through-ticket under

the RPRR. The Deutschlandtarif mainly concerns regional and (sub)urban rail

passenger services from around 50 public and private railway undertakings, and does

not include long-distance services from e.g. DB Fernverkehr AG, Flixtrain or

Eurostar29.

- In Hungary, all tickets for domestic journeys are considered through-tickets, including

multi-operator tickets. It has to be noted however that most domestic passenger rail

services are operated by MÁV. GYSEV operates only some railway services in the

North-West of the country and GYSEV is also partially Hungarian state owned like

MÁV30.

- In Poland, PKP Intercity cooperates with nine regional rail operators to offer joint

tickets that integrate fares (Wspolny Bilet - WB). WB does not extend to journeys on

27 Steer and KCW (2021), Long-distance cross-border passenger rail services, Final Report, Study Contract

MOVE/2020/OP/0013, Annex N, p. 329. 28 https://oneticket.cz 29See https://www.deutschlandtarifverbund.de/ueber-uns/ as well as parts A and C of the fare conditions

(Tarifbedingungen; version of 14.12.2025) 30 https://www.mavcsoport.hu/sites/default/files/upload/page/vasuti_uzletszabalyzat_25.10.01.pdf

7

TLK31 or Intercity (IC) trains in sleeper or couchette cars, or to rail services operated

by operators who decided not to take part in this cooperation32. In the event of delays

or other obstacles causing missed connections, passengers can obtain a delay

certificate for conditional continuation on the next available train of the participating

operator, subject to seat availability, with rights to refunds or compensation for the

whole integrated fare from the issuing operator33. The scheme does not, however,

seem to cover some independent railway undertakings active on the Polish market

such as RegioJet and Leo Express34.

- In Sweden, Resplus offers passengers the ability to combine travel with several

transport operators (train, bus, ferry, etc.) under one Resplus ticket, thanks to a

cooperation among Sweden’s public transport operators. Every train that starts or ends

in Sweden is covered by Resplus. In the event of a missed connection during a Resplus

journey, the Kom-Fram-Garanti (Arrival Guarantee) applies: the operator causing the

passenger to miss his connection is liable to ensure that the passenger can continue

their journey, provides alternatives for rebooking, accommodation, food and

beverages, a partial or full reimbursement or a delay compensation (for combined trips

with a total distance over 150 km), using the same thresholds and values as in the

RPRR35.

The low availability of through-tickets is particularly evident in the context of cross-border

rail journeys. While the information on the availability of through-tickets across the Union

is not readily available, Annex 1 shows a number of cross-border rail journeys in the EU

for which tickets can currently be bought in a single transaction on a single platform, either

directly from a railway undertaking or from a third-party ticket vendor. As illustrated in

Annex 1 and based on available evidence, most cross-border rail journeys are not offered

as through-tickets, leaving passengers without a clear framework to rely on if they miss a

connection. This results in unequal protection for passengers purchasing a trans-European

rail journey creating a strong disincentive for them to opt for rail for their cross-border

travel. Moreover, in the call for evidence linked to this initiative36, 4 out of 11 responses

received from consumer organisations describe cross-border ticketing as fragmented and

complex. The Greenpeace report also states: ‘The rail ticketing system in Europe is overly

complicated and not unified. For 44 out of the 109 cross-border routes analysed (40%), it

was not – or not always – possible to purchase a through-ticket, i.e. a single ticket covering

the entire journey. On most of these routes, a through-ticket was unavailable on any of the

days analysed; on others, it was only available on certain days, depending on the train

schedule.’37 This weaker consumer protection for cross-border rail journeys is also

recognised in Mario Draghi’s report: ‘Operators active in more than one national market

31 TLK or Twoje Linie Kolejowe are long-distance trains with more stops and lower speeds than IC trains. 32https://kolejedolnoslaskie.pl/wp-content/uploads/2024/06/Zalacznik-nr-2-do-ZW-WB_dane-

przewoznikow.pdf 33https://www.intercity.pl/pl/dokumenty/wspolny-bilet/tekst_ujednolicony_ZW-WB_zm_1-

20_2507_2025.pdf 34 https://www.gov.pl/web/infrastruktura/wspolny-bilet 35 https://samtrafiken.se/tjanster/resplus 36 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14691-Targeted-revision-of-

Regulation-EU-2021-782-on-rail-passengers-rights-and-obligations_en 37 https://greenpeace.at/uploads/2025/08/greenpeace-analysis-flight-vs-trains-2025.pdf

8

remain the exception in the EU. Consequently, the number of long-distance cross-border

rail services in Europe has hardly increased during the last two decades. Consumers

experience a lack of fast connections, complexity in booking multiple legs of journeys and

weaker consumer passenger rights […]’38.

The call for evidence related to this targeted revision (see Annex 2) points to a recurring

frustration among passengers on the lack of passenger rights for journeys bought in a single

transaction on a single platform. 36 citizens reported that passengers currently bear almost

all the risk of delays and missed connections in multi-operator journeys, with no clear

responsible party, inconsistent compensation practices, and frequent situations of being

stranded without help. In addition, 9 citizens reported to have purchased routes that they

assumed to be a single journey, only to find out after a disruption that their journey was

considered as multiple separate contracts. 11 citizens described situations in which rail

undertakings were shifting responsibility onto one another or using technicalities (i.e.,

delays slightly below a threshold on one leg, even if the journey was severely disrupted)

to avoid liability. Several consumer associations and NGOs, like BEUC, ECCNet and

T&E, also note the limited availability of through-tickets. Moreover, they see the current

legal regime as too narrow, too complex, and not suited to how people actually buy and

combine tickets today (often via digital platforms and involving several operators). 5

organisations out of 11 argue that stronger passenger protection can increase consumer

confidence in rail travel and favour a multimodal shift from other means of transport.

Moreover, the Eurobarometer survey 551, which is representative of the EU population,

shows that 18% of citizens avoid rail connections operated by different rail operators for

fear of being stranded in case of a missed connection39.

Therefore, passengers who book a multi-operator journey, especially cross-border, are not

always protected under EU law, even if they purchase all their tickets in a single transaction

on one platform. They are only guaranteed EU protection (assistance, re-routing or

reimbursement, and compensation) when they hold a through-ticket, which is not generally

available for all rail journeys, especially cross-border, as shown above.

2.2. MULTILATERAL SECTOR AGREEMENTS OFFER LIMITED RELIEF

It needs to be acknowledged that some railway undertakings have entered into multilateral

sector agreements to assist passengers if they miss a connection between rail services of

different undertakings which are not covered by a through-ticket (e.g. Agreement on

Journey Continuation (AJC)40, Hop On the Next Available Train (HOTNAT)41). However,

these business-to-business initiatives do not grant any individual rights to passengers and

38 Mario Draghi (2024), “The Future of European Competitiveness”. See in particular the in-depth analysis

of transport policies in Part B of the report and page 213. 39 European Commission (2025), Eurobarometer 551 Multimodal Digital Mobility Service. Accessed

https://europa.eu/eurobarometer/surveys/detail/3178 40 See the latest information leaflet on the AJC on the website of the International Rail Transport Committee

(CIT), published in December 2025: https://www.cit-rail.org/media/files/civ-products-april-

2025/ajc_leaflet_2025-12-14_en.pdf?cid=437997 (Note: the full agreement is not public). 41 See Railteam’s website: https://www.railteam.eu/en/services-on-your-journey/hop-on-the-next-available-

train-hotnat/ HOTNAT involves only a limited number of high-speed rail operators belonging to Railteam

(Deutsche Bahn, Eurostar, ÖBB, SNCF, SBB, SNCB/NMBS and NS. It only covers their high-speed

network.

9

are merely voluntary and self-binding on the undertakings42. They currently cover only

approximately twenty-three railway undertakings for AJC and seven high-speed operators

for HOTNAT. The AJC is limited to passengers undertaking international rail journeys

and HOTNAT to passengers using specific cross-border high-speed rail services. As a

result, passengers performing domestic long-distance and regional travel are left out of

these agreements, even though they also form a substantial part of rail passengers in the

EU.43 These sector agreements are also not widely known by passengers and train staff44,

are limited to offering journey continuation on the next available service, subject to the

availability of seats45 and the conditions for making use of these agreements can be unclear

to passengers46.

In the feedback to the call for evidence47, four consumer organisations and NGOs, as well

as an association of new rail entrants48, considered existing schemes to be insufficient and

unknown to passengers. Conversely, six incumbent railway undertakings and their

associations argue that the AJC represents a standard set by the sector which should be

used as a basis for any further regulatory intervention.49

It needs to be noted that the need to improve the AJC to provide better support during

disruptions and delays was included in the CER Ticketing Roadmap in 202150. While the

CER Ticketing Roadmap 6th Implementation Monitoring Report51 notes progress on

Action 8 (Better support during disruptions and delays), through expanded AJC

membership over the years and increased digitisation of ticket inspections across railway

undertakings52, this voluntary scheme still falls short of robust, comprehensive protection

for passengers during journey disruptions. Its non-universal adoption and limitation to

journey continuation does not provide for comprehensive and legally-enforceable

passengers’ protection during multi-operator journeys, while lacking binding enforcement

and relying on variable individual railway commitments rather than a level playing field

42 For example, the AJC’s information leaflet states that “As it is a commercial gesture, it is a self-binding

offer from the railway undertakings and differs from the rights you can claim e.g. under the [RPRR]”. 43 The combined share of regional, long-distance and international rail passengers out of the total number of

passengers travelling by rail is estimated at 57% at EU level. See also section 5.1. 44 See Annex 2: Call for evidence 45 “The AJC will allow you only to continue the journey by train, and does not reimburse you any costs for

hotels, taxis, payments for the ticket or compensation. Nor will the participating railway undertakings

provide you with complimentary meals or refreshments.” (AJC information leaflet); “HOTNAT allows

travellers to take the next available high-speed service leaving from the same transit station as originally

planned, when a delay on or cancellation of the inbound Railteam member’s high-speed service prevents

them from making their originally-planned connection.” (Railteam website). 46 To this end, CIT and the European Passengers’ Federation (EPF) jointly developed a note which “is

intended as a lay-person’s informal guide to what to do if passengers miss their connection on an

international journey and want to benefit from the AJC.”, see https://www.epf.eu/wp/digitalisation-of-the-

ajc/ and https://www.cit-rail.org/secure-media/files/civ-products-april-2025/ajc-note_2025-12-

14_en.pdf?cid=437998 . 47 Targeted revision of Regulation (EU) 2021/782 on rail passengers’ rights and obligations 48 Including ALLRAIL, BEUC, T&E, EPF, and UFC-Que Choisir. 49 Including CER, SNCF, SNCB, České dráhy, ÖBB and Deutsche Bahn. 50 CER Ticketing Roadmap 2021 available at:

https://www.cer.be/images/publications/positions/210920_CER_Position_Paper_Ticketing_Roadmap.pdf 51 CER Ticketing Roadmap 6th Implementation Monitoring Report, Spring 2025, available at:

250929_CER_Ticketing_Roadmap_6th_Report.pdf 52 Notably by means of the UIC initiative on the Electronic Ticket Control Database (eTCD).

10

framework. Furthermore, and as shown by the CER Ticketing Roadmap 7th

Implementation Monitoring Report, its further improvements are planned only by 2030

and are conditional on, amongst others, ‘sustained commitment by railway undertakings’

leaving a high degree of uncertainty as to the timely realisation of the industry goals53.

3. NECESSITY AND ADDED VALUE OF EU ACTION

While rail passenger transport in the EU occurs mainly at the national level54, cross-border

rail travel is growing55. At the same time, to promote rail services and cross-border

mobility, the EU must ensure that passengers travelling by rail across Member States enjoy

the same rights. National legislation alone cannot address the complexities of cross-border

journeys. EU-level intervention is therefore essential to guarantee uniform, high standards

of protection for all rail passengers. Only binding EU rules can secure equal rights for

passengers and a level playing field for operators56.

Without EU action, passengers who miss connections between trains operated by different

railway undertakings will likely continue to face limited support, even when tickets for a

journey are purchased in a single transaction on a single platform. This can result in

additional costs for alternative transport or overnight stays, undermining the attractiveness

of rail - including cross-border connections - compared with less sustainable modes.

Without EU action, gaps in passenger protection will persist, even with initiatives such as

the Single Digital Booking and Ticketing Regulation or the Multimodal Digital Mobility

Services framework. While these measures improve ticketing conditions, they do not cover

passenger rights in the event of missed connections.

The European Union has already taken steps to improve rail passenger protection by means

of the first rail passenger rights Regulation (EC) No 1371/2007 and the subsequent

adoption of the (recast) Regulation (EU) 2021/782 on rail passengers’ rights and

obligations. While already going in the right direction, this legislation has not solved the

insufficient protection of passengers during multi-operator journeys. The Treaty on the

Functioning of the European Union confers upon the EU the competence to lay down

appropriate provisions in the transport sector (Article 91 TFEU).

4. OBJECTIVES

In view of the problem identified in Section 2, the objective of this intervention is to

contribute to ensuring rail passenger rights for cross-border, long-distance and regional rail

journeys involving one or more connections carried out by at least two different railway

53 https://www.cer.be/cer-reports/cer-ticketing-roadmap-7th-progress-report 54 In 2022, domestic passenger services represented around 93% of all passenger-kilometres in the EU-27,

whereas international rail passenger services accounted for around 7% of total rail traffic. Rail market

monitoring (RMMS), July 2025. 55 See for instance: Ministerial Platform on International Rail Passenger Transport (IRP) , International rail

passenger market on the right track according to new progress report, 2024 56 See also the first sentence of recital 5 of Regulation (EU) 2021/782: “Granting the same rights to rail

passengers taking international and domestic journeys seeks to raise the level of consumer protection in the

Union, to ensure a level playing field for railway undertakings and to guarantee a uniform level of

passengers’ rights.”

11

undertakings, provided that the passenger acquires a single ticket57 for a journey in a single

transaction. This ties to the objective of the same measure in the impact assessment

accompanying the Proposal for a Regulation from the European Parliament and the

Council on rail passengers' rights and obligations (recast), published in 201758, which was

to improve the application and enforcement of the Regulation, so that all passengers can

fully exercise their rights when travelling by rail in the EU. The interinstitutional

negotiations on this legislative proposal resulted in the adoption of Regulation (EU)

2021/782 on rail passengers’ rights and obligations. This intervention aims for a targeted

amendment of that Regulation.

5. POLICY INTERVENTION

5.1. BASELINE SCENARIO

In line with the Better Regulation toolbox (Tool #60), the baseline has been designed to

include the initiatives of the ‘Fit for 55’ package59 and the amendment of the European

Climate Law to include a 2040 climate target for the EU60, of reducing the EU's net

greenhouse gas emissions by 90% by 2040 relative to 1990, with a limited contribution

towards the 2040 target of high-quality international credits. It also reflects the CO2

emission performance standards for heavy-duty vehicles61, the Euro 7 standards62, the

revised TEN-T Regulation63, as well as the initiatives part of the Greening Freight

package64 and Roadworthiness package65. It also reflects the National Energy and Climate

Plans prepared by the Member States under the Regulation 2018/1999 on the Governance

of the Energy Union and Climate Action and submitted to the Commission during 2024-

2025. The baseline is common to that of the impact assessment accompanying the

initiatives on Multimodal Digital Mobility Services and the Single Digital Booking and

ticketing regulation.

The baseline scenario assumes no further EU level intervention beyond the Regulation

(EU) 2021/782 on rail passengers’ rights and obligations. Despite the obligation on railway

undertakings to make all reasonable efforts to cooperate between them to offer through-

tickets, the baseline assumes no systematic and comprehensive cooperation and

corresponding offer for long-distance and regional journeys in the Union. Therefore,

without action at EU level, the current situation is likely to continue, meaning that

passengers holding a single ticket for a multi-operator journey with one or more

connections will not be guaranteed protection in the event of a missed connection, unless

a through-ticket is in place.

57 Valid evidence, regardless of its form, of a through-ticket or of the conclusion of two or more transport

contracts for a journey purchased on a single ticketing platform in a single commercial transaction from a

railway undertaking, ticket vendor or tour operator. 58 SWD(2017)318 final 59 Delivering the European Green Deal - European Commission 60 COM(2025) 524 final 61 Regulation (EU) 2024/1610 62 https://eur-lex.europa.eu/eli/reg/2024/1257/oj/eng 63 Regulation - EU - 2024/1679 - EN - EUR-Lex 64 Green Deal: Greening freight for more economic gain with less environmental impact (europa.eu). 65 Updated rules for safer roads, less air pollution and digital vehicle documents

12

The baseline also incorporates perspectives on potential future developments captured in

the 2022 Strategic Foresight Report66 and during a foresight workshop organised by DG

MOVE and JRC on 10 February 2025, analysing the impacts of the megatrends and drivers

of change on the EU transport sector67. In particular, the projected transport activity draws

on the long-term population projections from Eurostat and GDP growth from the Ageing

Report 202468. An increasingly connected world with high levels of access to digital

products and services and in which new services, business models, life and work patterns

emerge is the background against which the initiative is assessed.

The number of passengers travelling by rail is projected to increase from 8.6 billion in

2019 to 9.6 billion in 2028, 10.7 billion in 2030 and 12.5 billion by 2050, driven in

particular by the completion of the TEN-T core network by 2030, the extended core

network by 2040 and of the comprehensive network by 205069, supported by the CEF,

Cohesion Fund and ERDF funding, but also by measures of the ‘Fit for 55’ package and

the revised TEN-T Regulation.

The share of regional, long-distance and international rail passengers is estimated at 57%

at EU level and is assumed to be kept constant over time in the baseline scenario70. Thus,

the number of regional, long-distance and international rail passengers is projected to

increase from 5.5 billion in 2028 to 6.1 billion in 2030 and 7.1 billion in 2050. Out of this,

the number of regional, long-distance and international passengers taking journeys

involving multiple rail undertakings (excluding through-tickets) is estimated at 748 million

in 2028, increasing to 836 million in 2030 and 962 million in 205071. For the analysis, all

these journeys are assumed to be booked on one platform in a single transaction. However,

acknowledging the large uncertainty regarding the estimates, sensitivity analysis has been

further performed in section 6.5.

The number of passengers subject to delayed and cancelled trains that result in missed

connections for journeys booked on one platform in a single transaction are estimated at

24.5 million in 2028, 25.8 million in 2030 and 15.9 million in 2050 (see Table 1). Their

number is projected to increase until 2030, due to the expected increase in the rail travel,

but post-2030 this is projected to be counterbalanced by improvements in punctuality,

driven by the implementation of the TEN-T Regulation. More detailed information on the

baseline scenario is available in Annex 3.

66 COM(2022) 289 final 67 https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en#explore 68 DG ECFIN, 2024 Ageing Report. Economic and Budgetary Projections for the EU Member States (2022-

2070) - Economy and Finance 69 The core network includes the most important connections between major cities and nodes, and must be

completed by 2030. The extended core network needs to be completed ten years later, in 2040. The

comprehensive network connects all regions of the EU to the core network and needs to be completed by

2050. 70 Milieu consulting and Transport & Mobility Leuven (2026), Support study for a targeted revision of

Regulation (EU) 2021/782 on rail passengers’ rights and obligations. 71 According to the support study, multi-operator rail journeys, other than through-tickets, represent around

13% of ticket sales in regional, long-distance, and international services at EU level.

13

Table 1: Number of passengers subject to delayed and cancelled trains that result in missed

connections for journeys booked on one platform in a single transaction (in million) Country 2028 2030 2040 2050

AT 0.68 0.67 0.55 0.44

BE 0.63 0.62 0.50 0.37

BG 0.03 0.03 0.03 0.03

CY 0.00 0.00 0.00 0.00

CZ 0.56 0.59 0.46 0.35

DE 10.75 11.31 8.52 6.23

DK 0.36 0.35 0.26 0.20

EE 0.00 0.00 0.00 0.00

EL 0.03 0.03 0.02 0.02

ES 1.44 1.55 1.28 0.95

FI 0.15 0.15 0.12 0.09

FR 3.91 4.07 3.47 2.90

HR 0.05 0.05 0.05 0.04

HU 0.48 0.45 0.38 0.36

IE 0.14 0.14 0.11 0.09

IT 1.93 2.14 1.88 1.37

LT 0.01 0.01 0.01 0.01

LU 0.04 0.03 0.03 0.02

LV 0.02 0.02 0.01 0.01

MT 0.00 0.00 0.00 0.00

NL 0.66 0.67 0.49 0.37

PL 1.30 1.46 1.23 1.15

PT 0.19 0.18 0.21 0.19

RO 0.32 0.36 0.31 0.23

SE 0.63 0.65 0.48 0.35

SI 0.02 0.02 0.02 0.02

SK 0.20 0.20 0.16 0.13

EU total 24.54 25.75 20.59 15.94

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

5.2. DESCRIPTION OF THE POLICY INTERVENTION

The proposed policy intervention, corresponding to the policy measure proposed during

the last revision (see Section 1 above) , aims to ensure that passengers holding a ticket or

tickets for a journey involving successive regional, long-distance and international services

operated by different railway undertakings are entitled to the full set of passenger rights

where they miss one or more connections during their journey - namely reimbursement or

re-routing, compensation, and assistance - provided that the ticket or the tickets were

purchased on a single ticketing platform and as part of a single transaction (hereafter called

“single ticket”). This ticketing platform on which the single ticket would be purchased, can

be a MDMS platform, but does not have to be one. So also ticketing websites of railway

undertakings or third-party vendors which do not meet the definition of a MDMS platform

14

would be considered in this intervention. For journeys under a single ticket exceeding 12

hours, the right to compensation should arise only in relation to the delay affecting the

specific individual leg (or through-ticket). This should not apply where the journey under

the single ticket involves a night train. In addition, railway undertakings should not be

liable for the rights under this proposed policy intervention where a ticket vendor or tour

operator combines its services in a single ticket without respecting the applicable minimum

connection times. Where ticket vendors or tour operators fail to comply with this

requirement, they should be liable to offer the choice to the passenger between the

reimbursement of the single ticket and the reimbursement of the re-routing costs incurred

by the passenger. Furthermore, they should be liable to pay a compensation of 75% of the

amount paid for the single ticket. Consistently with the current protection of passengers

for single-leg rail journeys under the Regulation, the liability for passenger rights would

remain with the railway undertaking whose delayed or cancelled service caused a missed

connection under a single ticket72. At the same time, railway undertakings whose services

under a single ticket are missed due to a missed connection shall allow the passenger to

continue the journey on their next service, subject to the availability of seats. Moreover,

railway undertakings may entrust another railway undertaking, ticket vendor or tour

operator with the processing of the rights to reimbursement, rerouting, assistance and

compensation. Passengers should be clearly informed before purchase of the single ticket

about this transfer of tasks. This transfer should not affect the liability of the transferring

railway undertaking.

Hence, all passengers with a single ticket would get a comprehensive protection in the

event of a travel disruption. As a result of the intervention, the scope of journeys protected

by passenger rights would be extended from connecting journeys under through-tickets to

all connecting journeys insofar these are bought under a single ticket for regional, long-

distance and international rail services.

6. IMPACTS OF THE POLICY INTERVENTION

This section summarises the main expected economic, social and environmental impacts

of the proposed policy intervention.

The proposed intervention is assumed to be implemented from 2028 onwards, so the

assessment has been undertaken for the 2028-2050 period and covers the EU Member

States. Costs and benefits are expressed as present value over the 2028- 2050 period, using

a 3% discount rate. All costs and benefits are expressed in 2024 prices.

The estimation of the costs and benefits of introducing rights for 'single tickets’, beyond

what is currently applicable for through-tickets, relies on the projected number of journeys

booked on one platform in a single transaction that are affected by train delays and

cancellations resulting in a missed connection. Data was collected in the context of the

support study73 on rail passenger numbers (regional, long-distance and international

72 While not mandated by the intervention, railway undertakings may decide to develop industry-level

operational rules, modelled for instance on AJC/HOTNAT, to share liability and cooperate with regard to

passenger assistance. 73 Milieu consulting and Transport & Mobility Leuven (2026), Support study for a targeted revision of

Regulation (EU) 2021/782 on rail passengers’ rights and obligations.

15

passengers), punctuality performance, share of train cancellations, and the type of rights

triggered by the missed connection (assistance, re-routing, reimbursement, compensation).

