Ettepanek - SEC(2026) 300, SWD(2026) 300, SWD(2026) 301, COM(2026) 231

EN EN

EUROPEAN COMMISSION

Brussels, 13.5.2026

COM(2026) 231 final

2026/0113 (COD)

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on multimodal booking and repealing Regulation (EC) No 80/2009

{SEC(2026) 300 final} - {SWD(2026) 300 final} - {SWD(2026) 301 final}

(Text with EEA relevance)

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EXPLANATORY MEMORANDUM

1. CONTEXT OF THE PROPOSAL

• Reasons for and objectives of the proposal

This proposal, together with the proposal for a Rail Ticketing Regulation and the proposed

revision of the Rail Passengers' Rights Regulation1, aims to respond to the challenges

identified in the political guidelines for the European Commission 2024−20292.

Passengers still face significant barriers when trying to search for, compare, combine and

book travel options. An analysis of 100 representative routes in the EU found that multimodal

options were available in 76% of cases. Despite this, very few multimodal digital mobility

services (MDMS) showed options in different modes, and these were rarely combined.

Furthermore, a 2024 Eurobarometer survey of 26,000 EU citizens revealed that one third of

respondents had never booked a multimodal or multi-operator journey. Of those who had,

over a third had encountered booking difficulties, such as being unable to find suitable

combinations or unable to purchase all required tickets in one place, while such difficulties

were even more pronounced with rail tickets.

This proposal is intended to address the lack of transparency, unfair conditions and uneven

playing field in the digital passenger transport ticketing market, on all MDMS active in

aviation, rail, road and waterborne transport. In turn, it will improve the functioning of the

ticket distribution market, thereby ensuring travellers can find all options available, including

multimodal ones. As a result, the competitiveness of the transport services market will also

improve.

These objectives are aligned with the Sustainable and Smart Mobility Strategy3, which is

aimed at improving the competitiveness and sustainability of the transport sector and

making multimodal mobility a reality.

• Consistency with existing policy provisions in the policy area

This proposal has been coordinated with the proposal for a Rail Ticketing Regulation and the

proposed revision of the rail passengers’ rights and obligations Regulation, in order to ensure

a consistent framework that promotes single rail tickets and a well-

functioning digital ticketing market.

The proposal repeals the Code of Conduct for computerised reservation systems (‘CRS Code

of Conduct’4), whilst carrying over and updating the provisions of the CRS Code of Conduct

which remain relevant.

The proposal fits in with other EU laws relating to digital information services, in particular

the ITS Directive5, which establishes a framework for the deployment of intelligent transport

systems in the field of road transport and for interfaces with other modes of transport. The

1 OJ L172, 17.5.2021, p.1. 2 ‘Europe’s choice - Political guidelines for the next European Commission 2024−2029: ‘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’. 3 COM/2020/789 final. 4 OJ L 35, 4.2.2009, p.. 47. 5 OJ L 207, 6.8.2010, p. 1.

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Delegated Regulation on multimodal travel information services6 (MMTIS) requires

Member States to establish national access points constituting a single point of access for data

users to the static, historic, observed and dynamic travel and traffic data of different transport

modes, for the purpose of providing multimodal travel information services to end users. By

addressing barriers to the development of MDMS for reservation, booking or ticketing, this

proposal therefore complements the existing legislation.

Furthermore, by setting sectorial measures in relation to MDMS, this proposal does not

affect the application and complements the Digital Services Act7, the Digital Markets Act8

and the Data Act9. The proposal will also complement the revised Unfair Commercial

Practices Directive10 with measures which ensure search results on MDMS are displayed in a

neutral way (setting out a list of mandatory ranking criteria), and which prohibit self-

preferencing and paid prominence by allowing advertised content only under certain

conditions.

• Consistency with other Union policies

A 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

Deal11 and the European Climate Law12.

By requiring MDMS to display information on greenhouse gas emissions and CO2 emissions,

this proposal will also contribute to the objectives of the CountEmissionsEU and Flight

Emission Label initiatives13, setting out a common framework to calculate and report

transport-related greenhouse gas emissions. Transparent information applied on all modes will

enable passengers to choose the most sustainable travel options.

Finally, the proposal contributes to the objectives set out in the Report from the Commission

to the Council on the implementation of the European Tourism Agenda 203014, which

mentions multimodality as a key enabler of competitiveness in the tourism sector. Overall,

this initiative aims to promote a more multimodal and sustainable transport system and

contribute to Sustainable Development Goals SDG#3 ("Ensure healthy lives and promote

wellbeing for all at all ages"), SDG#9 ("Make cities and human settlements inclusive, safe,

resilient and sustainable") and SDG#13 ("Climate Action").

2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY

• Legal basis

The legal basis for this initiative is Article 91(1), point (d) and Article 100(2) of the Title VI.

Article 91 and Article 100(2) establish the EU’s prerogative to pursue the objectives of the

Treaties within the framework of a common transport policy and to set the appropriate rules to

that end. By contributing to the functioning of the transport ticket distribution market in

conformity with the objectives set out in the sustainable and smart mobility strategy15, this

initiative forms part of the common transport policy. The transport ticket distribution market

6 OJ L, 2024/490, 13.2.2024. 7 OJ L 277, 27.10.2022, p. . 1. 8 OJ L 265, 12.10.2022, p. 1. 9 OJ L, 2023/2854, 22.12.2023. 10 OJ L149, 11.6.2005, p. 22. 11 COM (2019)640 final. 12 OJ L 243, 9.7.2021, p . 1 13 OJ L, 2024/3170, 31.12.2024. 14 COM (2025) 763 final. 15 COM/2020/789 final.

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encompasses services inherently linked to transport services. The initiative thus takes into

account the distinctive features of transport. The application of this initiative will not affect

the standard of living and level of employment in certain regions, nor the operation of

transport facilities.

• Subsidiarity (for non-exclusive competence)

Although some challenges related to ticket distribution and digital access to rail tickets are

being addressed nationally or regionally, an EU-wide approach is needed to reduce the cross-

border impact of these challenges on long-distance travel within the EU and to ensure the

smooth operation of the European transport system.

Discrepancies between Member States in the way they implement new rules on ticket

distribution could further fragment the market, raise costs and reduce benefits for MDMS ,

authorities, operators and transport users. EU-level intervention is therefore needed to prevent

wide variation in Member State strategies and possibly unintended consequences.

• Proportionality

The proposal requires all MDMS providers to respect rules on the neutral display and

their ranking criteria, the sharing of marketing information data, the display of information on

greenhouse gas emissions and carbon dioxide equivalent emissions (when made available to

MDMS providers by transport operators), and on data sharing with transport authorities.

MDMS providers which are SMEs are excluded from the scope of this proposal.

Stricter measures, i.e. those establishing the conditions governing the commercial agreements

between MDMS providers and transport operators, are limited to MDMS providers deemed

indispensable. In the business-to-consumer (B2C) segment, this designation applies only to

MDMS providers that meet threshold criteria defined in this proposal. In the business-to-

business (B2B) segment, all MDMS providers are considered indispensable, due to their

strategic role as an intermediary between travel agents and transport operators. This approach

ensures that the strictest regulatory obligations are imposed exclusively on those entities that

are in a position to exert significant influence over transport operators, including the ability to

impose unfair commercial conditions. Moreover, this approach is fully proportional as it

limits EU level action to what is necessary to address a clear market failure. In that sense, it

does not mandate MDMS providers to enter into commercial agreements, instead establishing

a framework to ensure fairness in such agreements when they exist. By doing so, the proposed

measures foster a well-functioning transport ticketing market while maintaining

proportionality.

• Choice of the instrument

To ensure a well-functioning digital ticketing market, a common approach is needed so that

conditions are harmonised across the EU. This is best achieved through a Regulation.

3. RESULTS OF EX-POST EVALUATIONS, STAKEHOLDER

CONSULTATIONS AND IMPACT ASSESSMENTS

• Ex-post evaluations/fitness checks of existing legislation

Computerised reservation systems (CRSs) are a particular type of MDMS active in the B2B

segment. A code of conduct was adopted in 1989 to prevent possible anti-competitive

behaviour by CRSs. It was later revised in 2009 to regulate the B2B transactions between

CRS providers on the one hand, and air and rail carriers and travel agents on the other hand.

The Code of Conduct was subsequently evaluated in 2020 - to assess whether, in the light of

market and technological changes in B2B ticket distribution, it is still relevant in achieving

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the objectives of (i) preventing distortion of competition between CRSs owned by parent

carriers, and (ii) ensuring fair and effective competition between carriers; and whether it

remained fit for purpose in the face of broader horizontal legislation. The evaluation

concluded that the code of conduct had not been ensuring a fully level playing field for all

participating carriers as regards access to and use of CRS services as it failed to improve the

balance in the bargaining power between different-sized air carriers in relation to CRSs. Some

air carriers expressed concerns about specific clauses in their contracts with CRS providers

which reduced the ability of airlines to use alternative booking systems or technology.

Moreover, the evaluation concluded that transparency requirements, i.e. a neutral display,

remained important, as travel agents, both offline and online, and travel management

companies still relied heavily on CRS, especially for business travel. The evaluation also

concluded that specific sectoral treatment of traditional CRS providers was possibly no

longer justified in view of market and technological developments in air ticket distribution

(increased internet usage, emergence of other channels and divestment of CRS ownership by

airlines).

• Stakeholder consultations

This proposal and the proposal for a Rail Ticketing Regulation are underpinned by the same

impact assessment. To prepare for the impact assessment, various stakeholder consultation

activities were carried out with the aim of gathering both qualitative (opinions, views,

suggestions) and quantitative (data, statistics) information. These activities were carried out

between 2020 and 2025, initially only for the purposes of the review of the CRS Code

of Conduct in December 2020, subsequently also for the impact assessment supporting the

Regulation on multimodal booking (RMB) and a Rail Ticketing Regulation. Citizens were

consulted on five occasions, specifically for two inception impact assessments (IIA), two

online open public consultations (OPC) and a Eurobarometer survey16.

For the CRS Code of Conduct, an IIA ran from 9 July 2020 until 4 September 2020 to gather

feedback from stakeholders. A total of 13 responses were received. For the RMB proposal, an

IIA ran from 5 October 2021 until 2 November 2021 to gather feedback from stakeholders. A

total of 40 responses were received. An OPC for the CRS Code of Conduct was launched via

the Commission’s ‘Have your say’ platform on 23 February 2021 and ran until 18 May 2021.

A total of 23 responses were received from citizens and organisations. An OPC for the

MDMS proposal was launched17, on the Commission’s ‘Have your say’ platform on 1

December 2021 and ran until 23 February 2022. A total of 336 responses were received from

individuals and organisations.

A Eurobarometer survey was conducted during the summer of 2024, the results of which were

published by the Commission on 1 April 2025. The aim of the survey was to collect

information on booking and ticketing practices and experiences from representative sample of

the EU population, aged 15 and over, from each of the 27 Member States. In total, 25 805

interviews were conducted via the online survey. The survey provided insights into the travel

habits, preferences and experiences of the EU public, particularly regarding regional and

long-distance journeys. It examined key aspects, such as: (1) frequency of travel for leisure

and work, (2) factors influencing travel planning and booking decisions, (3) attitudes towards

environmentally friendly travel, (4) usage of different transport modes and multimodal

journeys, (5) ease of booking multimodal and multi-operator journeys, and (6) barriers to

combining different transport modes or operators. The results notably highlighted the

16 https://europa.eu/eurobarometer/surveys/detail/3178. 17 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13133-Multimodal-Digital-

Mobility- Services/public-consultation_en.

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obstacles people encounter when looking for sustainable travel options online, as well as their

willingness to book such journeys. It also identified the difficulties people experience when

booking multimodal and multi-operator journeys, and the extra burden they face when

booking multi-operator rail journeys.

• Collection and use of expertise

The impact assessment accompanying this proposal relied on an external study carried out by

a consultant.

Stakeholders provided a significant amount of additional information by way of targeted

consultation activities (surveys, interviews and workshops). In particular they provided

detailed information on the market structure and business practices in the different MDMS

segments (B2C and B2B), which helped confirm information from previous studies and

inform the modelling assumptions and analysis.

The information received covered aspects such as typical provisions (in particular regarding

distribution fees) in commercial agreements offered by MDMS to operators, display practices

on MDMS, trends in the digital distribution market and B2B distribution market; interactions

between CRSs, travel agents and carriers, and the share and role of SMEs in different types of

MDMS.

Overall, the impact assessment drew on a vast number of comprehensive sources which were

representative of the various stakeholders’ groups.

• Impact assessment

This proposal is accompanied by an impact assessment report. Following a negative opinion

from the Regulatory Scrutiny Board (RSB) on 13 September 2023, a draft impact

assessment report was resubmitted to the RSB on 10 March 2026. The RSB issued a positive

opinion with reservations on 13 April 2026. The impact assessment report was adjusted

accordingly to address the RSB’s comments.

The impact assessment screened a comprehensive list of possible policy measures and

options, based on the likely effectiveness, efficiency and proportionality of the proposed

measures in relation to the given objectives, as well as their legal and technical feasibility.

Four policy options were evaluated as part of the impact assessment, which was conducted

jointly for this proposal and for the proposal for a Rail Ticketing Regulation.

Policy option 1 proposed a minimalist approach. It contained policy measures common to all

four policy options including measures that establish minimal requirements for ensuring fair

treatment of information and data on MDMS. It also set out the key principles for all

commercial agreements between indispensable MDMS providers and transport operators, and

between indispensable railway undertakings (RUs) and MDMS providers.

This option fully addresses the first specific objective of improving transparency and

establishing a level playing field for transport operators on MDMS by extending the rules of

the CRS Code of Conduct to all MDMS providers. It sets thresholds for identifying MDMS

providers and RUs with significant market presence, which would be designated by national

enforcement bodies or the European Commission depending on the market in which they have

significant market presence. The Commission would publish a list of MDMS providers with

significant market presence. Such measures would be needed to ensure transport operators are

protected in commercial agreements with indispensable MDMS providers, including by

means of provisions that (1) safeguard commercially sensitive data of operators, (2) prohibit

the inclusion of unjustified or unnecessary contract conditions that could prevent the

conclusion of the agreement, and (3) ensure the remuneration received by MDMS providers is

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based on fair, reasonable and non-discriminatory criteria. Under this policy option, Member

States would be required to appoint a national authority to settle possible disputes between

parties. Moreover, an EU-level network of such authorities would be set up to ensure

consistent enforcement across the EU. In addition, MDMS providers would be required to

display information on greenhouse gas emissions and CO2 emissions, where that information

is provided by the transport operator, while B2C MDMS would have to share data with the

public authorities for mobility management purposes.

To ensure the range of rail services offered on MDMS is more comprehensive, this policy

option offers protection under the proposal for Rail Ticketing Regulation to MDMS providers

in their commercial agreements with indispensable RUs by setting rules on distribution fees

and prohibiting restrictive clauses in contracts (exclusivity clauses, unfair and unjustified

conditions, marketing clauses and other technical restrictions), thereby addressing imbalances

in bargaining power during the negotiation of commercial agreements.

Policy options 2, 3 and 4 build on policy option 1 and were specific to the Regulation on Rail

Ticketing proposal.

• Regulatory fitness and simplification

While the initiative introduces a new obligation for Member States to designate indispensable

MDMS and to settle disputes between parties, the additional administrative burden for public

authorities is kept to a minimum. The proposal builds on the fact that Member States already

have competent authorities responsible for resolving disputes in relevant areas, such as

competition authorities, transport regulatory authorities, and rail regulators.

• Fundamental rights

The proposal would not have any negative material impact on fundamental rights or data

protection. Data protection for B2C MDMS users is ensured by the General Data Protection

Regulation, which offers uniform protection of individuals. Furthermore, for B2B MDMS, the

entry into force of the General Data Protection Regulation is a key reason for revising and

repealing the CRS Code of Conduct’s rules on data protection. This example of regulatory

simplification will remove the duplicate rules, eliminating any scope for potential

inconsistencies.

4. BUDGETARY IMPLICATIONS

Two full-time equivalent (FTE) employees would be needed to support the Commission in

designating MDMS providers with significant market presence, streamlining coordination

with national enforcement bodies, and maintaining an accurate, up-to-date public register,

ensuring market transparency and effective enforcement.

5. OTHER ELEMENTS

• Implementation plans and monitoring, evaluation and reporting arrangements

The Commission will monitor the implementation of this Regulation through several actions

and a set of core indicators that will measure progress towards achieving the objectives. At

the latest five years after the start of implementation of the legislation, the Commission will

assess to what extent the objectives of this Regulation have been met.

Synergies between this proposal and the proposal for a Rail Ticketing Regulation and the

interplay with the revision of the Rail Passenger Rights Regulation will also need to be

analysed.

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Improvements in the online ticketing market will be assessed through market monitoring

carried out by national enforcement bodies and the Commission. Information on penalties will

be shared between authorities in the EU enforcement network in order to support

coordination. Consumer satisfaction in the EU will be measured every two years through

Eurobarometer surveys looking into the availability of travel information and ease of booking

for travellers.

• Detailed explanation of the specific provisions of the proposal

The proposal sets out a new Regulation which is structured as follows:

Article 1 defines the objectives and subject matter of the Regulation;

Article 2 sets out the scope of the Regulation;

Article 3 presents a list of definitions;

Article 4 outlines the designation process for B2C MDMS providers with significant market

presence;

Article 5 sets out the conditions that B2C MDMS providers with significant market presence

and B2B MDMS providers must adhere to in their commercial agreements with transport

operators;

Article 6 sets out the conditions that B2B MDMS providers must adhere to in commercial

agreements with subscribers;

Article 7 lays down neutral display and ranking criteria obligations for all MDMS providers;

Article 8 lays down rules on marketing information data for all MDMS providers;

Article 9 lays down rules on displaying information on greenhouse gas emissions and carbon

dioxide emissions equivalent for all MDMS providers;

Article 10 lays down rules on data sharing with public transport authorities for all B2C

MDMS providers;

Article 11 lays down rules on equivalent treatment of air carriers in third countries;

Article 12 describes the tasks of national enforcement bodies;

Article 13 details complaints rules;

Article 14 lays down penalties for infringements of the Regulation;

Article 15 sets out the conditions for exercising the delegation of power to adopt delegated

acts;

Article 16 sets out the committee procedure;

Article 17 lays down monitoring and reporting obligations;

Article 18 repeals the code of conduct on computerised reservation systems;

Article 19 sets the date of entry into force of the Regulation;

Annex I sets the thresholds for the designation of indispensable B2C MDMS at national and

Union levels;

Annex II presents a correlation table for the repeal of Regulation (EC) No 80/2009.

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2026/0113 (COD)

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on multimodal booking and repealing Regulation (EC) No 80/2009

(Text with EEA relevance)

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), point (d), and Article 100 (2) 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 Committee1,

Having regard to the opinion of the Committee of the Regions2,

Acting in accordance with the ordinary legislative procedure,

Whereas:

(1) Multimodal transport has the potential to enhance the sustainability and efficiency of

the Union transport system and in turn support the objectives of the European Green

Deal3, of the Sustainable and Smart Mobility Strategy4 and of Regulation (EU)

2021/1119 of the European Parliament and of the Council5, mandating that Member

States reduce net greenhouse gas (GHG) emissions by at least 55% by 2030

(compared to 1990 levels), by 90% by 2040, and achieve climate neutrality by 2050.

For passenger transport, the shift towards a multimodal transport system could be

supported by business-to-business (B2B) and business-to-consumer (B2C) multimodal

digital mobility service (MDMS) providers, making it easier for end users and

business users to find, compare, combine and buy suitable transport products for their

journey. Those B2B and B2C MDMS providers run services providing traffic and

travel information for long-distance travel (such as schedules, tariffs and service

availability) and allowing distribution of tickets, either directly or via re-linking, for

two or more transport operators in at least one transport mode.

(2) To support fair competition and innovation, common rules should be established to

ensure a level playing field in the ticket distribution market, in particular regarding the

1 OJ C [...], [...], p. [...]. 2 OJ C [...], [...], p. [...]. 3 Communication from the Commission 'The European Green Deal', COM(2019) 640 final of

11.12.2019. 4 Communication from the Commission ‘Sustainable and Smart Mobility Strategy – putting European

transport on track for the future’, COM(2020) 789 final of 09.12.2020. 5 Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 establishing

the framework for achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU)

2018/1999 (‘European Climate Law’) (OJ L 243, 9.7.2021, p. 1, ELI:

http://data.europa.eu/eli/reg/2021/1119/oj).

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visibility, accessibility and distribution of long-distance and regional transport services

offered within the Union. Those rules should ensure that end users and business users

are able to purchase the most appropriate travel option, including journeys combining

services across one or more transport modes or provided by multiple transport

operators.

(3) Regulation (EC) No 80/2009 of the European Parliament and of the Council6 aims to

ensure fair and unbiased conditions for air carriers and rail carriers in computerised

reservation systems (CRSs), which in turn safeguards consumer interests. In the light

of ongoing technological and market developments, it is essential to extend these

principles of fairness and impartiality to emerging business models that perform

functions comparable to those of CRSs.

(4) To ensure equal treatment of all carriers, providers of business-to-business multimodal

digital mobility services should fall within the scope of this Regulation if business

users can access their services and transport products from the Union, i.e. when the

point of sale is in the Union. They should also fall within the scope of this Regulation

even if the point of sale is outside of the Union but the transport product’s underlying

transport service is provided, wholly or partially, within the territory of the Union.

(5) The obligations imposed on MDMS providers under this Regulation should be without

prejudice to Regulation (EU) XXX (RTR) of the European Parliament and of the

Council.

(6) The obligations imposed on MDMS providers under this Regulation should be without

prejudice to Regulations (EU) 2022/20657 and (EU) 2022/19258 of the European

Parliament and of the Council. In particular, by establishing an obligation of neutral

display of transport products or the combination of transport products for B2B and

B2C MDMS according to specific ranking criteria, this Regulation aims only to

complement, but not to affect, any of the obligations imposed on intermediary service

providers under Regulation (EU) 2022/2065, including online platforms and online

search engines within the meaning of Regulation (EU) 2022/2065, in the Union.

Similarly, the obligations imposed on B2C MDMS providers with significant market

presence and B2B MDMS providers aim to complement Regulation (EU) 2022/1925,

as this Regulation applies similar requirements to services which, despite

being outside the scope of Regulation (EU) 2022/1925, may nonetheless still be

indispensable for business-users or end-users.

(7) Since a transport product offered by a transport operator at least partially under a code

share arrangement or an interlining agreement aims to increase connectivity for

operator’s own passengers, transport products offered under such agreements should

be considered transport products of the marketing transport operator only and not a

transport product of two or more transport operators.

6 Regulation (EC) No 80/2009 of the European Parliament and of the Council of 14 January 2009 on a

Code of Conduct for computerised reservation systems and repealing Council Regulation (EEC) No

2299/89 (OJ L 35, 4.2.2009, p. 47, ELI: http://data.europa.eu/eli/reg/2009/80/oj). 7 Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on a

Single Market For Digital Services and amending Directive 2000/31/EC (Digital Services Act) (OJ L

277, 27.10.2022, p. 1, ELI: http://data.europa.eu/eli/reg/2022/2065/oj). 8 Regulation (EU) 2022/1925 of the European Parliament and of the Council of 14 September 2022 on

contestable and fair markets in the digital sector and amending Directives (EU) 2019/1937 and (EU)

2020/1828 (Digital Markets Act) (OJ L 265, 12.10.2022, p. 1, ELI:

http://data.europa.eu/eli/reg/2022/1925/oj).