Costs and benefits were estimated in the context of the support study drawing on previous

impact assessments74, publicly available data (notably from Eurostat and the European

Union Agency for Railways), feedback received through the call for evidence (see a

summary in Annex 2), and targeted stakeholder interviews. Additional data was drawn

from the national-level information gathered in the process of preparing the

implementation report on the application of Regulation (EU) 2021/782. More detailed

explanations on the methodology and results at Member State level are provided in Annex

3.

6.1. ECONOMIC IMPACTS

6.1.1. Impact on passengers

The measure is expected to benefit passengers in the event of a missed connection during

a multi-operator journey bought under a single ticket by granting them full passenger rights

(such as re-routing, reimbursement, compensation, and assistance) if they miss a

connection on a rail journey involving multiple operators (regional, long-distance and

international). In addition, passengers will also benefit from reduced hassle costs since they

will have the right to claim their passenger rights from the rail operator whose delayed or

cancelled service led to a missed connection.

Benefits for passengers due to re-routing, reimbursement, compensation, and assistance

Passengers with single tickets will have the right to re-routing or reimbursement where

their arrival at the final destination under that single ticket is reasonably expected to be

delayed by at least 60 minutes due to a missed connection. In such a situation, the passenger

will have a choice between: (i) renouncing their journey and get full reimbursement of the

single ticket; (ii) re-routing or continuation of the journey free of charge, either at the

earliest opportunity or at a later date, at the passenger’s convenience. Based on the

available evidence, the proportion of passengers asking for re-routing is assumed at 90%75.

For the purpose of the analysis, it is assumed that those 90% of passengers choosing re-

routing will be re-routed in respect of all cancelled services as well as those delayed by at

least 60 minutes76. However, as rerouting may also be needed when delays are shorter than

60 minutes, sensitivity analysis has been further performed as shown in section 6.5. Out of

74 SWD(2017)318 final, SWD(2023)386. It should be noted that the assessment in the context of the

SWD(2017)318 was not focused on individual measures, and limited data was available as acknowledged in

the staff working document. The assumptions for quantifying the costs and benefits therefore draw on the

SWD(2023)386 and further updated in the context of the support study. 75 Milieu SRL (2026), Support study for the report on the implementation and results of Regulation (EU)

2021/782 on rail passengers’ rights and obligations. It should be noted that in some cases the AJC and

HOTNAT agreements are operational and some passengers on some multi-operator trips will be assisted in

the baseline, albeit on a voluntary basis. However, the number of passengers assisted is not available. Also,

some passengers neither ask for reimbursement nor for re-routing but simply abandon their journey without

asking for reimbursement despite being eligible. For example, Germany reports 60-70% for re-routing, 10-

15% for reimbursement, indicating that 15-30% choose neither. 76 SWD(2023)386

16

the remaining 10% of passengers who are assumed not to request re-routing, it is further

assumed that only 38% of them will actually ask for a reimbursement, with the rest making

no reimbursement claim77.

The benefits for the passengers consist of either: 1) the original ticket price that is

reimbursed, multiplied by the number of affected passengers, or 2) not having to bear the

cost of buying a new ticket or tickets at same prices to get to their final destination thanks

to the re-routing offered by the railway undertaking. The average ticket price per Member

State for regional, long-distance and international trips has been calculated based on the

railway undertakings’ revenues78, the number of passengers79 and the estimated length of

regional, long-distance and international trips. Expressed as present value over 2028-2050,

relative to the baseline, the benefits due to reimbursement or re-routing (see Table 2) are

estimated at EUR 5.84 billion (i.e. EUR 182.3 million for reimbursement and EUR 5.66

billion for re-routing).

Where they have single tickets, passengers will also have the right to compensation in

case they do not ask for reimbursement and provided that they arrive at the final destination

with a delay of at least 60 minutes between the place of departure and the final destination

stated in their single ticket. As above, it is assumed that 90% are expected to prefer re-

routing. The proportion of passengers actually requesting compensation out of those that

experience a delay of at least 60 minutes and do not ask for reimbursement is assumed at

38%80. At the same time, for journeys under a single ticket exceeding 12 hours, the right

to compensation should arise only in relation to the delay affecting the specific individual

transport contract, which corresponds to the baseline. This exemption should not apply

where the journey under the single ticket involves a night train. Given the uncertainty to

establish the number of passengers affected by this exemption, the assumption above is

retained. In line with the RPRR, a compensation of 25% of the ticket price is assumed for

delays of 60 to 119 minutes and 50% for delays above 120 minutes. It is also assumed that

the re-routed passengers due to a cancellation will be delayed for 60-119 minutes, and

benefit of a compensation of 25% of the ticket price, as they will typically be assigned to

the next train one hour later. The compensation benefits for passengers, expressed as

present value over 2028-2050, relative to the baseline, are estimated at EUR 632.3 million

at EU level (see Table 2). Given the uncertainties in estimating compensation benefits and

costs, a sensitivity analysis on the proportion of passengers actually requesting

compensation is elaborated in section 6.5.

Passengers will equally have the right to assistance when a cancelled or delayed service

causes a missed connection. Such assistance can comprise, depending on the

circumstances, basic provision of information, meals, refreshments and accommodation.

Based on the interviews with stakeholders, the average cost of such assistance is assumed

77 In line with SWD(2023)386, the share of passengers that claim reimbursement has been assumed to be

equal to that of passengers that claim reimbursement for travel by buses and coaches, in lack of specific data

for rail. 78 IRG-Rail (2024), 13th Market Monitoring Report, based on railway undertaking revenues for 2023. See

Annex 3 for further explanation. 79 Source: Eurostat. 80 SWD(2023)386. Furthermore, SNCF (France) confirmed in an interview that for TGV, 40% of the

passengers who experienced delays made a claim and received a compensation.

17

to be EUR 10 per passenger affected by the disruption and 5% of passengers are assumed

to request assistance81. Expressed as present value over 2028-2050, relative to the baseline,

the assistance benefits for passengers are estimated at EUR 169.6 million at EU level (see

Table 2).

The total benefits to passengers for re-routing or reimbursement, compensation, and

assistance, expressed as present value over 2028-2050 relative to the baseline, are

estimated at EUR 6.64 billion at EU level (see Table 2).

Hassle costs savings for passengers

In addition to re-routing or reimbursement, compensation and assistance, the proposed

intervention is expected to reduce hassle costs for passengers. This includes the efforts

required to get the information by the passengers, the waiting time due to the missed

connections and the effort to search for new tickets82. The hassle cost savings are quantified

by multiplying the number of affected tickets by the time saved per ticket and the

passengers' average value-of-time. The time saved per ticket is conservatively assumed at

15 minutes83, and the average value of time at EUR 11.68 per hour at EU level84, adjusted

for country-specific differences and distinguishing between professional and leisure

travel85. Total hassle costs savings for passengers, expressed as present value over 2028-

2050, relative to the baseline, are estimated at EUR 1.14 billion at EU level (see Table 2).

Total benefits for passengers

Total benefits for passengers, expressed as present value over 2028-2050 relative to the

baseline, are thus estimated at EUR 7.78 billion at EU level (see Table 2). Around 73% of

these total benefits are related to re-routing. Another 15% of the total benefits represent

hassle costs savings.

Table 2: Benefits for passengers at EU level (in million EUR, 2024 prices) 2028 2030 2040 2050 Present value

2028-2050

Benefits due to re-routing,

reimbursement, compensation, and

assistance

443.2 465.0 375.0 291.0 6,642.8

81 Assistance is estimated at 5% by Germany in its Country Research Template report, which records

national-level information regarding the application of Regulation (EU) 2021/782. In France, requests for

assistance are approximately 3 times less frequent than the requests for compensation. Since the percentage

of passengers requesting compensation (among those entitled to do it) is estimated to 38%, the percentage of

delayed passengers receiving assistance represents 12% in France. 82 This does not include the cost of the actual ticket. 83 A conservative assumption of 15 minutes savings is used. Drawing on a study by the World Bank

(https://thedocs.worldbank.org/en/doc/3ecf7262788a3ec69c8a45bbd3342a28-

0080022021/related/Spring2021-governance-talk-asli-0525.pdf), each complaint handling would benefit of

15 minutes saved under a conservative approach (lower bound) and up to 60 minutes saved (upper bound).

See also SWD(2023)386. 84 European Commission (2019): Handbook on the External Costs of Transport. 85 Source: https://www.autorite-transports.fr/wp-content/uploads/2020/07/enquete-tagv-2019.pdf. From this,

it is assumed that 27% of the train trips have a professional purpose, the remaining 73% are assumed to be

leisure trips.

18

2028 2030 2040 2050 Present value

2028-2050

Re-routing benefits 377.4 396.0 319.5 248.0 5,658.6

Reimbursement benefits 12.1 12.7 10.3 8.0 182.3

Compensation benefits 42.4 44.4 35.7 27.6 632.3

Assistance benefits 11.4 11.9 9.5 7.4 169.6

Hassle cost savings 76.9 80.5 63.8 48.9 1,136.9

Total benefits for passengers 520.1 545.5 438.7 339.9 7,779.7

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

6.1.2. Impact on railway undertakings

For railway undertakings, the proposed measure would require operational adjustments. It

would oblige them to extend the full range of passenger rights (reimbursement, re‑routing,

compensation and assistance) to more travellers, ensuring wider protection under single

tickets. In particular, they would be liable to ensure these rights where the delay or

cancellation of their service caused a missed connection for a passenger with a service of

another railway undertaking, provided that these services are covered by the same single

ticket. This would also lead to some administrative costs related to claims handling and

process adaptation. However, undertakings already participating in AJC or HOTNAT

agreements are likely to face lower additional costs, particularly for re‑routing. At the same

time, it could be expected that greater consumer confidence resulting from passenger rights

would increase demand for rail travel thereby benefiting rail operators, though this effect

cannot be quantified.

One-off and recurrent adjustment costs for railway undertakings

Railway undertakings are expected to incur one-off adjustment costs to ensure passenger

rights in case of missed connections under a single ticket. It will be important for railway

undertakings to define the extent of their financial liability, coordinating disruption

agreements with other railway undertakings, updating technical request-handling

processes, revising terms and passenger information, training sales and support staff, and

reviewing the legal and financial implications. While not mandated by the intervention,

railway undertakings may decide to enhance their mutual cooperation with a view to

reciprocal assistance and information sharing necessary to ensure effective passenger

rights (with the existing AJC and HOTNAT frameworks as likely bases for such

cooperation), being understood that the railway undertaking whose delayed or cancelled

service causes a missed connection shall by default bear the corresponding liability.

The one-off effort required is estimated at 100 person-days of work per railway

undertaking. Assuming 7.2 working hours per day on average86 and the tariff rates by

Member State for the ISCO 3 category (technicians and associate professionals)87 in 2024

prices, the one-off adjustment costs for the 158 railway undertakings88 is estimated at EUR

86 Actual and usual hours of work - Statistics Explained - Eurostat 87 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs. 88 It is estimated that 158 railway undertakings will be directly affected by the intervention, of which 9 SMEs.

Source: desk research based on websites of railway regulators, railway undertakings and competent

authorities.

19

4 million in 2028 (of which EUR 216,000 for SME railway undertakings).

Railway undertakings will also incur recurrent adjustment costs related to the assistance,

reimbursement, re-routing and compensation of passengers.

For most re-routing cases, when the passenger can continue the journey by taking the next

train where seats are available which were eventually not sold, this does not represent a

cost. However, in some cases, there might be costs to bear when re-routing is done by

paying a ticket (or seat reservation) to another railway undertaking. There is no data

available on how many of such operator-to-operator transactions could be performed.

Moreover, since this cost is paid by railway undertakings to other railway undertakings, at

aggregate level the impact is assumed to be neutral, as the first one bears the costs, and the

second one gets the benefits of selling an otherwise unsold ticket. At the same time, it is

noted that this may impact individual railway undertakings differently, depending on the

route, the number of delays/cancellations they face that result in missed connections, and

hence the impact of this re-routing cost will not be neutral at an individual rail operator

level. However, given the limited availability of data, it is not possible to establish costs at

individual railway undertaking level.

The adjustment costs related to the reimbursement of passengers are derived by

multiplying the ticket price that is reimbursed with the number of affected passengers. The

proportion of passengers actually requesting reimbursement out of those that experience a

delay of at least 60 minutes is assumed at 38%89. As explained in detail in Annex 3, the

average ticket price per Member State for regional, long-distance and international trips

has been calculated based on the railway undertakings’ revenues90, the number of

passengers91 and the estimated length of regional, long-distance and international trips.

Expressed as present value over 2028-2050, relative to the baseline, the adjustment costs

for railway undertakings related to reimbursement (see Table 3) are estimated at EUR

182.3 million (of which EUR 1 million for SME railway undertakings).

The adjustment costs related to compensation, are calculated in line with the RPRR, where

a compensation of 25% of the ticket price is assumed for delays of 60 to 119 minutes and

50% for delays above 120 minutes. It is also assumed that the re-routed passengers due to

a cancellation will be delayed for 60-119 minutes and will need to be paid a compensation

of 25% of the ticket price, as they will typically be assigned to the next train one hour later.

The adjustment costs for railway undertakings related to compensation are estimated at

EUR 632.3 million, expressed as present value over 2028-2050 relative to the baseline (of

which EUR 3.6 million for SME railway undertakings). At the same time, for journeys

under a single ticket exceeding 12 hours, the right to compensation should arise only in

relation to the delay affecting the specific individual transport contract, which corresponds

to the baseline. This exemption should not apply where the journey under the single ticket

involves a night train. Given the uncertainty to establish the number of passengers affected

by the exemption, the exact reduction of costs cannot be precisely quantified and would be

89 SWD(2023)386 90 IRG-Rail (2024), 13th Market Monitoring Report, based on railway undertaking revenues for 2023. 91 Source: Eurostat.

20

within the margin of the sensitivity analysis on the proportion of passengers actually

requesting compensation in section 6.5.

Railway undertakings will equally have to provide assistance when a cancelled or delayed

service causes a missed connection. Such assistance can comprise, depending on the

circumstances, basic provision of information, meals, refreshments and accommodation.

As explained in detail in Annex 3, based on the interviews with stakeholders, the average

cost of such assistance is assumed to be EUR 10 per passenger affected by the disruption

and 5% of passengers are assumed to request assistance92. Expressed as present value over

2028-2050, relative to the baseline, the adjustment costs for railway undertakings related

to assistance of passengers are estimated at EUR 169.6 million at EU level (of which EUR

1 million for SME railway undertakings).

Thus, the total one-off and recurrent adjustment costs for railway undertakings are

estimated at EUR 988.2 million (see Table 3), expressed as present value over 2028-2050

relative to the baseline (of which EUR 5.8 million for SME railway undertakings).

Recurrent administrative costs for railway undertakings

Railway undertakings will also experience recurrent administrative costsas they will need

to handle an increased number of re-routing, reimbursement, compensation and assistance

requests. This cost is derived by estimates of the time needed to handle each of the requests

(re-routing, reimbursement, compensation and assistance), multiplied by the total number

of requests in each Member State, and the tariff rates by Member State for the ISCO 3

category (technicians and associate professionals)93 in 2024 prices.

The time needed to handle compensation and reimbursement claims (15 minutes) is

derived based on the stakeholder consultation and previous impact assessments94. For the

time needed to handle re-routing (5 minutes), it is assumed that a large proportion of re-

routing will consist of simply allowing the passenger on the next available train, which

would involve little administrative time, and only in a minor number of cases more

complex re-routing would be offered as an alternative. For assistance, which can involve

simple information provision, but also handling out refreshments and meals as well as the

booking of hotels, 5 minutes are assumed per request. No recurrent administrative costs

are assumed where requests are handled through automation. It is assumed that automation

would cover 15% of requests for assistance, 20% of requests for reimbursement and

compensation and 30% of requests for re-routing in 2028, rising to 90% by 2050. Given

the uncertainty, sensitivity analysis has been further performed.

92 Assistance is estimated at 5% by Germany in its Country Research Template report, which records

national-level information regarding the application of Regulation (EU) 2021/782. In France, requests for

assistance are approximately 3 times less frequent than the requests for compensation. Since the percentage

of passengers requesting compensation (among those entitled to do it) is estimated to 38%, the percentage of

delayed passengers receiving assistance represents 12% in France. 93 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs. 94 SWD(2023)386

21

The total recurrent administrative costs for railway undertakings are estimated at EUR 1.15

billion (see Table 3), expressed as present value over 2028-2050 relative to the baseline

(of which EUR 6.5 million for SME railway undertakings).

For the purpose of ‘one in, one out’ approach and the Calculator of Administrative Costs (AC) &

Administrative Burdens (AB), the annual average recurrent administrative costs95 for railway

undertakings are estimated at EUR 96.1 million relative to the baseline (EUR 0.55 million for

SMEs96 and EUR 95.53 million for non-SME railway undertakings97).

Total costs for railway undertakings

The total costs for railway undertakings are estimated at EUR 2.14 billion (see Table 3),

expressed as present value over 2028-2050 relative to the baseline (of which EUR 12.4

million for SME railway undertakings). Adjustment costs related to the compensation of

the passengers provide around 30% of the total costs. Around 29% of these total costs are

administrative costs for handling compensation requests and another 21% administrative

costs for handling re-routing requests.

To get insights in the proportionality of the intervention, it is instructive to consider the

2028 costs for railway undertakings under the simplifying assumption that they fall entirely

on the main national incumbent railway undertaking in each Member State. France and

Germany have been selected here, as they represent the EU’s two largest rail markets, and

are jointly accounting for EUR 121 million i.e. 64% of the total EU intervention cost of

EUR 188.7 million. For the national incumbents, and under the assumption, this would

amount to EUR 87.4 million for Deutsche Bahn (Germany) and EUR 33.1 million for

SNCF (France). Against DB’s Integrated Rail System revenues of EUR 26.2 billion in

202498 and SNCF Group revenues of EUR 43.4 billion in the same year99, these figures

represent only 0.33% and 0.08% of their revenue bases, respectively. While not part of the

baseline, it could be expected that some of these costs (especially related to re-routing)

would be incurred anyway with the industry announcements to continue improving the

industry-solutions, such as the AJC100.

Table 3: Adjustment and administrative costs for railway undertakings at EU level (in million EUR,

2024 prices) 2028 2030 2040 2050 Present value 2028-

2050

Adjustment costs 69.8 69.0 55.5 43.0 988.2

95 For the purpose of the Calculator of Administrative Costs (AC) & Administrative Burdens (AB), the annual

average recurrent administrative costs are derived as simple averages (non-discounted) over a ten year period

(2028-2037). 96 EUR 60,811 for each of the 9 SME railway undertakings. 97 EUR 641,166 for each of the 149 of the non-SME railway undertakings. 98https://ibir.deutschebahn.com/2024/en/combined-management-report/business-development/income-

situation/revenues/ 99 https://echanges.dila.gouv.fr/OPENDATA/AMF/125/2025/03/FC125573457_20250312.pdf 100https://www.cer.be/cer-press-releases/rail-sector-continues-to-improve-passenger-experience-in-

international-travel CER and its members have committed, under the CER Ticketing Roadmap, to further

develop and expand the Agreement on Journey Continuation (AJC) as a key instrument to improve the

passenger experience in international rail. CER indicates that AJC will be progressively enhanced.

22

2028 2030 2040 2050 Present value 2028-

2050

One-off adjustment costs 4.0 4.0

Re-routing costs 0.0 0.0 0.0 0.0 0.0

Reimbursement costs 12.1 12.7 10.3 8.0 182.3

Compensation costs 42.4 44.4 35.7 27.6 632.3

Assistance costs 11.4 11.9 9.5 7.4 169.6

Administrative costs 118.9 114.5 51.8 9.9 1,148.3

Re-routing administrative costs 46.1 44.5 20.3 4.2 448.9

Reimbursement administrative

costs

5.0 4.8 2.2 0.4 48.7

Compensation administrative costs 64.7 62.2 27.9 5.1 621.8

Assistance administrative costs 3.0 2.9 1.3 0.2 28.8

Total costs for RUs 188.7183.5107.352.92,136.5

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Other impacts on railway undertakings

While difficult to quantify, stronger passenger rights protection following the intervention

is expected to boost consumer confidence and stimulate demand for rail travel. This benefit

is highlighted by the 2021 Steer and KCW study101, as well as by the Eurobarometer survey

on Multimodal Digital Mobility Services102, where 18% responded that they avoid rail

connections operated by different rail operators for fear of being stranded in case of a

missed connection. In the same Eurobarometer survey, 12% of the respondents indicated

that they would be encouraged to book a more environmentally friendly journey if it

offered them the same level of passenger rights in case of delays, cancellations, or missed

connections. The replies to the call for evidence point to the same conclusion, with 27

citizens indicating that the lack of rights and lower affordability of rail compared to air

travel make it difficult for them to choose rail as a form of transport, and with 5

organisations arguing that stronger passenger protection can increase consumer confidence

in rail (see Annex 2). With all this, it can therefore be expected that higher consumer

confidence will translate into higher demand for rail travel. On the other hand, railway

undertakings may pass additional costs on to consumers through higher ticket prices, the

extent of which will depend on market competition, price regulation, state intervention and

individual operators’ cost structures and efficiency. The overall impact on the demand for

rail travel is however expected to be positive, although not possible to quantify.

6.1.3. Impact on intermediaries

Intermediaries, including online ticket vendors and travel organisers, would need to

familiarise themselves with the new regulation and may also need to adapt their policies

and procedures to ensure compliance. In particular, when offering single tickets, they

would have to adhere at least to the applicable minimum connection times. Where ticket

vendors or tour operators fail to comply with this requirement, they should be liable to

offer the choice to the passenger between the reimbursement of the single ticket and the

reimbursement of the re-routing costs incurred by the passenger. Furthermore, they should

101 Steer and KCW (2021), Final Report “Long-distance cross-border passenger rail services”, p. 345. 102 European Commission (2025). Eurobarometer 551 Multimodal Digital Mobility Service Report. Accessed

https://europa.eu/eurobarometer/surveys/detail/3178, p. 55.

23

be liable to pay a compensation of 75% of the amount paid for the single ticket. At the

same time, intermediaries may benefit from a larger volume of ticket bookings carried out

via them.

One-off adjustment costs for intermediaries

Intermediaries are third parties that connect railway undertakings with passengers. Most

are small travel agencies or tour operators with limited rail sales, often relying on

specialised aggregators. A few major players, such as Trainline, Omio, Rail Europe and

EuroTrain, focus on reselling tickets from multiple railway undertakings directly to

passengers. Ticket vendors and tour operators may distribute combined tickets from

different railway undertakings for a journey. Currently, if they do so on their own initiative,

they must refund the full ticket price and pay 75% compensation of that amount if

connections are missed, unless passengers were clearly informed in advance before

purchase that the tickets represent separate contracts103. This particular liability would no

longer apply under this intervention given that these ticket combinations would now entitle

passengers to a full set of rights under the single ticket protection. At the same time, this

liability would be substituted by another liability regime where ticket vendors and tour

operators do not adhere to the applicable minimum connection times when offering a single

ticket. The proposed measure is expected to incentivise ticket vendors and tour operators

to improve their offer of single tickets, in order to reduce the likelihood of recurring

reimbursements and compensation. Given the uncertainty to establish the number of

passengers affected, the costs cannot be quantified although they are expected to be

limited.

The one-off adjustment costs for intermediaries cover the effort to understand the

regulation and to review the legal consequences. The specialised rail ticket sellers are

expected to adapt the front-end website (update the terms and conditions), to adapt their

overall strategy, and to take contact with the railway undertakings with whom they have a

commercial agreement. The effort per intermediary is estimated at 0.5 person-day in 2028.

There were 121,276 intermediaries (ticket vendors, tour operators and other reservation

service and related activities) according to Eurostat in 2024104, of which over 99% are

SMEs. Assuming 7.2 working hours per day on average105 and the tariff rate for the ISCO

3 category (technicians and associate professionals)106 by Member State in 2024 prices,

the one-off adjustment costs for the intermediaries are estimated at EUR 12.84 million (of

which EUR 12.82 million for SME intermediaries).

Other impacts on intermediaries

It can also be expected that intermediaries will gain from the intervention as consumers

will be more likely to book multi-operator journeys via them where these come with full

103 Article 12(4)-(5) of RPRR 104 ECTA estimates it rather to 80,000-90,000 and attributes the difference with Eurostat to

including/excluding 1-person travel consultants. 105 Actual and usual hours of work - Statistics Explained - Eurostat 106 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.

24

passenger rights. In particular, their revenues may increase if more single tickets are bought

through them. This impact was however not possible to quantify.

6.1.4. Impact on National Enforcement Bodies (NEBs)

Public authorities, particularly national enforcement bodies (NEBs) responsible for

monitoring the application of the rules and handling passenger complaints, would also be

affected by the policy intervention.

The planned initiative is expected to generate one-off adjustment costs for national

enforcement bodies (NEBs), mainly linked to understanding the amendment, assessing its

legal implications, and adapting complaint-handling procedures. The effort per NEB is

assumed at 5 person-days, resulting in total one-off adjustment costs of EUR 0.03 million

in 2028 at EU level. While the number of complaints may increase due to more single

tickets, greater legal clarity will simplify enforcement. Overall, additional enforcement

costs for NEBs and other complaint bodies are expected to remain very limited.

6.1.5. Impacts on competition

The intervention is likely to exert a positive impact on competition within the railway

sector. By extending passenger rights to single ticket journeys across multiple railway

undertakings, it incentivises new market entrants, particularly smaller undertakings,

through network effects: their services gain visibility and viability when bundled with

larger operators on digital platforms, mirroring how EU rail liberalisation since 2001 has

spurred new entry and resulted in a drop in fares in those markets with higher

competition107. The increased consumer confidence is also expected to lead to stronger

competition between rail and air, especially with regard to short-haul connections, thereby

contributing to modal shift towards more sustainable transport options.

6.1.6. Impacts on competitiveness

For railway undertakings, as shown in Table 3 above, the policy intervention is expected

to result in total one-off and recurrent costs of EUR 2.14 billion expressed as present value

over the period 2028-2050. Of this, adjustment costs represent EUR 988.2 million and

administrative costs EUR 1.15 billion over the period 2028-2050. These costs may be

passed on to consumers through higher ticket prices. The extent of the pass through will

depend on market competition, price regulation, state intervention and individual

operators’ cost structures and efficiency and it is thus not possible to quantify. At the same

time, while not quantifiable, the intervention is expected to result in higher consumer

confidence, which can in turn be expected to result in greater demand for rail travel thereby

also benefiting railway undertakings. The policy intervention also creates visibility for and

incentivises new entrants in the rail services market, enabling them to innovate and

compete with established railway undertakings.

107 See for instance: https://op.europa.eu/en/publication-detail/-/publication/4ea76998-7955-11ef-bbbe-

01aa75ed71a1

25

For intermediaries, the policy intervention is projected to result in one-off adjustment

costs of EUR 12.8 million in 2028. Intermediaries are expected to gain from the

intervention due to the expected higher number of transactions concluded through them.

The intervention is also expected to result in a positive impact on innovation, for both

railway undertakings and intermediaries. With increased competition, they will need to

improve user experience and customer care.

The entire economy is likely to benefit from these developments since transport represents

a significant share of households’ expenditures (12.8% in 2023)108 and is a critical input

for many economic sectors, notably tourism. This might result in knock-on effects

throughout the entire economy in the long term, leveraging the initial impact on the

transport sector.

The policy intervention will apply equally to all EU and non-EU intermediaries insofar as

they will need to offer journeys involving multiple railway operators under a single ticket.

It therefore does not introduce trade distortions. The impact on international

competitiveness is expected to be neutral. The economic effects are confined to improving

efficiency and performance within the EU passenger transport market.

6.1.7. Impacts on SMEs

Most SMEs in the rail sector are suppliers and thus outside the initiative’s scope. Of the

158 railway undertakings affected, only 9 are SMEs109. Given their smaller scale, often

focused on touristic or regional routes, typically passenger volumes are about one-tenth of

those of larger operators. Taking into account the share of SMEs in the total number of

railway undertakings in the scope and the fact that passenger volumes for SMEs are one-

tenth of those of larger operators, the adjustment and administrative costs for SME railway

undertakings are estimated at EUR 5.8 million and EUR 6.5 million, respectively,

expressed as present value over 2028-2050. Thus, the total costs for SME railway

undertakings would amount at EUR 12.4 million over 2028-2050, relative to the baseline

(see Table 4).

The policy intervention is expected to create visibility for and incentivises new entrants in

the rail services market, typically SMEs, enabling them to innovate and compete with

established railway undertakings. Improved passenger rights linked to single tickets are

expected to benefit SME railway undertakings in particular by enabling them to participate

more fully in network effects that are currently dominated by large incumbent railway

undertakings. When multi‑leg journeys involving several operators are covered by a single

ticket, passengers will enjoy clear, enforceable rights to assistance, reimbursement, and

compensation in case of disruption, which increases trust in itineraries that include smaller

railway undertakings alongside established ones.

108 This share includes the purchase of personal transport equipment, the operation of personal transport

equipment and purchased transport services (for both passenger and goods transport services). Statistical

pocketbook 2025 - Mobility and Transport - European Commission 109 Source: desk research based on websites of railway regulators, railway undertakings and competent

authorities.

26

Table 4: Adjustment and administrative costs for SME railway undertakings at EU level (in million

EUR, 2024 prices) 2028 2030 2040 2050 Present value

over 2028-2050

Adjustment costs 0.59 0.39 0.32 0.25 5.82

One-off adjustment costs 0.22 0.22

Re-routing costs 0.00 0.00 0.00 0.00 0.00

Reimbursement costs 0.07 0.07 0.06 0.05 1.04

Compensation costs 0.24 0.25 0.20 0.16 3.60

Assistance costs 0.06 0.07 0.05 0.04 0.97

Administrative costs 0.68 0.65 0.29 0.06 6.54

Re-routing administrative costs 0.26 0.25 0.12 0.02 2.56

Reimbursement administrative costs 0.03 0.03 0.01 0.00 0.28

Compensation administrative costs 0.37 0.35 0.16 0.03 3.54

Assistance administrative costs 0.02 0.02 0.01 0.00 0.16

Total costs for SME RUs 1.27 1.05 0.61 0.30 12.36

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

For intermediaries, over 99% are SMEs according to Eurostat data. One-off adjustment

costs for SME intermediaries are estimated at EUR 12.82 million, expressed as present

value over 2028-2050. Intermediaries are expected to gain from the intervention due to the

expected higher number of transactions concluded through them, although it was not

possible to quantify this impact. For SME intermediaries, being able to package several

legs into a single ticket, intermediaries can market rail as a simple, “one‑click” option

comparable to air tickets, rather than a fragmented set of separate segments that consumers

must piece together themselves with often no passenger rights in case of missed

connections. This enables them to design and promote attractive, door‑to‑door and

cross‑border itineraries, integrate rail more effectively into wider travel offers, and provide

clearer information on price, conditions and protection across the whole rail journey. In

turn, this improves the visibility and appeal of rail for end‑users, supports modal shift from

less sustainable modes, and helps unlock additional demand and revenue for the rail sector

as a whole.

A total of 14 stakeholders that replied to the call for evidence were SMEs (10 industry

associations110 and 4 SME intermediaries). None of them was an SME railway

undertaking. SME intermediaries/travel agencies support the initiative but claimed that

liability for disruptions should rest with the railway undertaking, citing their limited ability

to intervene in real time during such disruptions. It needs to be recalled that this initiative

puts liability for passenger rights under a single ticket on the railway undertaking whose

delayed or cancelled service led to a missed connection under a single ticket and there is

no liability for passenger rights imposed on the intermediary.

110 CER, UITP, ALLRAIL, GBTA, WKO, ECTAA, VDV, Pearle, EU TravelTech and UTPF

27

6.2. SOCIAL IMPACTS

In terms of social impacts, the policy intervention is expected to benefit all passengers,

including those with disabilities or reduced mobility, who may face increased challenges

during journeys with multiple connections. It is also expected to benefit young people, who

are more likely than other age groups to combine rail legs operated by different

operators111.

The impact on employment is expected to be positive for railway operators, due to a likely

increase in the use of rail passenger services given the potential increase in demand driven

by improved trust in rail transport thanks to the measure.

The impacts of the policy intervention are likely to be spread across EU Member States

with railways on their territory, especially for cross-border journeys. The policy measure

will also address the concerns of citizens who avoid rail journeys run by multiple rail

operators for fear of being stranded in the case of a missed connection112.

6.3. ENVIRONMENTAL IMPACTS

Improving rail passenger rights and trust in rail transport overall is expected to improve its

attractiveness, and may result in a lower use of other, less environmental-friendly

alternatives. This was also confirmed by several of the replies to the call for evidence, in

which 27 citizens noted that the lack of rights and the lower affordability of rail compared

to air travel (particularly on multi-operator trips) make it difficult for people to choose rail

as a form of transport. Of these respondents, 8 specifically mentioned that they choose road

or air transport over rail because rail is too complicated or expensive for international trips.

With the potential increase in demand for rail services, the targeted revision is expected to

contribute to the goals of the Sustainable and Smart Mobility Strategy, which include

doubling high-speed rail traffic by 2030 and making cross-border tickets easier to use and

to buy113. The initiative is also in line with the European Green Deal objectives and the

European Climate Law114. No significant harm is expected on the environment due to

the policy intervention. The initiative contributes towards Sustainable Development Goal

(SDG) #13 (“Climate action”).

111 According to the Eurobarometer on Multimodal Digital Mobility Services, page 50, younger respondents

(15-39) are more likely to have combined rail legs operated by different operators ‘every few months or more

frequently, for different journeys’ (12%-13%) or ‘every few months or more frequently, always for the same

journey’ (16-19%), compared to those aged 40-55 or 55+ (4-8% and 4-9%, respectively). Source:

https://europa.eu/eurobarometer/surveys/detail/3178 112 According to the Eurobarometer survey on Multimodal Digital Mobility Services, 18% of respondents

avoid rail connections operated by different rail operators for fear of being stranded in case of a missed

connection. 113 Sustainable and Smart Mobility Strategy, pp. 3 and 8. 114 Regulation (EU) 2021/1119 establishing the framework for achieving climate neutrality.

28

6.4. COST BENEFIT ANALYSIS

The estimates of costs and benefits, expressed as present value over 2028-2050, are

summarised in Table 5.

Table 5: Summary of costs and benefits of the policy intervention - present value over 2028-2050

compared to the baseline (in million EUR, 2024 prices) Difference to the baseline

Passengers

Benefits due to re-routing, reimbursement, compensation,

and assistance

6,642.8

Re-routing benefits 5,658.6

Reimbursement benefits 182.3

Compensation benefits 632.3

Assistance benefits 169.6

Hassle cost savings 1,136.9

Railway undertakings

Adjustment costs 988.2

One-off adjustment costs 4.0

Re-routing costs 0.0

Reimbursement costs 182.3

Compensation costs 632.3

Assistance costs 169.6

Administrative costs 1,148.3

Re-routing administrative costs 448.9

Reimbursement administrative costs 48.7

Compensation administrative costs 621.8

Assistance administrative costs 28.8

Intermediaries

One-off adjustment costs 12.8

National Enforcement Bodies

One-off adjustment costs 0.03

Total costs 2,149.4

Total benefits 7,779.7

Net benefits 5,630.3

Benefits to costs ratio 3.6

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Total costs due to the policy intervention are projected at EUR 2.15 billion, expressed as

present value over 2028-2050 relative to the baseline. Adjustment costs for railway

undertakings related to the compensation of the passengers represent 29% of the total costs

and the administrative costs for handling the compensation requests another 29% of the

total costs. Administrative costs for railway undertakings for handling the re-routing

requests of the passengers contribute another 21% of the total costs, while adjustment costs

related to reimbursement and assistance provide each 8% of the total costs.

Total benefits due to the policy intervention are estimated at EUR 7.78 billion, expressed as

present value over 2028-2050 relative to the baseline. Benefits for passengers due to re-

routing represent 73% of the total benefits and the hassle costs savings 15% of the total benefits.

Compensation benefits for passengers provide another 8% of the total benefits, and

reimbursement and assistance benefits around 2% each.

29

Overall, the policy intervention results in net benefits estimated at EUR 5.63 billion expressed

as present value over 2028-2050 relative to the baseline. The benefits to costs ratio is estimated

at 3.6. In conclusion, the proposed intervention would significantly improve the protection

of rail passengers across the EU while benefitting society at large.

6.5. SENSITIVITY ANALYSIS

Considering the uncertainty related to certain assumptions used in the analysis, sensitivity

analysis has been performed with respect to:

- Share of multi-operator journeys performed under a single ticket (other than through-

tickets);

- Level of automation for handling requests for compensation by railway undertakings;

- Time required for handling requests for compensation by railway undertakings;

- Time of re-routing;

- Synergies with the initiatives on Rail Ticketing Regulation (RTR) and the Regulation

on Multimodal Booking (RMB)115;

- Proportion of passengers actually requesting compensation out of those that experience

a delay of at least 60 minutes and do not ask for reimbursement.

The results of the sensitivity analysis are compared to the ‘central case’, described in the

previous sections. More detailed results of the sensitivity analysis performed are provided

in Annex 3 (section 4).

Share of multi-operator journeys performed under a single ticket (other than

through-tickets). The share of single tickets involving different rail operators for a single

journey bought in a single transaction, other than through-tickets, is estimated at 13% at

EU level in the central case. Two alternative cases have been tested: (i) 6% share of multi-

operator journeys performed under a single ticket, other than through-tickets (Case A –

6%); (ii) 26% share of multi-operator journeys performed under a single ticket, other than

through-tickets (Case A – 26%). The results for the two cases considered are compared to

the central case. The total costs and benefits, as well as the net benefits, for the central case

and the two alternative cases (Case A – 6% and Case A – 26%), expressed as present value

over 2028-2050 relative to the baseline, are provided in the table below. The table shows

that both alternative cases result in overall net benefits and similar benefits to costs ratio

as the central case.

Table 6: Total costs, total benefits and net benefits for the central case and the two alternative cases (Case

A – 6% and Case A – 26%) - present value over 2028-2050 compared to the baseline (in million EUR,

2024 prices) Central case Case A – 6% Case A – 26%

Total costs 2,149.4 1,019.6 4,362.1

Total benefits 7,779.7 3,658.1 15,851.6

Net benefits 5,630.3 2,638.5 11,489.5

115 EU rules on multimodal digital mobility services and single digital booking & ticketing

30

Central case Case A – 6% Case A – 26%

Benefits to costs ratio 3.6 3.6 3.6

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Level of automation for handling requests for compensation by railway undertakings.

In the central case, it is assumed that automation would cover 20% of requests for

compensation in 2028, rising to 90% by 2050. One alternative case is tested (Case B –

70%), where the share of requests for compensation handled automatically increases

gradually from 15% in 2028 to 70% by 2050. The results for the alternative case considered

is compared to the central case. The total costs and benefits, as well as the net benefits, for

the central case and the alternative case (Case B – 70%), expressed as present value over

2028-2050 relative to the baseline, are provided in the table below. The table shows that

the alternative case results in overall net benefits and somewhat lower benefits to costs

ratio relative to the central case.

Table 7: Total costs, total benefits and net benefits for the central case and the alternative case (Case B –

70%) - present value over 2028-2050 compared to the baseline (in million EUR, 2024 prices) Central case Case B – 70%

Total costs 2,149.4 2,279.9

Total benefits 7,779.7 7,779.7

Net benefits 5,630.3 5,499.7

Benefits to costs ratio 3.6 3.4

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Time required for handling requests for compensation by railway undertakings. In

the central case, the average time required to handle a request for compensation (if not

automated) is assumed at 15 minutes. Two alternative cases have been tested: (i) 10

minutes for handling a request for compensation by railway undertakings (Case C – 10

min); (ii) 20 minutes for handling a request for compensation by railway undertakings

(Case C – 20 min). The results for the two cases considered are compared to the central

case.

The total costs and benefits, as well as the net benefits, for the central case and the two

alternative cases (Case C – 10 min and Case C – 20 min), expressed as present value over

2028-2050 relative to the baseline, are provided in the table below. The table shows that

both alternative cases result in overall net benefits. The benefits to costs ratio is somewhat

higher in Case C – 10 min and lower than in the central case in the Case C – 20 min.

Table 8: Total costs, total benefits and net benefits for the central case and the two alternative cases (Case

C – 10 min and Case C – 20 min) - present value over 2028-2050 compared to the baseline (in million

EUR, 2024 prices) Central case Case C – 10 min Case C – 20 min

Total costs 2,149.4 1,942.1 2,356.7

Total benefits 7,779.7 7,779.7 7,779.7

Net benefits 5,630.3 5,837.5 5,423.0

Benefits to costs ratio 3.6 4.0 3.3

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Time of re-routing. In the central case, it is assumed that passengers choosing re-routing

will be re-routed in respect of all cancelled services as well as those delayed by at least 60

minutes. Two alternative cases have been tested: (i) passengers choosing re-routing will

31

be re-routed in respect of all cancelled services as well as those delayed by at least 5

minutes (Case D – 5 min); (ii) passengers choosing re-routing will be re-routed in respect

of all cancelled services as well as those delayed by at least 120 minutes (Case D – 120

min). The results for the two alternative cases considered are compared to the central case.

The total costs and benefits, as well as the net benefits, for the central case and the two

alternative cases (Case D – 5 min and Case D – 120 min), expressed as present value over

2028-2050 relative to the baseline, are provided in the table below. The table shows that

both alternative cases result in overall net benefits. The benefits to costs ratio is much

higher in Case D – 5 min and lower than in the central case in the Case D – 120 min.

Table 9: Total costs, total benefits and net benefits for the central case and the two alternative cases (Case

D – 5 min and Case D – 120 min) - present value over 2028-2050 compared to the baseline (in million

EUR, 2024 prices) Central case Case D – 5 min Case D – 120 min

Total costs 2,149.4 3,814.0 2,074.2

Total benefits 7,779.7 28,316.4 6,852.0

Net benefits 5,630.3 24,502.4 4,777.8

Benefits to costs ratio 3.6 7.4 3.3

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Synergies with the initiatives on Rail Ticketing Regulation (RTR) and the Regulation

on Multimodal Booking (RMB). In the central case, the number of passengers travelling

by rail is aligned with the baseline scenario of the impact assessment accompanying the

RTR/RMB initiatives. In other words, as explained in section 5.1, the baseline is common

to that of the impact assessment accompanying the RTR/RMB initiatives. An alternative

case has been tested (Case E – RTR/RMB), where the number of passengers travelling by

rail is aligned with the preferred policy option of the impact assessment accompanying the

RMB and RTR initiatives. The results for the alternative case considered is compared to

the central case.

The total costs and benefits, as well as the net benefits, for the central case and the

alternative case (Case E – RTR/RMB), expressed as present value over 2028-2050 relative

to the baseline, are provided in the table below. The table shows that the alternative case

result in overall net benefits and similar benefits to costs ratio relative to the central case.

Table 10: Total costs, total benefits and net benefits for the central case and the alternative cases (Case E

– RTR/RMB) - present value over 2028-2050 compared to the baseline (in million EUR, 2024 prices) Central case Case E – RTR/RMB

Total costs 2,149.4 2,185.9

Total benefits 7,779.7 7,929.1

Net benefits 5,630.3 5,743.3

Benefits to costs ratio 3.6 3.6

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Proportion of passengers actually requesting compensation out of those that

experience a delay of at least 60 minutes and do not ask for reimbursement. In the

central case, the proportion of passengers actually requesting compensation out of those

that experience a delay of at least 60 minutes and do not ask for reimbursement is assumed

at 38%. Three alternative cases have been tested: (i) the proportion of passengers actually

requesting compensation out of those that experience a delay of at least 60 minutes and do

32

not ask for reimbursement is 0% (Case F – 0%); (ii) the proportion of passengers actually

requesting compensation out of those that experience a delay of at least 60 minutes and do

not ask for reimbursement is 50% (Case F – 50%); (iii) the proportion of passengers

actually requesting compensation out of those that experience a delay of at least 60 minutes

and do not ask for reimbursement is 75% (Case F – 75%). The results for the three

alternative cases considered are compared to the central case.

The total costs and benefits, as well as the net benefits, for the central case and the three

alternative cases (Case F – 0%, Case F – 50% and Case F – 75%), expressed as present

value over 2028-2050 relative to the baseline, are provided in the table below. The table

shows that all alternative cases result in overall net benefits. The benefits to costs ratio is

highest in Case F – 0% and lower in Case F – 50% and Case F – 75% relative to the central

case.

Table 11: Total costs, total benefits and net benefits for the central case and the three alternative cases

(Case F – 0%, Case F – 50% and Case F – 75%) - present value over 2028-2050 compared to the baseline

(in million EUR, 2024 prices) Central case Case F – 0% Case F –

50%

Case F –

75%

Total costs 2,149.4 895.3 2,545.4 3,370.5

Total benefits 7,779.7 7,147.4 7,979.3 8,395.3

Net benefits 5,630.3 6,252.1 5,433.9 5,024.8

Benefits to costs ratio 3.6 8.0 3.1 2.5

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

7. STAKEHOLDERS’ VIEWS ON THE PROPOSED INTERVENTION

The European Commission published a Call for Evidence to collect feedback from

interested stakeholders. This Call gathered 215 contributions in total. The majority were

submitted by EU citizens (154 responses, 71.2% of the total), followed by companies and

businesses (17 responses, 7.9%). Non-EU citizens and business associations each provided

11 responses (5.1%), while public authorities submitted 8 (3.7%), including 3 from

National Enforcement Bodies (1.4%). Consumer organisations contributed with 7

responses (3.3%), NGOs with 3 (1.4%), and other stakeholders with 3 (1.4%), with 1

response (0.5%) from an environmental organisation.

90 citizens expressed their support for the policy initiative. 45 citizens complained about

the low availability of through-tickets and single tickets, especially for international trips.

A recurring frustration, shared by 36 citizens, is that passengers currently bear almost all

the risk of delays and missed connections in multi-operator journeys, with no clear

responsible party, inconsistent compensation practices and frequent situations of being

stranded without help. 9 citizens reported buying what ‘felt’ like a single trip, only to find

out after disruption that their journey was treated as multiple separate contracts.

Companies and business associations displayed mixed views. 8 incumbent railway

undertakings and their associations replied to the call for evidence. Overall, they tend to

support stronger protection in principle but oppose extending full passenger rights to all

single tickets. In their view, the Regulation should not undermine commercial initiatives

such as the AJC. In addition, out of 4 new rail entrants and their associations which

responded to the call for evidence 2 were supportive of the initiative, 1 opposed the

33

approach, and 1 did not explicitly state its support but gave some

recommendations. Intermediaries and their associations116 were generally supportive of

the idea of extending passenger rights to single tickets, with caveats. Regarding SMEs, a

total of 14 stakeholders that replied to the call for evidence were SMEs. 3 SME

intermediaries/travel agencies and their association argued that liability for disruptions

should rest with the operators, citing their limited ability to intervene in real time during

such disruptions.

Consumer organisations, NGOs and public authorities who replied117 generally backed the

initiative. The 11 participating respondents identifying as consumer organisations and

NGOs were supportive of extending EU rail passenger rights to cover multi-operator and

cross-border journeys more effectively, even going beyond the approach of this targeted

revision and suggesting guaranteeing passenger rights beyond single tickets.

A more detailed overview of the contributions to the call for evidence can be found in

Annex 2.

116 9 responses: Omio, Trainline, eu travel tech, Rail Europe, KILROY Group, GSM Viaggi, GBTA,

BT4Europe, ECTAA. 117 The respondent public authorities were the Catalan Consumer Agency (Spain), the Austrian Federal

Ministry of Labour, Social Affairs, Health, Care and Consumer Protection (Austria), the Autorité de

régulation des transports (France), the Public Transport Authorities Organisation (Denmark), the Agentur

für Passagier- und Fahrgastrechte (NEB – Austria), Transportstyrelsen (NEB – Sweden), ART - Italian

Tranport Regulation Authority (NEB – Italy), Ombudsrail (Ombudsman – Belgium),

ANNEX 1: SELECTION OF CROSS-BORDER JOURNEYS

This annex presents an illustrative sample of multi-operator train journeys and indicates, for each, whether a through-ticket currently exists that would

provide protection under Regulation (EU) 2021/782. The sample covers selected possible multi-operator journeys across several Member States and is

intended to be indicative of current market practice, in particular the limited availability of through-tickets for many cross-border rail connections. Given

the very large number of theoretically possible multi-operator journey combinations and connections across the Union, and the absence of a centralised

dataset covering all such offers, it is not feasible to construct a complete, exhaustive inventory of multi-operator journeys. The examples included here

should therefore be read as illustrative case studies rather than as a comprehensive mapping of all existing or potential through-ticketing arrangements.