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(8) B2C MDMS providers may account for a significant share of the total value or volume

of tickets sold at Union or national level, in one or several transport modes, and

therefore constitute a predominant point of access for end users. Such a position may

result from a strong or established presence in the underlying transport markets,

leading to strong incentives to promote some transport products, to the detriment of

competitors. That strategic position vis-à-vis end users may enable those B2C MDMS

providers to influence access to the online ticket distribution market, including by

limiting opportunities for new entrants or by imposing unjustified contractual

conditions affecting participating transport operators. Such conditions may include the

introduction of disproportionately high distribution fees or unfair data processing and

information sharing practices. Given their central role, those B2C MDMS providers

should be designated as providers with significant market presence for each of the

relevant transport modes, and in the relevant geographical area where that is the case.

Designated MDMS providers should therefore be subject to additional rules necessary

to ensure fair competition, transparency and non-discriminatory cooperation with

transport operators. Meta-search engines (MSEs) only re-linking transport products are

not directly selling transport products and therefore do not hold a significant market

presence for distribution.

(9) Websites or applications of transport operators which only offer the operator’s own

transport products or those of operators belonging to their own group do not constitute

an MDMS as they do not offer transport products of competitors. As such, they are

clearly identifiable to consumers. Furthermore, those websites do not offer similar

services to those provided by an MDMS, such as aggregation and comparison of

competitors' transport products. Unlike MDMS, online search engines, as defined in

Article 2, point (5), of Regulation (EU) 2019/1150 of the European Parliament and of

the Council9, allow users to input queries in order to perform searches of, in principle,

all websites, or all websites in a particular language, including, but not limited

to websites where transport products are sold. The sole fact that an online search

engine returns results that include transport products should not be sufficient to

consider it as a B2C MDMS.

(10) B2B MDMS providers function as commercial partners of air and rail carriers, travel

agents and travel management companies. An important share of airline reservations is

made through B2B MDMS providers, making them key gateways for

reaching business users and ultimately end users. The strategic position of B2B

MDMS providers enables them to influence carriers' access to travel agents and travel

management companies and therefore to end users. Given their central role, B2B

MDMS providers should be governed by additional obligations necessary to

ensure fair competition, transparency and non-discriminatory cooperation.

(11) B2C MDMS providers designated as having significant market presence within a

given Member State for a particular mode of transport should not be exempt from the

responsibility of informing the national authorities of other Member States of their

significant market presence within those jurisdictions so that they may, if relevant,

also be designated in those Member States.

(12) Where B2C MDMS providers with significant market presence and B2B MDMS

providers enter into commercial agreements with transport operators, they should

9 Regulation (EU) 2019/1150 of the European Parliament and of the Council of 20 June 2019 on

promoting fairness and transparency for business users of online intermediation services (OJ L 186,

11.7.2019, p. 57, ELI: http://data.europa.eu/eli/reg/2019/1150/oj).

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respect certain conditions. In particular, such providers should not make participation

to their service subject to exclusivity clauses, or impose restrictions limiting the

operator’s ability to freely use alternative reservation channels, including their own

internet booking platform, direct connect systems or call centres. This is because such

practices could create barriers to market entry for competing services and / or transport

operators, reduce consumer choice, and ultimately distort the level playing field

necessary for a competitive and innovative market environment. Pricing or other

general conditions should be considered unfair if they lead to an imbalance of rights

and obligations imposed on transport operators or confer an advantage on the B2B

MDMS provider or the B2C MDMS provider with significant market presence which

is disproportionate to the service provided by the MDMS provider to transport

operators. The following benchmarks can serve as a yardstick to determine the fairness

of the pricing and other general conditions: prices charged or conditions imposed for

the same or similar services by other MDMS providers; prices charged or conditions

imposed by the MDMS provider for different related or similar services or to different

types of users; prices charged or conditions imposed by the MDMS provider for the

same service in different geographic regions; prices charged or conditions imposed by

the MDMS provider for the same service that it provides to the transport operator

integrated with it. Where a B2C MDMS provider has been designated as B2C MDMS

provider with significant market presence at Union level, it should comply with those

specific rules across the Union.

(13) The obligations imposed on MDMS providers under this Regulation should be without

prejudice to Article 101 and Article 102 of the Treaty on Functioning of the European

Union (TFEU) and to the application of national competition rules. This Regulation

aims to protect a different legal interest from that protected by Union competition

rules. The Commission should receive information annually from B2C MDMS

providers to monitor the evolution of the ticketing markets and their interaction with

transport operators and users. Where developments may result in harm to competition,

transport operators or users in any of the transport modes and main segments at

national and Union level, or the related ticketing services, the Commission may

address them under existing tools, including Articles 101 and 102 TFEU or may

consider other action such as coordinating with relevant authorities in the Member

States.

(14) It follows that the market processes are often incapable of ensuring fair economic

outcomes with regard to MDMS providers. Although Articles 101 and 102 TFEU

apply to the conduct of MDMS providers, the scope of those provisions is limited to

certain instances of market power, for example dominance on specific markets and of

anti-competitive behaviour, and enforcement occurs ex post and requires an extensive

investigation of often very complex facts on a case-by-case basis. Moreover, existing

Union law does not address, or does not address effectively, the challenges to the

effective functioning of the internal market posed by the conduct of MDMS providers

that are not necessarily dominant in competition-law terms.

(15) In order to protect the interests of consumers and increase their trust in MDMSs,

transport products presented to business users and end users on B2B and B2C

MDMSs should be displayed in a manner that ensures no transport operator is unfairly

favoured over another transport operator. The provisions regarding the neutral display

EN 12 EN

of final price and travel time outlined in this Regulation should be without prejudice to

the application of existing rules on paid advertisement10.

(16) In accordance with Regulation (EC) No 1008/2008 of the European Parliament and of

the Council11, air carriers fares displayed to the public are to be inclusive of all

applicable taxes, and charges, surcharges and fees which are unavoidable and

foreseeable at the time of publication. Optional price supplements are to be

communicated in a clear, transparent and unambiguous way at the start of any booking

process. Air carriers and B2B MDMS providers should ensure that B2C MDMS

receive information on fares in such a way that those intermediaries can fulfil their

obligations under Article 23 of Regulation (EC) No 1008/2008. When displaying

information, B2C MDMS providers are to respect the requirements set out in Directive

(EU) 2019/882 of the European Parliament and of the Council12 and in particular offer

audio-visual options.

(17) B2C MDMS providers and B2B MDMS providers should display greenhouse gas and

carbon dioxide equivalent emissions’ data where such information is supplied by

transport operators. Making such data visible to users enhances transparency, enables

more informed decision-making and supports the broader objective of promoting

environmentally sustainable transport choices. By clearly presenting emissions

information, MDMS providers can help raise awareness of the environmental impact

of different travel options and encourage a shift towards lower-emission alternatives.

Since they do not hold the information themselves, MDMS providers should not be

bound by any additional obligations on displaying emissions data and should display

the data provided by the transport operators in accordance with the applicable

legislation. When sharing emissions’ data with MDMS providers, transport operators

should comply with the requirements laid down in Regulation (EU) XX/XX (CEEU),

including where applicable in accordance with the Commission Implementing

Regulation (EU) 2024/317013, Article 6 of which provides that airlines are only

allowed to display flight emissions in accordance with that Implementing Regulation.

(18) The requirements on neutral display should not apply to B2B MDMS providers where

their services are used by a transport operator or a group of transport operators at its

own offices or sales counters or on websites clearly identified as its own, as there is no

risk of one transport operator being favoured over another in such circumstances.

(19) Air carriers from the Union and from third countries should be given equivalent

treatment regarding B2B and B2C MDMS services.

10 Directive 2005/29/EC of the European Parliament and of the Council of 11 May 2005 concerning unfair

business-to-consumer commercial practices in the internal market and amending Council Directive

84/450/EEC, Directives 97/7/EC, 98/27/EC and 2002/65/EC of the European Parliament and of the

Council and Regulation (EC) No 2006/2004 of the European Parliament and of the Council (‘Unfair

Commercial Practices Directive’) (OJ L 149, 11.6.2005, p. 22, ELI:

http://data.europa.eu/eli/dir/2005/29/oj). 11 Regulation (EC) No 1008/2008 of the European Parliament and of the Council of 24 September 2008

on common rules for the operation of air services in the Community (OJ L 293, 31.10.2008, p. 3, ELI:

http://data.europa.eu/eli/reg/2008/1008/oj). 12 Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the

accessibility requirements for products and services (OJ L 151, 7.6.2019, p. 70, ELI:

http://data.europa.eu/eli/dir/2019/882/oj). 13 Commission Implementing Regulation (EU) 2024/3170 of 18 December 2024 laying down detailed

provisions concerning the voluntary environmental labelling scheme for the estimation of the

environmental performance of flights, established pursuant to Article 14 of Regulation (EU) 2023/2405

of the European Parliament and of the Council (Flight Emissions Label) (OJ L, 2024/3170, 31.12.2024,

ELI: http://data.europa.eu/eli/reg_impl/2024/3170/oj).

EN 13 EN

(20) Public authorities need data to support the planning of public transport services and

the broader mobility system, including the development and evaluation of Sustainable

Urban Mobility Plans (SUMPs). MDMS data can help assess the attractiveness of

public transport services, verify the adequacy of current offerings (for example, lines,

frequencies, timetables, multimodality efficiency), and evaluate infrastructure (for

example, bus lanes, cycle tracks). This data can also support the design of new

mobility products, packages, and demand studies.

(21) In order to achieve the objective of this Regulation to establish common Union rules

for B2C MDMS providers with significant market presence at national or Union level,

the power to adopt acts in accordance with Article 290 TFEU should be delegated to

the Commission to amend the thresholds for the designation of B2C MDMS providers

with significant market presence at national or Union’s level. It is of particular

importance that the Commission carry out appropriate consultations during its

preparatory work, including at expert level, and that those consultations be conducted

in accordance with the principles laid down in the Interinstitutional Agreement of 13

April 2016 on Better Law-Making14. In particular, to ensure equal participation in the

preparation of delegated acts, the European Parliament and the Council receive all

documents at the same time as Member States experts, and their experts systematically

have access to meetings of Commission expert groups dealing with the preparation of

delegated acts.

(22) Implementing powers should be conferred on the Commission to designate B2C

MDMS providers with significant market presence in the Union and, in case of

discrimination in the third country, require B2B MDMS providers operating in the

Union to treat air carriers from that third country in a manner that is equivalent to the

treatment of Union air carriers in that third country. Those powers should be exercised

in accordance with Regulation (EU) No 182/2011 of the European Parliament and of

the Council15.

(23) Where a provider designated as a B2C MDMS provider with significant market

presence in one or several Member States is designated as B2C MDMS provider with

significant market power at Union level, the Member States where the B2C MDMS

provider was designated as having a significant market remains competent to enforce

this Regulation against that B2C MDMS provider for the period preceding its

designation as B2C MDMS provider with significant market power at Union level.

(24) The objective of this Regulation, namely to establish common rules for B2B and B2C

MDMS providers in relation to transport products offered or used in the Union, cannot

be adequately met by Member States acting alone. This is due to the cross-border

nature of digital mobility services and the need to ensure interoperability, consistency,

and legal certainty across national markets. To avoid market fragmentation and ensure

a level playing field for transport operators and MDMS providers across the Union,

action at Union level is necessary. As a result, the Union may adopt measures in

accordance with the principle of subsidiarity as set out in Article 5 of the Treaty on

European Union. In accordance with the principle of proportionality as set out in that

Article, this Regulation does not go beyond what is necessary in order to achieve that

objective.

14 OJ L 123, 12.5.2016, p. 1, ELI: http://data.europa.eu/eli/agree_interinstit/2016/512/oj. 15 Regulation (EU) No 182/2011 of the European Parliament and of the Council of 16 February 2011

laying down the rules and general principles concerning mechanisms for control by the Member States

of the Commission's exercise of implementing powers (OJ L 55, 28.2.2011, p. 13, ELI:

http://data.europa.eu/eli/reg/2011/182/oj).

EN 14 EN

(25) Due to market and technological changes some provisions of Regulation (EC) No

80/2009 are no longer relevant, while some provisions remain relevant but are no

longer fit for purpose and need to be updated. The specific rules for parent carriers are

no longer relevant as airlines have fully divested their CRS ownership. Consequently,

the associated auditing and reporting requirements regarding their ownership and

structure should also be repealed, since they are intrinsically linked to those rules. The

provisions on the protection of personal data are now consistently enforced across the

Union under the rules of Regulation (EU) 2016/679 of the European Parliament and of

the Council16. Section 6 of Regulation (EC) No 80/2009 on infringements and

penalties is superseded by the rules set out in this Regulation. The other remaining

provisions of Regulation (EC) No 80/2009 should be retained, as they continue to be

relevant and updated to reflect market and technological changes in order to ensure a

level playing field between all providers performing similar functions in business-to-

business digital reservation services. In particular, the rules on the use of a neutral

display should be updated to offer all providers greater flexibility for ranking transport

products in accordance with new technological developments. Regulation (EC) No

80/2009 should therefore be repealed and the relevant provisions incorporated into

this Regulation,

HAVE ADOPTED THIS REGULATION:

Chapter 1

Subject matter, scope and definitions

Article 1

Subject matter

This Regulation establishes a framework to facilitate multimodal and multi-operator

passenger mobility through the deployment and use of business-to-consumer multimodal

digital mobility services and business-to-business digital mobility services.

It lays down common rules for cooperation that ensure a level playing field for providers of

multimodal digital mobility services, business users of such services, as well as the transport

operators providing the underlying transport service. It also sets out rules on information to be

provided by those providers to business users, end users and public transport authorities.

Article 2

Scope

(1) This Regulation applies to:

(a) providers of business-to-consumer multimodal digital mobility services when

they offer transport products to end users in the Union, for journeys within, to

or from the Union, except for transport services whose principal purpose is to

meet the transport needs of an urban centre or conurbation, including a cross-

border conurbation, or to meet the transport needs between such a centre or

conurbation and the surrounding area;

16 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the

protection of natural persons with regard to the processing of personal data and on the free movement of

such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016,

p. 1, ELI: http://data.europa.eu/eli/reg/2016/679).

EN 15 EN

(b) providers of business-to-business multimodal digital mobility services when

they offer transport products to business users in the Union, or when the

transport product's underlying transport service is provided, wholly or partially,

within the territory of the Union;

(c) transport operators when they have a commercial agreement with one of the

providers referred to in points (a) and (b).

(2) This Regulation does not apply to online search engines as defined in Article 2, point

(5), of Regulation (EU) 2019/1150.

(3) The obligations set out in this Regulation do not apply to:

(a) B2C MDMS providers which are small or medium-sized enterprises as

defined in Article 2 of the Annex to Commission Recommendation

2003/361/EC17;

(b) B2B MDMS providers which are small or medium-sized enterprises as

defined in Article 2 of the Annex to Recommendation 2003/361/EC.

(4) This Regulation is without prejudice to Articles 101 and 102 of the Treaty on the

Functioning of the European Union (TFEU) and to the application of national

competition rules.

(5) This Regulation is without prejudice to the application of Regulation (EU) XX

(RTR) and of other Union legal acts regulating the provision of information society

services.

Article 3

Definitions

For the purposes of this Regulation, the following definitions apply:

(1) ‘information society service’ means a service as defined in Article 1(1), point

(b), of Directive (EU) 2015/1535 of the European Parliament and of the

Council;

(2) ‘business-to-consumer multimodal digital mobility service’ or ‘B2C MDMS’

means an information society service which meets all of the following

conditions:

(a) it provides end users with traffic and travel information, such as schedules,

service availability and fares for transport products;

(b) it distributes online transport products or relinks transport products, with any

transport product offered at least partially under a code share arrangement or an

interlining agreement being considered as a transport product of the marketing

operator only, from two or more transport operators in the same mode, unless

those transport operators are part of the same group of transport operators;

(3) ‘business-to-business multimodal digital mobility service’ or ‘B2B MDMS’

means a service provided through IT systems to business users by an entity

which provides traffic and travel information, such as schedules, service

availability and fares for transport products, with any transport product offered

17 Commission Recommendation 2003/361/EC of 6 May 2003 concerning the definition of micro, small

and medium-sized enterprises (OJ L 124, 20.5.2003, p. 36, ELI:

http://data.europa.eu/eli/reco/2003/361/oj).

EN 16 EN

at least partially under a code share arrangement or an interlining agreement

being considered as a transport product of the marketing operator only, and

with or without the facility to make a reservation or issue tickets on behalf of a

client, of two or more transport operators, in the same transport mode, unless

those transport operators are part of the same group of transport operators;

(4) ‘journey’ means the end-to-end carriage of passengers, which can include

multiple legs and is carried out by one or more operators, using one or more

modes of transport;

(5) ‘transport service’ means the carriage of passengers by air, rail, bus, coach or

waterborne vessel, available to the public and operated according to a

published timetable between a point of departure and a point of arrival;

(6) ‘transport product’ means a tailored transport service linked to a fare;

(7) ‘ticket’ means valid evidence of the purchase of a transport product;

(8) ‘transport operator’ means any carrier that provides transport services or

organises transport services on the basis of a cooperation agreement with

carriers that are licensed to provide transport services on Union territory;

(9) ‘group of transport operators’ means at least two transport operators that

together form part of the same undertaking within the meaning of Article 101

TFEU;

(10) ‘business user’ means any natural or legal person acting in a commercial or

professional capacity using a B2B MDMS, including via subscription, under a

commercial agreement with the provider of that B2B MDMS, for the purpose

of reserving transport products on behalf of a client;

(11) ‘end user’ means any natural or legal person using a B2C MDMS;

(12) ‘client’ means any natural or legal person who is a customer of the business

user for the purpose of purchasing a transport product;

(13) ‘re-linking’ means the redirection of an end user to the relevant online mobility

websites or applications where the availability of one or more displayed

transport products can be checked and the transport products selected by the

end user can be purchased;

(14) ‘remuneration’ means a booking fee or any other financial compensation paid

by the transport operator for the services provided by a B2C MDMS provider

or B2B MDMS provider;

(15) ‘fare’ means the amount that the end user, or the client, has to pay for the

transport product, in accordance with any conditions applicable to the transport

product, such as mandatory seat reservations, and related auxiliary services,

such as luggage transfer;

(16) ‘final price’ means the amount that the end user, or the client, pays when

purchasing a transport product and which includes the fare and all charges,

applicable taxes, surcharges and booking fees, which are unavoidable and

foreseeable at the time when the price is shown on the display;

(17) ‘public transport authority’ means any public authority in a Member State

responsible for the traffic management or the planning or management of a

given transport network or transport service falling within its jurisdiction;

EN 17 EN

(18) ‘distribution facilities’ means features made available by a B2B MDMS

provider for providing information on transport operators’ schedules, service

availability, fares and related services, for making reservations, for issuing

tickets, for any other related services.

Chapter 2

B2C MDMS providers with significant market presence and B2B

MDMS providers

Article 4

Designation of B2C MDMS providers with significant market presence

1. B2C MDMS providers shall, each year, inform the Commission and the Member

State of their establishment, of the number and value of tickets sold per transport

mode per year per Member State.

2. A B2C MDMS provider shall be designated as a B2C MDMS provider with

significant market presence at Union level for each transport mode in which it meets

the thresholds laid down in point 1 of Annex I. To that end, a B2C MDMS provider

that meets those thresholds shall, for each transport mode concerned, notify that fact

to the Commission. A designation pursuant to this paragraph shall take precedence

over any designation concerning the same transport mode at national level.

3. A B2C MDMS provider shall be designated as a B2C MDMS provider with

significant market presence at national level for each transport mode in which it

meets the thresholds laid down in point 2 of Annex I. To that end, B2C MDMS

providers that meet those thresholds shall, for each transport mode concerned, notify

that fact to the national enforcement body of the Member State in which they have

met those thresholds.

4. By way of derogation from the obligation in paragraph 3 of this Article to notify

national enforcement bodies when it meets the thresholds laid down in point 2 of

Annex I, a B2C MDMS provider that meets the thresholds laid down in both points 1

and 2 of Annex I, shall, for each transport mode concerned, notify only the

Commission of that fact.

5. B2C MDMS providers shall submit all the notifications and information referred to

in paragraphs 1 to 4 of this Article by 31 January of the year following the financial

year for which the thresholds laid down in Annex I are assessed. By way of

derogation from the obligation in paragraphs 2 and 3 of this Article to notify either

the Commission or the relevant national enforcement bodies when it meets the

thresholds laid down in either points 1 or 2 of Annex I, a B2C MDMS provider that

has been designated in accordance with either of those paragraphs shall not be

obliged to submit any subsequent notification for the modes of transport concerned

unless the thresholds laid down in Annex I are modified in accordance with

paragraph 9 of this Article.

6. For the purposes of assessing whether they meet the thresholds laid down in points 1

and 2 of Annex I, B2C MDMS providers shall take into account all ticket sales of all

of their subsidiaries.

7. The designating authority shall adopt a decision designating a B2C MDMS provider

as having significant market presence when they meet the thresholds laid down in

EN 18 EN

points 1 or 2 of Annex I. The Commission shall adopt designation decisions by

means of implementing acts. Those implementing acts shall be adopted in

accordance with the advisory procedure referred to in Article 17(2).

The designating authority shall take its decision on the basis of the information

submitted by the B2C MDMS provider in accordance with paragraphs 1, 2 or 3 of

this Article or any other information available to it. The B2C MDMS provider shall

communicate to the designating authority, upon its request and within a reasonable

timeframe, and in any case within two months, any additional information needed for

the purpose of the assessment of its significant market presence. B2C MDMS

providers which do not submit the requested information within the

established timeframe may be designated, without undue delay, based on any other

information available to the designating authority.

The designating authority shall adopt that decision within six months from the

notification referred to in paragraphs 2 and 3 of this Article or, where applicable,

after an assessment concluding that the B2C MDMS provider meets the thresholds

laid down in Annex I, and in any case at the latest by 1 November of the year

following the financial year in which the thresholds laid down in Annex I are met.

National enforcement bodies shall notify oftheir decisions, designating a B2C

MDMS provider as having significant market presence to the Commission within

one month from the adoption of the decision. The Commission shall, without undue

delay, publish on a dedicated webpage and keep up to date a list of the B2C MDMS

providers designated at national and Union level.

8. The designating authority shall terminate the designation if, during an uninterrupted

period of one year, the B2C MDMS provider has not met the thresholds laid down in

points 1 and 2 of Annex I, for the transport mode in which it has been designated.

The rules laid down in paragraphs 1 to 7 of this Article shall apply mutatis mutandis

to the termination of designation.

9. The Commission is empowered to adopt delegated acts in accordance with Article

16 concerning the amendment of the thresholds laid down in Annex I, in order to

adapt the thresholds to changes in the B2C MDMS market.

Article 5

Conditions for commercial agreements between transport operators and B2C MDMS

providers with significant market presence or B2B MDMS providers

1. B2C MDMS providers shall comply with the rules laid down in this Article in

relation to the transport mode for which they have been designated pursuant to

Article 4(2) and (3) and in the Member States to which that designation relates.