Table 12: Selection of cross-border multi-operator rail journeys

Journey - Leg - operating railway undertaking Single ticket bought on… Type of contract

Bucharest (RO) to Sofia (BG)

Bucuresti Nord (RO) – Ruse (BG) -

CFR Călători & BDŽ

Ruse (BG) – Sofia (BG) - BDŽ

CFR Călători

bileteinternationale.cfrcalatori.ro/en/

Through-ticket

Brussels (BE) to Berlin (DE)118

Brussels-Midi/Zuid (BE) – Cologne Hbf

(DE) - Eurostar

Cologne Hbf (DE) – Berlin Hbf (DE) -

DB

DB

www.bahn.de

Separate contracts

118 This journey can also be booked as through- ticket with DB trains only

35

Journey - Leg - operating railway undertaking Single ticket bought on… Type of contract

Warszaw (PL) to Strasbourg (FR)

Warszawa Centralna (PL) - Berlin Hbf

(DE) - PKP & DB

Berlin Hbf (DE) – Offenburg (DE) - DB

Offenburg (DE) – Strasbourg (FR) - DB

DB

www.bahn.de

Through-ticket

Vilnius (LT) to Tallinn (EE)

Vilnius (LT) – Riga (LV) - LTG Link

Riga (LV) – Valga (EE) - Vivi

Valga (EE) – Tallinn (EE) - Elron

Elron

www.elron.ee

Through-ticket

Warsaw (PL) to Vilnius (LT)

Warszawa Centralna (PL) – Mockava

(LT) - PKP

Mockava (PL) – Vilnius (LT) - LTG Link

PKP Intercity

www.intercity.pl

Through-ticket

36

Journey - Leg - operating railway undertaking Single ticket bought on… Type of contract

Marseille (FR) to Stuttgart (DE)

Marseille Saint-Charles (FR) –

Mannheim Hbf (DE) - SNCF

Mannheim Hbf (DE) – Stuttgart (DE) -

DB

SNCF Connect

www.sncf-connect.com

Separate contracts

Madrid (ES) to Lisbon (PT)

Madrid – Atocha (ES) – Badajoz (ES) -

Renfe

Badajoz (ES) – Encontramento (PT) - CP

Encontramento (PT) – Lisboa-Oriente

(PT) - CP

Omio

www.omio.com

Separate contracts

Nice (FR) to Milan (IT)

Nice Ville (FR) – Ventimiglia (IT) –

SNCF

Ventimiglia (IT) – Milano Centrale (IT) -

Trenitalia

Omio

www.omio.com

Separate contracts

37

Journey - Leg - operating railway undertaking Single ticket bought on… Type of contract

Hamburg (DE) to Stockholm (SE)

Hamburg Hbf (DE) – Copenhagen

Central (DK) - DB & DSB

Copenhagen Central (DK) – Stockholm

Central (SE) - Snälltåget

Omio

www.omio.com

Separate contracts

Linz (AT) to Budapest (HU)

Linz Hbf (AT) - Wien Meidling (AT) -

ÖBB

Wien Meidling (AT) – Budapest-

Kelenföld (HU) - Regiojet

Omio

www.omio.com

Separate contracts

Perpignan (FR) to Valencia (ES)

Perpignan (FR) – Barcelona Sants (ES) -

SNCF

Barcelona Sants (ES) – Valencia Nord

(ES) - Renfe

Trainline

www.thetrainline.com

Separate contracts

38

Journey - Leg - operating railway undertaking Single ticket bought on… Type of contract

Munich (DE) to Rome (IT)

München Hbf (DE) – Bologna Centrale

(IT) - ÖBB

Bologna Centrale (IT) – Rome Termini

(IT) - Trenitalia

Trainline

www.thetrainline.com

Separate contracts

39

ANNEX 2: CALL FOR EVIDENCE

The Call for Evidence on the targeted revision of Regulation (EU) 2021/782 on rail

passengers’ rights and obligations was published on 28 July 2025, with an eight-week

feedback period, which closed on 22 September 2025.

1. Total number of contributions per stakeholder group and Member State

The call for evidence received 215 contributions in total (Table 13). Out of these, 154 were

submitted by EU citizens (71.6%). The second largest group of contributions came from

companies/businesses, with 17 responses (7.9%). Non-EU citizens accounted for 11

responses (5.1%). Business associations contributed 11 responses (5.1%). Public

authorities accounted for 8 responses, representing 3.7% of all contributions. Out of these,

3 came from National Enforcement Bodies (NEBs), representing 1.4% of the responses.

Consumer organisations and NGOs submitted 7 (3.3%) and 3 (1.4%) responses,

respectively. Additional responses were received from other stakeholders (3 responses,

1.4%)119 and an environmental organisation (1 response, 0.5%).

Table 13: Number of contributions by stakeholder group Stakeholder group Number of contributions

received

Share of total

contributions

EU citizen154 71.6%

Company/business17 7.9%

Business association11 5.1%

Non-EU citizen11 5.1%

Public authorities (excluding NEBs)5 2.3%

NEBs 3 1.4%

Consumer organisation7 3.3%

Non-governmental

organisation (NGO)

3 1.4%

Other3 1.4%

Environmental organisation1 0.5%

Total 215 100%

119 The ‘other stakeholders’ category includes a chamber of labour, an Alternative Dispute Resolution (ADR)

company and an association of ADR bodies.

40

A total of 203 responses were from stakeholders in the EU Member States. Participation

varied across Member States, with German respondents providing 45 responses (22.2%),

followed by France with 27 responses (13.3%). Belgium and the Netherlands each

contributed with 22 responses (10.8%), Italy with 19 responses (9.4%), and Austria with

13 responses (6.4%). Respondents from Poland and Denmark submitted 10 responses

(4.9%) each, followed by 9 responses from Spain (4.4%), and 7 responses from Sweden

(3.4%). Participation was lower in Czechia with 5 responses (2.5%), Hungary with 4

(2.0%), Ireland and Finland with 3 each (1.5%), Romania with 2 (1.0%), and Croatia and

Lithuania with 1 each (0.5%).

2. Stakeholder views on the initiative

• Citizens

Across 165 replies from 21 countries, respondents identifying as citizens were very

supportive of extending EU rail passenger rights in general.

45 citizens120 complained about the low availability of through-tickets and single tickets,

especially for international trips. A recurring frustration, shared by 36 citizens, is that

passengers currently bear almost all the risk of delays and missed connections in multi-

operator journeys, with no clear responsible party, inconsistent compensation practices and

frequent situations of being stranded without help. Of those, 9 citizens reported buying

what ‘felt’ like a single trip, only to find out after disruption that their journey was actually

treated as multiple separate contracts.

This has consequences for the rail industry as a whole: 27 citizens mentioned that the lack

of rights and the lower affordability of rail compared to air travel – particularly on multi-

operator trips – make it difficult for people to choose rail as a form of transport. Of these

respondents, 8 explicitly mention that they choose road or air transport over rail, as it is

too complicated or expensive for international trips – potentially undermining the EU’s

own climate and transport goals.

With regard to the proposal to extend the passenger rights to all single tickets, defined as

multi-leg journeys bought on a single platform in a single transaction irrespective of the

number of operators involved, the analysis found that 90 citizens out of 165 support the

initiative presented. Several other citizens (26) further argue that rights should also apply

when separate tickets bought in different transactions (self-combined tickets) clearly form

one journey. Several citizens not only support the targeted revision but also associate it

with positive impacts on train travel: a total of 37 respondents out of 165 believe that

improving passenger rights can increase the attractiveness and competitiveness of the rail

sector vis-à-vis other modes of transports, contributing to the EU’s climate goals. In their

perspective, a stronger framework characterised by clearer liability, sounder protection

mechanisms and simpler booking procedures can improve consumer confidence in rail

travel reducing reliance on air and road transport. In addition, a few respondents (5

contributions) believe that the revision could contribute to reducing travel time for rail

120 Distributed across Austria, Germany, France, Belgium, Czechia, Hungary, Italy, the Netherlands, Spain,

Denmark, Sweden, Poland and the UK.

41

passengers. In their view, a more stringent framework could foster better coordination

among operators, improve punctuality and eliminate the need for excessive buffer times

currently required by passengers.

• Companies/business associations

Support for the initiative is mixed across businesses and varies by segment. More than half

of business stakeholders (16 out of 28) that responded to the call for evidence broadly

agreed with extending passenger rights to single tickets, while nine opposed the

Commission’s proposed extension of rights.

Table 14: Companies/business associations views on the initiative Stakeholder group Oppose Support (with caveats) Unclear

Intermediary 0 5 0

Intermediary association 0 4 0

Railway undertakings (RUs) 5 3 0

RU association 3 1 0

Local / Urban transport 0 0 2

Other 0 2 0

Transport association 1 0 0

Chamber of commerce 1 0 0

Other association 0 1 0

Total 10 16 2

8 incumbent railway undertakings and their associations replied to the call for evidence121.

Overall, they tend to support stronger protection in principle, but oppose extending full

passenger rights to all single tickets. In their view, the Regulation should not undermine

commercial initiatives such as the AJC. Five of the major rail actors (ÖBB, DB, CER,

SNCB, ČD) explicitly promote extending the AJC to more routes and operators, codifying

this approach for certain ticket types. CER and incumbent railway undertakings also state

that liability for missed connections should be put on the intermediary who has put together

a multi-operator journey under a single ticket.

4 new rail entrants and their associations responded to the call for evidence (Transdev,

Intermodalidad de Levante, ALLRAIL, and ITALO NTV). 2 of them were fully supportive

of the initiative, 1 opposed the chosen approach, and 1 did not explicitly stated its support

but gave some recommendations. ALLRAIL considers voluntary schemes such as AJC

and HOTNAT insufficient and recommends that passengers purchasing tickets with

reasonable connection times in a single transaction should always be protected. In their

view, the regulatory framework should shift from a ‘buyer beware’ to a ‘network

assurance’ logic, whereby journeys with realistic minimum connection times purchased in

a single transaction should be always protected. ALLRAIL further supports the liability

staying with the railway undertaking whose delayed or cancelled service led to a missed

connection (causer pays). At the same time, ALLRAIL proposes a solution whereby

121 CER, ÖBB, DB, SNCB, SNCF, ČD, UTPF and VDV.

42

railway undertakings with significant market power would be obliged to enter into through-

ticketing agreements with willing other railway undertakings122.

10 out of 13 RUs and associations that replied caution that imposing full passenger right

obligations on single tickets could bring about a reduction in the supply of complex multi-

leg journeys, including cross-border ones. Additionally, six of these organisations note that

RUs could face prohibitive costs due to compensation. Therefore, these RUs and

associations favour a protection framework based on the AJC or HOTNAT, which would

allow operators to guarantee journey continuation, keeping liability costs at a minimum.

Intermediaries and their associations who responded to the call for evidence are generally

supportive of the idea of extending passenger rights to single tickets, with caveats123. For

instance, they stress that legal liability should fall on RUs and warn that an overly

prescriptive or costly regime will decrease the availability of single tickets. Intermediaries

contend that they cannot be primarily liable for disruptions as they do not operate services,

set timetables, or control real-time information. 4 out of 9 intermediaries and their

associations worry that placing full liability on ticket vendors would be disproportionate,

as vendors would not be able to cover costs related to refunds, compensation and

accommodation. This might expose intermediaries to severe financial risks, distort the

level playing field with incumbent RUs and lead to a reduction or withdrawal of multi-leg

offers. At the same time, they argue that well-designed rules could boost competitiveness;

these include clear, standardised criteria for ‘protected connections’, reasonable minimum

connection times, and mandatory fair, reasonable and non-discriminatory (FRAND) access

to timetable, reservation and after-sales interfaces.

3 business stakeholders noted that minimum connection times need to be realistic for any

multi-operator ticket to which passenger rights are made obligatory. Other business

stakeholders (Trans-Mission, AirHelp, Pearle) welcome extending passenger rights to

single tickets as this in line with their mission to improve the rail sector and support

passengers. Meanwhile, local transport organisations (Wiener Stadtwerke, RATP Group)

do not take a strong stance on the Commission’s proposal, but underline the need for an

explicit exclusion of urban and suburban railway services from the scope of the review.

Regarding SMEs, a total of 7 stakeholders that replied to the call for evidence had less than

10 employees, 2 had less than 50 employees, and 5 had less than 250 employees. Of these,

9 were associations of intermediaries or railway undertakings. 3 were labelled as

intermediaries/travel agencies (GSM Viaggi, The Kilroy Group, and Rail Europe), one was

a consultancy (Trans-Missions), and another one was a federation representing employers

in the live performance sector (Pearle Live Performance Europe). The intermediaries/travel

agencies argued that liability for disruptions should rest with the operators, citing their

limited ability to intervene in real time during such disruptions.

122 https://www.allrail.eu/policies/the-great-rail-ticket-unbundling-part-ii-unbundle-passenger-rights-from-

formal-through-ticketing/ 123 Intermediaries and intermediary associations that expressed support for the initiative (support or support

with caveats) include GSM Viaggi, Global Business Travel Association (GBTA) Europe), Kilroy Group,

Rail Europe, ECTAA, BT4Europe, eu travel tech, Omio, and Trainline.

43

• Consumer organisations and NGOs

The 11 participating respondents identifying as consumer organisations and NGOs are

supportive of extending EU rail passenger rights to cover multi-operator and cross-border

journeys more effectively. They see the current legal regime as too narrow, too complex,

and not suited to how people actually buy and combine tickets today (often via digital

platforms and involving several operators)124. 5 organisations out of 11 argue that stronger

passenger protection can increase consumer confidence in rail travel and favour a

multimodal shift from other means of transport, such as the aviation sector. Several

consumers organisations and NGOs warn that the current legal situation where only

passenger rights are granted to through-tickets leaves major gaps and can lead to situations

where passengers are misled into believing they are protected when they are not.

4 responses received from consumer organisations out of 11 describe cross-border

ticketing as fragmented and complex, underlining ‘uneven national practice’ and confusing

booking and pricing procedures. Platforms often fail to offer the most suitable international

combinations, and even when innovative multi-model products are available, liability and

protections are unclear, leaving consumers unsure whether to trust these offers.

This group also tends to emphasise the lack of clear information available to passengers at

the time of booking international or multi-operator tickets, especially via digital platforms

and third-party sellers. This essentially confirms the problem noted in the call for evidence,

namely that tickets purchased in a single transaction appear to be single journeys, but in

effect do not come with guaranteed passenger rights, even the right to journey continuation.

4 of them note that existing voluntary schemes (e.g., AJC) are insufficient125. As such, for

10 out of 11 consumer organisations who responded to the call for evidence suggest

guaranteeing passenger rights beyond single tickets. Thus, there is clear support in this

group for clarifying – but also broadening – the existing definition of ‘through-tickets’ so

that more combined journeys would fall under full protection. Five organisations out of 11

argue that stronger passenger protection can increase consumer confidence in rail travel

and favour a multimodal shift from other means of transport, such as the aviation sector.

• Public authorities

Across the 8 public-authority submissions (3 of which are NEBs)126, they are broadly

supportive of strengthening rail passenger rights for multi-operator journeys, especially by

clarifying and reinforcing Article 12 on through-tickets in Regulation (EU) 2021/782.

Authorities generally agree that passengers should not be left unprotected when they buy

combined tickets for a single journey, but they differ on how far obligations should extend

124 See also https://www.beuc.eu/sites/default/files/publications/BEUC-X-2026-

035_Targeted_revision_of_the_Rail_Passenger_Rights_Regulation_BEUC_additional_inputs_to_the_202

5_call_for_evidence.pdf 125 BEUC, T&E, UFC-Que Choisir, and EPF. 126 The respondent public authorities were the Catalan Consumer Agency (Spain), the Austrian Federal

Ministry of Labour, Social Affairs, Health, Care and Consumer Protection (Austria), the Autorité de

régulation des transports (France), the Public Transport Authorities Organisation (Denmark), the Agentur

für Passagier- und Fahrgastrechte (NEB – Austria), Transportstyrelsen (NEB – Sweden), ART - Italian

Tranport Regulation Authority (NEB – Italy), Ombudsrail (Ombudsman – Belgium).

44

– particularly for separately purchased tickets, regional services, and the liability of

platforms.

ANNEX 3: ANALYTICAL METHODS

1. DESCRIPTION OF THE ANALYTICAL METHODS USED

The analytical framework used for the purpose of this Staff Working Document builds on

the PRIMES-TREMOVE and ASTRA models, as well as an excel-based tool developed in

the context of the support study127.

The main model used for developing the baseline scenario for this initiative is the

PRIMES-TREMOVE transport model by E3-Modelling, a specific module of the PRIMES

models. The model has a successful record of use in the Commission's energy, transport

and climate policy assessments. In particular, it has been used for the impact assessments

underpinning the Communication on a 2040 climate target128, the “Fit for 55” package129,

the impact assessments accompanying the 2030 Climate Target Plan130 and the Staff

Working Document accompanying the Sustainable and Smart Mobility Strategy131, the

Commission’s proposal for a Long Term Strategy132 as well as for the 2020 and 2030 EU’s

climate and energy policy framework.

The baseline scenario of the ASTRA model has been calibrated on the PRIMES-

TREMOVE results. The ASTRA model has been further used for deriving the projected

number of passengers in the baseline, consistent with the PRIMES-TREMOVE transport

activity projections. The model provides results at Member State and EU level on

economic, social and environmental indicators, including external costs. The ASTRA

model is a well-established model that has been used for numerous impact assessments in

the energy, transport and climate action fields for the past 15 years133.

For the assessment of the impacts of the policy intervention, an Excel-based tool was

developed to quantify the effects on costs and benefits in the context of the support

study134. This tool relies on the Standard Cost Model.

The proposed intervention is assumed to be implemented from 2028 onwards. The

assessment has been undertaken for the 2028-2050 period and refers to EU27. Costs and

benefits are expressed as present value over the 2028-2050 period, using a 3% discount

rate. All costs and benefits are expressed in 2024 prices.

127 Milieu consulting and Transport & Mobility Leuven (2026), Support study for a targeted revision of

Regulation (EU) 2021/782 on rail passengers’ rights and obligations. 128 EUR-Lex - 52024DC0063 - EN - EUR-Lex (europa.eu) 129 Delivering the European Green Deal | European Commission (europa.eu) 130 SWD(2020)176 final 131 EUR-Lex - 52020SC0331 - EN - EUR-Lex (europa.eu) 132 Source: 2050 long-term strategy (europa.eu) 133 For example, Register of Commission Documents - SWD(2023)351; Register of Commission Documents

- SWD(2023)443; Register of Commission Documents - SWD(2021)472; Register of Commission

Documents - SWD(2021)474 134 Milieu consulting and Transport & Mobility Leuven (2026), Support study for a targeted revision of

Regulation (EU) 2021/782 on rail passengers’ rights and obligations.

46

1.1. PRIMES-TREMOVE model

The PRIMES-TREMOVE transport model projects the evolution of demand for

passengers and freight transport, by transport mode, and transport vehicle/technology,

following a formulation based on microeconomic foundation of decisions of multiple

actors135. Operation, investment and emission costs, various policy measures, utility

factors and congestion are among the drivers that influence the projections of the model.

The projections of activity, equipment (fleet), usage of equipment, energy consumption

and emissions (and other externalities) constitute the set of model outputs.

The PRIMES-TREMOVE transport model can therefore provide the quantitative analysis

for the transport sector in the EU, candidate and neighbouring countries covering activity,

equipment, energy and emissions. The model accounts for each country separately which

means that the detailed long-term outlooks are available both for each country and in

aggregate forms (e.g. EU level).

In the transport field, PRIMES-TREMOVE is suitable for modelling soft measures (e.g.

eco-driving, labelling); economic measures (e.g. subsidies and taxes on fuels, vehicles,

emissions; ETS for transport when linked with PRIMES; pricing of congestion and other

externalities such as air pollution, accidents and noise; measures supporting R&D);

regulatory measures (e.g. CO2 emission performance standards for new light-duty vehicles

and heavy-duty vehicles; EURO standards on road transport vehicles; technology

standards for non-road transport technologies, deployment of Intelligent Transport

Systems) and infrastructure policies for alternative fuels (e.g. deployment of

refuelling/recharging infrastructure for electricity, hydrogen, LNG, CNG). Used as a

module that contributes to the PRIMES energy system model, PRIMES-TREMOVE can

show how policies and trends in the field of transport contribute to economy-wide trends

in energy use and emissions. Using data disaggregated per Member State, the model can

show differentiated trends across Member States.

The PRIMES-TREMOVE has been developed and is maintained by E3-Modelling, based

on, but extending features of, the open source TREMOVE model developed by the

TREMOVE136 modelling community. Part of the model (e.g. the utility nested tree) was

built following the TREMOVE model137. Other parts, like the component on fuel

consumption and emissions, follow the COPERT model138.

135 A detailed description of the model is available at: PRIMES MODEL 136 https://www.tmleuven.be/en/navigation/TREMOVE. 137 Several model enhancements were made compared to the standard TREMOVE model, as for example:

for the number of vintages (allowing representation of the choice of second-hand cars); for the technology

categories which include vehicle types using electricity from the grid and fuel cells. The model also

incorporates additional fuel types, such as biofuels (when they differ from standard fossil fuel technologies),

LPG, LNG, hydrogen and e-fuels. In addition, representation of infrastructure for refuelling and recharging

are among the model refinements, influencing fuel choices. A major model enhancement concerns the

inclusion of heterogeneity in the distance of stylised trips; the model considers that the trip distances follow

a distribution function with different distances and frequencies. The inclusion of heterogeneity was found to

be of significant influence in the choice of vehicle-fuels especially for vehicles-fuels with range limitations. 138 COPERT | Calculations of Emissions from Road Transport

47

Data inputs

The main data sources for inputs to the PRIMES-TREMOVE model, such as for activity

and energy consumption, come from EUROSTAT databases and from the Statistical

Pocketbook EU transport in figures139. Excise taxes are derived from DG TAXUD excise

duty tables. Other data comes from different sources such as research projects (e.g.

TRACCS and New Mobility Pattern projects) and reports. In the context of this exercise,

the PRIMES-TREMOVE transport model is calibrated to 2005, 2010, 2015 and 2020-2023

historical data, as well as the most recent data on the structure of the road transport vehicle

fleet for the first half of 2025 from the European Alternative Fuels Observatory (EAFO)140.

1.2. ASTRA - ASsessment of TRAnsport Strategies

ASTRA is a strategic model based on the Systems Dynamics Modelling approach

simulating the transport system development in combination with the economy and the

environment until the year 2050141.

ASTRA consists of different modules, each related to one specific aspect such as the

economy, transport demand or the vehicle fleet. The main modules cover the following

aspects:

1. Population and social structure (age cohorts and income groups)

2. Economy (e.g. GDP, input-output tables, employment, consumption and investment

both at aggregate and at sectoral level)

3. Foreign trade (inside EU and to partners from outside EU)

4. Transport (including demand estimation, modal split, transport cost and infrastructure

networks)

5. Vehicle fleet (passenger and freight road vehicles by segment and drivetrain)

6. Environment (including air pollutant emissions, CO2 emissions, energy consumption).

The economy module simulates the main economic variables. Some of these variables (e.g.

GDP) are transferred to the transport generation module, which uses the input to generate

a distributed transport demand.

The transport component is represented by means of two classical 4-stage transport

models, one for passenger and one for freight transport, including endogenous feedback

on all stages. Even if a full origin-destination matrix is not modelled, demand is segmented

according to trip purpose and in different distance bands to better consider the competition

between alternative modes. The transport network is not explicitly represented but

information on network capacity is considered in a simplified way for the different

transport modes drawing on the TRUST network transport model. In the transport module,

demand is split by mode of transport. The traffic performance by mode is associated with

139 Statistical pocketbook 2025 - Mobility and Transport - European Commission 140 Homepage | European Alternative Fuels Observatory 141 A detailed description of the model is available at https://www.astra-model.eu/

48

the composition of the fleet (computed in the vehicle fleet module) and the emissions

factors (defined in the environmental module), in order to estimate total emissions.

Several feedback effects take place in the ASTRA model. For instance, the economy

module provides the level of income to the fleet module, in order to estimate vehicle

purchase. The economy module then receives information on the total number of

purchased vehicles from the fleet module to account for this item of transport consumption

and investment. Furthermore, changes in the economic system feed into changes of the

transport behaviour and alter origins, destinations and volumes of European transport

flows.

The indicators that ASTRA can produce cover a wide range of impacts, in particular

transport system operation, economic, environmental and social indicators. The

environment module uses input from the transport module (in terms of vehicle-kilometres

travelled per mode and geographical context) and from the vehicle fleet module (in terms

of composition of vehicle fleets by type of powertrain), in order to compute fuel

consumption, greenhouse gas emissions and air pollutant emissions from transport.

Strategic assessment capabilities in ASTRA cover a wide range of transport measures and

investments with flexible timing and levels of implementation. Geographically, ASTRA

covers all EU Member States plus the United Kingdom, Norway and Switzerland.

The model is built in the Vensim software and is developed and maintained by TRT, M-

Five and ISI Fraunhofer. The ASTRA model is a well-established model that has been used

for numerous impact assessments in the energy, transport and climate action fields for the

past 15 years. A dedicated version of the ASTRA model was developed by TRT and M-

Five on behalf of JRC and is being used since 2013, when the first version was developed

as part of the ASSIST project. The baseline scenario of the ASTRA model has been

calibrated on the PRIMES-TREMOVE results.

Data inputs

The main data sources for inputs to the ASTRA model, such as for activity and energy

consumption, come from EUROSTAT databases and from the Statistical Pocketbook EU

transport in figures142. Excise taxes are derived from DG TAXUD excise duty tables. Other

data comes from different sources such as research projects (e.g. New Mobility Pattern

projects) and reports. In the context of this exercise, the ASTRA transport model is

calibrated to 2005, 2010, 2015 and 2020-2023 historical data. As explained above, the

baseline scenario of the ASTRA model has been calibrated on the PRIMES-TREMOVE

results.

142 Statistical pocketbook 2025 - Mobility and Transport - European Commission

49

2. BASELINE

2.1. Main assumptions of the baseline scenario

As explained in section 1 of this Annex, the baseline scenario for this impact assessment

has been developed with the PRIMES-TREMOVE model. The baseline scenario of the

ASTRA model has been calibrated on the PRIMES-TREMOVE results.

The assumptions used for developing baseline scenarios that underpin impact assessments

in the energy, transport and climate policy areas, are consulted regularly with Member

States and other stakeholders in the context of the so-called Reference scenario process.

The baseline scenario underpinning this initiative builds on the work on the EU Reference

scenario process 2025, that is currently ongoing. In this context, the PRIMES-TREMOVE

model (and subsequently the ASTRA model) has been calibrated on the latest available

statistics. The macro-economic projections, the energy price projections and the

technology assumptions have been consulted with Member States during a meeting of the

Reference scenario expert group on 5 June 2024. In addition, bilateral meetings with

Member States took place between September 2024 and April 2025 to discuss the national

policies to be reflected, based on the updated National Energy and Climate Plans prepared

by the Member States under the Regulation 2018/1999 on the Governance of the Energy

Union and Climate Action and submitted to the Commission during 2024-2025.

The technology assumptions, that drive the magnitude of the impacts on costs and benefits,

are based on a rigorous literature review carried out by E3-Modelling in collaboration with

the JRC and building on studies conducted for the Commission and used in previous impact

assessments on related topics143. Continuing the approach adopted in the long-term

strategy in 2018 and for the Reference Scenario 2020, the Commission consulted on the

technology assumptions with Member States and stakeholders in 2024, as further

explained in the following sections.

The baseline scenario reflects the projected higher energy prices driven by the Russian

invasion of Ukraine. Beyond this aspect, it was however not possible to quantify the impact

of the Russian invasion of Ukraine, as there is large uncertainty with respect to its impacts,

in particular for the medium to long-term. While its impact is felt in terms of trade (e.g.,

grain, bulk fertilizers and hydrocarbons) and in certain geographical areas, the impact on

the baseline of this initiative is expected to be limited.

The main assumptions related to economic development, international energy prices and

technologies are described below.

2.1.1. Economic assumptions

The modelling work is based on socio-economic assumptions describing the expected

evolution of the European society. Long-term projections on population dynamics and

143 Sources include: ACEA, Bloomberg, NEF, Goldman Sachs, ICCT, IEA, Ricardo, DEA, other scientific

publications.

50

economic activity form part of the input to the model and are used to estimate transport

activity, particularly relevant for this impact assessment.

Population projections rely on Eurostat’s long-term projections (EUROPOP2023)144. The

EU population is projected to remain broadly stable over the projection period to 2050.

However, there is a noticeable trend towards the ageing of the population, with a 10%

decline in the working-age population aged 20 to 64 between 2025 and 2050 and an

increase in the old-age dependency ratio from 38% to 55.2% (Figure 2).

Figure 2: Population assumptions

Source: Eurostat

Economic projections have taken place in an unusually unstable context in the past few

years, as the EU and world economies were hit first by the COVID pandemic and second

by Russia’s war of aggression against Ukraine, with the ensuing sharp increase in

international energy prices. The GDP projections for 2025 rely on the Spring Forecast145

of the Directorate General for Economic and Financial Affairs (DG ECFIN). From 2025

onwards, the GDP growth projections converge to those prepared by DG ECFIN for the

2024 Ageing Report146. At EU level, real GDP is projected to be 23% higher in 2030 than

in 2015, 39% higher in 2040, and 60% higher in 2050 compared to 2015.

Projections on the sectoral composition of GDP were prepared using the GEM-E3

computable general economic model. It is projected that the EU economy will continue to

become increasingly services-oriented, with the sector’s share rising from close to 74% of

total gross value added (GVA) in 2016-2020 to around 75% in 2040 and 76% in 2050.

While the share of the transport sector in total GVA declined during the COVID pandemic,

the projections assume that this was only a temporary phenomenon, and that the sector’s

144 EUROPOP2023 (proj_23n). 145 DG ECFIN, https://ec.europa.eu/commission/presscorner/detail/en/ip_22_6782 146 DG ECFIN, 2024 Ageing Report. Economic and budgetary projections for the EU Member States (2022-

2070).

0%

10%

20%

30%

40%

50%

60%

0

50

100

150

200

250

300

350

400

450

500

20 25

20 26

20 27

20 28

20 29

20 30

20 31

20 32

20 33

20 34

20 35

20 36

20 37

20 38

20 39

20 40

20 41

20 42

20 43

20 44

20 45

20 46

20 47

20 48

20 49

20 50

M ill

io n

pe op

le

Old-age dependency ratio (RHS) Total population Working-age population (20-64y)

51

share remains broadly constant at close to 5% of the total. This is consistent with recent

economic developments.

Figure 3: EU GDP (2015 = 100) and GDP growth (%)

Source: DG ECFIN

2.1.2. International energy prices assumptions

Alongside socio-economic projections, transport modelling requires projections of

international fuel prices. The table below shows the oil prices assumptions of the baseline

used in this impact assessment.

Table 15: Oil prices assumptions

Oil 2015 2020 2030 2040 2050

in $'2023 per boe 62.6 48.0 92.8 105.7 131.6

in €'2023 per boe 57.5 44.0 85.2 97.0 120.7

2.1.3. Technology assumptions

Modelling scenarios on the evolution of the transport system is highly dependent on the

assumptions on the development of technologies - both in terms of performance and costs.

For the purpose of the development of the baseline, these assumptions have been updated

based on a rigorous literature review carried out by external consultants in collaboration

with the JRC.

Continuing the approach adopted in the long-term strategy in 2018 and for the Reference

Scenario 2020, the Commission consulted on the technology assumptions with Member

States and stakeholders in 2024. In particular, the technology database of PRIMES-

TREMOVE transport model was discussed with Member States during a meeting of the

Reference scenario expert group on 5 June 2024. They also benefited from a dedicated

consultation workshop with stakeholders, held on 22-23 October 2024.

-6%

-4%

-2%

0%

2%

4%

6%

90

100

110

120

130

140

150

160

170

20 15

20 17

20 19

20 21

20 23

20 25

20 27

20 29

20 31

20 33

20 35

20 37

20 39

20 41

20 43

20 45

20 47

20 49

20 15

=1 00

Real GDP (2015=100) Real GDP growth (RHS)

52

2.1.4. Policies in the Baseline scenario

In line with the Better Regulation toolbox (Tool #60), the baseline has been designed to

include the initiatives of the ‘Fit for 55’ package147 and the proposed amendment of the

European Climate Law to include a 2040 climate target for the EU148, of reducing the EU's

net greenhouse gas emissions by 90% by 2040 relative to 1990, with a limited contribution

towards the 2040 target of high-quality international credits. It also reflects the CO2

emission performance standards for heavy-duty vehicles149, the Euro 7 standards150, the

revised TEN-T Regulation151, as well as the initiatives part of the Greening Freight

package152 and Roadworthiness package153. It further reflects the National Energy and

Climate Plans prepared by the Member States under the Regulation 2018/1999 on the

Governance of the Energy Union and Climate Action and submitted to the Commission

during 2024-2025. The baseline is common to that of the impact assessment accompanying

the initiatives on Multimodal Digital Mobility Services and the Single Digital Booking and

ticketing regulation.

The baseline scenario assumes no further EU level intervention beyond the Regulation

(EU) 2021/782 on rail passengers’ rights and obligations. Despite the obligation on railway

undertakings to make all reasonable efforts to cooperate between them to offer through-

tickets, the baseline assumes no systematic and comprehensive cooperation and

corresponding offer for long-distance and regional journeys in the Union. Thus, without

EU level intervention, the current situation is expected to persist, with passengers with a

single ticket for a multi-operator journey with one or more connections not being

guaranteed protection in the event of a missed connection in the absence of a through-

ticket.

The baseline also incorporates perspectives on potential future developments captured in

the 2022 Strategic Foresight Report154 and during a foresight workshop organised by DG

MOVE and JRC on 10 February 2025, analysing the impacts of the megatrends and drivers

of change on the EU transport sector155. In particular, the projected transport activity draws

on the long-term population projections from Eurostat and GDP growth from the Ageing

Report 2024156. An increasingly connected world with high levels of access to digital

products and services and in which new services, business models, life and work patterns

emerge is the background against which the initiative is assessed.

147 Delivering the European Green Deal - European Commission 148 COM(2025) 524 final 149 Regulation (EU) 2024/1610 150 Regulation - 2024/1257 - EN - EUR-Lex 151 Regulation - EU - 2024/1679 - EN - EUR-Lex 152 Green Deal: Greening freight for more economic gain with less environmental impact (europa.eu). 153 Updated rules for safer roads, less air pollution and digital vehicle documents 154 COM(2022) 289 final 155 https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en#explore 156 DG ECFIN, 2024 Ageing Report. Economic and Budgetary Projections for the EU Member States (2022-

2070) - Economy and Finance

53

2.2. Baseline scenario results

2.2.1. Number of passengers

Total number of passengers travelling by rail. The number of passengers travelling by rail

is projected to increase from 8.6 billion in 2019 to 9.6 billion in 2028, 10.7 billion in 2030

and 12.5 billion by 2050, driven in particular by the completion of the TEN-T core network

by 2030, the extended core network by 2040 and of the comprehensive network by 2050,

supported by the CEF, Cohesion Fund and ERDF funding, but also by measures of the ‘Fit

for 55’ package and the revised TEN-T Regulation.

Table 16: Projected number of passengers travelling by rail at EU level in the baseline (million) 2019 2028 2030 2040 2050 2019-2030 2019-2040 2019-2050

Number of

passengers

8,639 9,639 10,720 11,864 12,525 24.1% 37.3% 45.0%

Source: Ricardo et al. (2026), Impact assessment support study; ASTRA. Note: Excluding tram and metro.

The projected number of passengers travelling by rail, by Member State, is provided in the

table below.

Table 17: Projected number of passengers travelling by rail, by Member State, in the baseline

(million) Country 2019 2028 2030 2040 2050

AT 315 358 367 393 396

BE 317 340 353 390 394

BG 21 23 25 30 37

CY 0 0 0 0 0

CZ 194 212 239 254 257

DE 2,938 3,200 3,596 3,736 3,742

DK 207 224 229 233 235

EE 8 9 9 10 11

EL 20 16 20 20 21

ES 635 787 900 1,008 1,038

FI 93 93 98 100 102

FR 1,265 1,430 1,575 1,833 2,078

HR 20 27 29 34 40

HU 273 314 316 368 469

IE 50 55 60 60 73

IT 898 978 1,155 1,375 1,380

LT 5 8 11 15 16

LU 25 32 33 34 35

LV 19 21 22 22 23

MT 0 0 0 0 0

NL 389 412 447 451 452

PL 344 428 512 592 727

PT 176 224 227 370 443

54

Country 2019 2028 2030 2040 2050

RO 70 86 104 121 127

SE 265 271 294 299 301

SI 13 17 17 24 32

SK 81 76 81 90 97

EU total 8,639 9,639 10,720 11,864 12,525

Source: Ricardo et al. (2026), Impact assessment support study; ASTRA. Note: Excluding tram and metro.

Number of regional, long-distance and international rail passengers. The share of

regional, long-distance and international rail passengers is estimated at 57% at EU level,

with a variation of around 20% depending on the Member State157. The shares at Member

State level are kept constant over time in the baseline scenario. The number of regional,

long-distance and international rail passengers is projected to increase from around 5

billion in 2023 to 5.5 billion in 2028, 6.1 billion in 2030 and 7.1 billion in 2050.

Table 18: Projected number of regional, long-distance and international rail passengers, by

Member State, in the baseline (million) Country 2023 2028 2030 2040 2050

AT 197 208 214 229 231

BE 178 185 193 213 215

BG 12 13 14 18 21

CY 0 0 0 0 0

CZ 119 131 148 157 159

DE 1,796 1,968 2,211 2,297 2,301

DK 103 107 110 111 112

EE 5 5 5 6 7

EL 6 6 7 7 8

ES 274 317 363 406 418

FI 60 62 66 67 68

FR 893 979 1,078 1,255 1,423

HR 14 16 17 20 24

HU 116 122 122 142 182

IE 33 36 39 39 47

IT 492 556 657 782 785

LT 3 5 7 9 9

LU 13 15 15 16 16

LV 12 12 13 13 13

MT 0 0 0 0 0

NL 208 221 240 242 243

157 Milieu consulting and Transport & Mobility Leuven (2026), Support study for a targeted revision of

Regulation (EU) 2021/782 on rail passengers’ rights and obligations. The 2017 IA assumed that regional,

long-distance, and international services accounted for 81% of passenger-kilometres. This share exceeds the

corresponding share of passengers for those services, as urban and suburban journeys are numerous but

contribute fewer passenger-kilometres per trip.

55

Country 2023 2028 2030 2040 2050

PL 208 248 296 343 421

PT 43 47 48 78 93

RO 48 57 69 80 84

SE 153 161 174 177 178

SI 7 7 8 11 14

SK 46 47 49 55 59

EU total 5,039 5,530 6,163 6,773 7,131

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Number of regional, long-distance and international passengers taking journeys involving

multiple rail undertakings (excluding through-tickets). According to the support study,

multi-operator rail journeys, other than through-tickets, represent around 13% of ticket

sales in regional, long-distance, and international services at EU level. This share is

estimated based on stakeholder consultation, expert opinions158 and the 2024

Eurobarometer survey on Multimodal Digital Mobility Service159. Thus, the number of

regional, long-distance and international passengers taking journeys involving multiple rail

undertakings (excluding through-tickets) is estimated at 748 million in 2028, increasing to

836 million in 2030 and 962 million in 2050.

For the analysis, all these journeys are assumed to be booked on one platform in a single

transaction. However, acknowledging the large uncertainty regarding the estimates,

sensitivity analysis has been further performed.

Table 19: Projected number of regional, long-distance and international passengers taking

journeys involving multiple rail undertakings (excluding through-tickets), by Member State, in the

baseline (million) Country 2023 2028 2030 2040 2050

AT 23 25 25 27 27

BE 19 20 21 23 23

BG 1 1 1 1 2

CY 0 0 0 0 0

CZ 16 18 20 22 22

DE 285 312 350 364 365

DK 12 12 12 12 13

EE 0 0 0 0 0

EL 1 1 1 1 1

ES 39 45 51 57 59

FI 5 5 6 6 6

FR 114 125 137 160 181

158 The share of total number of combined journey rail tickets that are not a trough ticket, varies from 13%

in 2019 to 16% in 2024 in Croatia. According to SNCF Voyageurs (France) estimations, 94% of the tickets

that include a transfer are sold as a through ticket in 2024 (TGV + other train from SNCF Voyageurs). 159 Flash Eurobarometer 551 – Multimodal Digital Mobility Service

https://europa.eu/eurobarometer/surveys/detail/3178

56

Country 2023 2028 2030 2040 2050

HR 1 1 1 2 2

HU 13 14 14 16 21

IE 4 4 4 5 5

IT 53 60 71 85 85

LT 0 0 0 1 1

LU 1 1 1 1 1

LV 1 1 1 1 1

MT 0 0 0 0 0

NL 20 21 23 23 23

PL 35 42 51 58 72

PT 5 5 6 9 11

RO 6 8 9 11 11

SE 19 20 22 22 22

SI 1 1 1 1 1

SK 6 6 6 7 7

EU total 680 748 836 914 962

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

2.2.2. Number of passengers subject to delayed and cancelled trains that result in

missed connections for journeys booked on one platform in a single

transaction

Considering a typical rail journey (regional, long-distance and international) consisting of

two legs each operated by a different railway undertaking160, it is assumed that a missed

connection with the second leg occurs due to a delay or cancellation of the first leg.

For the purpose of the analysis, it is assumed that a delay of at least 60 minutes on the first

leg results in a missed connection on the subsequent leg(s) of the journey performed under

the single ticket, which will subsequently lead to a delay at arrival at the final destination

of at least 60 minutes or more. While delays of shorter duration may result in missed

connections, the 60 minutes mirrors the current legal threshold for reimbursement and re-

routing, assistance and compensation. This assumption is also supported by evidence from

Renfe’s guaranteed connection for its own trains, which applies only when there is a delay

of at least 60 minutes between the arrival of the first train and the departure of the second

train, if the connection takes place within the same train station161.

Punctuality figures have been gathered for each Member State for 2023 drawing on the

individual Service Quality Reports for RUs available on European Union Agency for

Railways (ERA) website162. These Service Quality Reports provide details for each

Member State on the trains that are delayed above 5 minutes. Based on this data, as shown

160 The assumption that a typical multi-operator rail journey (that is not a through-ticket) involves two

operators and one connection between them is also supported by Annex 1.

161 https://www.renfe.com/es/en/ayuda/informacion-legal-viajeros/condiciones-generales-renfe-viajeros 162 ERA (2025), Service Quality Reports,https://www.era.europa.eu/library/railway-undertakings-service-

quality-reports

57

in the table below, at EU level, 13.61% of trains were delayed above 5 minutes on average

in 2023.

Table 20: Share of delayed trains (above 5 minutes), EU average for 2023 Data source International Domestic

long-distance

International, long-distance

and regional trains

Average

ERA Service Quality Reports 28.12% 22.94% 9.49% 13.61%

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Data on delays above 60 minutes is not widely available. However, for some RUs the

proportion of trains delayed by 60-119 minutes and above 120 minutes, compared to all

trains delayed above 5 minutes, is available in the service quality reports. The table below

shows the data for the RUs with sufficient data to allow performing a statistical analysis

for the shares above 60 and 120 minutes. For each of them, the most recent year (2021-

2024) is shown.

Regression analysis was performed to determine the probability of a delay of at least 60 or

120 minutes compared to the probability of a delay of at least 5 minutes. This was used to

fill in the data gaps for Member States that lacked data for longer delay durations. Based

on the table below, the analysis shows that in 2023:

• 0.83% of the regional, international and long-distance trains (i.e. 6.13% of the 13.61%

trains with a delay of more than 5 minutes) experienced a delay of 60-119 minutes;

• 0.26% of the regional, international and long-distance trains (i.e. 1.89% of the 13.61%

trains with a delay of more than 5 minutes) experienced a delay of more than 120

minutes.

In the baseline scenario, improvements in punctuality are projected over time due to the

implementation of the TEN-T Regulation163. Thus, by 2050, 0.44% of the regional,

international and long-distance trains are projected to experience a delay of 60-119 minutes

and 0.10% of the regional, international and long-distance trains a delay of more than 120

minutes.

In lack of other data available, it has been assumed that the share of affected passengers is

the same as the share of affected trains.

163 The effect of the implementation of the TEN-T Regulation on the 5 minutes punctuality draws on the

impact assessment underpinning the Proposal for a Regulation of the European Parliament and of the Council

amending Regulations (EC) No 261/2004, (EC) No 1107/2006, (EU) No 1177/2010, (EU) No 181/2011 and

(EU) 2021/782 as regards enforcement of passenger rights in the Union Proposal for a Regulation of the

European Parliament and of the Council on passenger rights in the context of multimodal journeys

(SWD(2023) 386 final): (i) below 80% punctuality, an improvement of 1 percentage point of the punctuality

is assumed on yearly basis; (ii) between 80% and 90%, an improvement of 0.5 percentage point of the

punctuality is assumed on yearly basis; (iii) between 90% and 95%, an improvement of 0.25 percentage point

of the punctuality is assumed on yearly basis. It was further assumed that punctuality cannot improve above

95%, meaning that 5% of the trains will be delayed by at least 5 minutes. Based on this, the share of regional,

international and long-distance trains delayed by 60-119 minutes and by more than 120 minutes was further

calculated.

Table 21: Share of trains delayed above 5 minutes, above 60 minutes, for 60-119 minutes and above 120 minutes, by type of trains and RU. (-) means that there is no

data available.

% delay (>5') % delay (>60') % delay (60'-119') % delay (>120')

RU Year Long

distance

Regio-

nal

Inter-

national

Average

for all

distances

Long

distance

Regio-

nal

Inter-

national

Average

for all

distances

Long

distance

Regio-

nal

Inter-

national

Average

for all

distances

Long

distance

Regio-

nal

Inter-

national

Average

for all

distances

IT Trenitalia 2024 11.600 6.400 28.500 - 2.400 0.100 1.700 - 1.900 0.100 1.300 - 0.500 0.0 0.300 -

ES Renfe 2021 17.850 7.510 - - 1.110 0.870 - - 0.810 0.740 - - 0.300 0.130 - -

SE SJ 2024 41.000 13.000 - 13.000 - - - - - - - - - - - -

BE Eurostar

(THI) 2024 - - - 23.100 - - - - - - - - - - - -

BE SNCB

/NMBS 2024 12.300 8.400 25.550 10.300 - - - 0.042 - - 0.040 0.002

FR Eurostar

(London) 2022 - - 30.400 - - - - - - - - - - - - -

BE Eurostar 2024 - - 30.300 - - - - - - - - - - - - -

FR SNCF 2022 - - 16.300 11.700 - - - - - - - - - - - -

AT ÖBB 2023 19.700 4.300 5.000 1.400 0 - 0.100 1.100 0 - 0.100 0.300 0 - 0

NL NS 2023 - - 31.700 6.300 - - - 0.100 - - - 0.100 - - - 0

DE DB 2024 37.500 - - - 2.800 - - - 2.400 - - - 0.400 - - -

DE Flixtrain 2024 - - - - - - - - - - - - - - - -

ES ELRON 2024 - - - 3.650 - - - - - - - - - - - -

DK DSB 2024 13.650 11.625 - 9.478 - - - 0.024 - - - 0.010 - - - 0.014

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study, based on ERA Service Quality Report data

The number of passengers subject to trains delayed for 60-119 minutes and above 120

minutes that result in missed connections for journeys booked on one platform in a single

transaction is provided in the tables below.