2. When concluding commercial agreements with transport operators, B2C MDMS

providers designated as having significant market presence in the transport mode

concerned, and B2B MDMS providers, shall:

(a) provide guarantees to ensure that commercially sensitive data shared by transport

operators are not disclosed, including to other transport operators using the same

MDMS, or to transport operators vertically integrated with the B2C MDMS provider,

or to other B2B MDMS providers;

(b) not attach any unfair conditions or exclusivity clauses to the commercial agreement

that would, intentionally or otherwise:

EN 19 EN

(i) hinder or prevent transport operators from concluding commercial

agreements with other B2C MDMS providers or B2B MDMS providers

for the effective use of their services;

(ii) require the acceptance of any supplementary conditions that, by their

nature or according to commercial usage, would not be necessary for the

distribution or re-linking of transport products;

(iii) make it a condition that a participating transport operator is forbidden at

the same time from using another system or that a participating transport

operator is forbidden from freely using alternative reservation systems

such as its own direct connect system, internet booking system and call

centres;

(c) ensure that where remuneration for the services of the B2C MDMS provider or the

B2B MDMS provider is agreed with the transport operator, remuneration levels are

based on fair, reasonable and non-discriminatory criteria.

3. B2B MDMS providers shall:

(a) not reserve any specific loading or processing procedures, any other

distribution facilities or any changes to those procedures or facilities, for

certain transport operators;

(b) provide the same information to all participating transport operators about

changes to their distribution facilities, loading procedures and processing

procedures;

(c) ensure that their distribution facilities are separated in a clear and verifiable

manner from any transport operator’s private inventory, management

facilities and marketing facilities.

Article 6

Conditions for commercial agreements between B2B MDMS providers and business

users

1. Commercial agreements between B2B MDMS providers and business users shall not

intentionally or otherwise:

(a) hinder or prevent a business user from subscribing to or using effectively any

other similar system;

(b) require the acceptance of additional conditions which are not necessary for the

subscription to the B2B MDMS;

(c) impose an obligation to accept specific technical equipment or software;

(d) impose any other unfair or unjustified conditions.

2. Where a business user is a small enterprise within the meaning of Article 2(2) of the

Annex to Recommendation 2003/361/EC it may terminate its commercial agreement

with a B2B MDMS provider any time after the first year of that agreement. To that

end, it shall give written notice, which shall not exceed three months. In such a case,

a B2B MDMS provider shall not be entitled to recover more than the administrative

costs directly related to the termination of the commercial agreement.

EN 20 EN

Chapter 3

General obligations of B2C MDMS and B2B MDMS providers in

relation to the display and exchange of information

Article 7

Neutral display and ranking criteria

1. When displaying transport products or a combination of transport products, B2C

MDMS providers and B2B MDMS providers shall load and process data provided by

transport operators with equal care and in a timely manner.

2. When B2C MDMS providers and B2B MDMS providers display transport products

or a combination of transport products, they shall do so in a neutral and

comprehensive manner, without discrimination or bias.

3. Transport operators shall ensure that the data submitted to B2C MDMS providers

and B2B MDMS providers is accurate, up to date and allows the provider to comply

with the rules set out in this Article.

4. B2C MDMS providers and B2B MDMS providers shall apply the criteria referred to

in paragraph 5 to rank the transport products and combinations of transport

products on a non-discriminatory basis to all transport operators. Those criteria shall

not be based on any factor directly or indirectly related to the transport operator’s

identity, unless explicitly required by the end user or business user. B2C MDMS

providers and B2B MDMS providers shall display transport products

and combinations of transport products in such a way that the end user or business

user is not misled, and can easily access them, the display criteria are clearly

indicated, and the rules set out in this Article are met.

5. When displaying transport products or a combination of transport products, B2C

MDMS providers and B2B MDMS providers shall by default rank the transport

products or combinations of transport products based on one or more of the

following criteria:

(a) final price;

(b) travel time;

(c) greenhouse gas (GHG) emissions;

(d) CO2 equivalent emissions;

(e) products including a single-leg transport service ranked by departure time;

(f) products including stops and available subsequent connecting transport

services, ranked by departure time and total travel time;

(g) accessible transport services for persons with disabilities or reduced mobility.

6. B2C MDMS providers and B2B MDMS providers shall always present final prices

to end users or business users when displaying transport products or a combination of

transport products. For air services, those shall be presented in accordance with

Article 23 of Regulation (EC) No 1008/2008.

7. B2C MDMS providers and B2B MDMS providers shall always allow end users and

business users to rank transport products or a combination of transport products on

the basis of GHG emissions or CO2 equivalent emissions.

EN 21 EN

8. B2C MDMS providers and B2B MDMS providers shall enable end users

and business users to use or combine any of the criteria listed in paragraph 5, points

(a) to (g), in any order.

9. B2C MDMS providers and B2B MDMS providers shall display a transport

product only once within a given search result. By way of derogation, in case of

code-share arrangements, each of the two code-share transport operators shall be

allowed to ask for the relevant transport products to be displayed as their own

service, using their own individual carrier designator code. Where more than two

transport operators participate in a code-share agreement, identification of the two

carriers for the purposes of the display shall fall within the responsibility of the

transport operator that actually operates the journey.

10. When displaying transport products or a combination of transport products, B2C

MDMS providers and B2B MDMS providers may use other ranking criteria in

addition to those laid down in paragraph 5, if explicitly requested by the end user or

client of the business user. When displaying final prices, B2B MDMS providers shall

communicate any optional price supplements to business users in a clear and

transparent manner.

11. B2C MDMS providers may accept direct or indirect payment from transport

operators in order to display those operators prominently. Such ‘paid prominence’

shall not be one of the default ranking criteria and shall only be available upon

request by the end user. The offers to which that criterion has been applied shall be

clearly displayed with the indication “choice of” or “sponsored content”. The effects

of the payment on the ranking shall be transparently described.

12. Flights operated by air carriers subject to an operating ban pursuant to Regulation

(EC) No 2111/2005 of the European Parliament and of the Council18 shall be clearly

and specifically identified by B2C MDMS providers and B2B MDMS

providers when they display transport products. The B2C MDMS providers and B2B

MDMS providers shall include a specific symbol when they display transport

products which shall inform end users and business users of the identity of the

operating air carrier as provided for in Article 11 of Regulation (EC) 2111/2005.

13. This Article shall not apply to B2B MDMS used by a transport operator or a group of

transport operators at its own offices or sales counters, or on direct distribution

websites clearly identified as its own.

19Article 8

Marketing information data

1. If any marketing, booking or sales data is provided by a B2C MDMS provider or a

B2B MDMS provider at the request of one transport operator, it shall also be made

available in a timely manner to all transport operators with whom that provider has

concluded a commercial agreement. That data may, and on the transport

18 Regulation (EC) No 2111/2005 of the European Parliament and of the Council of 14 December 2005 on

the establishment of a Community list of air carriers subject to an operating ban within the Community

and on informing air transport passengers of the identity of the operating air carrier, and repealing

Article 9 of Directive 2004/36/EC (OJ L 344, 27.12.2005, p. 15, ELI:

http://data.europa.eu/eli/reg/2005/2111/oj). 19 Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the

accessibility requirements for products and services (OJ L 151, 7.6.2019, p. 70, ELI:

http://data.europa.eu/eli/dir/2019/882/oj).

EN 22 EN

operator’s request, shall, cover all transport operators and business users with whom

that provider has concluded a commercial agreement. Only anonymised and

aggregated data may be made available.

2. Transport operators shall not use the data referred to in paragraph 1 in order to

identify and influence the choice of the end user or business user.

3. Where the data referred to in paragraph 1 results from the use by a business user

established in the Union of the distribution facilities of a B2B MDMS provider, it

shall not identify the business user unless that business user agrees on the conditions

for making appropriate use of that data with the B2B MDMS provider. The same

shall apply to the sharing of such data by the B2B MDMS provider with any other

party for use by that party for reasons other than billing settlement.

Article 9

Information on greenhouse gas emissions and carbon dioxide equivalent emissions

1. MDMS providers shall display clear, transparent and accessible information on the

GHG emissions or CO2 equivalent emissions, as applicable, of transport products,

wherever such information is made available by transport operators. That

information shall be displayed as provided by the transport operator, in accordance

with Regulation (EU) XXX of the European Parliament and of the Council CEEU,

including where applicable in accordance with Implementing Regulation (EU)

2024/3170.

2. If the information referred to in paragraph 1 is not available for all transport products

included in a combination of transport products, the B2C MDMS provider or B2B

MDMS provider shall specify which transport products the information relates to and

explicitly indicate which transport products lack information on GHG emissions or

CO2 equivalent emissions.

3. When ranking transport products or a combination of transport products on the basis

of GHG emissions or CO2 equivalent emissions, B2C MDMS providers or B2B

MDMS providers shall display the transport products or combination of transport

products for which such information is not available at the end of the ranking. Where

information is only partially available for a part of the journey, B2C MDMS

providers or B2B MDMS providers shall display that product in the ranking order

lower than the display of transport products or a combination of transport products

for which all information is available.

Article 10

Sharing of data with public transport authorities

1. Upon request of a public transport authority, and provided that they offer transport

products within the territory under the responsibility of that authority, B2C MDMS

providers shall transmit passenger volumes data in each transport mode covered by

the MDMS. Such data shall be used exclusively to improve the effectiveness of

public transport policies and sustainable mobility policies falling under the

responsibility of that authority. The data shall be aggregated and anonymised. B2C

MDMS providers shall only be required to share data already in their possession and

shall not be obliged to produce new data in response to a request from a public

transport authority.

EN 23 EN

2. Requests referred to in paragraph 1 shall clearly indicate the specific objective of

transport policies or sustainable mobility policies for which the data is needed. The

public transport authority shall not use the data for any other purpose than to support

the design, implementation and evaluation of public transport policies. The public

transport authority shall not use or share the requested data for commercial purposes.

3. Public transport authorities shall cover the costs reasonably incurred by the B2C

MDMS provider for providing the data requested by that authority.

Article 11

Equivalent treatment of air carriers in third countries

1. Without prejudice to international agreements to which the Union or Member States

are parties, where a B2B MDMS provider operating in a third country does not treat

Union air carriers and carriers from that third country to whom it provides services in

an equivalent way with regard to any of the matters covered by this Regulation, the

Commission may require, by means of an implementing act adopted in accordance

with the procedure referred to in Article 17(2), all B2B MDMS providers operating

in the Union to treat air carriers from that third country in a manner that is equivalent

to the treatment of Union air carriers in that third country.

2. For the purposes of paragraph 1, the Commission shall monitor discriminatory or

non-equivalent treatment of Union air carriers by B2B MDMS providers in third

countries. At the request of a Member State or on its own initiative, the Commission

shall investigate potential cases of discrimination against Union air carriers in B2B

MDMS in third countries. Before taking a decision in accordance with paragraph 1,

the Commission shall inform the interested parties.

Chapter 4

Implementation and enforcement

Article 12

National enforcement bodies

1. Member States shall designate a national enforcement body to be responsible for the

enforcement of this Regulation. Member States shall ensure that their national

enforcement body has all the necessary administrative and financial resources and

has the necessary expertise to adequately carry out the tasks under this Regulation.

2. Each Member State shall notify the Commission of the identity of the national

enforcement body it has designated in accordance with paragraph 1 and specify

the tasks and responsibilities of that body. The national enforcement body shall

publish the information about its tasks and responsibilities on its webpage. The

Commission shall publish a list of those bodies on a dedicated webpage and keep it

up to date.

3. The national enforcement body of the Member State in which the main establishment

of the B2C MDMS provider is located shall have the power to enforce this

Regulation in relation to that B2C MDMS provider.

4. By way of derogation from paragraph 3, and on the basis of a duly reasoned request

from the national enforcement body of a Member State where the B2C MDMS

provider has been designated as having significant market presence, the power to

EN 24 EN

enforce the obligations laid down in Article 5(2) shall, for the purposes laid down in

that request, be transferred to that national enforcement body by the national

enforcement body of the Member State in which the main establishment of that B2C

MDMS provider is located.

5. The national enforcement body of the Member State in which the main establishment

of the B2B MDMS provider and of the transport operator, respectively, is located

shall have the exclusive power to enforce this Regulation in relation to that B2B

MDMS provider and that transport operator.

6. Where a B2C MDMS provider or a B2B MDMS provider does not have any

establishment in the Union, any national enforcement body shall be competent to

enforce this Regulation in relation to that provider.

7. Member States shall ensure that their national enforcement body is independent in

terms of its organisation, funding, legal structure, and decision-making procedures

from any transport operator, B2C MDMS provider, B2B MDMS provider, business

user or public transport authority.

Article 13

Tasks of national enforcement bodies

1. Member States shall ensure the tasks and responsibilities of the national enforcement

body are clearly defined and cover at least the following:

(a) promoting awareness of the rights and obligations laid down in this Regulation;

(b) designating B2C MDMS providers with significant market presence in

accordance with Article 4;

(c) monitoring compliance with this Regulation and taking measures to ensure its

correct implementation;

(d) handling complaints of alleged breaches of this Regulation;

(e) imposing penalties laid down in accordance with Article 15, where the national

enforcement body established that the provisions of this Regulation have been

breached;

(f) cooperating with national enforcement bodies of other Member States and with

the Commission to ensure the coherent enforcement of this Regulation, mutual

assistance in market monitoring tasks, enforcement, designation process and

complaint handling, including through the exchange of relevant information by

electronic means while duly respecting the confidentiality of commercially

sensitive data.

2. National enforcement bodies shall enforce this Regulation in close cooperation with

one another.

3. Where a national enforcement body requests information from a national

enforcement body in another Member State in order to carry out its tasks or

responsibilities, that information shall be provided without undue delay and, in any

event, within one month from receipt of the request. In complex cases, the national

enforcement body to whom the request is addressed may extend that deadline to a

maximum of three months from receipt of the request.

EN 25 EN

4. The national enforcement bodies shall set up and cooperate through a network that

convenes regularly and at least once a year, to exchange information in particular on

their monitoring, enforcement and implementation work, decision-making principles,

and administrative practices. The Commission shall be a member, coordinate and

support the work of the network and make recommendations to the network, as

appropriate. It shall ensure active cooperation of the appropriate regulatory bodies.

Article 14

Complaints

1. B2C MDMS providers, B2B MDMS providers or business users shall have the right

to lodge a complaint alleging a breach of this Regulation with the national

enforcement body of the Member State where they are established alleging a breach

of this Regulation, or if they believe they have been unfairly treated, discriminated

against or are in any other way aggrieved.

2. Public transport authorities may lodge a complaint alleging a breach of Article 10

with the national enforcement body of their Member State.

3. Transport operators shall have the right to lodge complaints alleging a breach of this

Regulation with the national enforcement body of the Member State in which their

licence to operate on Union territory has been granted, or if they believe they have

been unfairly treated, discriminated against or are in any way other way aggrieved.

4. When they are not located or established in the Union, B2C MDMS providers, B2B

MDMS providers and business users, as well as a transport operators whose license

was granted by a third country shall have the right to lodge a complaint alleging

a breach of this Regulation with the competent national enforcement body of the

Member State in which the other party allegedly committing the infringement is

established, or which granted its operating licence, or in whose territory the transport

services concerned, or a part of those services, were provided.

5. Where a complaint cannot be lodged in accordance with the rules established in

paragraphs 1 to 4, the complaint may be lodged with the national enforcement body

of any Member State.

6. The national enforcement body receiving a complaint pursuant to paragraphs 1 to 5

of this Article shall assess the complaint and, where appropriate, transmit it to the

competent national enforcement body of the Member State in accordance with

Article 12(1).

7. National enforcement bodies shall refuse to handle a complaint if another complaint

on the same subject between the same parties has already been lodged with another

national enforcement body or an effective remedy has been sought before a national

court of a Member State.

National enforcement bodies handling a complaint shall inform the national

enforcement bodies of the Member States:

(a) in which the B2C MDMS provider or B2B MDMS provider that is subject to

the complaint is established;

(b) which granted the operating licence of the transport operator that is subject to

the complaint;

(c) in whose territory the transport services were provided.

EN 26 EN

The national enforcement body handling a complaint may also request relevant

information from the national enforcement bodies referred to in the first

subparagraph and shall take it into account before taking a decision in relation to the

complaint.

8. On [Publication Office, insert the date of entry into force of this Regulation +2

years], and every two years thereafter, national enforcement bodies shall publish

activity reports with statistics including the issues which most frequently gave rise to

complaints and information on penalties imposed for breaches of this Regulation.

The reports shall not disclose commercially sensitive data. The reports shall be

published on the website of the respective national enforcement body by 30 June of

the calendar year following the end of the reference period.

Article 15

Penalties

1. Member States shall lay down the rules on penalties applicable to infringements of

this Regulation. Those penalties shall be effective, proportionate, dissuasive and non-

discriminatory.

2. Member States shall notify the Commission of those rules and measures by [date of

application of the Regulation] and shall notify it without delay of any amendments to

them.

Article 16

Exercise of the delegation

1. The power to adopt delegated acts is conferred on the Commission subject to the

conditions laid down in this Article.

2. The power to adopt delegated acts as referred to in Article 4 (10) shall be conferred

on the Commission for a period of five years from [date of entry into force of this

act]. The Commission shall draw up a report in respect of the delegation of power

no later than nine months before the end of the five-year period. The delegation of

power shall be tacitly extended for periods of an identical duration, unless the

European Parliament or the Council opposes such extension not later than three

months before the end of each period.

3. The delegation of power may be revoked at any time by the European Parliament or

by the Council. A decision to revoke shall put an end to the delegation of power set

out in that decision. It shall take effect the day following its publication in the

Official Journal of the European Union or at a later date specified therein. It shall not

affect the validity of any delegated acts already in force.

4. Before adopting a delegated act, the Commission shall consult experts designated by

each Member State in accordance with the principles laid down in the

Interinstitutional Agreement of 13 April 2016 on Better Law-Making.

5. As soon as it adopts a delegated act, the Commission shall notify it simultaneously to

the European Parliament and to the Council.

6. A delegated act adopted pursuant to Article 4 (10) shall enter into force only if no

objection has been raised either by the European Parliament or by the Council within

a period of two months of notification of that act to the European Parliament and the

EN 27 EN

Council or if, before the expiry of that period, the European Parliament and the

Council have both informed the Commission that they will not object. That period

shall be extended by two months at the initiative of the European Parliament or of the

Council.

Article 17

Committee procedure

1. The Commission shall be assisted by a committee. That committee shall be a

committee within the meaning of Regulation (EU) No 182/2011.

2. Where reference is made to this paragraph, Article 4 of Regulation (EU) No

182/2011 shall apply.

Chapter 5

Final provisions

Article 18

Review and report

By [dd/mm/20yy - five years after the date of application of this Regulation], the Commission

shall evaluate the implementation of this Regulation and submit a report to the European

Parliament and the Council on its main findings.

The report shall, where necessary, be accompanied by appropriate legislative proposals.

Article 19

Repeal

1. Regulation (EC) No 80/2009 is repealed.

2. References to the repealed Regulation shall be construed as references to this

Regulation and shall be read in accordance with the correlation table in Annex II.

Article 20

Entry into force

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

the Official Journal of the European Union.

It shall apply from [ DATE XX months after the date of entry into force of this Regulation].

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 28 EN

LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE

1.1. Title of the proposal/initiative

Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF

THE COUNCIL on Multimodal Booking

1.2. Policy area(s) concerned

Transport, Digital Services

1.3. Objective(s)

1.3.1. General objective(s)

Better functioning of the online ticket distribution market

1.3.2. Specific objective(s)

Specific objective

Improve transparency and establish a level playing field for transport operators in

terms of access and use of indispensable multimodal digital mobility services

(MDMS).

1.3.3. Expected result(s) and impact

Specify the effects which the proposal/initiative should have on the

beneficiaries/groups targeted.

The initiative is expected to have positive impacts on MDMS, transport operators

(with net benefits for each group), competitiveness and functioning of the internal

market as well as innovation. The proposal is also expected to impact modal shift

towards more sustainable transport modes, thereby positively impacting transport

safety, CO2 emissions and air pollutants.

1.3.4. Indicators of performance

Specify the indicators for monitoring progress and achievements.

The main milestones considered for monitoring progress and achievements of the

objective are to (i) achieve fair and non-discriminatory commercial agreement

negotiations, (ii) ensure unbiased display of travel options for end-users on all

MDMS and (iii) minimise unjustified price divergence for identical offers across

services. Progress towards this objective will be monitored using four key indicators

(compared to the baseline described in the impact assessment accompanying the

proposal): (i) the number of transport operators distributing transport products on

indispensable MDMS (ii) the number of agreements between MDMS and transport

operators, (iii) the number of sanctions imposed and (iv) increased consumer

satisfactions scores on travel information availability and bookability.

1.4. The proposal/initiative relates to:

☑ a new action

☐ a new action following a pilot project/preparatory action 37

☐ the extension of an existing action

37 As referred to in Article 58(2), point (a) or (b) of the Financial Regulation.

EN 29 EN

☐ a merger or redirection of one or more actions towards another/a new

action

1.5. Grounds for the proposal/initiative

1.5.1. Requirement(s) to be met in the short or long-term including a detailed timeline for

roll-out of the implementation of the initiative

Several measures are considered to improve transparency and establish a level

playing field for transport operators in terms of access and use of indispensable

MDMS:

(a) First the proposal includes measures that ensure fair treatment of information

and data on all MDMS. This is done by obliging MDMS to respect neutral

display (following display criteria) on their online interface. MDMS will also

be required to display information on greenhouse gas emissions, when that

information is shared by the transport operator, and to share data for mobility

management with public authorities.

(b) It also sets out key principles framing all commercial agreements between

indispensable MDMS and transport operators. These rules aim to protect

transport operators in their commercial agreements with indispensable

MDMS. A notification process at national and EU level is planned to identify

and designate B2C MDMS with significant market presence (indispensable

ones).

(c) Member States would be required to appoint a national authority to settle

disputes that could arise between parties and an EU enforcement network of

such authorities would ensure consistent enforcement across the EU.

1.5.2. Added value of EU involvement (it may result from different factors, e.g.

coordination gains, legal certainty, greater effectiveness or complementarities). For

the purposes of this section 'added value of EU involvement' is the value resulting

from EU action, that is additional to the value that would have been otherwise

created by Member States alone.

This initiative will enable end users and, in the case of B2B services, subscribers to

benefit from a greater choice of tickets, displayed in a fair and transparent way,

across transport operators and modes. This should in turn improve the functioning of

the internal market, through a smoother and more coherent booking experience for

passengers, and support the EU's objective of economic, social and territorial

cohesion. Action at EU level with horizontal rules would support a better functioning

of the online ticket distribution market, removing obstacles for operators and

MDMS. EU level action for B2B ticket distribution would continue to promote a

level playing field in the sector. The 2020 ex-post evaluation of the CRS Code of

Conduct concluded that the EU level is the right level for intervention in ticket

distribution, compared to national and international intervention. This is due to the

multinational nature of both CRS providers and aviation services. If regulated at the

national level, CRS providers would need to adapt to a multitude of regulatory

regimes with negative impacts on efficiency. In addition, the risk of “rule shopping”

would result in fragmentation of the EU single market. At the international level, the

International Civil Aviation Organisation (ICAO) has adopted a non-binding CRS

Code of Conduct. However, the EU CRS Code of Conduct is binding, making it

more effective and adding value compared to the Member States adopting the ICAO

code.

EN 30 EN

1.5.3. Lessons learned from similar experiences in the past

Lessons can be drawn from the Code of Conduct on Computerised Reservation

Systems (CRS): Regulation 2299/8938 was adopted to ensure equal treatment of all

airlines whose flights were included in a CRS as to promote competition between

airlines in the indirect air ticket distribution sector. It introduced requirements for

results to be shown on an unbiased display that did not favour the CRS’s parent

carriers (or any other carriers) and to ensure that parent carriers did not favour their

own CRS over the others as well as to ensure that travel agents and finally consumers

have access to offers without bias. The CRS Code of Conduct was evaluated in 2020.

The evaluation concluded that the objectives of (i) ensuring a level playing field and

(ii) increasing transparency remain relevant. The evaluation showed that the Code

has not fully ensured a level playing field for all participating carriers, as regards

access to, and use of CRS services, since it did not lead to better balancing of the

bargaining power of different-sized air carriers vis-à-vis CRSs. However, the

evaluation concluded that the transparency requirements, in the form of the neutral

display, remain important, since travel agents, both offline and online, and travel

management companies still heavily rely on CRS data especially for business travel.

Finally, the evaluation concluded that while promoting rail and multimodal transport

remains important, this should be pursued through broader initiatives rather than

CRS-specific rules.

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments

The proposal is consistent with other EU instruments and relevant EU policies. and

in particular:

Digital transport policies: The proposal complements the work done in the context of

the ITS Directive which establishes a framework for the deployment of Intelligent

Transport Systems in the road sector and its interfaces with other modes of transport.

Under the Delegated Regulation on multimodal travel information services

(MMTIS), Member States must establish national access points constituting a single

point of access for data users to the static, historic, observed and dynamic travel and

traffic data of different transport modes, for the purpose of providing multimodal

travel information services. Developing MDMS capable of reservations, bookings, or

ticketing however re-quires additional data (e.g. real-time fares).

Horizontal data policies: To complement the general principles of the Digital

Markets Act in relation to MDMS, sectorial measures are considered in the MDMS

proposal to enhance transparent consumer information for transport options. The

MDMS proposal is complementary to the Digital Services Act (DSA) provisions as it

also supports a safe, predictable, and trusted online environment. The Data Act (DA)

has synergies with the MDMS proposal, through harmonised rules on data sharing

including rules on Business to Government (B2G) data sharing and rules on unfair

contractual agreement terms.

Commercial practices policies: The Platform to Business (P2B) Regulation is

applicable to business-to-consumer (B2C) MDMS in the EU and imposes

transparency obligations on the parameters used for ranking. The revised Directive

38 Regulation (EC) No 2299/89 of the European Parliament and of the Council of 24 July 1989 on a code

of conduct for computerized reservation systems (OJ L 220, 29.7.1989, p.1, ELI:

http://data.europa.eu/eli/reg/1989/2299/oj).

EN 31 EN

on Unfair Commercial Practices prohibits undisclosed advertising and paid

promotion for higher ranking of products within search results on MDMS. The

MDMS proposal complements these acts with measures that ensure that search

results on MDMS are displayed in a neutral way (setting out a list of mandatory

ranking criteria and indicating which criterion was used for display), prohibit self-

preferencing and paid prominence, allowing advertised content only under certain

conditions.

Other initiatives: The CountEmissionsEU and Flight Emission Label initiatives set

out a common framework to calculate and report transport-related greenhouse gas

emissions. Transparent information applied across modes will enable passengers to

choose the most sustainable options for their trips.

1.5.5. Assessment of the different available financing options, including scope for

redeployment

The recurrent adjustment costs for the European Commission are related to the

requirement for the European Commission to designate B2C MDMS with SMP at

EU-level. This is assumed to require 2 FTE per year from 2028 onwards.

1.6. Duration of the proposal/initiative and of its financial impact

☐ limited duration

☐ in effect from [DD.MM]YYYY to [DD.MM]YYYY

☐ financial impact from YYYY to YYYY for commitment appropriations

and from YYYY to YYYY for payment appropriations.

☑ unlimited duration

Implementation with a start-up period from YYYY to YYYY,

followed by full-scale operation.

1.7. Method(s) of budget implementation planned39

☑ Direct management by the Commission

☑ by its departments, including by its staff in the Union delegations;

☐ by the executive agencies

☐ Shared management with the Member States

☐ Indirect management by entrusting budget implementation tasks to:

☐ third countries or the bodies they have designated;

☐ international organisations and their agencies (to be specified);

☐ the European Investment Bank and the European Investment Fund;

☐ bodies referred to in Articles 70 and 71 of the Financial Regulation;

☐ public law bodies;

39 Details of budget implementation methods and references to the Financial Regulation may be found on

the BUDGpedia site: https://myintracomm.ec.europa.eu/corp/budget/financial-rules/budget-

implementation/Pages/implementation-methods.aspx.

EN 32 EN

☐ bodies governed by private law with a public service mission to the

extent that they are provided with adequate financial guarantees;

☐ bodies governed by the private law of a Member State that are entrusted

with the implementation of a public-private partnership and that are

provided with adequate financial guarantees;

☐ bodies or persons entrusted with the implementation of specific actions in

the common foreign and security policy pursuant to Title V of the Treaty

on European Union, and identified in the relevant basic act

☐ bodies established in a Member State, governed by the private law of a

Member State or Union law and eligible to be entrusted, in accordance

with sector-specific rules, with the implementation of Union funds or

budgetary guarantees, to the extent that such bodies are controlled by

public law bodies or by bodies governed by private law with a public

service mission, and are provided with adequate financial guarantees in

the form of joint and several liability by the controlling bodies or

equivalent financial guarantees and which may be, for each action,

limited to the maximum amount of the Union support.

Comments

[...]

2. MANAGEMENT MEASURES

2.1. Monitoring and reporting rules

The proposed measure is focused on policy action and monitoring and does not

foresee any revenue or expenditure management, only the recruitment of additional

human resources (2 FTE).

2.2. Management and control system(s)

2.2.1. Justification of the budget implementation method(s), the funding implementation

mechanism(s), the payment modalities and the control strategy proposed

The expenditure corresponding to these contracts will be managed in line with

corporate processes.

2.2.2. Information concerning the risks identified and the internal control system(s) set up

to mitigate them

The Commission applies thorough controls on the management of employment

contracts and DG MOVE abides by strict ethical standards. The legislative proposal

does not entail any revenue collection and does not require any additional control

mechanism.

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between

the control costs and the value of the related funds managed), and assessment of the

expected levels of risk of error (at payment & at closure)

The overall risk of errors is expected to be very low and is already covered by the

existing control environment. No automated controls are expected to be required.

2.3. Measures to prevent fraud and irregularities

The legislative proposal does not entail any revenue collection by DG MOVE.

Regarding the expenditures, they are foreseen for the hiring of additional human

EN 33 EN

resources. The risk of fraud and irregularities is considered very low and will be

covered by existing controls. DG MOVE revised its antifraud strategy in line with

OLAF guidelines in 2020 and plans for a subsequent update in 2026. The local

strategy includes relevant actions to ensure awareness raising on fraud prevention,

dedicated risk assessment actions and ensures an effective and efficient cooperation

with investigative bodies. The corporate framework ensures the right of access to

information, premises and staff to the external (European Court of Auditors) and

internal (IAS) auditors.

EN 34 EN

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE

3.1. Heading(s) of the multiannual financial framework and expenditure budget line(s) affected

Existing budget lines

In order of multiannual financial framework headings and budget lines.

Heading of

multiannual

financial

framework

Budget line Type of

expenditure Contribution

Number Diff./Non-diff. 40 from EFTA

countries 41

from candidate

countries and

potential

candidates 42

from other third

countries

other assigned

revenue

4

Budget line will

be available once

we have the new

MFF budget

structure

Non-diff. NO NO NO NO

New budget lines requested

In order of multiannual financial framework headings and budget lines.

3.2. Estimated financial impact of the proposal on appropriations

3.2.1. Summary of estimated impact on operational appropriations

☑ The proposal/initiative does not require the use of operational appropriations

☐ The proposal/initiative requires the use of operational appropriations, as explained below:

40 Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. 41 EFTA: European Free Trade Association. 42 Candidate countries and, where applicable, potential candidates from the Western Balkans.

EN 35 EN

3.2.1.1. Appropriations from voted budget

EUR million (to three decimal places)

Heading of multiannual financial framework43

DG: MOVE Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034

TOTAL MFF

2028-2034

Operational appropriations

Budget line Commitments (1a) 0.000

Payments (2a) 0.000

Budget line Commitments (1b) 0.000

Payments (2b) 0.000

Appropriations of an administrative nature financed from the envelope of specific programmes 44

Budget line (3) 0.000

TOTAL

appropriations for

DG <.......>

Commitments =1a+1b+3 0.000 0.000 0.000 0.000 0.000

Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

43 The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage. 44 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 36 EN

Operational appropriations

Budget line Commitments (1a) 0.000

Payments (2a) 0.000

Budget line Commitments (1b) 0.000

Payments (2b) 0.000

Appropriations of an administrative nature financed from the envelope of specific programmes 45

Budget line (3) 0.000

TOTAL appropriations for DG

<.......>

Commitments =1a+1b+3 0.000 0.000 0.000 0.000 0.000

Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

TOTAL operational appropriations Commitments (4) 0.000 0.000 0.000 0.000 0.000

Payments (5) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations of an administrative nature

financed from the envelope for specific programmes (6) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations under Commitments =4+6 0.000 0.000 0.000 0.000 0.000

45 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 37 EN

HEADING <....>

of the multiannual financial framework Payments =5+6 0.000 0.000 0.000 0.000 0.000

Heading of multiannual financial framework Number

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Operational appropriations

Budget line Commitments (1a) 0.000

Payments (2a) 0.000

Budget line Commitments (1b) 0.000

Payments (2b) 0.000

Appropriations of an administrative nature financed from the envelope of specific programmes 46

Budget line (3) 0.000

TOTAL appropriations for DG

<.......>

Commitments =1a+1b +3 0.000 0.000 0.000 0.000 0.000

Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Operational appropriations

46 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 38 EN

Budget line Commitments (1a) 0.000

Payments (2a) 0.000

Budget line Commitments (1b) 0.000

Payments (2b) 0.000

Appropriations of an administrative nature financed from the envelope of specific programmes 47

Budget line (3) 0.000

TOTAL appropriations for DG

<.......>

Commitments =1a+1b +3 0.000 0.000 0.000 0.000 0.000

Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

TOTAL operational appropriations Commitments (4) 0.000 0.000 0.000 0.000 0.000

Payments (5) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations of an administrative nature

financed from the envelope for specific programmes (6) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations

under HEADING <....>

of the multiannual financial framework

Commitments =4+6 0.000 0.000 0.000 0.000 0.000

Payments =5+6 0.000 0.000 0.000 0.000 0.000

47 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 39 EN

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

TOTAL operational appropriations (all

operational headings)

Commitments (4) 0.000 0.000 0.000 0.000 0.000

Payments (5) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations of an administrative nature

financed from the envelope for specific programmes (all

operational headings)

(6) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations

Under Heading 1 to 3

of the multiannual financial framework

(Reference amount)

Commitments =4+6 0.000 0.000 0.000 0.000 0.000

Payments =5+6 0.000 0.000 0.000 0.000 0.000

Heading of multiannual financial

framework 4 ‘Administrative expenditure’ 48

DG: MOVE Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034

Total MFF

2028-2034

Human resources 0.388 0.388 0.388 0.388 0.388 0.388 0.388 2.716

Other administrative expenditure 0.010 0.010 0.010 0.010 0.010 0.010 0.010 0.07

TOTAL DG MOVE Appropriations 0.398 0.398 0.398 0.398 0.398 0.398 0.398 2.786

TOTAL appropriations under HEADING 4 of the

multiannual financial framework

(Total commitments =

Total payments) 0.398 0.398 0.398 0.398 2.786

48 The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage.

EN 40 EN

EUR million (to three decimal places)

Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034

TOTAL MFF

2028-2034

TOTAL appropriations under

HEADINGS 1 to 4

of the multiannual financial

framework

Commitments 0.398 0.398 0.398 0.398 0.398 0.398 0.398 2.786

Payments 0.398 0.398 0.398 0.398 0.398 0.398 0.398 2.786

3.2.1.2. Appropriations from external assigned revenues

EUR million (to three decimal places)

Heading of multiannual financial framework Number

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Operational appropriations

Budget line Commitments (1a) 0.000

Payments (2a) 0.000

Budget line Commitments (1b) 0.000

Payments (2b) 0.000

Appropriations of an administrative nature financed from the envelope of specific programmes 49

49 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 41 EN

Budget line (3) 0.000

TOTAL appropriations

for DG <.......>

Commitments =1a+1b+3 0.000 0.000 0.000 0.000 0.000

Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Operational appropriations

Budget line Commitments (1a) 0.000

Payments (2a) 0.000

Budget line Commitments (1b) 0.000

Payments (2b) 0.000

Appropriations of an administrative nature financed from the envelope of specific programmes 50

Budget line (3) 0.000

TOTAL appropriations

for DG <.......>

Commitments =1a+1b+3 0.000 0.000 0.000 0.000 0.000

Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

50 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 42 EN

TOTAL operational appropriations Commitments (4) 0.000 0.000 0.000 0.000 0.000

Payments (5) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations of an administrative nature financed from

the envelope for specific programmes (6) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations

under HEADING <....>

of the multiannual financial framework

Commitments =4+6 0.000 0.000 0.000 0.000 0.000

Payments =5+6 0.000 0.000 0.000 0.000 0.000

Heading of multiannual financial framework Number

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Operational appropriations

Budget line Commitments (1a) 0.000

Payments (2a) 0.000

Budget line Commitments (1b) 0.000

Payments (2b) 0.000

Appropriations of an administrative nature financed from the envelope of specific programmes 51

Budget line (3) 0.000

51 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 43 EN

TOTAL appropriations

for DG <.......>

Commitments =1a+1b+3 0.000 0.000 0.000 0.000 0.000

Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Operational appropriations

Budget line Commitments (1a) 0.000

Payments (2a) 0.000

Budget line Commitments (1b) 0.000

Payments (2b) 0.000

Appropriations of an administrative nature financed from the envelope of specific programmes52

Budget line (3) 0.000

TOTAL appropriations

for DG <.......>

Commitments =1a+1b+3 0.000 0.000 0.000 0.000 0.000

Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

TOTAL operational appropriations Commitments (4) 0.000 0.000 0.000 0.000 0.000

52 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former 'BA' lines), indirect research,

direct research.

EN 44 EN

Payments (5) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations of an administrative nature financed from

the envelope for specific programmes (6) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations

under HEADING <....>

of the multiannual financial framework

Commitments =4+6 0.000 0.000 0.000 0.000 0.000

Payments =5+6 0.000 0.000 0.000 0.000 0.000

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

TOTAL operational appropriations (all

operational headings)

Commitments (4) 0.000 0.000 0.000 0.000 0.000

Payments (5) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations of an administrative nature financed from

the envelope for specific programmes (all operational headings) (6) 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations under Headings 1

to 6

of the multiannual financial framework

(Reference amount)

Commitments =4+6 0.000 0.000 0.000 0.000 0.000

Payments =5+6 0.000 0.000 0.000 0.000 0.000

Heading of multiannual financial framework 4 ‘Administrative expenditure’ 53

EUR million (to three decimal places)

DG: MOVE Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034

TOTAL MFF

2028-2034

53 The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage.

EN 45 EN

Human resources 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

Other administrative expenditure 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

TOTAL Appropriations 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

DG: <.......> Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

Human resources 0.000 0.000 0.000 0.000 0.000

Other administrative expenditure 0.000 0.000 0.000 0.000 0.000

TOTAL DG <.......> Appropriations 0.000 0.000 0.000 0.000 0.000

TOTAL appropriations under HEADING 4 of the

multiannual financial framework

(Total commitments =

Total payments) 0.000 0.000 0.000 0.000

EUR million (to three decimal places)

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

TOTAL appropriations under HEADINGS 1 to 7

of the multiannual financial framework

Commitments 0.000 0.000 0.000 0.000 0.000

Payments 0.000 0.000 0.000 0.000 0.000

3.2.2. Estimated output funded from operational appropriations (not to be completed for decentralised agencies)

Commitment appropriations in EUR million (to three decimal places)

Indi

cate

obje

Year

2024

Year

2025

Year

2026

Year

2027

Enter as many years as necessary to

show

the duration of the impact (see Section

TOTAL

EN 46 EN

ctive

s

and

outp

uts

⇓

1.6)

OUTPUTS

Typ

e 54

Aver

age

cost

No Cost No Cost No Cost No Cost No Cost No Cost No Cost

Tota

l

No

Tota

l

Cost

SPECIFIC

OBJECTIVE No 1 55: [...]

-

Outp

ut

-

Outp

ut

-

Outp

ut

Subtotal for

specific objective

No 1

SPECIFIC

OBJECTIVE No 2

54 Outputs are products and services to be supplied (e.g.: number of student exchanges financed, number of km of roads built, etc.). 55 As described in point 1.4.2. 'Specific objective(s)...'

EN 47 EN

-

Outp

ut

Subtotal for

specific objective

No 2

TOTALS

3.2.3. Summary of estimated impact on administrative appropriations

☑ The proposal/initiative does not require the use of appropriations of an administrative nature

☐ The proposal/initiative requires the use of appropriations of an administrative nature, as explained below:

3.2.3.1. Appropriations from voted budget

VOTED APPROPRIATIONS Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034

TOTAL

MFF

2028-2034

HEADING 4

Human resources 0.388 0.388 0.388 0.388 0.388 0.388 0.388 2.716

Other administrative expenditure 0.010 0.010 0.010 0.010 0.010 0.010 0.010 0.070

Subtotal HEADING 4 0.398 0.398 0.398 0.398 0.398 0.398 0.398 2.786

Outside HEADING 4

Human resources 0.000 0.000 0.000 0.000 0.000

EN 48 EN

Other expenditure of an administrative nature 0.000 0.000 0.000 0.000 0.000

Subtotal outside HEADING 4 0.000 0.000 0.000 0.000 0.000

TOTAL 0.398 0.398 0.398 0.398 0.398 0.398 0.398 2.786

Staff required to implement the proposal: 2 FTE. The

estimated impact on expenditure and staffing for 2028

and beyond is added for illustrative purposes only and

does not pre-judge the next Multiannual Financial

Framework. The source of financing and scope of

Union financial commitment in the post-2027 period

remain subject to the outcome of interinstitutional

negotiations on the MFF 2028-2034 and thereafter

shall be determined through the annual budgetary

procedure. All appropriations and staffing allocations

as of 2028 are indicative

3.2.3.2. Appropriations from external assigned revenues

EXTERNAL ASSIGNED REVENUES Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

HEADING 7

Human resources 0.000 0.000 0.000 0.000 0.000

Other administrative expenditure 0.000 0.000 0.000 0.000 0.000

Subtotal HEADING 7 0.000 0.000 0.000 0.000 0.000

EN 49 EN

Outside HEADING 7

Human resources 0.000 0.000 0.000 0.000 0.000

Other expenditure of an administrative nature 0.000 0.000 0.000 0.000 0.000

Subtotal outside HEADING 7 0.000 0.000 0.000 0.000 0.000

TOTAL 0.000 0.000 0.000 0.000 0.000

3.2.3.3. Total appropriations

TOTAL VOTED APPROPRIATIONS

+

EXTERNAL ASSIGNED REVENUES

Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

HEADING 7

Human resources 0.000 0.000 0.000 0.000 0.000

Other administrative expenditure 0.000 0.000 0.000 0.000 0.000

Subtotal HEADING 7 0.000 0.000 0.000 0.000 0.000

Outside HEADING 7

Human resources 0.000 0.000 0.000 0.000 0.000

Other expenditure of an administrative nature 0.000 0.000 0.000 0.000 0.000

Subtotal outside HEADING 7 0.000 0.000 0.000 0.000 0.000

TOTAL 0.000 0.000 0.000 0.000 0.000

EN 50 EN

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the

next Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period

remain subject to the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the

annual budgetary procedure. All appropriations and staffing allocations as of 2028 are indicative.

.

3.2.4. Estimated requirements of human resources

☐ The proposal/initiative does not require the use of human resources

☑ The proposal/initiative requires the use of human resources, as explained below

3.2.4.1. Financed from voted budget

Estimate to be expressed in full-time equivalent units (FTEs) 56

VOTED APPROPRIATIONS Year

2028

Year

2029

Year

2030

Year

2031

Year

2032

Year

2033

Year

2034

Establishment plan posts (officials and temporary staff)

20 01 02 01 (Headquarters and Commission’s

Representation Offices) 2 2 2 2 2 2 2

20 01 02 03 (EU Delegations) 0 0 0 0 0 0 0

01 01 01 01 (Indirect research) 0 0 0 0 0 0 0

01 01 01 11 (Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) 0 0 0 0 0 0 0

56 Please specify below the table how many FTEs within the number indicated are already assigned to the management of the action and/or can be redeployed within

your DG and what are your net needs.

EN 51 EN

External staff (in FTEs)

20 02 01 (AC, END from the 'global envelope') 0 0 0 0 0 0 0

20 02 03 (AC, AL, END and JPD in the EU

Delegations) 0 0 0 0 0 0 0

Admin. support line

[XX.01.YY.YY]

at Headquarters 0 0 0 0 0 0 0

in EU Delegations 0 0 0 0 0 0 0

01 01 01 02 (AC, END Indirect research) 0 0 0 0 0 0 0

01 01 01 12 (AC, END Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) Heading 7 0 0 0 0 0 0 0

Other budget lines (specify) Outside Heading 7 0 0 0 0 0 0 0

TOTAL 2 2 2 2 2 2 2

3.2.4.2. Financed from external assigned revenues

EXTERNAL ASSIGNED REVENUES Year

2024

Year

2025

Year

2026

Year

2027

Establishment plan posts (officials and temporary staff)

20 01 02 01 (Headquarters and Commission's Representation Offices) 0 0 0 0

20 01 02 03 (EU Delegations) 0 0 0 0

01 01 01 01 (Indirect research) 0 0 0 0

EN 52 EN

01 01 01 11 (Direct research) 0 0 0 0

Other budget lines (specify) 0 0 0 0

External staff (in full time equivalent units)

20 02 01 (AC, END from the global envelope) 0 0 0 0

20 02 03 (AC, AL, END and JPD in the EU Delegations) 0 0 0 0

Admin. support line

[XX.01.YY.YY]

- at Headquarters 0 0 0 0

- in EU Delegations 0 0 0 0

01 01 01 02 (AC, END - Indirect research) 0 0 0 0

01 01 01 12 (AC, END - Direct research) 0 0 0 0

Other budget lines (specify) - Heading 7 0 0 0 0

Other budget lines (specify) - Outside Heading 7 0 0 0 0

TOTAL 0 0 0 0

3.2.4.3. Total requirements of human resources

TOTAL VOTED APPROPRIATIONS

+

EXTERNAL ASSIGNED REVENUES

Year

2024

Year

2025

Year

2026

Year

2027

Establishment plan posts (officials and temporary staff)

20 01 02 01 (Headquarters and Commission's Representation Offices) 0 0 0 0

EN 53 EN

20 01 02 03 (EU Delegations) 0 0 0 0

01 01 01 01 (Indirect research) 0 0 0 0

01 01 01 11 (Direct research) 0 0 0 0

Other budget lines (specify) 0 0 0 0

External staff (in full time equivalent units)

20 02 01 (AC, END from the global envelope) 0 0 0 0

20 02 03 (AC, AL, END and JPD in the EU Delegations) 0 0 0 0

Admin. support line

[XX.01.YY.YY]

- at Headquarters 0 0 0 0

- in EU Delegations 0 0 0 0

01 01 01 02 (AC, END - Indirect research) 0 0 0 0

01 01 01 12 (AC, END - Direct research) 0 0 0 0

Other budget lines (specify) - Heading 7 0 0 0 0

Other budget lines (specify) - Outside Heading 7 0 0 0 0

TOTAL 0 0 0 0

The staff required to implement the proposal (in FTEs):

To be covered by current

staff available in the

Commission services

Exceptional additional staff*

EN 54 EN

To be financed under

Heading 4 or Research

To be financed from BA

line

To be financed from

fees

Establishment plan

posts 2 N/A 0

External staff (CA,

SNEs, INT) 0 0 0

Description of tasks to be carried out by:

Officials

and

temporar

y staff

The additional work on implementing the Regulation, will require an internal redeployment of 2 establishment posts as

from the adoption of the Regulation.