Table 22: Number of passengers subject to trains delayed for 60-119 minutes that result in missed

connections for journeys booked on one platform in a single transaction (in million) Country 2028 2030 2040 2050

AT 0.08 0.08 0.08 0.08

BE 0.12 0.12 0.10 0.07

BG 0.00 0.00 0.00 0.01

CY 0.00 0.00 0.00 0.00

CZ 0.10 0.11 0.08 0.07

DE 2.56 2.66 1.93 1.38

DK 0.06 0.06 0.04 0.04

EE 0.00 0.00 0.00 0.00

EL 0.01 0.01 0.01 0.00

ES 0.29 0.31 0.26 0.18

FI 0.01 0.02 0.02 0.02

FR 0.73 0.77 0.65 0.54

HR 0.02 0.02 0.02 0.01

HU 0.12 0.11 0.09 0.08

IE 0.03 0.03 0.02 0.02

IT 0.39 0.42 0.38 0.26

LT 0.00 0.00 0.00 0.00

LU 0.01 0.01 0.00 0.00

LV 0.00 0.00 0.00 0.00

MT 0.00 0.00 0.00 0.00

NL 0.12 0.12 0.08 0.07

PL 0.22 0.25 0.20 0.22

PT 0.05 0.04 0.05 0.04

RO 0.11 0.12 0.10 0.07

SE 0.12 0.12 0.09 0.07

SI 0.00 0.00 0.00 0.00

SK 0.05 0.05 0.04 0.03

EU total 5.20 5.43 4.24 3.26

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Table 23: Number of passengers subject to trains delayed above 120 minutes that result in missed

connections for journeys booked on one platform in a single transaction (in million) Country 2028 2030 2040 2050

AT 0.02 0.02 0.03 0.03

BE 0.04 0.04 0.03 0.02

BG 0.00 0.00 0.00 0.00

CY 0.00 0.00 0.00 0.00

CZ 0.03 0.03 0.02 0.02

DE 0.79 0.82 0.60 0.42

DK 0.02 0.02 0.01 0.01

60

Country 2028 2030 2040 2050

EE 0.00 0.00 0.00 0.00

EL 0.00 0.00 0.00 0.00

ES 0.09 0.09 0.08 0.06

FI 0.00 0.00 0.00 0.00

FR 0.23 0.24 0.20 0.17

HR 0.01 0.01 0.00 0.00

HU 0.04 0.03 0.03 0.02

IE 0.01 0.01 0.01 0.01

IT 0.12 0.13 0.12 0.08

LT 0.00 0.00 0.00 0.00

LU 0.00 0.00 0.00 0.00

LV 0.00 0.00 0.00 0.00

MT 0.00 0.00 0.00 0.00

NL 0.04 0.04 0.03 0.02

PL 0.07 0.08 0.06 0.07

PT 0.01 0.01 0.01 0.01

RO 0.03 0.04 0.03 0.02

SE 0.04 0.04 0.03 0.02

SI 0.00 0.00 0.00 0.00

SK 0.02 0.02 0.01 0.01

EU total 1.60 1.67 1.31 1.00

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

A cancellation of the first leg of a journey booked on one platform in a single transaction

is also assumed to result in a missed connection and a delay of at least 60 minutes at the

final destination.

Based on the information available in the ERA Service Quality Reports164 and a T&E

study165, the average share of trains affected by cancellations resulting in missed

connections is estimated at 2.76% for each Member States in 2023166. This average rate is

expected to decline to 1.21% in 2050, given the expected improved quality of services

driven by the implementation of the TEN-T Regulation167. In lack of other data available,

it has been assumed that the share of affected passengers is the same as the share of affected

trains.

164 ERA (2025), Service Quality Reports,https://www.era.europa.eu/library/railway-undertakings-service-

quality-reports 165 T&E (2024). Mind the Gap! Europe’s Rail Operators: A Comparative Ranking 166 A weighted average was calculated using ERA data from operators providing sufficient detail to

distinguish between (sub)urban, regional, long-distance, and international passengers: Trenitalia (IT, 2024),

Renfe (ES, 2021), SNCB/NMBS (BE, 2024), SNCF (FR, 2022), ÖBB (AT, 2023), NS (NL, 2023), DB (DE,

2024), and DSB (DK, 2024). The overall average also takes into account the T&E study. 167 A yearly rate of decline of 3% in the proportion of cancelled trains is considered due to the implementation

of the TEN-T Regulation (SWD(2023) 386 final).

61

Table 24: Share of cancelled trains, EU average for 2023 Data source International Domestic

long-distance

International, long-distance

and regional trains

T&E study 3.12% 2.38%

ERA Service Quality Reports 2.93% 2.24% 1.91%

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

The number of passengers subject to cancelled trains that result in missed connections for

journeys booked on one platform in a single transaction is provided in the table below.

Table 25: Number of passengers subject to cancelled trains that result in missed connections for

journeys booked on one platform in a single transaction (in million) Country 2028 2030 2040 2050

AT 0.58 0.56 0.44 0.33

BE 0.47 0.46 0.38 0.28

BG 0.03 0.03 0.02 0.02

CY 0.00 0.00 0.00 0.00

CZ 0.43 0.46 0.36 0.27

DE 7.40 7.82 5.99 4.43

DK 0.28 0.27 0.21 0.15

EE 0.00 0.00 0.00 0.00

EL 0.02 0.02 0.01 0.01

ES 1.06 1.14 0.95 0.72

FI 0.13 0.13 0.10 0.07

FR 2.95 3.06 2.63 2.20

HR 0.03 0.03 0.03 0.02

HU 0.33 0.31 0.27 0.25

IE 0.10 0.10 0.07 0.07

IT 1.43 1.58 1.39 1.03

LT 0.01 0.01 0.01 0.01

LU 0.03 0.03 0.02 0.02

LV 0.02 0.02 0.01 0.01

MT 0.00 0.00 0.00 0.00

NL 0.51 0.52 0.38 0.28

PL 1.00 1.13 0.96 0.87

PT 0.13 0.12 0.15 0.13

RO 0.18 0.21 0.18 0.14

SE 0.47 0.48 0.36 0.27

SI 0.01 0.01 0.01 0.01

SK 0.14 0.14 0.11 0.09

EU total 17.74 18.65 15.05 11.67

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Overall, in the baseline scenario the number of passengers subject to delayed and cancelled

trains that result in missed connections for journeys booked on one platform in a single

transaction are estimated at 24.5 million in 2028, 25.8 million in 2030 and 15.9 million in

62

2050 at EU level. Their number is projected to increase until 2030, due to the expected

increase in the rail travel, but post-2030 this is projected to be counterbalanced by

improvements in punctuality, driven by the implementation of the TEN-T Regulation.

Table 26: Number of passengers subject to delayed and cancelled trains that result in missed

connections for journeys booked on one platform in a single transaction (in million) Country 2028 2030 2040 2050

AT 0.68 0.67 0.55 0.44

BE 0.63 0.62 0.50 0.37

BG 0.03 0.03 0.03 0.03

CY 0.00 0.00 0.00 0.00

CZ 0.56 0.59 0.46 0.35

DE 10.75 11.31 8.52 6.23

DK 0.36 0.35 0.26 0.20

EE 0.00 0.00 0.00 0.00

EL 0.03 0.03 0.02 0.02

ES 1.44 1.55 1.28 0.95

FI 0.15 0.15 0.12 0.09

FR 3.91 4.07 3.47 2.90

HR 0.05 0.05 0.05 0.04

HU 0.48 0.45 0.38 0.36

IE 0.14 0.14 0.11 0.09

IT 1.93 2.14 1.88 1.37

LT 0.01 0.01 0.01 0.01

LU 0.04 0.03 0.03 0.02

LV 0.02 0.02 0.01 0.01

MT 0.00 0.00 0.00 0.00

NL 0.66 0.67 0.49 0.37

PL 1.30 1.46 1.23 1.15

PT 0.19 0.18 0.21 0.19

RO 0.32 0.36 0.31 0.23

SE 0.63 0.65 0.48 0.35

SI 0.02 0.02 0.02 0.02

SK 0.20 0.20 0.16 0.13

EU total 24.54 25.75 20.59 15.94

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

While the affected number of passengers is limited in absolute numbers, it needs to be

noted that the impact of a missed connection on an individual passenger is high and has a

chilling effect on the willingness to travel by rail. According to a Eurobarometer survey

18% of respondents fear being stranded when travelling on separate tickets168.

168 European Commission (2025), Eurobarometer No. 3178.

63

3. IMPACTS OF THE POLICY INTERVENTION ON COSTS AND COSTS SAVINGS

This section explains the inputs used and provides the detailed assessment of the impacts

of the policy intervention on costs and costs savings.

3.1. Impact on passengers

The measure is expected to benefit passengers in the event of a missed connection during

a multi-operator journey bought under a “single ticket” by granting them full passenger

rights (such as re-routing, reimbursement, compensation, and assistance) if they miss a

connection on a rail journey involving multiple operators provided that they hold a single

ticket. In addition, passengers will also benefit from reduced hassle costs. More detailed

explanations on the calculation of the benefits and hassle costs savings are provided below.

Benefits due to re-routing or reimbursement

Passengers with single tickets will have the right to re-routing or reimbursement where

their arrival at the final destination is reasonably expected to be delayed due to a missed

connection. In such a situation, the passenger will have a choice between: (i) renouncing

to their journey and get full reimbursement of the ticket; (ii) re-routing or continuation of

the journey free of charge, either at the earliest opportunity or at a later date, at the

passenger’s convenience. Based on the available evidence, the proportion of passengers

asking for re-routing is assumed at 90%169. For the purpose of the analysis, it is assumed

that those 90% of passenger choosing re-routing will be re-routed in respect of all cancelled

services as well as those delayed by at least 60 minutes170. Out of the remaining 10% of

passengers who are assumed not to request re-routing, it is further assumed that only 38%

of them will actually ask for a reimbursement, with the rest making no claim171.

The benefits for the passengers consist of either: 1) the original ticket price that is

reimbursed, multiplied by the number of affected passengers, or 2) not having to bear the

cost of buying a new ticket or tickets at same prices to get to their final destination thanks

to the re-routing offered by the railway undertaking. The average ticket price per Member

State for regional, long-distance and international trips has been calculated based on the

169 Milieu SRL (2026), Support study for the report on the implementation and results of Regulation (EU)

2021/782 on rail passengers’ rights and obligations. It should be noted that in some cases the AJC and

HOTNAT agreements are operational and some passengers on some multi-operator trips will be assisted in

the baseline, albeit on a voluntary basis. However, the number of passengers assisted is not available. Also,

some passengers neither ask for reimbursement nor for re-routing but simply abandon their journey without

asking for reimbursement despite being eligible. For example, Germany reports 60-70% for re-routing, 10-

15% for reimbursement, indicating that 15-30% chooses neither. 170 SWD(2023)386 171 SWD(2023)386

64

railway undertaking’s revenues172, the number of passengers173 and the estimated length

of regional, long-distance and international trips. The average ticket prices for regional,

long-distance and international trips per Member State for 2023 (expressed in 2024 prices)

are presented in the table below. For the assessment, they are kept constant over time in

2024 prices.

Table 27: Average ticket price per passenger for regional, long-distance and international trips,

by Member State (in EUR, in 2024 prices) Country Average ticket price per passenger (in EUR)

AT 17.2

BE 31.0

BG 13.1

CY -

CZ 18.5

DE 15.6

DK 15.1

EE 16.2

EL 30.0

ES 20.8

FI 9.8

FR 24.2

HR 9.9

HU 16.0

IE 16.4

IT 20.0

LT 32.9

LU 37.6

LV 6.7

MT -

NL 26.4

PL 13.9

PT 15.7

RO 18.5

SE 12.7

172 IRG-Rail (2024), 13th Market Monitoring Report, based on railway undertaking revenues for 2023. The

average ticket price has been estimated for regional, long‑distance and international rail services by first

estimating the average length of such services in each Member State and then multiplying this distance by

the estimated ticket price per passenger‑kilometer in that Member State. The latter is obtained by dividing

total passenger revenues by the total number of passenger‑kilometers of the relevant incumbent railway

undertaking. As no disaggregated data on revenue per passenger‑kilometer by service type are available, the

same estimated price per passenger‑kilometer is applied to all services (regional, long‑distance and

international) within each Member State. 173 Source: Eurostat.

65

Country Average ticket price per passenger (in EUR)

SI 29.7

SK 17.7

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

The benefits for passengers due to reimbursement, by Member State, are provided in the

table below. Expressed as present value over 2028-2050, relative to the baseline, they are

estimated at EUR 182.3 million at EU level.

Table 28: Benefits for passengers due to reimbursement, by Member State (in million EUR, in 2024

prices) Country 2028 2030 2040 2050

AT 0.38 0.37 0.29 0.22

BE 0.55 0.54 0.44 0.33

BG 0.01 0.01 0.01 0.01

CY 0.00 0.00 0.00 0.00

CZ 0.30 0.32 0.25 0.19

DE 4.38 4.63 3.55 2.62

DK 0.16 0.16 0.12 0.09

EE 0.00 0.00 0.00 0.00

EL 0.02 0.02 0.02 0.01

ES 0.84 0.90 0.75 0.57

FI 0.05 0.05 0.04 0.03

FR 2.72 2.82 2.42 2.02

HR 0.01 0.01 0.01 0.01

HU 0.20 0.19 0.16 0.15

IE 0.06 0.06 0.05 0.04

IT 1.08 1.20 1.06 0.78

LT 0.01 0.01 0.01 0.01

LU 0.04 0.04 0.03 0.02

LV 0.00 0.00 0.00 0.00

MT 0.00 0.00 0.00 0.00

NL 0.51 0.52 0.39 0.28

PL 0.53 0.59 0.51 0.46

PT 0.08 0.07 0.09 0.08

RO 0.13 0.14 0.12 0.10

SE 0.00 0.00 0.00 0.00

SI 0.00 0.00 0.00 0.00

SK 0.00 0.00 0.00 0.00

EU total 12.07 12.68 10.31 8.02

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

The benefits for passengers due to re-routing, by Member State, are provided in the table

below. Expressed as present value over 2028-2050, relative to the baseline, they are

estimated at EUR 5,658.6 million at EU level.

66

Table 29: Benefits for passengers due to re-routing, by Member State (in million EUR, in 2024

prices) Country 2028 2030 2040 2050

AT 10.36 10.08 8.32 6.57

BE 16.89 16.54 13.48 9.97

BG 0.37 0.37 0.34 0.32

CY 0.00 0.00 0.00 0.00

CZ 8.97 9.54 7.41 5.67

DE 143.73 151.27 114.17 83.54

DK 4.78 4.60 3.39 2.65

EE 0.06 0.06 0.05 0.04

EL 0.65 0.73 0.54 0.41

ES 25.89 27.79 22.99 17.19

FI 1.28 1.29 1.01 0.80

FR 82.24 85.40 73.01 61.02

HR 0.44 0.45 0.38 0.33

HU 6.65 6.25 5.30 4.94

IE 2.00 2.04 1.49 1.32

IT 33.37 36.97 32.53 23.70

LT 0.27 0.36 0.36 0.27

LU 1.15 1.12 0.84 0.66

LV 0.11 0.11 0.08 0.06

MT 0.00 0.00 0.00 0.00

NL 15.06 15.39 11.32 8.56

PL 15.60 17.57 14.80 13.85

PT 2.56 2.44 2.87 2.52

RO 5.00 5.62 4.79 3.57

SE 0.00 0.00 0.00 0.00

SI 0.00 0.00 0.00 0.00

SK 0.00 0.00 0.00 0.00

EU total 377.42 395.97 319.46 247.96

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Compensation benefits

Where they have single tickets, passengers will also have the right to compensationin case

they do not ask for reimbursement and provided that they arrive at the final destination

with a delay of at least 60 minutes between the place of departure and the final destination

stated in their single ticket. As above, it is assumed that 90% are expected to prefer re-

routing. The proportion of passengers actually requesting compensation out of those that

experience a delay of at least 60 minutes and do not ask for reimbursement is assumed at

38%174. In line with the RPRR, a compensation of 25% of the ticket price is assumed for

174 SWD(2023)386. Furthermore, SNCF (France) confirmed in an interview that for TGV, 40% of the

passengers who experienced delays made a claim and received a compensation.

67

delays of 60 to 119 minutes and 50% for delays above 120 minutes. It is also assumed that

the re-routed passengers due to a cancellation will be delayed for 60-119 minutes, and

benefit of a compensation of 25% of the ticket price, as they will typically be assigned to

the next train one hour later. At the same time, for journeys under a single ticket exceeding

12 hours, the right to compensation should arise only in relation to the delay affecting the

specific individual transport contract, which corresponds to the baseline. This exemption

should not apply where the journey under the single ticket involves a night train. Given the

uncertainty to establish the number of passengers affected by the exemption, the exact

reduction of benefits cannot be precisely quantified and would be within the margin of the

sensitivity analysis on the proportion of passengers actually requesting compensation in

section 6.5.

The compensation benefits for passengers, by Member State, are provided in the table

below. Expressed as present value over 2028-2050, relative to the baseline, they are

estimated at EUR 632.3 million at EU level.

Table 30: Compensation benefits for passengers, by Member State (in million EUR, in 2024 prices) Country 2028 2030 2040 2050

AT 1.06 1.04 0.87 0.71

BE 1.83 1.79 1.46 1.07

BG 0.04 0.04 0.04 0.03

CY 0.00 0.00 0.00 0.00

CZ 0.96 1.02 0.79 0.61

DE 15.99 16.80 12.61 9.19

DK 0.51 0.49 0.36 0.29

EE 0.01 0.01 0.00 0.00

EL 0.07 0.08 0.06 0.05

ES 2.81 3.01 2.49 1.85

FI 0.13 0.13 0.11 0.09

FR 8.86 9.20 7.85 6.56

HR 0.05 0.05 0.04 0.04

HU 0.74 0.69 0.59 0.54

IE 0.22 0.23 0.17 0.15

IT 3.62 4.01 3.53 2.56

LT 0.03 0.04 0.04 0.03

LU 0.12 0.12 0.09 0.07

LV 0.01 0.01 0.01 0.01

MT 0.00 0.00 0.00 0.00

NL 1.61 1.64 1.20 0.92

PL 1.66 1.87 1.57 1.49

PT 0.29 0.27 0.32 0.28

RO 0.59 0.66 0.56 0.42

SE 0.75 0.76 0.57 0.42

SI 0.05 0.05 0.05 0.05

SK 0.35 0.35 0.28 0.22

68

Country 2028 2030 2040 2050

EU total 42.35 44.37 35.66 27.64

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Assistance benefits

Passengers will equally have the right to assistance when a cancelled or delayed service

causes a missed connection. Such assistance can comprise, depending on the

circumstances, basic provision of information, meals, refreshments and accommodation.

Based on the interviews with stakeholders, the average cost of such assistance is assumed

to be EUR 10 per passenger affected by the disruption175 and 5% of passengers are assumed

to request assistance176.

The assistance benefits for passengers, by Member State, are provided in the table below.

Expressed as present value over 2028-2050, relative to the baseline, they are estimated at

EUR 169.6 million at EU level.

Table 31: Assistance benefits for passengers, by Member State (in million EUR, in 2024 prices) Country 2028 2030 2040 2050

AT 0.31 0.30 0.25 0.20

BE 0.29 0.29 0.23 0.17

BG 0.01 0.01 0.01 0.01

CY 0.00 0.00 0.00 0.00

CZ 0.26 0.27 0.21 0.16

DE 5.01 5.26 3.96 2.89

DK 0.17 0.16 0.12 0.09

EE 0.00 0.00 0.00 0.00

EL 0.01 0.01 0.01 0.01

ES 0.67 0.72 0.59 0.44

FI 0.07 0.07 0.05 0.04

FR 1.81 1.88 1.61 1.34

HR 0.03 0.03 0.02 0.02

HU 0.23 0.21 0.18 0.17

IE 0.07 0.07 0.05 0.04

IT 0.89 0.99 0.87 0.63

LT 0.00 0.01 0.01 0.00

175 Assistance can comprise, depending on the circumstances, different types of services and goods such as

meals, refreshments and hotel accommodation. For an hourly frequency, or 15 trains per day, it is estimated

that all 15 possible delayed or cancelled trains lead to assistance with a drink and snack (EUR 2 per

passenger), 3 of them to a meal (EUR 10 per passenger) and one (the last one) to a hotel (EUR 100 per

passenger). The average per passenger is thus estimated at EUR 10. This assumption is based on interviews

with stakeholders and market prices. 176 Assistance is estimated at 5% by Germany in its Country Research Template report, which records

national-level information regarding the application of Regulation (EU) 2021/782. In France, requests for

assistance are approximately 3 times less frequent than the requests for compensation. Since the percentage

of passengers requesting compensation (among those entitled to do it) is estimated to 38%, the percentage of

delayed passengers receiving assistance represents 12% in France.

69

Country 2028 2030 2040 2050

LU 0.02 0.02 0.01 0.01

LV 0.01 0.01 0.01 0.00

MT 0.00 0.00 0.00 0.00

NL 0.30 0.31 0.23 0.17

PL 0.60 0.67 0.57 0.53

PT 0.09 0.08 0.10 0.09

RO 0.15 0.17 0.15 0.11

SE 0.29 0.30 0.22 0.16

SI 0.01 0.01 0.01 0.01

SK 0.10 0.10 0.08 0.06

EU total 11.38 11.95 9.54 7.38

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Total benefits for passengers due to re-routing, reimbursement, compensation, and

assistance

The total benefits due to re-routing, reimbursement, compensation, and assistance by

Member State are provided in the table below. Expressed as present value over 2028-2050,

relative to the baseline, they are estimated at EUR 6,642.8 million at EU level.

Table 32: Total benefits due to re-routing, reimbursement, compensation, and assistance for

passengers, by Member State (in million EUR, in 2024 prices) Country 2028 2030 2040 2050

AT 12.11 11.79 9.74 7.69

BE 19.56 19.15 15.61 11.54

BG 0.43 0.44 0.40 0.38

CY 0.00 0.00 0.00 0.00

CZ 10.49 11.15 8.66 6.63

DE 169.11 177.96 134.29 98.25

DK 5.62 5.41 3.99 3.12

EE 0.07 0.07 0.06 0.05

EL 0.75 0.84 0.63 0.48

ES 30.20 32.42 26.82 20.05

FI 1.53 1.53 1.21 0.95

FR 95.63 99.31 84.89 70.95

HR 0.53 0.54 0.45 0.39

HU 7.82 7.35 6.23 5.81

IE 2.35 2.39 1.75 1.55

IT 38.97 43.17 37.98 27.68

LT 0.31 0.42 0.41 0.32

LU 1.32 1.29 0.97 0.76

LV 0.13 0.13 0.10 0.08

MT 0.00 0.00 0.00 0.00

NL 17.47 17.86 13.13 9.94

70

Country 2028 2030 2040 2050

PL 18.39 20.71 17.45 16.33

PT 3.01 2.87 3.38 2.96

RO 5.87 6.60 5.63 4.18

SE 1.04 1.06 0.80 0.58

SI 0.06 0.05 0.06 0.06

SK 0.44 0.44 0.35 0.28

EU total 443.23 464.97 374.97 291.00

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Hassle costs savings for passengers

In addition to re-routing or reimbursement, compensation and assistance, the proposed

intervention is expected to reduce hassle costs for passengers. This includes the efforts

required to get the information by the passengers, the waiting time due to the missed

connections and the effort to search for new tickets177. The hassle cost savings are

quantified by multiplying the number of affected tickets by the time saved per ticket and

the passengers' average value-of-time. The time saved per ticket is conservatively assumed

at 15 minutes178, and the average value of time at EUR 11.68 per hour at EU level179,

adjusted for country-specific differences and distinguishing between professional and

leisure travel180.

The hassle costs savings for passengers, by Member State, are provided in the table below.

Expressed as present value over 2028-2050, relative to the baseline, they are estimated at

EUR 1,136.9 million at EU level.

Table 33: Hassle costs savings for passengers, by Member State (in million EUR, in 2024 prices) Country 2028 2030 2040 2050

AT 2.51 2.44 2.03 1.61

BE 2.24 2.19 1.78 1.32

BG 0.05 0.05 0.05 0.04

CY 0.00 0.00 0.00 0.00

CZ 1.63 1.73 1.34 1.03

DE 37.81 39.77 29.96 21.90

DK 1.21 1.16 0.85 0.67

EE 0.01 0.01 0.01 0.01

EL 0.05 0.05 0.04 0.03

177 This does not include the cost of the actual ticket. 178 A conservative assumption of 15 minutes savings is used. Drawing on a study by the World Bank

(https://thedocs.worldbank.org/en/doc/3ecf7262788a3ec69c8a45bbd3342a28-

0080022021/related/Spring2021-governance-talk-asli-0525.pdf), each complaint handling would benefit of

15 minutes saved under a conservative approach (lower bound) and up to 60 minutes saved (upper bound).

See also SWD(2023)386. 179 European Commission (2019): Handbook on the External Costs of Transport. 180 Source: https://www.autorite-transports.fr/wp-content/uploads/2020/07/enquete-tagv-2019.pdf. From

this, it is assumed that 27% of the train trips have a professional purpose, the remaining 73% are assumed to

be leisure trips.

71

Country 2028 2030 2040 2050

ES 3.63 3.89 3.22 2.40

FI 0.46 0.46 0.37 0.29

FR 10.72 11.13 9.51 7.95

HR 0.09 0.10 0.08 0.07

HU 1.23 1.16 0.98 0.91

IE 0.67 0.68 0.50 0.44

IT 5.21 5.77 5.08 3.70

LT 0.02 0.03 0.03 0.02

LU 0.24 0.23 0.18 0.14

LV 0.04 0.04 0.03 0.02

MT 0.00 0.00 0.00 0.00

NL 2.53 2.58 1.90 1.44

PL 2.83 3.19 2.68 2.52

PT 0.39 0.38 0.44 0.39

RO 0.61 0.69 0.58 0.43

SE 2.18 2.23 1.67 1.23

SI 0.04 0.04 0.04 0.04

SK 0.52 0.52 0.41 0.33

EU total 76.91 80.52 63.77 48.94

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Total benefits for passengers

The total benefits for passengers due to re-routing, reimbursement, compensation and

assistance as well as reduced hassle costs are provided in the table below, by Member

State. Expressed as present value over 2028-2050, relative to the baseline, they are

estimated at EUR 7,779.7 million at EU level.

Table 34: Total benefits for passengers, by Member State (in million EUR, in 2024 prices) Country 2028 2030 2040 2050

AT 14.62 14.23 11.77 9.31

BE 21.80 21.34 17.39 12.86

BG 0.48 0.49 0.45 0.42

CY 0.00 0.00 0.00 0.00

CZ 12.12 12.88 10.00 7.66

DE 206.92 217.73 164.25 120.14

DK 6.82 6.57 4.84 3.79

EE 0.08 0.08 0.07 0.06

EL 0.80 0.90 0.67 0.50

ES 33.83 36.31 30.04 22.45

FI 1.99 1.99 1.58 1.25

FR 106.35 110.44 94.40 78.90

HR 0.63 0.64 0.53 0.46

HU 9.05 8.50 7.21 6.72

72

Country 2028 2030 2040 2050

IE 3.03 3.08 2.25 1.99

IT 44.18 48.94 43.06 31.37

LT 0.33 0.45 0.44 0.34

LU 1.56 1.52 1.14 0.90

LV 0.17 0.17 0.13 0.10

MT 0.00 0.00 0.00 0.00

NL 20.00 20.44 15.03 11.37

PL 21.23 23.90 20.13 18.85

PT 3.41 3.25 3.82 3.35

RO 6.48 7.29 6.21 4.62

SE 3.22 3.29 2.46 1.81

SI 0.10 0.09 0.10 0.10

SK 0.96 0.96 0.77 0.61

EU total 520.15 545.49 438.74 339.94

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

3.2. Impact on railway undertakings

It is estimated that 158 railway undertakings will be directly affected by the intervention181.

These include all railway undertakings which have a license for passenger transport and

operate trains on regional or longer distances (excluding railway undertakings who operate

on urban and suburban lines only). Out of the 158 railway undertakings 9 are small and

medium sized enterprises.

One-off and recurrent adjustment costs for railway undertakings

Railway undertakings are expected to incur one-off adjustment costs to ensure passenger

rights in case of missed connections under a single ticket. It will be important for railway

undertakings to define the extent of their financial liability, coordinating disruption

agreements with other railway undertakings, updating technical request-handling

processes, revising terms and passenger information, training sales and support staff, and

reviewing the legal and financial implications. While not mandated by the intervention,

railway undertakings may decide to enhance their mutual cooperation with a view to

reciprocal assistance and information sharing necessary to ensure effective passenger

rights (with the existing AJC and HOTNAT frameworks as likely bases for such

cooperation), being understood that the railway undertaking whose delayed or cancelled

service causes a missed connection shall by default bear the corresponding liability.

The one-off effort required is estimated at 100 person-days of work per railway

undertaking. Assuming 7.2 working hours per day on average182 and the tariff rates by

Member State for the ISCO 3 category (technicians and associate professionals)183 in 2024

181 Source: desk research based on websites of railway regulators, railway undertakings and competent

authorities. 182 Actual and usual hours of work - Statistics Explained - Eurostat 183 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.

73

prices, the one-off adjustment costs for the 158 railway undertakings184 is estimated at

EUR 4 million in 2028 (of which EUR 216,000 for SME railway undertakings).

Table 35: One-off adjustment costs for railway undertakings, by Member State (in thousand EUR,

in 2024 prices) Country Total one-off adjustment costs of which for SMEs

AT 276 33

BE 34 0

BG 7 0

CY 0 0

CZ 103 17

DE 1,534 68

DK 197 0

EE 16 0

EL 12 0

ES 152 41

FI 26 0

FR 194 0

HR 10 0

HU 30 0

IE 34 0

IT 379 0

LT 11 0

LU 35 0

LV 13 0

MT 0 0

NL 176 32

PL 126 14

PT 24 0

RO 42 11

SE 515 0

SI 16 0

SK 28 0

EU total 3,990 216

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Railway undertakings will also incur recurrent adjustment costs related to the assistance,

reimbursement, re-routing and compensation of passengers.

For most re-routing cases, when the passenger can continue the journey by taking the next

train where seats are available which were eventually not sold, this does not represent a

cost. However, in some cases, there might be costs to bear when re-routing is done by

paying a ticket (or seat reservation) to another railway undertaking. There is no data

184 It is estimated that 158 railway undertakings will be directly affected by the intervention.

74

available on how many of such operator-to-operator transactions could be performed.

Moreover, since this cost is paid by railway undertakings to other railway undertakings, at

aggregate level the impact is assumed to be neutral, as the first one bears the costs, and the

second one gets the benefits of selling an otherwise unsold ticket. At the same time, it is

noted that this may impact individual railway undertakings differently, depending on the

route, ticket pricing policy, the number of delays/cancellations they face that result in

missed connections, and hence the impact of this re-routing cost will not be neutral at an

individual rail operator level. However, given the limited availability of data, it is not

possible to establish costs at individual railway undertaking level.

The adjustment costs related to the reimbursement of passengers (i.e. those who

experience a delay of at least 60 minutes and do not request rerouting) are derived by

multiplying the ticket price that is reimbursed with the number of affected passengers. The

proportion of such passengers actually requesting reimbursement is assumed at 38%185.

The average ticket price per Member State for regional, long-distance and international

trips has been calculated based on the railway undertaking’s revenues186, the number of

passengers187 and the estimated length of regional, long-distance and international trips.

Expressed as present value over 2028-2050, relative to the baseline, the adjustment costs

for railway undertakings related to reimbursement are estimated at EUR 182.3 million (of

which EUR 1 million for SME railway undertakings). The costs for 2028, 2030, 2040 and

2050 by Member State are provided in the table below.

Table 36: Recurrent adjustment costs for railway undertakings for reimbursement of passengers,

by Member State (in million EUR, in 2024 prices) Country 2028 2030 2040 2050

AT 0.38 0.37 0.29 0.22

BE 0.55 0.54 0.44 0.33

BG 0.01 0.01 0.01 0.01

CY 0.00 0.00 0.00 0.00

CZ 0.30 0.32 0.25 0.19

DE 4.38 4.63 3.55 2.62

DK 0.16 0.16 0.12 0.09

EE 0.00 0.00 0.00 0.00

EL 0.02 0.02 0.02 0.01

ES 0.84 0.90 0.75 0.57

FI 0.05 0.05 0.04 0.03

FR 2.72 2.82 2.42 2.02

HR 0.01 0.01 0.01 0.01

HU 0.20 0.19 0.16 0.15

IE 0.06 0.06 0.05 0.04

IT 1.08 1.20 1.06 0.78

LT 0.01 0.01 0.01 0.01

185 SWD(2023)386 186 IRG-Rail (2024), 13th Market Monitoring Report, based on railway undertaking revenues for 2023. 187 Source: Eurostat.

75

Country 2028 2030 2040 2050

LU 0.04 0.04 0.03 0.02

LV 0.00 0.00 0.00 0.00

MT 0.00 0.00 0.00 0.00

NL 0.51 0.52 0.39 0.28

PL 0.53 0.59 0.51 0.46

PT 0.08 0.07 0.09 0.08

RO 0.13 0.14 0.12 0.10

SE 0.00 0.00 0.00 0.00

SI 0.00 0.00 0.00 0.00

SK 0.00 0.00 0.00 0.00

EU total 12.07 12.68 10.31 8.02

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

The adjustment costs related to compensation, are calculated in line with the RPRR, where

a compensation of 25% of the ticket price is assumed for delays of 60 to 119 minutes and

50% for delays above 120 minutes. It is also assumed that the re-routed passengers due to

a cancellation will be delayed for 60-119 minutes and will need to be paid a compensation

of 25% of the ticket price, as they will typically be assigned to the next train one hour later.

At the same time, for journeys under a single ticket exceeding 12 hours, the right to

compensation should arise only in relation to the delay affecting the specific individual

transport contract, which corresponds to the baseline. This exemption should not apply

where the journey under the single ticket involves a night train. Given the uncertainty to

establish the number of passengers affected by the exemption, the exact reduction of costs

cannot be precisely quantified and would be within the margin of the sensitivity analysis

on the proportion of passengers actually requesting compensation in section 6.5. The

adjustment costs for railway undertakings related to compensation are estimated at EUR

632.3 million, expressed as present value over 2028-2050 relative to the baseline (of which

EUR 3.6 million for SME railway undertakings). The costs for 2028, 2030, 2040 and 2050

by Member State are provided in the table below.

Table 37: Recurrent adjustment costs for railway undertakings for compensation of passengers,

by Member State (in million EUR, in 2024 prices) Country 2028 2030 2040 2050

AT 1.06 1.04 0.87 0.71

BE 1.83 1.79 1.46 1.07

BG 0.04 0.04 0.04 0.03

CY 0.00 0.00 0.00 0.00

CZ 0.96 1.02 0.79 0.61

DE 15.99 16.80 12.61 9.19

DK 0.51 0.49 0.36 0.29

EE 0.01 0.01 0.00 0.00

EL 0.07 0.08 0.06 0.05

ES 2.81 3.01 2.49 1.85

FI 0.13 0.13 0.11 0.09

FR 8.86 9.20 7.85 6.56

76

Country 2028 2030 2040 2050

HR 0.05 0.05 0.04 0.04

HU 0.74 0.69 0.59 0.54

IE 0.22 0.23 0.17 0.15

IT 3.62 4.01 3.53 2.56

LT 0.03 0.04 0.04 0.03

LU 0.12 0.12 0.09 0.07

LV 0.01 0.01 0.01 0.01

MT 0.00 0.00 0.00 0.00

NL 1.61 1.64 1.20 0.92

PL 1.66 1.87 1.57 1.49

PT 0.29 0.27 0.32 0.28

RO 0.59 0.66 0.56 0.42

SE 0.75 0.76 0.57 0.42

SI 0.05 0.05 0.05 0.05

SK 0.35 0.35 0.28 0.22

EU total 42.35 44.37 35.66 27.64

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Railway undertakings will equally have to provide assistance when a cancelled or delayed

service causes a missed connection. Such assistance can comprise, depending on the

circumstances, basic provision of information, meals, refreshments and accommodation.

As explained in section 6.1.1, based on the interviews with stakeholders, the average cost

of such assistance is assumed to be EUR 10 per passenger affected by the disruption and

5% of passengers are assumed to request assistance188. Expressed as present value over

2028-2050, relative to the baseline, the adjustment costs for railway undertakings related

to assistance of passengers are estimated at EUR 169.6 million at EU level (of which EUR

1 million for SME railway undertakings). The costs for 2028, 2030, 2040 and 2050 by

Member State are provided in the table below.

Table 38: Recurrent adjustment costs for railway undertakings for assistance of passengers, by

Member State (in million EUR, in 2024 prices) Country 2028 2030 2040 2050

AT 0.31 0.30 0.25 0.20

BE 0.29 0.29 0.23 0.17

BG 0.01 0.01 0.01 0.01

CY 0.00 0.00 0.00 0.00

CZ 0.26 0.27 0.21 0.16

DE 5.01 5.26 3.96 2.89

DK 0.17 0.16 0.12 0.09

188 Assistance is estimated at 5% by Germany in its Country Research Template report, which records

national-level information regarding the application of Regulation (EU) 2021/782. In France, requests for

assistance are approximately 3 times less frequent than the requests for compensation. Since the percentage

of passengers requesting compensation (among those entitled to do it) is estimated to 38%, the percentage of

delayed passengers receiving assistance represents 12% in France.

77

Country 2028 2030 2040 2050

EE 0.00 0.00 0.00 0.00

EL 0.01 0.01 0.01 0.01

ES 0.67 0.72 0.59 0.44

FI 0.07 0.07 0.05 0.04

FR 1.81 1.88 1.61 1.34

HR 0.03 0.03 0.02 0.02

HU 0.23 0.21 0.18 0.17

IE 0.07 0.07 0.05 0.04

IT 0.89 0.99 0.87 0.63

LT 0.00 0.01 0.01 0.00

LU 0.02 0.02 0.01 0.01

LV 0.01 0.01 0.01 0.00

MT 0.00 0.00 0.00 0.00

NL 0.30 0.31 0.23 0.17

PL 0.60 0.67 0.57 0.53

PT 0.09 0.08 0.10 0.09

RO 0.15 0.17 0.15 0.11

SE 0.29 0.30 0.22 0.16

SI 0.01 0.01 0.01 0.01

SK 0.10 0.10 0.08 0.06

EU total 11.38 11.95 9.54 7.38

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Total recurrent adjustment costs for railway undertakings are estimated at EUR 984.2

million, expressed as present value over 2028-2050 relative to the baseline (of which EUR

5.6 million for SME railway undertakings). The costs for 2028, 2030, 2040 and 2050 by

Member State are provided in the table below.

Table 39: Total recurrent adjustment costs for railway, by Member State (in million EUR, in 2024

prices) Country 2028 2030 2040 2050

AT 1.75 1.71 1.42 1.13

BE 2.67 2.62 2.13 1.58

BG 0.07 0.07 0.06 0.06

CY 0.00 0.00 0.00 0.00

CZ 1.52 1.62 1.25 0.96

DE 25.38 26.70 20.12 14.71

DK 0.84 0.81 0.59 0.47

EE 0.01 0.01 0.01 0.01

EL 0.10 0.12 0.09 0.07

ES 4.32 4.63 3.83 2.86

FI 0.25 0.25 0.20 0.16

FR 13.39 13.90 11.88 9.93

78

Country 2028 2030 2040 2050

HR 0.09 0.09 0.08 0.07

HU 1.17 1.10 0.93 0.87

IE 0.35 0.36 0.26 0.23

IT 5.60 6.20 5.46 3.97

LT 0.04 0.06 0.06 0.04

LU 0.18 0.17 0.13 0.10

LV 0.02 0.02 0.02 0.01

MT 0.00 0.00 0.00 0.00

NL 2.42 2.47 1.82 1.38

PL 2.79 3.14 2.64 2.48

PT 0.45 0.43 0.51 0.44

RO 0.87 0.98 0.83 0.62

SE 1.04 1.06 0.80 0.58

SI 0.06 0.05 0.06 0.06

SK 0.44 0.44 0.35 0.28

EU total 65.81 69.00 55.51 43.04

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Total one-off and recurrent adjustment costs for railway undertakings are estimated at EUR

988.2 million, expressed as present value over 2028-2050 relative to the baseline (of which

EUR 5.8 million for SME railway undertakings). The costs for 2028, 2030, 2040 and 2050

by Member State are provided in the table below.

Table 40: Total one-off and recurrent adjustment costs for railway, by Member State (in million

EUR, in 2024 prices) Country 2028 2030 2040 2050

AT 2.03 1.71 1.42 1.13

BE 2.70 2.62 2.13 1.58

BG 0.07 0.07 0.06 0.06

CY 0.00 0.00 0.00 0.00

CZ 1.62 1.62 1.25 0.96

DE 26.92 26.70 20.12 14.71

DK 1.03 0.81 0.59 0.47

EE 0.03 0.01 0.01 0.01

EL 0.12 0.12 0.09 0.07

ES 4.47 4.63 3.83 2.86

FI 0.27 0.25 0.20 0.16

FR 13.58 13.90 11.88 9.93

HR 0.10 0.09 0.08 0.07

HU 1.20 1.10 0.93 0.87

IE 0.38 0.36 0.26 0.23

IT 5.98 6.20 5.46 3.97

LT 0.05 0.06 0.06 0.04

79

Country 2028 2030 2040 2050

LU 0.21 0.17 0.13 0.10

LV 0.04 0.02 0.02 0.01

MT 0.00 0.00 0.00 0.00

NL 2.60 2.47 1.82 1.38

PL 2.92 3.14 2.64 2.48

PT 0.48 0.43 0.51 0.44

RO 0.91 0.98 0.83 0.62

SE 1.55 1.06 0.80 0.58

SI 0.07 0.05 0.06 0.06

SK 0.47 0.44 0.35 0.28

EU total 69.80 69.00 55.51 43.04

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Recurrent administrative costs for railway undertakings

Railway undertakings will also experience recurrent administrative costsas they will need

to handle an increased number of re-routing, reimbursement, compensation and assistance

requests. This cost is derived by estimates of the time needed to handle each of the requests

(re-routing, reimbursement, compensation and assistance), multiplied by the total number

of requests in each Member State, and the tariff rates by Member State for the ISCO 3

category (technicians and associate professionals)189 in 2024 prices.

Table 41: Time estimates to handle requests and share of their automation Time

in minutes

Share of automated

handling

in 2028

Share of automated handling

in 2050

Reimbursement 15 20% 90%

Re-routing 5 30% 90%

Compensation 15 20% 90%

Assistance 5 15% 90%

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

The time needed to handle compensation and reimbursement claims (15 minutes) is

derived based on the stakeholder consultation and previous impact assessments190. For the

time needed to handle re-routing (5 minutes), it is assumed that a large proportion of re-

routing will consist of simply allowing the passenger on the next available train, which

would involve little administrative time, and only in a minor number of cases more

complex re-routing would be offered as an alternative. For assistance, which can involve

simple information provision, but also handling out refreshments and meals as well as the

booking of hotels, 5 minutes are assumed per request. No recurrent administrative costs

are assumed where requests are handled through automation. It is assumed that automation

would cover 15% of requests for assistance, 20% of requests for reimbursement and

189 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs. 190 SWD(2023)386

80

compensation and 30% of requests for re-routing in 2028, rising to 90% by 2050. Given

the uncertainty, sensitivity analysis has been further performed.

The recurrent administrative costs for railway undertakings for handling reimbursement

requests are provided in the table below, by Member State. Expressed as present value over

2028-2050, relative to the baseline, they are estimated at EUR 48.7 million at EU level.

Table 42: Recurrent administrative costs for railway undertakings for handling reimbursement

requests, by Member State (in million EUR, in 2024 prices) Country 2028 2030 2040 2050

AT 0.19 0.17 0.08 0.01

BE 0.17 0.15 0.07 0.01

BG 0.00 0.00 0.00 0.00

CY 0.00 0.00 0.00 0.00

CZ 0.07 0.07 0.03 0.01

DE 2.44 2.38 1.03 0.18

DK 0.12 0.10 0.04 0.01

EE 0.00 0.00 0.00 0.00

EL 0.00 0.00 0.00 0.00

ES 0.21 0.21 0.10 0.02

FI 0.03 0.03 0.01 0.00

FR 0.86 0.82 0.40 0.08

HR 0.00 0.00 0.00 0.00

HU 0.03 0.03 0.01 0.00

IE 0.04 0.03 0.01 0.00

IT 0.36 0.36 0.18 0.03

LT 0.00 0.00 0.00 0.00

LU 0.01 0.01 0.00 0.00

LV 0.00 0.00 0.00 0.00

MT 0.00 0.00 0.00 0.00

NL 0.16 0.15 0.06 0.01

PL 0.11 0.12 0.06 0.01

PT 0.02 0.01 0.01 0.00

RO 0.02 0.02 0.01 0.00

SE 0.16 0.15 0.06 0.01

SI 0.00 0.00 0.00 0.00

SK 0.02 0.02 0.01 0.00

EU total 5.03 4.85 2.20 0.40

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

The recurrent administrative costs for railway undertakings for handling re-routing

requests are provided in the table below, by Member State. Expressed as present value over

2028-2050, relative to the baseline, they are estimated at EUR 448.9 million at EU level.

81

Table 43: Recurrent administrative costs for railway undertakings for re-routing requests, by

Member State (in million EUR, in 2024 prices) Country 2028 2030 2040 2050

AT 1.49 1.34 0.64 0.14

BE 1.49 1.35 0.63 0.13

BG 0.02 0.02 0.01 0.00

CY 0.00 0.00 0.00 0.00

CZ 0.58 0.57 0.25 0.05

DE 23.38 22.69 9.89 1.94

DK 1.01 0.90 0.38 0.08

EE 0.00 0.00 0.00 0.00

EL 0.02 0.02 0.01 0.00

ES 1.92 1.90 0.91 0.18

FI 0.27 0.25 0.11 0.02

FR 7.62 7.29 3.60 0.81

HR 0.04 0.04 0.02 0.00

HU 0.33 0.29 0.14 0.04

IE 0.34 0.32 0.13 0.03

IT 3.20 3.27 1.66 0.33

LT 0.01 0.01 0.01 0.00

LU 0.09 0.08 0.03 0.01

LV 0.02 0.01 0.01 0.00

MT 0.00 0.00 0.00 0.00

NL 1.36 1.28 0.54 0.11

PL 0.96 1.00 0.48 0.12

PT 0.16 0.14 0.10 0.02

RO 0.18 0.19 0.09 0.02

SE 1.43 1.34 0.58 0.11

SI 0.02 0.02 0.01 0.00

SK 0.20 0.18 0.08 0.02

EU total 46.13 44.49 20.33 4.17

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

The recurrent administrative costs for railway undertakings for handling compensation

requests are provided in the table below, by Member State. Expressed as present value over

2028-2050, relative to the baseline, they are estimated at EUR 621.8 million at EU level.

Table 44: Recurrent administrative costs for railway undertakings for compensation requests, by

Member State (in million EUR, in 2024 prices) Country 2028 2030 2040 2050

AT 2.02 1.81 0.86 0.16

BE 2.08 1.88 0.87 0.15

BG 0.02 0.02 0.01 0.00

CY 0.00 0.00 0.00 0.00

CZ 0.80 0.79 0.35 0.06

82

Country 2028 2030 2040 2050

DE 33.07 32.01 13.68 2.39

DK 1.39 1.23 0.51 0.10

EE 0.01 0.01 0.00 0.00

EL 0.03 0.03 0.01 0.00

ES 2.68 2.64 1.24 0.22

FI 0.36 0.34 0.15 0.03

FR 10.59 10.12 4.91 0.98

HR 0.06 0.05 0.02 0.01

HU 0.47 0.41 0.20 0.04

IE 0.48 0.45 0.19 0.04

IT 4.47 4.56 2.28 0.40

LT 0.01 0.01 0.01 0.00

LU 0.12 0.11 0.05 0.01

LV 0.02 0.02 0.01 0.00

MT 0.00 0.00 0.00 0.00

NL 1.88 1.77 0.74 0.13

PL 1.33 1.37 0.66 0.15

PT 0.23 0.20 0.13 0.03

RO 0.27 0.28 0.13 0.02

SE 1.99 1.87 0.79 0.14

SI 0.03 0.02 0.01 0.00

SK 0.28 0.26 0.12 0.02

EU total 64.68 62.25 27.93 5.10

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

The recurrent administrative costs for railway undertakings for handling assistance

requests are provided in the table below, by Member State. Expressed as present value over

2028-2050, relative to the baseline, they are estimated at EUR 28.8 million at EU level.