The additional work relates to:

1) Designation of B2C MDMS with significant market presence (SMP) at EU level: The Regulation introduces a

requirement for the EC to designate B2C MDMS with SMP at EU level – this will require EC to deal with notifications

received from services providers, monitor developments and monitor the market to ensure that all relevant service providers

notify. EC might also need to deal with complaints/further investigations related to the designation process. Over time, EC

will need to monitor developments and manage the list of designated entities (with potential additions or removals from the

list).

2) Designation of B2C MDMS with significant market presence (SMP) at national level: this will be handled by national

enforcement authorities, however, EC must verify notifications from Member States, coordinate with national enforcement

bodies, publish and update dynamic lists on EC website, all while ensuring compliance with strict deadlines. The multi-

layered notification and designation processes at both EU and national levels, requiring real-time oversight.

The recurrent burden of assessing notification received, monitoring the EU MDMS market and potentially processing

removal requests demands dedicated capacity. Two FTE are therefore foreseen to streamline coordination, reduce delays in

designations, and maintain an accurate, up-to-date public register, ensuring market transparency and effective enforcement

under the new regulatory framework. Given the required very specialised knowledge and the combination of competences

(specialised competition background combined with legal drafting skills), the needs could be fulfilled by 2 AD post.

EN 55 EN

External

staff

3.2.5. Overview of estimated impact on digital technology-related investments

Compulsory: the best estimate of the digital technology-related investments entailed by the proposal/initiative should be included in the

table below.

Exceptionally, when required for the implementation of the proposal/initiative, the appropriations under Heading 7 should be presented

in the designated line.

The appropriations under Headings 1-6 should be reflected as "Policy IT expenditure on operational programmes". This expenditure

refers to the operational budget to be used to re-use/ buy/ develop IT platforms/ tools directly linked to the implementation of the

initiative and their associated investments (e.g. licences, studies, data storage etc). The information provided in this table should be

consistent with details presented under Section 4 "Digital dimensions".

TOTAL Digital and IT appropriations Year

2024

Year

2025

Year

2026

Year

2027

TOTAL MFF

2021-2027

HEADING 7

IT expenditure (corporate) 0.000 0.000 0.000 0.000 0.000

Subtotal HEADING 7 0.000 0.000 0.000 0.000 0.000

Outside HEADING 7

Policy IT expenditure on operational programmes 0.000 0.000 0.000 0.000 0.000

Subtotal outside HEADING 7 0.000 0.000 0.000 0.000 0.000

TOTAL 0.000 0.000 0.000 0.000 0.000

EN 56 EN

3.2.6. Compatibility with the current multiannual financial framework

The proposal/initiative:

☑ can be fully financed through redeployment within the relevant heading of the multiannual financial framework (MFF).

☐ requires use of the unallocated margin under the relevant heading of the MFF and/or use of the special instruments as defined in

the MFF Regulation.

☐ requires a revision of the MFF.

3.2.7. Third-party contributions

The proposal/initiative:

☑ does not provide for co-financing by third parties

☐ provides for the co-financing by third parties estimated below:

Appropriations in EUR million (to three decimal places)

Year

2024

Year

2025

Year

2026

Year

2027 Total

Specify the co-financing body

TOTAL appropriations co-financed

3.3. Estimated impact on revenue

☑ The proposal/initiative has no financial impact on revenue.

☐ The proposal/initiative has the following financial impact:

☐ on own resources

☐ on other revenue

☐ please indicate, if the revenue is assigned to expenditure lines

EN 57 EN

EUR million (to three decimal places)

Budget revenue line: Appropriations available for the current financial year

Impact of the proposal/initiative57

Year

2024

Year

2025

Year

2026

Year

2027

Article

For assigned revenue, specify the budget expenditure line(s) affected.

[...]

Other remarks (e.g. method/formula used for calculating the impact on revenue or any other information).

[...]

4. DIGITAL DIMENSIONS

4.1. Requirements of digital relevance

Otherwise, please list the requirements of digital relevance in the table below:

Reference to

the

requirement

Requirement description

Actor(s) affected

or concerned by

the requirement

High-level

Processes Categories

Article 4

B2C MDMS provider shall share data on the number of tickets

sold per mode and their value with EC (for EU data) and

national enforcement authorities (for national data).

B2C MDMS

European

Commission

National

Enforcement

Authorities

Reporting

obligation

Data

Digital public

service

57 As regards traditional own resources (customs duties, sugar levies), the amounts indicated must be net amounts, i.e. gross amounts after deduction of 20% for

collection costs.

EN 58 EN

Article 6

Commercial agreements between B2B MDMS providers and

business suers shall not intentionally or otherwise: (a) prevent a

business user from subscribing to or using any other similar

system, (b) require the acceptance of additional conditions to be

accepted which are not necessary for the subscription to the

B2B MDMS, (c) impose an obligation to accept specific

technical equipment or software, and (d) impose any other

unfair or unjustified conditions.

B2B MDMS n.a

Data,

Commercial

agreement

Article 7

B2C and B2B MDMS providers shall load and process data of

operators with equal care and shall display transport products of

operators in a neutral and comprehensive manner. Article 7 sets

out the criteria for the default ranking of transport products and

other functionalities of the MDMS.

B2C and B2B

MDMS

Data

processing and

publication

Data

Digital public

service

Digital

Solution

Article 8

Article 8 sets out requirements for the marketing, booking and

sales data provided by B2C MDMS and B2B MDMS providers

to participating transport operators.

B2C and B2B

MDMS

Data

processing and

publication

Data

Digital public

service

Article 9

Article 9 sets out the requirements related to the information on

greenhouse gas emissions and carbon dioxide equivalent

emissions.

B2C and B2B

MDMS

Disclosure of

information

Data

Digital public

service

Digital

solution

Article 10 Article 10 sets out the requirements for the B2C MDMS

sharing of data with public transport authorities. B2C MDMS

Statistics

Reporting

obligations

Data

Article 12 Where the national enforcement body requests to receive National Policy Data

EN 59 EN

relevant information, it shall be presented without undue delay

and, in any event, within one month from the receipt of the

request.

Enforcement

Bodies

B2C MDMS

monitoring and

enforcement

Article 12

Cooperation between national enforcement bodies of Member

States to ensure a coherent enforcement of this Regulation,

mutual assistance in market monitoring tasks and complaint

handling, including through the exchange of relevant

information by electronic means while duly respecting the

confidentiality of commercially sensitive data.

National

Enforcement

Bodies

Policy

monitoring and

enforcement

Data

Digital Public

Service

Article 12

The national enforcement bodies shall participate in a network

that convenes regularly, and at least once a year, to exchange

information in particular on their (i) monitoring, enforcement

and implementation work, (ii) decision-making principles; and

(iii) administrative practices.

National

Enforcement

Bodies

B2C MDMS

Policy

monitoring and

enforcement

Data

4.2. Data

High-level description of the data in scope and any related standards/specifications

Type of data Reference to the requirement(s) Standard and/or specification (if

applicable)

Data on the number of tickets sold per

mode and their value Article 4 n.a

Operators’ data Article 7 n.a

Marketing, booking and sales data Article 8 n.a

Data on greenhouse gas emissions or

carbon dioxide equivalent emissions of the Article 9

CountEmissionsEU and Flight Emission

Label standards

EN 60 EN

transport products

Data which may be used to improve the

effectiveness of public transport policies

and sustainable mobility

Article 10 n.a

Monitoring and enforcement data

(information about the thresholds) Article 12 n.a

Monitoring and enforcement data (in

particular as regards disputes between

parties) between authorities

Article 12 n.a

Alignment with the European Data Strategy

The conditions for commercial agreements between transport operators and B2C MDMS providers with significant market presence or

B2B MDMS providers from Article 5 and Article 6 are mitigating the abuse of contractual imbalances, in line with the DMA.

Alignment with the once-only principle

Any B2C MDMS provider vertically integrated with a railway undertaking designated as having significant railway market presence

pursuant to the proposal on rail ticketing shall be designated as a B2C MDMS provider with significant railway market presence at

national level and shall not be required to notify the national enforcement body referred to in Article 13 of the Member State in which

the railway undertaking is designated as having significant railway market presence.

For the purposes of assessing whether the thresholds laid down in Annex I are met, the designating authority may request B2C MDMS

providers to submit all relevant information within a reasonable timeframe, and at the latest within two months. An already designated

B2C MDMS provider with significant market presence shall not be subject to such information requests for the transport mode in which

it has been designated. B2C MDMS providers which do not submit within the set timeframe the requested information on their

significant market presence, may be designated without undue delay, based on information available to the designating authority.

Explain how newly created data is findable, accessible, interoperable and reusable, and meets high-quality standards

Data on indispensable B2C MDMS will be published on the Commission website.

Data flows

For each data flow, please fill the table below:

EN 61 EN

Type of data Reference(s) to the

requirement(s)

Actor who

provides the

Actor who receives

the data

Trigger for the

data exchange

Frequency (if

applicable)

Data on the number

of tickets sold per

mode and their

value

Article 4 B2C MDMS

European

Commission,

National

Enforcement Bodies

Obligation under

Art.4/ request from

EC or a NEB.

Yearly

Operators’ data Article 7 Transport operator B2C and B2B

MDMS

Agreement for the

display/ distribution

of transport tickets

n.a

Marketing, booking

and sales data Article 8 B2B MDMS Transport operators

Request from a

transport operator n.a

Data on greenhouse

gas emissions or

carbon dioxide

equivalent

emissions of the

transport products

Article 9 Transport operators B2C and B2B

MDMS

Willingness of the

transport operator to

share that data.

n.a

Data which may be

used to improve the

effectiveness of

public transport

policies and

sustainable mobility

Article 10 B2C MDMS ad

B2B MDMS

Public transport

authorities

Request from a

public transport

authority

n.a

Monitoring and

enforcement data

(information about

Article 12

National

Enforcement Body/

Member States

European

Commission

Change in the list of

B2C MDMS with

SMP

n.a

EN 62 EN

the thresholds)

Monitoring and

enforcement data (in

particular as regards

disputes between

parties) between

authorities

Article 13 National

Enforcement Body

National

Enforcement Body

EU Network for

National

Enforcement

Bodies meetings.

At least once a year

4.3. For each digital solution, please provide the reference to the requirement(s) of digital relevance concerning it, a description of the

digital solution's mandated functionality, the body that will be responsible for it, and other relevant aspects such as reusability and

accessibility. Finally, explain whether the digital solution intends to make use of AI technologies.

Digital

solution

Reference(s) to

the

requirement(s)

Main mandated

functionalities

Responsible

body

How is accessibility

catered for?

How is reusability

considered?

Use of AI

technologies

(if

applicable)

MDMS Article 7

Article 9

B2C and B2B MDMS

providers shall load and

process data of operators

with equal care and shall

display transport products

of operators in a neutral

and comprehensive

manner.

Clear, transparent and

accessible information on

the greenhouse gas

emissions or carbon

dioxide equivalent

emissions of the transport

products displayed shall

B2C MDMS

providers

B2B MDMS

providers

When displaying

information, B2C

MDMS providers

should respect the

requirements set in

Directive (EU)

2019/882 of the

European Parliament

and of the Council on

the accessibility for

products and services,

and in particular offer

audio-visual options.

The proposal acts in

synergy with other of

EU legislation

affecting digital

information services,

and in particular the

ITS Directive which

establishes a

framework for the

deployment of

Intelligent Transport

Systems in the road

sector and its

interfaces with other

modes of transport.

n.a.

EN 63 EN

be provided by the B2C

MDMS providers to end

users and by B2B MDMS

providers to business

users, whenever such

information is shared by

transport operators.

For each digital solution, explain how the digital solution complies with the requirements and obligations of the EU cybersecurity

framework, and other applicable digital policies and legislative enactments (such as eIDAS, Single Digital Gateway, etc.).

Digital solution #1: MDMS

Digital and/or sectorial policy

(when these are applicable) Explanation on how it aligns

AI Act n.a.

EU Cybersecurity framework n.a

eIDAS n.a

Single Digital Gateway and IMI n.a

Others n.a

Digital solution #2

Digital and/or sectorial policy

(when these are applicable) Explanation on how it aligns

AI Act

EU Cybersecurity framework

EN 64 EN

eIDAS

Single Digital Gateway and IMI

Others

4.4. Interoperability assessment

Describe the digital public service(s) affected by the requirements

Digital public

service or

category of digital

public services

Description

Reference(s) to

the

requirement(s)

Interoperable

Europe

Solution(s)

Other

interoperability

solution(s)

Designation of

B2C MDMS

providers with

significant market

presence

An MDMS provider shall be designated as B2C

MDMS provider with significant market power for

the distribution of transport products for that

transport mode (‘significant market presence’) at

Union level if it meets the thresholds laid down in

point 1 of Annex I. It shall notify the Commission

thereof and provide information on the number of

tickets sold per mode and their value.

Article 4 n.a. n.a.

Assess the impact of the requirement(s) on cross-border interoperability

Digital public service #1

Assessment Measure(s) Potential remaining barriers (if applicable)

Alignment with

existing digital and

sectorial policies.

The proposal is coordinated with the proposal on rail

ticketing and the proposed revision of the Rail Passenger

Rights Regulation, to create a consistent framework that

promotes rail single tickets and an ensures good

n.a.

EN 65 EN

functioning of the online ticketing market. The proposal

repeals Regulation (EC) No 80/2009 on a Code of

Conduct for Computerised Reservation Systems (‘CRS

Code of Conduct’), whilst updating and integrating the

provisions of that text that remain relevant. The proposal

acts in synergy with other of EU legislation affecting

digital information services, and in particular the ITS

Directive which establishes a framework for the

deployment of Intelligent Transport Systems in the road

sector and its interfaces with other modes of transport.

Under the Delegated Regulation on multimodal travel

information services (MMTIS) Member States must

establish national access points constituting a single point

of access for data users to the static, historic, observed and

dynamic travel and traffic data of different transport

modes, for the purpose of providing multimodal travel

information services. Addressing the barriers for the

development of MDMS capable of reservations, bookings,

or ticketing therefore complements this existing set of

legislation. Further, this proposal will complement the

general principles of the Digital Markets Act and the Data

Act by setting sectorial measures in relation to MDMS.

The proposal will also complement the revised Directive

on Unfair Commercial Practices with measures that ensure

that search results on MDMS are displayed in a neutral

way (setting out a list of mandatory ranking criteria and

indicating which criterion was used for display), prohibit

self-preferencing and paid prominence, allowing

advertised content only under certain conditions.

This proposal aims to promote a more multimodal and

sustainable transport system and contribute to the

objectives of the European Green Deal. By requiring that

EN 66 EN

MDMS display information on greenhouse gas emissions

and CO2 emissions, this proposal will also contribute to

the objectives of the CountEmissionsEU and Flight

Emission Label initiatives, setting out a common

framework to calculate and report transport-related

greenhouse gas emissions.

Organisational

measures for a smooth

cross-border digital

public services

delivery.

The Regulation stipulates that each Member State shall

designate a national enforcement body responsible for the

enforcement of this Regulation. Member States shall

ensure that the designated body is provided with the

necessary administrative and financial resources and has

the expertise needed to adequately carry out the tasks

under this Regulation. Article 12 describes the tasks of the

national enforcement bodies, including the mutual

assistance in market monitoring tasks and complaint

handling.

n.a

Measures taken to

ensure a shared

understanding of the

data.

The information on the greenhouse gas emissions or

carbon dioxide equivalent emissions shall be provided in

accordance with Commission Implementing Regulation

(EU) 2024/3170.

Article 7 sets neutral display and ranking criteria

obligations for all MDMS providers.

It is important that digital aspects of the

information exchange are clearly defined in the

implementation of the Regulation, in the

context of complaints management and sharing

of data with public authorities.

Use of commonly

agreed open technical

specifications and

standards.

The information on the greenhouse gas emissions or

carbon dioxide equivalent emissions shall be provided in

accordance with Commission Implementing Regulation

(EU) 2024/3170.

Article 7 sets neutral display and ranking criteria

obligations for all MDMS providers.

It is important that digital aspects of the

information exchange are clearly defined in the

implementation of the Regulation, in the

context of complaints management and sharing

of data with public authorities.

EN 67 EN

4.5. Measures to support digital implementation

For each measure to support digital implementation, please fill in the table below

Description

of the

measure

Reference(s) to the requirement(s) Commission role (if applicable)

Actors to be

involved (if

applicable)

Expected

timeline (if

applicable)

Requirement 7

The national enforcement bodies shall

participate in a network that convenes

regularly to exchange information in

particular on their (i) monitoring,

enforcement and implementation work, (ii)

decision-making principles; and (iii)

administrative practices.

The Commission services shall

participate in the discussions

within the network, and coordinate

and support the cooperation on

matters of common interest and the

exchange of best practices.

National

enforcement

bodies/ European

Commission

At least once

a year

EN EN

EUROPEAN COMMISSION

Brussels, 13.5.2026

COM(2026) 231 final

ANNEX 1

ANNEX

to the

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on multimodal booking and repealing Regulation (EC) No 80/2009

{SEC(2026) 300 final} - {SWD(2026) 300 final} - {SWD(2026) 301 final}

EN 1 EN

Annex I

Thresholds for the designation of B2C MDMS providers with significant market

presence

1. A B2C MDMS provider shall be considered to have a significant market presence in

the Union if it has sold in the Union during the last financial year, for one of the

transport modes in which it provides distribution services, at least:

(a) for air transport, 53.5 million products or products whose total value was of 6

394;

(b) for rail transport, 203 million rail products or products whose total value was 3

832 million EUR;

(c) for bus and coach transport, 318 million products or products whose total value

was 18 071 million EUR;

(d) for waterborne transport, 45 million products or products whose total value was

792 million EUR.

EN 2 EN

2. A B2C MDMS provider shall be considered to have a significant market presence in a Member State if it has reached in that Member

State, within the last financial year, for one of the transport modes in which it provides distribution services one of the two thresholds set

out in Table 1.

Member

States

Rail transport

products

Bus and coach transport

products

Waterborne transport

products

Transport

products sold

annually (in )

Value of

transport

products

sold

annually

(in

millions

of EUR)

Transport

products

sold

annually

(in )

Value of

transport

products

sold

annually

(in

millions

of EUR)

Transport

products

sold

annually

(in )

Value of

transport

products sold

annually (in

millions of

EUR)

Transport

products sold

annually (in )

Value of

transport

products sold

annually (in

millions of

EUR)

Austria 3.51 419.09 21.0 360.4 7.05 400.54 0.00 0.00

Belgium 3.31 395.16 20.5 636.4 1.80 102.26 0.30 5.22

Bulgaria 1.04 123.80 1.7 22.5 11.35 644.84 0.00 0.00

Croatia 1.19 141.63 2.2 21.8 7.60 431.78 11.20 194.73

Cyprus 1.28 152.91 0.00 0.00 2.70 153.40 0.00 0.00

Czechia 1.86 222.62 10.2 188 34.75 1947.28 0.00 0.00

Denmark 3.65 436.05 10.9 165.1 14.00 795.39 13.20 229.50

Estonia 0.29 34.17 0.8 12.4 4.70 267.02 4.25 73.89

Finland 2.00 239.10 5.4 52.5 11.45 650.52 5.20 90.41

EN 3 EN

France 20.58 2458.53 98.8 2392.1 75.85 4309.33 6.50 113.01

Germany 23.01 2747.83 205.2 3201.1 173.20 9840.15 9.80 170.39

Greece 7.96 951.29 1.3 38.3 34.30 1948.71 22.70 394.67

Hungary 1.77 211.66 22.5 359.4 48.50 2755.47 0.00 0.00

Ireland 4.32 516.44 5.8 95.6 10.10 573.82 0.90 15.65

Italy 22.09 2638.22 57.1 1142.8 128.45 7297.73 30.85 536.37

Latvia 0.65 77.43 1.4 9.4 4.05 230.10 0.30 5.22

Lithuania 0.65 77.52 0.5 17.4 9.70 551.09 0.00 0.00

Luxemburg 0.36 42.69 1.5 58.2 0.85 48.29 0.00 0.00

Malta 0.76 91.03 0.00 0.00 0.00 0.00 4.95 86.06

8.22 981.28 23.1 1140.4 8.45 480.08 0.85 14.78

Poland 5.93 708.01 25.4 352.9 127.40 7238.08 1.15 19.99

Portugal 7.08 845.82 13.1 205.6 25.80 1465.80 0.55 9.56

Romania 2.31 276.39 5.5 101.8 44.90 2550.94 0.00 0.00

Slovakia 0.29 35.19 2.3 40.8 7.10 403.38 0.00 0.00

Slovenia 0.16 18.77 1.4 42.8 6.95 394.86 0.00 0.00

Spain 31.76 3793.07 56.5 1174.7 135.60 7703.95 10.95 190.38

EN 4 EN

Sweden 3.42 408.15 15.3 193.9 15.85 900.50 13.05 226.89

EUROPEAN COMMISSION

13.04.2026

SEC(2026) 300

REGULATORY SCRUTINY BOARD OPINION

{COM(2026) 231}{COM(2026) 232} {SWD(2026) 300-301}

Impact assessment of Multimodal Digital Mobility Services (MDMS) and Single Digital Booking and Ticketing Regulation (SDBTR)

________________________________ Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111 [email protected]

EUROPEAN COMMISSION REGULATORY SCRUTINY BOARD

Brussels, RSB

Opinion

Title: Impact assessment of Multimodal Digital Mobility Services (MDMS) and Single Digital Booking and Ticketing Regulation (SDBTR)

Overall 2nd opinion: POSITIVE WITH RESERVATIONS

(A) Policy context The Multimodal Digital Mobility Services Regulation (MDMS) targets all digital platforms for passenger transport in waterborne, air, rail, and road, and aims at facilitating the access to information, booking or payment of travel tickets by setting rules to ensure a level playing field and fair cooperation between platforms and transport operators. The MDMS proposal includes the repeal of Regulation (EC) No 80/2009 on a Code of Conduct for Computerised Reservation Systems (‘CRS Code of Conduct’) whilst updating and integrating the provisions that remain relevant. The Single Digital Booking and Ticketing Regulation (SDBTR) targets railway undertakings (RU) and will set rules on access to rail tickets as well as access for RUs to rail ticketing platforms. The legislative proposals are part of the wider framework of EU measures aimed at achieving climate-neutrality by 2050 as set out in the European Green Deal, the Sustainable and Smart Mobility Strategy (SSMS), and the Single European Rail Area.

2

(B) Key issues The Board notes the improvements in the revised report. However, the report still contains significant shortcomings. The Board gives a positive opinion with reservations because it expects the lead Service to rectify the following aspects: (1) The report should further clarify the scope of the intervention, including on

multi-modal versus rail and the inclusion of mere transport information services versus on-line ticketing.

(2) The existence and magnitude of the alleged market failure(s) of ‘uneven playing field in the online ticketing market’ and ‘incomplete offer of rail tickets on (rail) platforms’ are not sufficiently demonstrated.

(3) The report does not take into account the limitations of the methodology for estimating the modal shift and the resulting uncertainties which drive the estimation of the benefits and the identification of the preferred option.

(4) The impact on competition and distribution of costs and benefits between different market actors is not sufficiently assessed.

(5) The assessment of the proportionality of the preferred option, including sharing and hosting obligations by ‘indispensable’ RU platforms, is not sufficient.

(C) What to improve (1) Regarding the scope of the initiative, the report should explain why platforms that do not sell tickets but only offer transport information and redirect to ticket-selling intermediaries and operators are included in the scope even though the alleged two market failures/problems of uneven playing field in the online ticketing market and incomplete offer of rail tickets on (rail) platforms are about ticketing. Based on an improved analysis of market failures (see point 2 below), the intervention logic should be reviewed to clarify how far market failure/problem 1 on ticketing relates to the wider specific objective 1 and can be addressed by policy measures 1-4 that do not specifically refer to ticketing. Throughout the report and the description of measures and options, ticket selling services and mere transportation information services should be more clearly distinguished.

(2) The report should demonstrate more clearly the evidence base for the alleged market failures and their magnitude. In view of the recent technological evolution, including artificial intelligence since the initiative was first put forward in 2023, the report should analyse to which extent these developments would facilitate a level playing field in the concerned markets with regards to transparency. (3) The report should assess to what extent the problem drivers are sufficiently exhaustive and/or to what extent drivers outside the initiative’s scope might impact the success of the initiative. (4) The analysis of unintended consequences should be significantly strengthened, including the risks that incumbent RUs would decide to move out of scope of PM14 (‘hosting obligation’) by only selling tickets of services they operate directly, thus potentially leading to the opposite than the intended effect. The additional administrative burden on undertakings and public authorities for the identification of indispensable actors

3

and the control of commercial agreements on distribution fees (PM9-12) should be enhanced in light of simplification efforts and the one-in, one-out approach. (5) While an effort was made to quantify the benefits, the expected contribution of the intervention to modal shift is based on methodology and assumptions which have limitations as they rely on stated preferences, expert judgment and opinions of stakeholders. Consequently, the benefits resulting from the estimated modal shift should not be included in the cost benefit analysis and the comparison of the options should be revised. (6) In light of the far-reaching nature of some of the measures (such as PM13, PM14, PM15), the impact on market dynamics and market power, competition and innovation should be better assessed, including on indispensable RUs, willing RUs and willing MDMS platforms. The report should detail better what the impacts are of PM13 (‘sharing obligation’) compared to PM14 (‘hosting obligation’) for incumbent RUs and how the resulting increase in costs for RUs is likely to impact the rail sector operation overall, including potential pass-through costs to consumers. It should discuss the business model underlying the sharing obligation and whether independent platforms are supposed to pay the operators for the provision of transport data or vice-versa. (7) The analysis underlying the comparison of options is insufficient for supporting the conclusion on the preferred option, especially regarding the comparison of PO2 and PO3. The report needs to sufficiently assess the relative importance of hosting on indispensable RU’s ticketing system, not least taking into account that the marginal contribution of PM13 on modal shift is substantially higher than for PM14, according to the report. The proportionality of the requirement for a company to host services for its competitors is not sufficiently demonstrated. The alignment of incentives between sellers and buyers should be further analysed. (8) The report should be clearer on the available enforcement options. If enforcement is left to national authorities, it should explain how a level playing enforcement field will be ensured and regulatory implementation fragmentation avoided. (9) Regarding coherence, the report should explain better how far the EU consumer and digital legislation – e.g. Unfair Commercial Practices Directive, Platform to Business Regulation, Data Act, Digital Services Act (DSA), Digital Markets Act (DMA), AI Act and the forthcoming Digital Fairness Act –already addresses the identified problems.

4

(D) Conclusion The lead Service may proceed with the initiative. The lead Service must revise the report and its executive summary in accordance with the Board’s findings before launching the interservice consultation.

Full title Regulation on Multimodal Digital Mobility Services (MDMS) (including revision of Regulation (EC) No 80/2009 on a Code of Conduct for Computerised Reservation Systems) and Single Digital Booking and Ticketing Regulation (SDBTR)

Reference number PLAN/2021/10509

Submitted to RSB on 11 March 2026

Date of RSB meeting Written procedure

5

EUROPEAN COMMISSION REGULATORY SCRUTINY BOARD

Brussels, RSB

Opinion

Title: Impact assessment / Multimodal Digital Mobility Services (MDMS)

Overall opinion: NEGATIVE

(A) Policy context Multimodal Digital Mobility Services (MDMS) is a legislative proposal to help develop MDMS platforms and to revise the existing Code of Conduct for Computerised Reservation System (CRS). By facilitating the access to information, booking and payment of travel tickets, MDMS aims to make it easier for travellers to choose multimodal mobility options. MDMS is part of a framework of EU measures aimed at achieving climate-neutrality by 2050.

(B) Summary of findings The Board notes the additional information provided and commitments to make changes to the report.However, the Board gives a negative opinion because the report contains the following significant shortcomings: (1) The report does not clearly set out the problem and expected contribution to the

modal shift to be achieved by the initiative, and which MDMS services will be included/excluded in its scope. It does not clearly explain the initiative’s expected impact on the behavioural change of travellers and transport operators, and its potential to tackle the underlying problem drivers.

(2) The report does not sufficiently explain the design of the options, nor the link between policy options and specific objectives. It does not clearly set out the rationale, content and functioning of key measures, including the rules on rail journey continuation, the coverage of SMEs, the designation of indispensable actors and the role of competent public authorities.

(3) The report does not adequately explain the methodological approach, the limitations of the evidence used, the underlying assumptions, and the robustness of the analytical results presented. The analysis of impacts on SMEs, competitiveness and of administrative costs under the One In, One Out approach is under- developed.

(4) When comparing the options, the report does not sufficiently reflect the limitations of the evidence base when assessing the proportionality of measures, including mandatory sales and services obligations, and selecting preferred options. It neither analyses sufficiently, nor clearly presents opposing stakeholders’ views on key

6

issues, in particular on the identified problems, their drivers and the proposed policy measures.

7

(C) What to improve (1) The report should set out a clear definition of the initiative’s scope upfront. It should clearly set out the scope of MDMS including by explaining what “competing operators” implies in practice. It should clarify upfront the scale of the problem, substantiating with evidence the untapped potential of multimodal mobility solutions under the dynamic baseline scenario and by being clear what realistically the expected contribution of the initiative could be, in the context of all current initiatives in multimodality. It should also clarify with evidence in its problem definition, the key market failures justifying EU intervention and the relative importance of the problem drivers. The report should assess to what extent these problem drivers are sufficiently exhaustive and/or to what extent other drivers are relevant for the success of the initiative (but outside the initiative’s scope). It should also better describe the relevance of each of the drivers depending on the transport mode. (2) Given the significant decrease of market share of CRSs in the distribution of tickets over the last decade, the report should substantiate with evidence their assumed continued (joint) dominance and (potential) abusive market behaviour. It should better argue why a revision of the Code of conduct for CRS is still relevant, given the market innovation and technology dynamics of the airline ticket distribution sector. Regarding the issue of rail journey continuation, the report should provide an evidence-based analysis supported by a market failure-based rationale for regulatory intervention. Given existing regulations and measures in place, the report should be clear on the size of the remaining gap, both within the same operators and across all operators, including potential developments of the rail markets. (3) The report should clarify the intervention logic, in particular, how this initiative would induce behavioural change among users of mobility services and transport operators, as well as the evidence base supporting these expectations. It should make clear how the policy options address the specific objectives. The specific objectives should be phrased in more SMART terms to better understand what the change potential of this initiative is and how “success” is defined. These objectives should be reflected in corresponding evaluation and monitoring indicators measuring the specific impacts of the measures in terms of contribution to the increased multimodality deployment and modal shift, including private road transport reduction. (4) The report should better explain the rationale, content and functioning of key policy choices. It should provide greater clarity on how ‘indispensable’ operators and MDMS have been defined and what the supporting economic analysis for choosing a single 50% national market share for all MDMS and transport modes is. It should clarify how alternative thresholds would affect the impacts of the measures. It should also describe in greater detail what the rules for rail journey continuation would look like, including how compensation fees in case of multi-operator journey continuation would be fixed. It should explain the need for all MDMS to have neutral display requirements, even if they do not have market power. The option chapter should also clarify the relevance of each of the different policy measures to SMEs and whether these might result in adjustment costs should they want to benefit from them. The report should be clearer on the available enforcement options. If enforcement is left to national authorities, it should explain how a level playing enforcement field will be ensured and regulatory implementation fragmentation avoided. (5) The report should significantly improve the explanation and presentation of the impact analysis. The impact section should explain the theory of change, evidence and assumptions used in the analysis while Annex 4 should should be clear how all parts of the analysis link

8

together, provide more detail on the approach and assumptions that underpin the ASTRA modelling and its link to the cost-benefit analysis. The report should be more transparent about the methodological limitations and uncertainties. It should be explicit on the reliability of extrapolating specific municipal level evidence to the EU level and on whether the evidence refers to specific modes of transport or specific settings such as urban transport. Given that the benefits related to reduction in external costs of road accidents are significant and drive the net benefit impact of the initiative, it should be clear what evidence underpins the estimates and how robust the analysis is. The report should provide a clear and convincing analysis explaining how the initiative will result in an expected modal shift leading to very high estimated benefits from the reduction of the number of road accidents. (6) The report should undertake further analysis employing multiple evidence sources to assess the impacts of the options and measures are on competitiveness, SMEs, competition and Member States (in their enforcement role). It should, including through a dedicated SME test, more clearly explain the impacts on SMEs. It should provide a more nuanced and comprehensive assessment of competitiveness of the affected transport and services sectors, both in the main report and in the annexed competitiveness check. It should better assess the impact on market dynamics and market power, competition and innovation, including the risk of collusive behaviour potentially emerging from fixing interline fares or selling tickets of competitors, in particular, in light of the far-reaching nature of some of the measures. The report should further elaborate on the enforcement role of Member States and estimate the enforcement costs that will fall exclusively upon them. It should present the One In, One Out estimates in a clear and comparable way. (7) The report should explain better the divergent views of different groups of stakeholders, in particular, on the identified problems, their drivers and the proposed policy options. The report should be more open and nuanced about the limitations of marrying a limited evidence base to ambitious policy measures. It should include a strengthened proportionality assessment regarding mandatory sales and service agreements. Given that no single preferred option is identified, the report should better inform the decision makers in terms of the pros and cons of the two short-listed preferred options. Some more technical comments have been sent directly to the author DG.

(D) Conclusion The DG must revise the report in accordance with the Board’s findings and resubmit it for a final RSB opinion.

Full title Multimodal Digital Mobility Services (MDMS) (including revision of Regulation 80/2009 on a Code of conduct for Computerised Reservation Systems)

Reference number PLAN/2021/10509

Submitted to RSB on 20 July 2023

Date of RSB meeting 13 September 2023

9

Electronically signed on 13/04/2026 18:43 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121

EN EN

EUROPEAN COMMISSION

Brussels, 13.5.2026

SWD(2026) 300 final

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT REPORT

Accompanying the documents

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on multimodal booking and repealing Regulation (EC) No 80/2009

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on rail ticketing

{COM(2026) 231 final} - {COM(2026) 232 final} - {SEC(2026) 300 final} -

{SWD(2026) 301 final}

I

Table of Contents

Glossary ........................................................................................................................................ III

1. INTRODUCTION: POLITICAL AND LEGAL CONTEXT ..................................................................... 1

1.1. Political context ............................................................................................................. 1

1.2. Legal context .................................................................................................................. 2

1.3. Synergies with other EU policy instruments ................................................................. 3

1.4. Evaluation of the Regulation on a Code of Conduct for CRS ....................................... 4

2. PROBLEM DEFINITION ............................................................................................................... 5

2.1. What are the problems? ................................................................................................. 5

2.2. What are the problem drivers? ..................................................................................... 16

2.3. How likely is the problem to persist? .......................................................................... 23

3. WHY SHOULD THE EU ACT? .................................................................................................... 24

3.1. Legal basis .............................................................................................................. 24

3.2. Subsidiarity: Necessity of EU action ........................................................................... 24

3.3. Subsidiarity: Added value of EU action ...................................................................... 24

4. OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................................ 25

4.1. General objective ......................................................................................................... 25

4.2. Specific objectives ....................................................................................................... 25

5. WHAT ARE THE AVAILABLE POLICY OPTIONS? ...................................................................... 26

5.1. What is the baseline from which options are assessed? ............................................... 26

5.2. Description of the policy measures and policy options ............................................... 28

6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS?.................................................................. 35

6.1. Economic impacts ........................................................................................................ 37

6.2. Social impacts .............................................................................................................. 54

6.3. Environmental impacts ................................................................................................ 56

6.4. Summary of the economic, social and environmental impacts ................................... 57

7. HOW DO THE OPTIONS COMPARE? ........................................................................................... 59

7.1. Effectiveness .............................................................................................................. 59

7.2. Efficiency .............................................................................................................. 60

7.3. Coherence .............................................................................................................. 63

7.4. Subsidiarity and proportionality .................................................................................. 64

7.5. Summary of the effectiveness, efficiency, coherence, subsidiarity and proportionality .

.............................................................................................................. 65

7.6. Sensitivity analysis ...................................................................................................... 66

8. PREFERRED OPTION ................................................................................................................. 69

8.1. Identification of the preferred policy option and stakeholder views ........................... 69

8.2. REFIT (simplification and improved efficiency) ........................................................ 70

II

8.3. Application of the ‘one in, one out’ approach ............................................................. 70

9. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED ............................................... 71

ANNEX 1: PROCEDURAL INFORMATION .......................................................................................... 73

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) ..................................................... 85

ANNEX 3: WHO IS AFFECTED AND HOW? ...................................................................................... 102

ANNEX 4: ANALYTICAL METHODS ............................................................................................... 107

ANNEX 5: COMPETITIVENESS CHECK ........................................................................................... 214

ANNEX 6: SME CHECK ................................................................................................................ 218

ANNEX 7: DISCARDED POLICY MEASURES .................................................................................... 222

ANNEX 8: RETAINED POLICY MEASURES ...................................................................................... 225

ANNEX 9: BACKGROUND ON THE CODE OF CONDUCT ON COMPUTERISED RESERVATION

SYSTEMS AND AIR MARKET ......................................................................................................... 232

ANNEX 10: LINKS BETWEEN CONCLUSIONS OF THE EX-POST EVALUATION OF THE CRS CODE OF

CONDUCT AND THE IMPACT ASSESSMENT .................................................................................... 237

ANNEX 11: DECISIONS AND RULINGS CONCERNING ANTI-COMPETITIVE PRACTICES ON RAIL

TICKET DISTRIBUTION .................................................................................................................. 241

ANNEX 12: MONITORING AND EVALUATION ................................................................................ 244

ANNEX 13: DETAILED ASSESSMENT OF IMPACT ON COMPETITION .......................................................... 246

III

Glossary

Term or acronym Meaning or definition

API Application Programming Interface

B2B Business-to-Business

B2C Business-to-Consumer

CRS Computerised Reservation Systems

DC system Direct Connect system

DMA Digital Markets Act

DSA Digital Services Act

EC European Commission

EDIFACT Electronic Data Interchange for Administration, Commerce and

Transport

EEA European Economic Area

FRAND Fair, Reasonable and Non-Discriminatory

GDP Gross Domestic Product

GDS CRS is also known as Global Distribution System

LCC Low-Cost Carrier

MaaS Mobility as a Service

MIDT Market Information Data Tapes (from airline booking systems)

MSE Meta-Search Engine

MDMS Multimodal Digital Mobility Services

MMTIS Multimodal Travel Information Services

NAP National Access Point

NEB National Enforcement Body

NCA New Content Aggregator

NDC New Distribution Capability

OPC Open Public Consultation

OTA Online Travel Agent

PM Policy Measure

PO Policy Option

PSO Public Service Obligation

RU Railway Undertaking

IV

SERA Single European Rail Area

SMP Significant Market Presence

SSMS Sustainable and Smart Mobility Strategy

TMC Travel Management Company

1

1. INTRODUCTION: POLITICAL AND LEGAL CONTEXT

This Impact Assessment (IA) accompanies two new legislative proposals seeking to improve the functioning

of the online ticket distribution market for passenger transport in the EU and foster the availability of single

tickets in rail.

The Regulation on Multimodal Booking (RMB) targets all

ticketing platforms for passenger transport in waterborne, air,

rail, and road and will set rules to establish a level playing

field across all actors in the distribution chain, and to ensure fair

cooperation with transport operators.

The Rail Ticketing Regulation (RTR)

targets railway undertakings (RU) and will

set rules on access to rail tickets as well as

access for RUs to rail ticketing platforms.

The RMB proposal includes the repeal of Regulation (EC) No 80/2009 on a Code of Conduct for

Computerised Reservation Systems (‘CRS Code of Conduct’1) whilst updating and integrating the

provisions that remain relevant.

These initiatives are needed because, as highlighted in the political guidelines for the European

Commission 2024−20292, it is currently difficult for travellers to find, compare, combine and book tickets for

regional and long-distance journeys in the EU3. This becomes significantly more difficult when combining

offers from multiple operators and is particularly challenging in the case of cross-border train travel, which

limits the attractiveness of rail for such journeys. A 2024 Eurobarometer survey on ticketing4 showed that

a third of all respondents have never booked a multimodal journey (e.g. combining trains, planes or coaches),

and over a third of respondents who booked such journeys reported difficulties in doing so. Barriers included

the inability to find a suitable combination, lack of information on where to search for such offers and not

being able to buy all the tickets in one place. According to the survey these barriers were higher for journeys

involving multiple railway undertakings. Another major concern for rail passengers is that they often do not

enjoy passenger rights when their journey involves different RUs. While the passenger rights dimension falls

outside the scope of this IA, since it does not concern ticket distribution and is addressed through a targeted

revision of the Rail Passenger Rights Regulation, which will ensure that tickets purchased in a single

transaction on one platform are treated as “single tickets”, thereby granting passengers full rights for the entire

journey. This targeted revision is supported by an analytical Staff Working Document which updates

the assessment of impacts from 2017 of the related policy measure. To maximise the effectiveness of

both initiatives, SDBTR will ensure that RUs cannot withhold platforms from combining their tickets

into “single tickets”. These complementary initiatives are all expected to strengthen passenger confidence and

help unlock the potential for a modal shift towards rail.

1.1. Political context

These initiatives aim to promote a more multimodal and sustainable transport system and contribute to

Sustainable Development Goals SDG#3 (“Ensure healthy lives and promote wellbeing for all at all ages”),

SDG#9 (“Make cities and human settlements inclusive, safe, resilient and sustainable”), SDG#13 (“Climate

Action”). The European Green Deal5 sets a goal of reducing transport-related greenhouse gas emissions by

90% by 2050, compared to 1990 levels, and the Sustainable and Smart Mobility Strategy (SSMS) refers

1 OJ L 35, 4.2.2009, pp. 47–55.2 ‘Europe’s choice - Political guidelines for the next European Commission 2024−2029: ‘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’ 3 These initiatives do not apply to local or urban transport services. 4 Flash Eurobarometer 551 - Multimodal Digital Mobility Service – August – September 2024 5 COM (2019)640 final

2

to simpler multimodal ticketing and possible regulatory action on multimodal digital mobility services

(MDMS), together with an initiative on ticketing, including rail ticketing (Action 37) as supporting actions to

achieve this ambition6.

After four legislative railway packages, the Single European Rail Area has been opened to competition,

resulting in a more diverse, improved and more affordable offer to passengers7. In 2024, passenger rail km

grew by 5.8%, driven by strong consumer demand and the launch of new services, including by new entrants.

However, whilst significant progress has been made on other fundamental elements of the Single European

Railway Area, such as common infrastructure development, improved interoperability and capacity

management, rail ticketing remains a significant structural weakness. The digital revolution in retail,

experienced in other sectors (hotels, flights) has not materialised for rail. Incumbent companies act as

gatekeepers, who operate the vast majority of services while also owning the established ticket platforms.

They can leverage incumbency to disadvantage competing platforms by sharing data and offers selectively

and exclude competing operators by refusing to sell their tickets on the main platform. This situation limits

price transparency and makes new operators commercially invisible, undermining the business case for new

rail services that would drive affordability and induce a modal shift. For new operators, ticket distribution is

key to reaching customers.

Directive 2012/34/EU8 recognised the importance of market-developed common information and through-

ticketing systems9 , which should be interoperable and non-discriminatory and enable passengers to plan

journeys and book tickets across the EU. Improving rail ticketing is also highlighted as a priority in the

Communication on connecting Europe through high-speed rail10 and the Action plan to boost long-

distance and cross-border passenger rail11.

The Council also underlines digitalisation as a key driving force to EU transport competitiveness and stresses

that multimodality depends on interoperable travel information, ticketing and payment systems12. The Letta

Report on the Future of the Single Market13 highlights that “to facilitate new entrants' access to service

facilities and ensure fair competition in the railway sector, especially in relation to ticket vending, there is a

pressing need for an EU-wide, integrated, multimodal information, ticketing, and payment services

framework. In that field, significant advancements in developing interoperable and non-discriminatory sector-

led initiatives are still ongoing, while a conducive regulatory environment for such services is still lacking”.

The Draghi Report on the Future of European Competitiveness14 also states that “market barriers remain

for new entrants who in some cases face high track access charges and difficulties in accessing equipment

and ticketing systems. This weakens the ability of providers to scale up and operate across borders”.