Table 45: Recurrent administrative costs for railway undertakings for assistance requests, by

Member State (in million EUR, in 2024 prices) Country 2028 2030 2040 2050

AT 0.09 0.08 0.04 0.01

BE 0.10 0.09 0.04 0.01

BG 0.00 0.00 0.00 0.00

CY 0.00 0.00 0.00 0.00

CZ 0.04 0.04 0.02 0.00

DE 1.54 1.49 0.63 0.10

DK 0.06 0.06 0.02 0.00

EE 0.00 0.00 0.00 0.00

EL 0.00 0.00 0.00 0.00

ES 0.12 0.12 0.06 0.01

FI 0.02 0.02 0.01 0.00

83

Country 2028 2030 2040 2050

FR 0.49 0.47 0.23 0.04

HR 0.00 0.00 0.00 0.00

HU 0.02 0.02 0.01 0.00

IE 0.02 0.02 0.01 0.00

IT 0.21 0.21 0.11 0.02

LT 0.00 0.00 0.00 0.00

LU 0.01 0.00 0.00 0.00

LV 0.00 0.00 0.00 0.00

MT 0.00 0.00 0.00 0.00

NL 0.09 0.08 0.03 0.01

PL 0.06 0.06 0.03 0.01

PT 0.01 0.01 0.01 0.00

RO 0.01 0.01 0.01 0.00

SE 0.09 0.09 0.04 0.01

SI 0.00 0.00 0.00 0.00

SK 0.01 0.01 0.01 0.00

EU total 3.01 2.90 1.29 0.22

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Thus, the total recurrent administrative costs for railway undertakings for handling

reimbursement, re-routing, compensation and assistance requests, expressed as present

value over 2028-2050 relative to the baseline, are estimated at EUR 1.15 billion at EU

level.

Table 46: Total recurrent administrative costs for railway undertakings, by Member State (in

million EUR, in 2024 prices) Country 2028 2030 2040 2050

AT 3.80 3.41 1.61 0.32

BE 3.84 3.46 1.61 0.30

BG 0.04 0.04 0.02 0.00

CY 0.00 0.00 0.00 0.00

CZ 1.49 1.45 0.65 0.12

DE 60.44 58.57 25.23 4.62

DK 2.58 2.29 0.96 0.19

EE 0.01 0.01 0.01 0.00

EL 0.06 0.06 0.02 0.00

ES 4.93 4.87 2.30 0.43

FI 0.69 0.63 0.29 0.06

FR 19.56 18.71 9.14 1.91

HR 0.10 0.09 0.04 0.01

HU 0.86 0.75 0.36 0.08

IE 0.88 0.82 0.34 0.08

IT 8.24 8.41 4.23 0.77

84

Country 2028 2030 2040 2050

LT 0.02 0.02 0.01 0.00

LU 0.22 0.20 0.09 0.02

LV 0.04 0.04 0.02 0.00

MT 0.00 0.00 0.00 0.00

NL 3.48 3.28 1.38 0.26

PL 2.46 2.55 1.23 0.29

PT 0.42 0.37 0.25 0.05

RO 0.48 0.50 0.24 0.04

SE 3.67 3.45 1.48 0.27

SI 0.05 0.04 0.03 0.01

SK 0.51 0.47 0.21 0.04

EU total 118.85 114.49 51.75 9.89

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

Total adjustment and administrative costs for railway undertakings

Overall, the total adjustment and administrative costs for railway undertakings, expressed

as present value over 2028-2050 relative to the baseline, are estimated at EUR 2.14 billion

at EU level. Total costs for 2028, 2030, 2040 and 2050 by Member State are provided in

the table below.

Table 47: Total adjustment and administrative costs for railway undertakings, by Member State

(in million EUR, in 2024 prices) Country 2028 2030 2040 2050

AT 5.83 5.11 3.03 1.45

BE 6.54 6.08 3.75 1.87

BG 0.11 0.11 0.08 0.06

CY 0.00 0.00 0.00 0.00

CZ 3.11 3.07 1.90 1.08

DE 87.36 85.27 45.35 19.32

DK 3.62 3.10 1.56 0.66

EE 0.04 0.02 0.01 0.01

EL 0.17 0.18 0.11 0.07

ES 9.40 9.51 6.14 3.29

FI 0.96 0.88 0.48 0.21

FR 33.14 32.61 21.02 11.84

HR 0.20 0.18 0.12 0.07

HU 2.06 1.85 1.29 0.95

IE 1.26 1.18 0.60 0.31

IT 14.22 14.61 9.69 4.74

LT 0.07 0.08 0.07 0.05

LU 0.43 0.37 0.21 0.12

LV 0.08 0.06 0.03 0.02

MT 0.00 0.00 0.00 0.00

85

Country 2028 2030 2040 2050

NL 6.08 5.75 3.19 1.64

PL 5.37 5.69 3.87 2.77

PT 0.89 0.80 0.75 0.50

RO 1.39 1.48 1.08 0.66

SE 5.22 4.51 2.27 0.85

SI 0.12 0.10 0.08 0.06

SK 0.98 0.91 0.57 0.32

EU total 188.66 183.49 107.26 52.94

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

3.3. Impact on intermediaries

Intermediaries are third parties that connect railway undertakings with passengers. Most

are small travel agencies or tour operators with limited rail sales, often relying on

specialised aggregators. A few major players, such as Trainline, Omio, Rail Europe and

EuroTrain, focus on reselling tickets from multiple railway undertakings directly to

passengers. Ticket vendors and tour operators may distribute combined tickets from

different railway undertakings for a journey. Under the Regulation, if they do so on their

own initiative, they must refund the full ticket price and pay 75% compensation of that

amount if connections are missed, unless passengers were clearly informed in advance

before purchase that the tickets represent separate contracts191. This particular liability

would no longer apply under this intervention given that these ticket combinations would

now entitle passengers to a full set of rights under the single ticket protection. At the same

time, this liability would be substituted by another liability regime where ticket vendors

and tour operators do not adhere to the applicable minimum connection times when

offering a single ticket. The proposed measure is expected to incentivise ticket vendors and

tour operators to improve their offer of single tickets, in order to reduce the likelihood of

recurring reimbursements and compensation. Given the uncertainty to establish the number

of passengers affected, the costs cannot be quantified although they are expected to be

limited.

The one-off adjustment costs for intermediaries cover the effort to understand the

regulation and to review the legal consequences. The specialised rail ticket sellers are

expected to adapt the front-end website (update the terms and conditions), to adapt their

overall strategy, and to take contact with the railway undertakings with whom they have a

commercial agreement, to agree on a procedure. The effort per intermediary is estimated

at 0.5 person-day in 2028. There were 121,276 intermediaries (ticket vendors, tour

operators and other reservation service and related activities) according to Eurostat in

2024192, of which over 99% are SMEs. Assuming 7.2 working hours per day on average193

and the tariff rate for the ISCO 3 category (technicians and associate professionals)194 by

191 Article 12(4)-(5) of RPRR 192 ECTA estimates it rather to 80,000-90,000 and attributes the difference with Eurostat to

including/excluding 1-person travel consultants. 193 Actual and usual hours of work - Statistics Explained - Eurostat 194 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.

86

Member State in 2024 prices, the one-off adjustment costs for the intermediaries are

estimated at EUR 12.84 million (of which EUR 12.82 million for SME intermediaries).

Table 48: One-off adjustment costs for intermediaries, by Member State (in thousand EUR, in 2024

prices) Country Total one-off adjustment costs of which for SMEs

AT 366 365

BE 347 351

BG 66 66

CY 37 37

CZ 479 478

DE 1,770 1,766

DK 148 148

EE 55 55

EL 285 286

ES 1,507 1,505

FI 330 330

FR 1,639 1,637

HR 162 162

HU 118 118

IE 238 233

IT 2,466 2,464

LT 81 81

LU 15 15

LV 53 53

MT 36 36

NL 1,061 1,060

PL 415 414

PT 336 336

RO 147 147

SE 480 479

SI 90 90

SK 108 108

EU total 12,835 12,822

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

3.4. Impact on National Enforcement Bodies (NEBs)

The planned initiative is expected to generate one-off adjustment costs for national

enforcement bodies (NEBs), mainly linked to understanding the amendment, assessing its

legal implications, and adapting complaint-handling procedures. The effort per NEB is

assumed at 5 person-days. Assuming 7.2 working hours per day on average195 and the tariff

195 Actual and usual hours of work - Statistics Explained - Eurostat

87

rate for the ISCO 3 category (technicians and associate professionals)196 by Member State

in 2024 prices, the total one-off adjustment costs for NEBs are estimated at EUR 0.03

million in 2028.

While the number of complaints may increase due to more single tickets, greater legal

clarity will simplify enforcement. Overall, additional enforcement costs for NEBs and

other complaint bodies are expected to remain very limited.

Table 49: One-off adjustment costs for NEBs, by Member State (in thousand EUR, in 2024 prices) Country Total one-off adjustment costs

AT 1.5

BE 1.7

BG 0.4

CY 0.9

CZ 0.7

DE 1.6

DK 2.0

EE 0.8

EL 0.6

ES 0.9

FI 1.3

FR 1.4

HR 0.5

HU 0.5

IE 1.7

IT 1.2

LT 0.6

LU 1.8

LV 0.6

MT 0.7

NL 1.5

PL 0.5

PT 0.6

RO 0.4

SE 1.6

SI 0.8

SK 0.7

EU total 27.4

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

196 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.

88

4. SENSITIVITY ANALYSIS

Considering the uncertainty related to certain assumptions used in the analysis, sensitivity

analysis has been performed with respect to:

- Share of multi-operator journeys performed under a single ticket (other than through-

tickets);

- Level of automation by 2050 for handling requests for compensation by railway

undertakings;

- Time required for handling requests for compensation by railway undertakings;

- Time of re-routing;

- Synergies with the initiatives on the Rail Ticketing Regulation (RTR) and the

Regulation on Multimodal Booking (RMB)197;

- Proportion of passengers actually requesting compensation out of those that experience

a delay of at least 60 minutes and do not ask for reimbursement.

The results of the sensitivity analysis are compared to the ‘central case’, described in the

previous sections.

4.1. Share of multi-operator journeys performed under a single ticket (other

than through-tickets)

The share of single tickets involving different rail operators for a single journey bought in

a single transaction, other than through-tickets, is estimated at 13% at EU level in the

central case. Two alternative cases have been tested: (i) 6% share of multi-operator

journeys performed under a single ticket, other than through-tickets (Case A – 6%); (ii)

26% share of multi-operator journeys performed under a single ticket, other than through-

tickets (Case A – 26%). The results for the two cases considered are compared to the central

case.

The summary of costs and benefits for the central case and the two alternative cases (Case

A – 6% and Case A – 26%), expressed as present value over 2028-2050 relative to the

baseline, is provided in the table below. The table shows that both alternative cases result

in overall net benefits and similar benefits to costs ratio as the central case.

Table 50: Summary of costs and benefits for the central case and the two alternative cases (Case A – 6%

and Case A – 26%) - present value over 2028-2050 compared to the baseline (in million EUR, 2024

prices) Central case Case A – 6% Case A – 26%

Passengers

Benefits due to re-routing, reimbursement,

compensation, and assistance

6,642.8 3,123.5 13,535.2

Re-routing benefits 5,658.6 2,660.7 11,529.7

Reimbursement benefits 182.3 85.7 371.4

Compensation benefits 632.3 297.3 1,288.4

197 EU rules on multimodal digital mobility services and single digital booking & ticketing

89

Central case Case A – 6% Case A – 26%

Assistance benefits 169.6 79.8 345.6

Hassle cost savings 1,136.9 534.6 2,316.4

Railway undertakings

Adjustment costs 988.2 466.8 2,009.4

One-off adjustment costs 4.0 4.0 4.0

Re-routing costs 0.0 0.0 0.0

Reimbursement costs 182.3 85.7 371.4

Compensation costs 632.3 297.3 1,288.4

Assistance costs 169.6 79.8 345.6

Administrative costs 1,148.3 539.9 2,339.8

Re-routing administrative costs 448.9 211.1 914.7

Reimbursement administrative costs 48.7 22.9 99.3

Compensation administrative costs 621.8 292.4 1,267.0

Assistance administrative costs 28.8 13.6 58.8

Intermediaries

One-off adjustment cost 12.8 12.8 12.8

National Enforcement Bodies

One-off adjustment cost 0.03 0.03 0.03

Total costs 2,149.4 1,019.6 4,362.1

Total benefits 7,779.7 3,658.1 15,851.6

Net benefits 5,630.3 2,638.5 11,489.5

Benefits to costs ratio 3.6 3.6 3.6

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

4.2. Level of automation for handling requests for compensation by railway

undertakings

In the central case, it is assumed that automation would cover 20% of requests for

compensation in 2028, rising to 90% by 2050. One alternative case is tested (Case B –

70%), where the share of requests for compensation handled automatically increases

gradually from 15% in 2028 to 70% by 2050. The results for the alternative case considered

is compared to the central case.

The summary of costs and benefits for the central case and the alternative case (Case B –

70%), expressed as present value over 2028-2050 relative to the baseline, is provided in

the table below. The table shows that the alternative case result in overall net benefits and

somewhat lower benefits to costs ratio relative to the central case.

Table 51: Summary of costs and benefits for the central case and the alternative cases (Case B – 70%) -

present value over 2028-2050 compared to the baseline (in million EUR, 2024 prices) Central case Case B – 70%

Passengers

Benefits due to re-routing, reimbursement, compensation, and

assistance

6,642.8 6,642.8

Re-routing benefits 5,658.6 5,658.6

Reimbursement benefits 182.3 182.3

Compensation benefits 632.3 632.3

Assistance benefits 169.6 169.6

Hassle cost savings 1,136.9 1,136.9

Railway undertakings

Adjustment costs 988.2 988.2

90

Central case Case B – 70%

One-off adjustment costs 4.0 4.0

Re-routing costs 0.0 0.0

Reimbursement costs 182.3 182.3

Compensation costs 632.3 632.3

Assistance costs 169.6 169.6

Administrative costs 1,148.3 1,278.8

Re-routing administrative costs 448.9 448.9

Reimbursement administrative costs 48.7 48.7

Compensation administrative costs 621.8 752.3

Assistance administrative costs 28.8 28.8

Intermediaries

One-off adjustment cost 12.8 12.8

National Enforcement Bodies

One-off adjustment cost 0.03 0.03

Total costs 2,149.4 2,279.9

Total benefits 7,779.7 7,779.7

Net benefits 5,630.3 5,499.7

Benefits to costs ratio 3.6 3.4

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

4.3. Time required for handling requests for compensation by railway

undertakings

In the central case, the average time required to handle a request for compensation (if not

automated) is assumed at 15 minutes. Two alternative cases have been tested: (i) 10

minutes for handling a request for compensation by railway undertakings (Case C – 10

min); (ii) 20 minutes for handling a request for compensation by railway undertakings

(Case C – 20 min). The results for the two cases considered are compared to the central

case.

The summary of costs and benefits for the central case and the two alternative cases (Case

C – 10 min and Case C – 20 min), expressed as present value over 2028-2050 relative to

the baseline, is provided in the table below. The table shows that both alternative cases

result in overall net benefits. The benefits to costs ratio is somewhat higher in Case C – 10

min and lower than the central case in the Case C – 20 min.

Table 52: Summary of costs and benefits for the central case and the two alternative cases (Case C – 10

min and Case C – 20 min) - present value over 2028-2050 compared to the baseline (in million EUR,

2024 prices) Central case Case C – 10 min Case C – 20 min

Passengers

Benefits due to re-routing, reimbursement,

compensation, and assistance

6,642.8 6,642.8 6,642.8

Re-routing benefits 5,658.6 5,658.6 5,658.6

Reimbursement benefits 182.3 182.3 182.3

Compensation benefits 632.3 632.3 632.3

Assistance benefits 169.6 169.6 169.6

Hassle cost savings 1,136.9 1,136.9 1,136.9

Railway undertakings

Adjustment costs 988.2 988.2 988.2

One-off adjustment costs 4.0 4.0 4.0

91

Central case Case C – 10 min Case C – 20 min

Re-routing costs 0.0 0.0 0.0

Reimbursement costs 182.3 182.3 182.3

Compensation costs 632.3 632.3 632.3

Assistance costs 169.6 169.6 169.6

Administrative costs 1,148.3 941.0 1,355.6

Re-routing administrative costs 448.9 448.9 448.9

Reimbursement administrative costs 48.7 48.7 48.7

Compensation administrative costs 621.8 414.5 829.1

Assistance administrative costs 28.8 28.8 28.8

Intermediaries

One-off adjustment cost 12.8 12.8 12.8

National Enforcement Bodies

One-off adjustment cost 0.03 0.03 0.03

Total costs 2,149.4 1,942.1 2,356.7

Total benefits 7,779.7 7,779.7 7,779.7

Net benefits 5,630.3 5,837.5 5,423.0

Benefits to costs ratio 3.6 4.0 3.3

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

4.4. Time of re-routing

In the central case, it is assumed that passengers choosing re-routing will be re-routed in

respect of all cancelled services as well as those delayed by at least 60 minutes. Two

alternative cases have been tested: (i) passengers choosing re-routing will be re-routed in

respect of all cancelled services as well as those delayed by at least 5 minutes (Case D – 5

min); (ii) passengers choosing re-routing will be re-routed in respect of all cancelled

services as well as those delayed by at least 120 minutes (Case D – 120 min). The results

for the two alternative cases considered are compared to the central case.

The summary of costs and benefits for the central case and the two alternative cases (Case

D – 5 min and Case D – 120 min), expressed as present value over 2028-2050 relative to

the baseline, is provided in the table below. The table shows that both alternative cases

result in overall net benefits. The benefits to costs ratio is much higher in Case D – 5 min

and lower than in the central case in the Case D – 120 min.

Table 53: Summary of costs and benefits for the central case and the two alternative cases (Case D – 5

min and Case D – 120 min) - present value over 2028-2050 compared to the baseline (in million EUR,

2024 prices) Central case Case D – 5 min Case D – 120 min

Passengers

Benefits due to re-routing,

reimbursement, compensation, and

assistance

6,642.8 27,179.5 5,715.2

Re-routing benefits 5,658.6 26,195.3 4,731.0

Reimbursement benefits 182.3 182.3 182.3

Compensation benefits 632.3 632.3 632.3

Assistance benefits 169.6 169.6 169.6

Hassle cost savings 1,136.9 1,136.9 1,136.9

Railway undertakings

Adjustment costs 988.2 988.2 988.2

One-off adjustment costs 4.0 4.0 4.0

92

Central case Case D – 5 min Case D – 120 min

Re-routing costs 0.0 0.0 0.0

Reimbursement costs 182.3 182.3 182.3

Compensation costs 632.3 632.3 632.3

Assistance costs 169.6 169.6 169.6

Administrative costs 1,148.3 2,813.0 1,073.1

Re-routing administrative costs 448.9 2,113.6 373.7

Reimbursement administrative costs 48.7 48.7 48.7

Compensation administrative costs 621.8 621.8 621.8

Assistance administrative costs 28.8 28.8 28.8

Intermediaries

One-off adjustment cost 12.8 12.8 12.8

National Enforcement Bodies

One-off adjustment cost 0.03 0.03 0.03

Total costs 2,149.4 3,814.0 2,074.2

Total benefits 7,779.7 28,316.4 6,852.0

Net benefits 5,630.3 24,502.4 4,777.8

Benefits to costs ratio 3.6 7.4 3.3

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

4.5. Synergies with the initiatives on Rail Ticketing Regulation (RTR) and the

Regulation on Multimodal Booking (RMB)

In the central case, the number of passengers travelling by rail is aligned with the baseline

scenario of the impact assessment accompanying the initiatives on RTR and RMB. In other

words, as explained in section 5.1, the baseline is common to that of the impact assessment

accompanying the initiatives on RTR and RMB. An alternative case has been tested (Case

E – RTR/RMB), where the number of passengers travelling by rail is aligned with the

preferred policy option of the impact assessment accompanying the initiatives on RTR and

RMB. The results for the alternative case considered is compared to the central case.

The summary of costs and benefits for the central case and the alternative case (Case E –

RTR/RMB), expressed as present value over 2028-2050 relative to the baseline, is

provided in the table below. The table shows that the alternative case result in overall net

benefits and similar benefits to costs ratio relative to the central case.

Table 54: Summary of costs and benefits for the central case and the alternative cases (Case E –

RTR/RMB) - present value over 2028-2050 compared to the baseline (in million EUR, 2024 prices) Central case Case E – RTR/RMB

Passengers

Benefits due to re-routing,

reimbursement, compensation, and

assistance

6,642.8 6,771.0

Re-routing benefits 5,658.6 5,767.9

Reimbursement benefits 182.3 185.8

Compensation benefits 632.3 644.5

Assistance benefits 169.6 172.8

Hassle cost savings 1,136.9 1,158.1

Railway undertakings

Adjustment costs 988.2 1,007.1

One-off adjustment costs 4.0 4.0

Re-routing costs 0.0 0.0

93

Central case Case E – RTR/RMB

Reimbursement costs 182.3 185.8

Compensation costs 632.3 644.5

Assistance costs 169.6 172.8

Administrative costs 1,148.3 1,165.9

Re-routing administrative costs 448.9 455.8

Reimbursement administrative costs 48.7 49.5

Compensation administrative costs 621.8 631.3

Assistance administrative costs 28.8 29.3

Intermediaries

One-off adjustment cost 12.8 12.8

National Enforcement Bodies

One-off adjustment cost 0.03 0.03

Total costs 2,149.4 2,185.9

Total benefits 7,779.7 7,929.1

Net benefits 5,630.3 5,743.3

Benefits to costs ratio 3.6 3.6

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study

4.6. Proportion of passengers actually requesting compensation out of those

that experience a delay of at least 60 minutes and do not ask for

reimbursement

In the central case, the proportion of passengers actually requesting compensation out of

those that experience a delay of at least 60 minutes and do not ask for reimbursement is

assumed at 38%. Three alternative cases have been tested: (i) the proportion of passengers

actually requesting compensation out of those that experience a delay of at least 60 minutes

and do not ask for reimbursement is 0% (Case F – 0%); (ii) the proportion of passengers

actually requesting compensation out of those that experience a delay of at least 60 minutes

and do not ask for reimbursement is 50% (Case F – 50%); (iii) the proportion of passengers

actually requesting compensation out of those that experience a delay of at least 60 minutes

and do not ask for reimbursement is 75% (Case F – 75%). The results for the three

alternative cases considered are compared to the central case.

The summary of costs and benefits for the central case and the three alternative cases (Case

F – 0%, Case F – 50% and Case F – 75%), expressed as present value over 2028-2050

relative to the baseline, is provided in the table below. The table shows that all alternative

cases result in overall net benefits. The benefits to costs ratio is highest in Case F – 0% and

lower in Case F – 50% and Case F – 75% relative to the central case.

Table 55: Summary of costs and benefits for the central case and the three alternative cases (Case F –

0%, Case F – 50% and Case F – 75%) - present value over 2028-2050 compared to the baseline (in

million EUR, 2024 prices) Central case Case F – 0% Case F –

50%

Case F –

75%

Passengers

Benefits due to re-routing,

reimbursement, compensation, and

assistance

6,642.8 6,010.5 6,842.5 7,258.5

Re-routing benefits 5,658.6 5,658.6 5,658.6 5,658.6

Reimbursement benefits 182.3 182.3 182.3 182.3

Compensation benefits 632.3 0.0 832.0 1,248.0

94

Central case Case F – 0% Case F –

50%

Case F –

75%

Assistance benefits 169.6 169.6 169.6 169.6

Hassle cost savings 1,136.9 1,136.9 1,136.9 1,136.9

Railway undertakings

Adjustment costs 988.2 355.9 1,187.9 1,603.9

One-off adjustment costs 4.0 4.0 4.0 4.0

Re-routing costs 0.0 0.0 0.0 0.0

Reimbursement costs 182.3 182.3 182.3 182.3

Compensation costs 632.3 0.0 832.0 1,248.0

Assistance costs 169.6 169.6 169.6 169.6

Administrative costs 1,148.3 526.5 1,344.7 1,753.8

Re-routing administrative costs 448.9 448.9 448.9 448.9

Reimbursement administrative

costs

48.7 48.7 48.7 48.7

Compensation administrative

costs

621.8 0.0 818.2 1,227.3

Assistance administrative costs 28.8 28.8 28.8 28.8

Intermediaries

One-off adjustment cost 12.8 12.8 12.8 12.8

National Enforcement Bodies

One-off adjustment cost 0.03 0.03 0.03 0.03

Total costs 2,149.4 895.3 2,545.4 3,370.5

Total benefits 7,779.7 7,147.4 7,979.3 8,395.3

Net benefits 5,630.3 6,252.1 5,433.9 5,024.8

Benefits to costs ratio 3.6 8.0 3.1 2.5

Source: Milieu consulting and Transport & Mobility Leuven (2026), Support study