1.2. Legal context

Article 102 of the Treaty on the Functioning of the European Union (TFEU) prohibits abuse of

6 COM (2020)789 final 7 European Commission: Directorate-General for Mobility and Transport and EY, Study on passenger and freight rail

transport services’ prices to final customers – Final report, Publications Office of the European Union, 2024,

https://data.europa.eu/doi/10.2832/403804 8 OJ L 343, 14.12.2012, p. 32, as amended by OJ L 352, 23.12.2016, p. 1. 9 Under the provisions of this Directive, Member States may require RUs operating domestic passenger services to

participate in common information and integrated ticketing schemes for the supply of tickets, through-tickets and

reservations, provided these schemes do not distort the market or discriminate between RUs. A through-ticket represents

a transport contract covering multiple connected legs of a journey, entitling passengers to certain rights (re-routing or a

refund, assistance, and potentially delay compensation based on the time of arrival at the final destination) in case of a

missed connection between services covered by that ticket. 10 COM (2025)903 final 11 2022/2022(INI) 12 https://data.consilium.europa.eu/doc/document/ST-8824-2021-INIT/en/pdf 13 Letta, Enrico. Much More Than a Market. Council of the European Union, 2024, p. 85 14 Draghi, Mario - The Future of European Competitiveness: In-Depth Analysis and Recommendations. 2024, p. 213

3

dominance. In line with this provision, the Commission, as well as national courts and competition authorities

across the EU, have investigated online ticket distribution practices, in particular in the rail sector, such as

restricting access to ticketing data, and imposing unreasonable fees and technical requirements to third-party

platforms. The large number of cases shows that the issue is systemic and further outlines the necessity of an

EU-wide regulatory intervention. Member States have also adopted legislation to support the development of

MDMS.

In France, transport service operators15 must grant access to their digital sales channels, to allow the

distribution of their tickets16. In Finland, the 2018 “Act on Transport Services”17 also requires transport

authorities and operators to make their tickets available on MDMS platforms18. In 2017, the Dutch Ministry

of Infrastructure and Water Management and the interested Regional Authorities launched seven pilot

projects for regional MDMS19requiring compliance with common rules and transparent conditions. In

Spain, the 2025 “Sustainable Mobility law”20 establishes rules for distribution agreements between transport

operators and multimodal ticketing platforms. In Sweden, regional authorities are progressively moving

toward a unified digital ticketing system21, with initiatives to integrate local and regional tickets into single

platforms accessible via mobile apps or smart cards.

1.3. Synergies with other EU policy instruments

Digital Transport policies: The ITS Directive22 establishes a framework for the deployment of Intelligent

Transport Systems in the road sector and its interfaces with other modes of transport. Under the Delegated

Regulation on multimodal travel information services (MMTIS)23 Member States must establish national

access points constituting a single point of access for data users to the static, historic, observed and dynamic

travel and traffic data of different transport modes, for the purpose of providing multimodal travel information

services. Developing MDMS platforms capable of reservations, bookings, or ticketing however

requires additional data (e.g. real-time fares).

Under the rail interoperability Directive (EU) 2016/79724, the Commission developed functional and

technical specifications for telematics applications (TEL TSI)25 supporting the interoperability of data

sharing in rail transport.

Horizontal data policies: To complement the general principles of the Digital Markets Act26 in relation to

MDMS platforms, sectorial measures are considered in the RMB proposal. These ensure that they do not

impose general conditions that would be unfair or lead to discrimination. They complement the rules of the

DMA applying to gatekeepers as MDMS platforms fall below the DMA’s thresholds. The RMB proposal is

also complementary to the Digital Services Act27 (DSA) provisions as it also supports a safe, predictable, and

trusted online environment. The Data Act28 (DA) hassynergies with the RMB proposal, through harmonised

15 Only public transport services organised by regions and privately run rail, road, and maritime services within

regional/100 km limits are subject to that obligation. 16 Law No. 2019-1428 of 24 December 2019 on Mobility Orientation, Article 28. 17 Act on Transport Services (320/2017; amendments up to 731/2018 included). 18 A mobility service provider in Finnish law is any company or operator that offers transport services or services

connected to transport (trip information, ticketing/brokerage, dispatching, parking, or other supporting mobility services). 19 1900019 Brochure MaaS-pilots A4-EN.indd (dutchmobilityinnovations.com). 20 Law 9/2025 of 3d December on Sustainable Mobility, Article 92. 21 Samtrafiken's National Distribution System - Services | Samtrafiken 22 OJ L, 2023/2661 23 OJ L, 2024/490 24 OJ L 138, 26.5.2016, p. 44–101. 25 OJ L, 2026/253, 10.2.2026, p. 1. 26 OJ L 265, 12.10.2022, p. 1–66. 27 OJ L 2022/2065, 19.10.2022 28 OJ L 2023/2854, 22.12.2023

4

rules on data sharing including rules on Business to Government (B2G) data sharing and rules on unfair

contractual agreement terms. In addition, the rules on Artificial Intelligence29complement the RMB proposal

by establishing rules on AI systems used by MDMS platforms, ensuring safety, transparency, and respect of

fundamental rights.

Commercial practices policies: The revised Directive on Unfair Commercial Practices prohibits

undisclosed advertising and paid promotion for higher ranking of products within search results on MDMS30.

The RMB proposal complements these acts with measures that ensure that search results on MDMS platforms

are displayed in a neutral way (setting out a list of mandatory ranking criteria and indicating which criterion

was used for display), prohibit self-preferencing and paid prominence, allowing advertised content only under

certain conditions.

Passenger rights policy: The recast Regulation on rail passengers’ rights and obligations31entered into force

in June 2021 and applies from June 2023. It replaces the initial EU rules in the domain that applied since 2009.

The Regulation improves real-time travel information, introduces data-sharing rules for operators and third

parties (including ticket vendors and other RU) when they have an agreement, adds a self-rerouting right, and

requires RU under the same ownership to offer through-tickets. A targeted revision of this Regulation is being

undertaken in parallel to this initiative to increase rights for rail passengers holding a single ticket for a single

journey with multiple RUs, booked on a single platform in a single transaction. SDBTR complements this

revision by creating the conditions for rail travellers to book these single tickets. The Commission adopted a

proposal in 2023 for passenger rights in the context of multimodal journeys32 that puts forward rules to ensure

the protection of passengers when switching between different transport modes. It proposes that passengers

with single contracts for a multimodal journey should be assisted in the event of travel disruptions and suggests

a specific liability regime for intermediaries who combine separate tickets into a multimodal journey that the

passenger buys from them in a single transaction.

Other initiatives: The CountEmissions EU33 and Flight Emission Label34 initiatives set out a common

framework to calculate and report transport-related greenhouse gas emissions. Transparent information

applied across modes will enable passengers to choose the most sustainable options for their trips. The

Transition Pathway for Tourism35 sets up a common European data space for tourism with the objectives

to facilitate stakeholder cooperation and to encourage the active sharing of tourism-related data including

mobility data. The Report from the Commission to the Council on the implementation of the European

Tourism Agenda 203036mentions multimodality as a key enablerof competitiveness in the sector.

1.4. Evaluation of the Regulation on a Code of Conduct for CRS

A particular type of MDMS, active in the business-to-business (B2B) segment, are the Computerised

Reservation Systems (CRSs)37. These were created by airlines in the 1960s, to grant travel agents access to air

29 OJ L, 2024/1689, 12.7.2024. 30 OJ L 328, 18.12.2019, p. 7–28. 31 OJL 172, 17.5.2021, p. 1–52. 32 COM (2023)752 33 COM (2023) 441 34 OJ L, 2024/3170. 35 European Commission: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, Transition

pathway for tourism, Publications Office of the European Union, 2022 36 COM (2025) 763 final 37 CRS aggregate and provide information on travel options (inter alia schedules, availability and fares) of different

airlines and rail operators to online and offline travel agents and Travel Management Companies. Unlike B2C MDMS

they do not sell directly to consumers but enable travel agencies to book tickets on behalf of their clients (Sabre, Amadeus,

Travelport).

5

offers. Specific rules were adopted in 198938 to avoid risks of anti-competitive behaviour by CRSs. These

were later revised in 200939 to regulate the business-to-business transactions between the providers of CRSs

and air and rail carriers, and travel agents. The CRS Code of Conduct was evaluated in 202040 to assess

whether, in light of market and technological changes in air B2B ticket distribution, it is still relevant in

achieving the objectives of (i) preventing distortion of competition between CRSs owned by parent carriers,

and (ii) ensuring fair and effective competition between carriers; and, whether it remains fit for purpose given

broader horizontal legislation. The evaluation concluded that the Code has not fully ensured a level playing

field for all participating carriers, as regards access to, and use of CRS services, since it did not lead to

better balancing of the bargaining power of different-sized air carriers vis-à-vis CRSs.Some carriers expressed

concerns about specific clauses in their contracts with CRS providers, reducing the ability of airlines to use

alternative booking systems or technology.Moreover, the evaluation concluded that the transparency

requirements, in the form of the neutral display, remain important, since travel agents, both offline and

online, and travel management companies still heavily rely on CRS data especially for business travel. The

evaluation also concluded that specific sectoral treatment of traditional CRS providers may no longer be

justified in view of market and technological developments in air ticket distribution (increased internet

penetration, the rise of other channels and divestment of airlines from CRSs). More details on the evaluation,

and its links with this impact assessment, are presented in Annex 10.

2. PROBLEM DEFINITION

2.1. What are the problems?

The problems, problem drivers and consequences identified are presented in Figure 1.

Figure 1: Problem tree

38 Council Regulation (EEC) No 2299/89 of 24 July 1989 on a code of conduct for computerised reservation systems, OJ

L 220, 29.07.1989, p. 1-7. 39 Regulation (EC) No 80/2009 of the European Parliament and of the Council of 14 January 2009 on a Code of Conduct

for computerised reservation systems. 40 SWD (2020)9

6

This initiative identifies 4 problem drivers and addresses two market failures in online ticket distribution,

which are described in more detail in Problem 1: Lack of transparency, unfair conditions, and uneven playing

field in the online ticketing market and Problem 2: Incomplete offer of rail tickets on (rail) platforms. These

problems have consequences in the operational rail service market and means consumers do not find all travel

choices on online platforms. The latter limits their ability to compare and combine travel options and fares,

including on their environmental impact. To better understand the magnitude of the consequences on

consumers, including the potential for behavioural change and their ability to make more sustainable travel

choices, several questions must be considered:

1) Do alternative travel options exist?

2) Are travellers willing to changes their habits?

3) Is travellers’ ability to make alternative choices impaired?

To answer the first question an EU-wide analysis

of 100 origin-destination routes (performed in the

context of the impact assessment support study41)

assessed the level of completeness of information

and tickets on B2C MDMS platforms across

modes. The routes were selected to represent

41 Ricardo et al. (2026), Study supporting the MDMS and SDBTR Impact assessment.

Problem Drivers (PD) Problems (PB)

PD1: Regulatory framework no longer

fit for purpose due to market and

technological changes in ticket

distribution

PD3: Imbalanced commercial relations

of indispensable MDMS platforms and

transport operators

Problem 1: Lack of

transparency, unfair

conditions, and

uneven playing field

in the online

ticketing market

PD4: Vertical integration of railway

undertakings and rail ticketing

platforms hinders wider ticket

distribution

PD2: Commercial incentives of

MDMS platforms to promote certain

operators or products

Problem 2:

Incomplete offer of

rail tickets on (rail)

platforms

Consequences

For the consumer:

limited ability to compare

and combine travel

options and fares,

including the ability to

compare the

environmental impact of

the travel choice.

For the rail sector:

obstacles to market entry,

reduced competition,

lower demand for rail

services, and suboptimal

return on public

investment

Figure 2: 100 origin-destination pairs

7

different levels of (1) attractiveness42, (2) traffic intensity and (3) distance, and ensure (4) good geographical

balance and (5) matching availability of transport modes with modal split data on EU passenger traffic from

Eurostat. The analysis compared the options shown on Omio43 with a fuller set of possibilities identified

through Google Maps (for land and sea) and Google Flight (for air)44, and found that multimodal options were

available on 76% of the routes, yet today, even though some MDMS platforms show options in different

modes, these are rarely combined. In fact, in the analysis 39% of possible rail or coach connections were not

visible on the MDMS platform, let alone being combined. This is worse for rail options, which were entirely

absent from the MDMS platform in 29% of cases, but visible on at least one rail platform. Looking at coach

only 7% of routes had missing connections. Furthermore, for 17% of the routes faster connections existed on

operators’ platforms and in 34% of the routes, cheaper connections were available on operator websites,

though the latter finding was not sufficiently robust to include in the quantitative analysis as a possible cost

saving 45. The 100 origin-destination analysis illustrates that alternative travel options, including multimodal

ones, exist, yet these options are neither displayed nor combined by MDMS platforms. The problem is bigger

when looking for options that include more than one RU.

“One concrete example is with the Polish operator PKP. To travel with PKP between Warsaw and Gdansk,

you need to buy your ticket on PKP. Third party platforms (Trainline, Omio, RailEurope) don’t have access

to the data to provide those tickets to travellers.” T&E

“To understand everything that is wrong with European train ticketing, the perfect test case is Nice to Milan.

A route which should be competitive with road and air, but there are no through trains, no through tickets, no

timetable co-ordination, you must buy a Nice-Ventimiglia ticket on the French Railways website then a

Ventimiglia to Milan ticket on the Trenitalia website, two tickets mean zero passenger rights in the event of a

missed connection. It can be sold as one journey, but still without passenger rights, at Raileurope.com or

Thetrainline.com. If you know where to look, and only with an added booking fee.” The Man in the Seat 61

“When we look at independent platforms like Trainline, all railway companies are technically integrated, but

not all services are fully accessible. For instance, there was a situation where Trainline users could book

Deutsche Bahn tickets, but they couldn't use the Deutsche Bahn discount card on Trainline.” National

(German) Consumer organization

The best way to answer the two remaining questions is to ask travellers directly: a 2024 Eurobarometer

survey on Multimodal Digital Mobility Services asked almost 26,000 citizens about their online booking

experiences46. The Eurobarometer survey was designed to be representative for the EU population. More than

three-quarters of respondents reply that environmental impact is important to them when planning a regional

or long-distance journey. Nonetheless, while 21% of respondents report that this means they adapt their

journey accordingly, 22% find it difficult to change their habits, and another 22% find it difficult to find

42 The attractiveness of origin or destination nodes was assessed considering for each NUTS3 region the economic

attractiveness (as indicated by the GDP by NUTS3 region from Eurostat), personal attractiveness (as indicated by the

number of bed places for tourism per NUTS3 region from Eurostat), and its status as a capital city. The Nomenclature of

territorial units for statistics (NUTS) is a geographical nomenclature subdividing the EU territory into regions at three

different levels (NUTS1, NUTS2 and NUTS3 respectively, moving from larger to smaller territorial units). NUTS3

regions are those with population between 150,000 and 800,000. More details on the analysis of the 100 origin-destination

routes are provided in Annex 4 (section 1.3.1). 43 Whilst it only provides options for within-mode travel (e.g. bus-bus or rail-rail), Omio is used as a proxy for availability

of travel options on MDMS as it is one of the most comprehensive independent MDMS platform for land travel in the

market that allows to book travel options from different modes. Other platforms either lack multimodal booking (e.g.

Rome2Rio only does re-linking) or have limited modal or geographic scope. 44 Google Maps was used to list all possible within-mode and multimodal connections possible via land and sea and their

associated journey times. Costs for these connections were collected by direct research on the websites of relevant

operators. This was supplemented by additional information from Google Flights on possible direct air connections and

their associated journey times/costs. 45 A direct comparison of costs was only possible in 56 OD pairs, limiting the representativeness of the exercise, and the

cost data collected directly via operator websites was for a point further in the future than the costs extracted from Omio. 46 Flash Eurobarometer 551 - Multimodal Digital Mobility Service – August – September 2024

8

sustainable alternatives. More specifically, over a third of respondents who have experience with booking

multimodal journeys (e.g. combining trains, planes or coaches), report that these journeys are difficult to

book47 and 31% of all respondents have never booked such journeys. The same holds for journeys combining

different operators in one mode: more than a third of respondents who intended to book such journeys found

them difficult to book48 and 36% of all respondents have never booked such journeys. When asked why they

had never or rarely booked combined journeys, 17% of respondents said they couldn’t find a suitable

combination, 5% lacked information, and another 5% could not buy all the tickets in one place. Confirming

these results, in the open public consultation (OPC) for this impact assessment, 174 of the 226 respondents

highlighted that they had difficulties booking and purchasing tickets combining different modes. The most

common issue identified was that they had to visit multiple sites to find the information needed.

Concluding, travellers care about the environmental impact of their journeys and while one fifth already

changes their habits today, another fifth finds it difficult to find, or buy, sustainable alternatives. So, what if

travellers had the ability to see all (rail) offerings on MDMS platforms and could book all legs of their journeys

on a single MDMS platform? Based on the answers from the Eurobarometer related to travellers’ ability or

difficulties in booking tickets, we can estimate the magnitude of the consequences for consumers. We start by

looking only at respondents which, despite travelling by train in the last two years, indicated they rarely

(13.2%) or never (16.9%) combined in one single journey two or more rail legs (connecting trains), operated

by different rail operators. Next, we eliminate from that group (30.1% of citizens) all those that indicated they

simply did not need to combine two operators on their journey(s), leaving us with 17.3% of citizens. Within

that group we look at which reasons were given for not combining two rail operators and find that 8% of

citizens either did not know it was possible, did not know where to search for such travel information, could

not find a suitable combination or could not buy all tickets they needed in one place.

This means that up to 8% of people experience ticketing issues when trying to book multi-operator rail

journeys in a single ticket. This however does not mean that if all ticketing issues were resolved and single

tickets were widely available, all travellers experiencing those issues would change their habits and purchase

those single tickets. They may still opt for other modes of transport, such as the car. Therefore, we only

consider respondents that indicated they could not buy all tickets they needed in one place (1.7%). This group

most clearly represents travellers who already knew which tickets they needed, and intended to buy them, but

were prevented from doing so by ticketing barriers. Though not all of them would necessarily complete the

purchase if the barriers were removed, it is also reasonable to assume that some respondents in the larger group

of 8% which experienced ticketing barriers would also buy single tickets if these barriers were removed.

In conclusion, based on the Eurobarometer results, we estimate the magnitude of the consequences for

consumers of limited ability to compare and combine travel options and fares, including the ability to compare

the environmental impact of the travel choice, as the maximum potential increase in journeys using railway

services, and a corresponding decrease in journeys using less sustainable modes49 at 1.7%. This illustrates the

dimension and size of the underlying problems 1 and 2.

2.1.1. Problem 1: Lack of transparency, unfair conditions, and uneven playing field in the

online ticketing market

The growing digitalisation and broad access to internet has changed the online ticketing market for transport

services, which is becoming increasingly diversified and includes a wider than ever range of stakeholders, in

both the B2C and B2B domains (see Figure 3). 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

47 5% selected the response 'very difficult' and 30% 'rather difficult'. 48 6% selected the response 'very difficult' and 30% 'rather difficult'. 49 See section 1.3.2 of Annex 4.

9

transport modes. Online distribution channels of transport operators – used exclusively for the distribution of

their own transport services50 without offering third party tickets – are not considered to be in the ‘platform

market’ and do not qualify as MDMS within the meaning of this initiative, therefore falling out of its scope.

Similarly, online search engines that direct end-users to different types of websites, including but not limited

to websites where transport products are sold, do not qualify as MDMS, therefore also falling out of its scope.

Finally, multimodal travel information services that provide journey planning to end users, but do not facilitate

booking, whether directly or via re-linking (e.g. Google Maps, City Mappers), do not qualify as MDMS.

Figure 3: The online ticketing landscape51

This diversification creates opportunities to offer better and more tailored services to consumers but also raises

issues when a level playing field between all actors is not ensured. The evaluation of the CRS Code of Conduct

found that the rise of indirect distribution channels, such as New Content Aggregators (NCAs) that offer

similar services as CRSs to travel agents, but without being subject to similar rules, presents a risk of distortion

of competition between B2B MDMS platforms. In addition, the platform market has significantly changed

and diversified over-time, with a wide range of new type of B2C platforms (see Figure above) that currently

do not have to comply with neutral display requirements nor fair treatment of transport operators. These

market developments, combined with the blurring boundaries between B2B and B2C distribution, drive the

50 Including those of operators which they control, operators which control them or operators that are controlled by the

same entity as the one controlling them and including those of operators that are part of the same economic undertaking

(group). This includes Direct Connect systems, identified as a carrier system that does not provide aggregation and

comparison service with other carriers which do not belong to their group and excludes code share and interlining

agreements. Code share agreements allow an airline to market and sell flights operated by another airline under its own

flight number. Interlining agreements enable airlines to issue tickets and manage passengers on journeys involving

multiple airlines. These arrangements may also include cooperation with other transport operators (e.g. air-rail or air-

coach). They are forms of operational cooperation, not ticket sales on behalf of other operators which ensure better

connectivity, a wider range of travel options and may also be beneficial to consumers from the passenger rights

perspective. 51 Meta search engines (MSE) aggregate and present travel option(s) to users (schedules, availability and fares),

redirecting them to other MDMS platforms (Online Travel Agents (OTAs)) or direct distribution channels (transport

operator’s website) to complete the booking for the selected option(s). Examples include Skyscanner and Google Flights.

OTAs aggregate and offer travel option(s) from multiple operators and enable users to book tickets directly on the

platform. This requires the MDMS platforms to have access to each operator’s booking and reservation systems through

standardised interfaces. Such platforms can be independent from transport operators (e.g., Trainline, Omio, eDreams) or

be owned by an operator (e.g., SNCF Connect, DB Navigator). New Content Aggregators (NCAs) aggregate and present

travel options (schedules, availability and fares) to online and offline travel agents. Examples include Travelfusion,

Farelogix.

10

need to (i) update the relevant provisions of the CRS Code of Conduct, and (ii) extend them to alternative

business models in all modes.

In the interviews and targeted survey conducted in 2025 in the context of the impact assessment support

study, one MDMS, four airlines / airline associations including A4E, one region and three CRS providers

raised concerns about uneven regulatory treatment of B2B air ticket intermediation services and its potential

risks of distortion of competition. Six airlines and the three CRSs, indicated that, while the Code is still relevant

for traditional CRSs, it no longer reflects current market realities, including the growing role of other MDMS

platforms (where transport tickets can be booked directly or via a re-linking feature), not subject to neutral

display rules52. Across all stakeholder groups, 36 of 74 respondents to the targeted survey agreed with the

problem as stated53, whereas 7 disagreed. The remaining 31 neither agreed nor disagreed (7) or did not know

(24). Among MDMS platforms, 13 of 19 respondents agreed (6 Online Travel Agents (OTAs), 2 CRSs, 2

NCAs and others MDMS providers), while 4 disagreed (2 OTAs, 1 rail platform and 1 Meta search engine

(MSE)) and 4 did not know (rail platforms). CRS providers agreed, stressing that they face stricter rules despite

handling a declining share of ticket sales, while views among NCAs were mixed54. Among transport

operators, 11 of 31 agreed, while three partially disagreed. Four airlines, including airline associations, called

for an update of the Code of Conduct, noting that it predates the rise of NCAs and airline websites and

highlighting that OTAs, MSEs and other MDMS platforms playing a role in distribution are not subject to

comparable rules. One operator suggested extending core principles – transparency, equal access and fairness

– to all MDMS platforms. Among national authorities, 6 of 13 agreed, 1 disagreed, and 6 were neutral or did

not know. Other responding stakeholders mostly agreed with the problem and A4E found that the

regulation should reflect technological developments and ensure transparent, unbiased consumer access across

all transport modes.

“The Code of Conduct for Computer Reservation Systems (CRS) contributes to a distorted and outdated

airline distribution system. This code mandates how air content (e.g., prices, schedules) must be displayed,

but it only applies to regulated CRS platforms, not to many newer B2B and B2C digital solutions. As a result,

significant portions of the distribution landscape operate outside its scope, leading to inconsistencies and

reduced flexibility for airlines, particularly in Europe.” a B2B MDMS in an interview

Indeed, MDMS platforms may design search algorithms to prioritise certain transport services and relegate

competing services to less visible positions, display journey times or prices in a way that makes some services

appear more attractive or exclude travel options to promote services for which they receive financial

incentives, or which are sold by their parent company. During an interview, an association of airlines expressed

concern that OTAs and MSEs (whose business consist of displaying travel information and price of several

transport operators to end-users, re-linking them to the websites where they would be able to book their

journey) tend to promote operators or products based on commercial interests rather than objective consumer

value. Similarly, MDMS platforms (both OTAs and MSEs) do not always display available information on

GHG emissions, which would allow users to compare the environmental impact of their travel choice.

In the targeted survey, two medium-sized airline operators raised concerns about major OTAs selectively

promoting certain operators or adding non-transparent fees, which misleads consumers and distorts

competition. The European Regions Airline Association mentioned that regional airlines in particular struggle

52 Ricardo et al. (2026), Study supporting the RMB and RTR Impact assessment. 53 Since the survey was carried out, the problem tree has evolved, reformulating the problems and drivers identified. This

paragraph reflects answers from stakeholders on the following problem: Potential distortion of competition between

regulated (CRS) and non-regulated B2B distribution channels performing similar functions to CRS. 54 One saw no unfair competition, while another acknowledged the Code’s benefits in preventing abusive practices such

as biasing but supported its review to address technological developments and the extension of core principles to

unregulated actors, including OTAs.

11

to compete fairly due to limited economies of scale and the prioritisation of major carriers by gatekeeping

platforms, reducing consumer choice especially for connectivity to peripheral areas in Europe. In this sense,

eight stakeholders55 called for stronger regulation to ensure neutral display obligations, prevent discrimination

and mandate transparency in how content is presented on MDMS platforms. Conversely, MDMS platforms

detailing their views in the survey pointed out to unfair practices from transport operators leading to distorted

information on platforms. An OTA stated that certain airlines “limit the comparability, availability and

attractiveness of their services on indirect distribution channels”, which “harms consumer choice and

competition.” Another OTA reported that “some operators restrict the information that can be shown on

MDMS platforms creating barriers to providing accurate and comprehensive content".

The Frankfurt am Main Higher Regional Court (Oberlandesgericht Frankfurt am Main) published a decision

on 2 October 202356 prohibiting DB’s ticketing platform DB Navigator to offer a “show fastest connection”

search filter. This filter was found to mislead consumers by not displaying all possible connections that were

fast. The filter, preset by default, prioritised DB's own services even if alternative options existed that were

faster but had different departure or arrival times. This algorithm thus deprived competitors of the opportunity

to compete fairly and influenced consumer choices towards DB products. The court deemed this practice to

be a form of anti-competitive behaviour, as it manipulated search results in DB’s favour. This competition

case has been cited by three new entrant railway undertakings and one passenger organization during

interviews, as a clear example of abuse of dominance of indispensable RU and the inability for new entrants

to compete fairly.

Finally, MDMS platforms, can have such Significant Market Presence (SMP) or strategic position that they

become essential gateways to consumers. Access to such platforms is thus crucial for transport operators.

When two transport operators compete with similar services (e.g. connections between the same two airports

/ train stations) and one of them does not have access to the dominant platform for the distribution of such

services, then its access to the service market is also restricted. Transport operators, and in particular different

sized air carriers, enjoy uneven access to and use of CRSs. Despite the decline in the share of total tickets sold

in the EU air ticket market through CRSs - selling approximately 22% of those tickets in 202457, CRSs still

hold a strategic position in the air ticket distribution market thanks to the symbiotic relationship between CRSs

and traditional travel agents and dynamics such as single homing58 of travel agents. Partially compensating

for the decline in market share from CRSs, sales through non-CRS B2B channels increased from 5% to 9%

between 2019 and 2024. As a result, in 2024 B2B MDMS distribution remains relevant at approximately 31%

of the overall air tickets sold in the EU.At the same time, 73% of all ticket selling channels are connected

through a CRS59,whichthus continue to occupy a unique position, particularly for small and medium sized

airlines which rely on CRSs to effectively reach large travel agents’ networks and be visible for consumers.

Between 2019 and 2024, the average CRS’s booking fee reached around EUR 8.4 per flight segment60 and

airlines argue they should be able to withhold certain fares (notably cheapest fares) from these channels when

distribution costs exceed the benefits61. However, the strategic position could allow CRSs to (i) impose highly

55 Including Airlines for Europe, ALLRAIL, and ERA. 56 Oberlandesgericht Frankfurt am Main, Decision of 2 October 2023, Case No 57 Ricardo et al. (2026), Study supporting the RMB and RTR Impact assessment. 58 The practice of travel agents and OTAs to remain loyal to a single CRS, encouraged through financial incentives, IT

equipment and free training. 59 This 73% represents the heavy reliance of OTAs and travel agents on CRSs to distribute their tickets. 60 Ricardo et al. (2026), Study supporting the RMB and RTR Impact assessment, market report. 61 One airline interviewed in the context of impact assessment support study indicated that every major European airline

group utilises Amadeus CRS backend systems despite this charging 20 EUR per ticket sold.

12

restrictive terms and conditions (such as full content parity clauses62) in exchange for lower fees63; (ii) and

apply biased display practices, if the current legislation on CRSs were to be repealed. Small airlines are directly

and most severely affected by the problem as they do not have the financial ability to develop Direct Connect

systems64 or set-up alternative distribution channels through new content aggregators. This ability, combined

with the CRSs’ need to provide a comprehensive offer to remain an attractive partner for travel agents, allows

large airlines to negotiate better conditions. Despite that, CRSs hold a strong position in the business travel

segment65 and in the long-haul leisure travel segment in EU markets outside the operators’ home market, as

well as extra EU markets which makes all airlines still dependent from CRS in these segments.

In the targeted survey, the surveyed transport operators agreeing with the potential distortion of competition

between CRSs and non-regulated B2B platforms performing similar functions to CRSs included 11 airlines /

airline associations, alleging “the exploitative practices by dominant CRS providers”66. One airline’s

association and eight airlines argue that removing safeguard provisions such as fair treatment could expose

airlines, in particular smaller ones, to discriminatory practices. One operator mentioned that regional airlines

in particular struggle to compete fairly, due to the prioritisation of major carriers by MDMS, reducing

consumer choice especially for connectivity to peripheral areas in Europe. One airline association, eight

airlines out of 11 and BEUC (the European Consumer Organisation) raised concerns over full content parity

clauses67, which may reinforce the market power of established CRS and MDMS platforms. On the contrary,

the three main CRS providers disagreed with Problem 1 outlining that they viewed access decisions as

commercially rational rather than discriminatory68, with difficulties arising from operator behaviour

withholding content or market structure rather than MDMS practices. One MDMS provider added that if it

costs too much to connect or there isn’t enough customer demand, they may not add a transport offer. 9 out of

20 MDMS providers, including two associations, highlighted that the real challenge lies in gaining access to

operator information.

2.1.2. Problem 2: Incomplete offer of rail tickets on (rail) platforms

All incumbent RUs (except in PL, see Error! Not a valid bookmark self-reference.) have Significant

Market Presence (SMP) in the national transport service market, i.e. a market share above 50% in terms of

62 Full content parity clauses require airlines to provide the same flight content and prices to a CRS as to other distribution

channels, preventing airlines from offering better or differentiated terms elsewhere. 63 In an interview, an airline indicated that the big three CRSs account for 50% of the airline revenue and that, during the

pandemics, they were about to exit contracts with two of the big three due to “unacceptable conditions”. Two airlines’

associations and three airlines highlighted the role of contractual provisions such as full content obligations and parity

clauses in reinforcing the commercial position of dominant CRSs. They also argue that these mechanisms have limited

flexibility and slowed the entry of new distribution models. One airline noted, such conditions “placed commercial

advantage with CRSs to maintain their incentive structures, locking agencies in”. 64 Direct connects directly connect airlines to travel agents, bypassing CRSs and their fees. 65 The corporate segment is lower in terms of volume but much more profitable than the leisure segment. One major

airline interviewed indicated that the profitability of airlines is to a large extent dependent on corporate/business travel

bookings that are managed by travel agents/ Travel Management Companies (TMCs) that in turn rely on CRSs to make

the bookings. 66 ERA highlighted the important role CRSs play in enabling fair competition between small and large carriers. One

operator noted that access conditions vary widely across MDMS platforms, with high integration costs and selective

policies disproportionately affecting smaller or regional operators. A large operator indicated that airlines may not have

difficulties in accessing MDMS platforms but have difficulties with the costs associated with this access, noting that for

some newer or smaller airlines, the cost may lead to a “negative business case”. 67 Two airlines and two airline associations in the interviews further argued that B2C platforms taking the feed from

CRSs gain unrestricted access to content without the need to negotiate commercial terms with air carriers. They also

argue that this dynamic, coupled with the limited bargaining power of smaller airlines, risks to further strengthen the

market power of both B2B and B2C MDMS providers. 68 One CRS mentioned that the inclusion of operators is based on “a positive business case driven by consumer demand,”

noting that factors such as API integration costs, commission levels, and maintenance fees determine feasibility. Another

CRS disagreed with the problem while cautioning that mandating access on operator-owned platforms could “reinforce

their dominant position” in distribution markets.

13

passenger kilometres. All of them also have one or more digital ticket sales channels, 19 of which are MDMS

platforms as they also sell tickets of other RUs or operators in other modes, while only 6 sell their own tickets

and are greyed out in the chart. The platforms owned by incumbent RUs have a very large customer base and

are the standard reference for rail ticket customers. National competition authorities and economic studies

consistently show that the vast majority of consumer searches and online ticket sales are concentrated on the

RUs with SMP’s proprietary digital channels (websites and mobile applications), while third-party ticketing

platforms account for only a limited share of transactions69. For example, the 2021 report of the

Monopolkommission70 shows that among major online platforms for long-distance rail tickets in Germany,

about 90% of website visits go to Bahn.de, indicating DB’s dominant position in online distribution markets71.

This renders the incumbent platforms an indispensable distribution channel for any rail operator offering

transport services in the respective national market. This is particularly the case of platforms that sell tickets

of multiple RUs, as customers may not realise that their offer is incomplete and are thus less likely to make

alternative searches. On the other hand, when it is clear for customers that they must look elsewhere to access

tickets of competing RUs, they are more likely to use competitors’ or independent platforms. Accordingly, in

the rest of this document, the ticketing platforms owned by incumbent RUs (the 19 in blue in Figure 4) are

referred to as ‘indispensable RU platforms’, but not when they do not sell third party tickets (the 6 in grey in

Figure 4).

Figure 4: Incumbent market share (in terms of pkm) in the passenger service market per Member State (2022)

Source: Rail market monitoring (RMMS), July 2025

Indispensable RU platforms often display only the offer of certain train services, excluding competing offers

despite those services being cheaper or more convenient for passengers. The exclusion of competing RUs or

other transport operators may also arise due to stringent integration requirements or high service fees72.

Evidence supports the concern of uneven access: the French transport authority (ART) found73 that new

entrants receive no visibility on incumbent rail platforms, which mainly display the incumbent’s own services

and those of its partners. For example, SNCF Connect does not display the offers of Trenitalia France. Similar

69 A Commission investigation into Renfe found that in 2021 Renfe’s own online direct channels accounted for 80-90%

of its total online ticket revenues (a fair proxy of the total size of the potential market for online rail ticketing services in

Spain), with third-party platforms representing only 10-20%. On this basis, the Commission took the initial view that

Renfe, as a vertically integrated dominant RU, holds a dominant position in the potential downstream Spanish online rail

ticketing market through its proprietary distribution solutions. However, the Commission recalled that Renfe’s potential

dominance in the Spanish online rail ticketing market had no bearing on the preliminary finding that Renfe’s dominant

position in the Spanish passenger rail market would likely be leveraged and lead to the elimination of effective

competition in the ticketing market (see Annex 11). In France, a 2024 study by Compass Lexecon estimated SNCF

Connect’s market share in the online distribution of rail tickets to the general public at 80-90%. In Sweden, the Swedish

Competition Authority found that alternative online channels represent only a marginal share of ticket sales and that the

vast majority of ticket sales by SJ and other RUs occur via SJ’s digital channels. A government public investigation

further highlighted the limited competitive constraint exerted by the neutral platform Resrobot, which recorded around

10,000 bookings in 2019 compared to approximately 25 million bookings through SJ’s digital channels (see Annex 11). 70 Monopolkommission, Rail 2021: Competition into the Timetable! 71 According to two industry associations and one NGO passengers primarily use indispensable RU websites for booking

rail tickets. This statement has been outlined by T&E, ADN Mobilités and AllRail during interviews. 72 As reported by All Rail and WestBahn in interviews. 73 Autorité de régulation des transports, Ouverture et utilisation des données de mobilité, February 2025 p.25

14

issues have been identified in Sweden in 2019, the Swedish Competition Authority examined allegations that

Statens Järnvägar (SJ) abused its dominant position in ticketing by excluding competitors’ tickets and altering

search visibility (see Annex 11). The large customer base, incomplete offer and lack of transparency of

indispensable RU platforms leads to many consumers not being aware of relevant offers: the 2025 FNAUT

Opinion Way survey74 shows that in France, despite over four years of operations, 55% of respondents have

never heard of Trenitalia and only 15% of respondents know it well. Similarly, 68% of respondents have never

heard of Renfe and just 11% know it well.

Example: On the ÖBB website, competing Westbahn services are only displayed in the trip planner,

without price, and without the possibility to buy tickets (and not at all in the booking section).

The targeted survey conducted in 2025, in the context of the impact assessment support study, revealed

opposing views between independent MDMS platforms and indispensable RU platforms, and other

stakeholders on whether they agree with problem 275. Most independent MDMS platforms that responded to

the survey (14 of 20) disagreed with problem 2, as did most indispensable RU platforms that replied (4 of 5)76,

outlining that their business model relies on offering a broad range of content and that any absence of operators

results from restrictive or economically unviable contractual terms imposed by those operators, or, in rare

cases, concerns about service quality. By contrast, only 8 of 31 transport operators – of which 4 own an

indispensable RU platform – disagreed with Problem 277 in the targeted survey, while 16 agreed78. In addition,

8 out of 13 national authorities that replied confirmed that some transport operators face uneven access to

platforms. Similarly, 7 out of 11 NGOs and consumer organisations surveyed agreed, noting that platforms

owned by railway incumbents dominate national markets and often restrict competitor access79.

MDMS platforms willing to sell do not have access to all (rail) offers

Passengers struggle to find and compare alternatives offered by RUs and are often unable to book their entire

journey through a single platform. The 2024 Eurobarometer survey on Multimodal Digital Mobility Services

shows that ticketing barriers are higher for rail journeys involving multiple RUs: 23% of respondents could

not find a suitable combination, 11% did not know how to find information and 9% could not buy all tickets

in one place. The higher barriers to finding single ticket journeys involving different RUs makes rail less

accessible and attractive for passengers and limits its potential to contribute to a more sustainable and

74 2025 Opinion Way survey for FNAUT 75 Since the survey was carried out, the problem tree has evolved, reformulating the problems and drivers identified. This

paragraph summarises the views of stakeholders on the following problem: Uneven access of operators to indispensable

MDMS platforms. 76 EUTT (an association representing independent ticketing platforms) and the MDMS platform Dohop confirmed that

operators are included based on commercial viability and that they have no incentive to discriminate. Indispensable RU

platforms added that integrating third-party offers can be disproportionately costly when expected demand is low. 77 16 out of 31 agreed, 7 neither agreed nor disagreed/did not know and 8 disagreed (including 4 incumbent RU) 78 Amongst those agreeing, AllRail stated that uneven access to indispensable RU platforms restricts competitor visibility

and hampers market entry. In a follow-up interview, Flix stated that DB’s ticketing platform reduces the visibility of

competing services, including by omitting price information or placing them in less prominent positions, despite legal

obligations on fair visibility, a practice also recognised by the Frankfurt am Main Higher Regional Court (see Annex 11). 79 They pointed to a gatekeeper effect that limits competition and consumer choice and highlighted the high technical,

financial, and commercial barriers faced by smaller operators when attempting to integrate with these dominant platforms.

15

multimodal transport system. It is therefore essential that platforms have access to tickets that RUs might not

have an interest in sharing, but that are necessary to establish a critical mass of travel offers, in view of the

number and scope of these connections and/or the lack of alternatives. This is the case of rail tickets for services

provided by a RU that has a very large market share in a geographical area (see Figure 5)80 or under a Public

Service Obligation (PSO) contract81 as well as in the case of cross-border services82. Accordingly, in the rest

of this document, operators of these services are referred to as “indispensable RUs”.

Figure 5: Market share of rail operators in 2022

Source: Rail market monitoring (RMMS), July 2025

A 2021 study conducted by St. Pölten University of Applied Sciences83 examined the bookability of

international rail journeys and found that approximately one third of customers fail to successfully purchase

international train tickets. The study involved 76 participants who attempted 46 European routes on 20

ticketing platforms. Rail bookings failed ten times more often than flights and generally took 15-30 minutes

to complete, compared to 5-10 minutes for flights.

In 2024, UFC Que Choisir compared train ticket offers on seven booking platforms in France84 and eleven

RU platforms across the EU85, analysing 24 routes86. No platform showed all available train options. Even the

most complete platforms, such as SNCF Connect and Trainline, lacked key international alternatives such as

Trenitalia and ÖBB night trains. Availability, prices, and key details such as class differences or discounts

varied widely and were often unclear until late in the booking process. Price differences for the same journey

could exceed 85%, and inconsistencies were also observed between platforms of partner RUs, such as SNCF

and Deutsche Bahn on the Paris-Frankfurt line.

80 As reported in the 9th monitoring report on the development of the rail market (SWD (2025) 239 final), in 2022, state-

owned rail incumbents held 87.4% of the overall EU commercial passenger rail service market and 79% share in public

service obligation (PSO) passenger services market. However, 13 countries still have a monopoly or a share of domestic

incumbent in PSO passenger-km over 99% in 2023. 81 Transport services awarded and operated in accordance with Regulation (EC) No 1370/2007. PSO passenger services

represented 59% of the total passenger kilometres in the EU in 2022 (SWD (2023) 288 final). A PSO contract provides

the RU the right (and obligation) to operate services on an, in principle, exclusive basis (on a network or on a bundle of

one or more railway lines) in most cases or at least on the biggest part of the network served. 82 In most cases there are no alternatives whilst cross-border rail services are highly relevant for EU connectivity and to

decarbonise intra-EU long-distance travel. 83 Preslmayr, T., Stütz, T., Gerstenmayer, T., & Kadam, H. (2021). International rail ticketing: stumbling block on modal

shift. Eisenbahntechnische Rundschau (ETR) Austria, No. 6, pp. 72–78. 84 SNCF Connect, Trainline, Tictatrip, Kombo, Omio, Rome2Rio, Rail Europe. 85 Trenitalia, Renfe, SNCB, Deutsche Bahn, NS International, ÖBB, ÖBB Nightjet, CFL, HZPP, CD and Eurostar. 86 UFC Que Choisir, Transport Ferroviaire ‘L’information tarifaire et les droits des consommateurs déraillent’, 2024.

16

A T&E study from 2025 compared special rail fares offered by RUs platforms and those available on

independent MDMS platforms in four Member States. It showed that operator-specific promotional fares are

often not accessible on third-party platforms, resulting in significantly higher prices for passengers who book

outside the operators’ own websites. The analysis covered routes in the Netherlands, Belgium, Denmark and

Italy and found substantial price differences. In the Netherlands and Belgium, tickets purchased via

independent platforms were on average 1.7 to 1.9 times more expensive than the special fares available directly

from the railway undertakings. In Denmark, the difference was even more pronounced, with platform prices

reaching up to six times the operator’s promotional fare. In Italy, where one special fare was partially available

on some platforms, prices were still around 16% higher on platforms that did not provide access to the

discounted offer.

A poll conducted by YouGov for the NGO Transport and Environment87 outlines similar results. The study

surveyed 10,514 adults across seven European countries88. Overall, 61% of long-distance rail users surveyed

faced difficulties while booking tickets. In total, 42% of participants wish to access more travel options on

booking platforms, and 45.6% of respondents wish to be able to book a trip easily and combine tickets of

different RUs on a single website. In addition, 43% of long-distance rail passengers surveyed state that they

would book more rail travel if ticket booking was easier.

In the targeted survey, there was a distinct split in views, with incumbent RUs participating in the survey

mostly disagreeing with the above-mentioned problem while there was broad support from respondents in

other stakeholder groups89. Only six transport operators out of 30 participating in the survey agreed with

Problem 2, mostly new entrant RUs, while one large national RU argued that offers should be displayed only

if they provide for a positive business case. On the other hand, all 20 independent MDMS platforms

responding to the survey agreed with Problem 2 as did all 11 ‘other’ stakeholders (including consumer

organisations, NGOs, individual experts). Consumer groups BEUC and EPF (European Passengers’

Federation) highlighted issues in international rail travel, as it involves multiple national RUs with different

booking systems, data standards, ticketing rules, refund policies, and real-time information protocols. Among

national authorities, 10 out of 13 responding to the survey agreed with the problem.

2.2. What are the problem drivers?

Four problem drivers were identified which are considered exhaustive – addressing them is expected to tackle

problems related to competition in the online ticket distribution market and foster completeness of the rail

offer on MDMS platforms. Nevertheless, it should be acknowledged that the objectives of promoting

multimodality and modal shift are also linked to other challenges, particularly those concerning infrastructure

use and development, interoperability, as well as passenger rights. These issues are being addressed through

other initiatives, for example, the 2023 proposal on the use of railway infrastructure capacity in the SERA90,

and infrastructure development under TEN-T91, while data exchange and standardisation have been addressed

through the functional and technical specifications for telematics applications (TEL TSI)92.

87 Transport & Environment, "Here’s what Europeans from 7 countries think of rail booking processes”, 22 October

2025, url: Here’s what Europeans from 7 countries think of rail booking… | T&E 88 France, Germany, Italy, Spain, Poland, Romania and UK. 89 Since the survey was carried out, the problem tree has evolved, reformulating the problems and drivers identified. This

paragraph summarises the views of stakeholders on the following problem: Limited and distorted information and access

to tickets for consumers on MDMS, in particular for rail. 90 2023/0271 (COD) 91 OJ L, 2024/1679, 28.6.2024 92 OJ L, 2026/253, 10.2.2026, p. 1.

17

2.2.1. Problem Driver 1: Regulatory framework no longer fit for purpose due to market and

technological changes in air ticket distribution (PD1)

This problem driver links to Problem 1 and reflects market and technological developments in air ticket

distribution since the 1980s, when the first Code of Conduct was adopted. At the time, air ticket distribution

was dominated by CRSs, whereas today it is a multi-pronged sector. The rise of sales through direct

distribution channels (by 4 percentage points from 2019 to 2024) is driven by increased internet penetration,

enabling EU consumers to book more easily via airline websites93 and indirectly through MSEs or OTAs. The

rise of direct connect systems (DCs) and NCAs is due to other technological and market developments94 (see

Annex 9).

Concerns arising from airline ownership of CRS providers was the original driving force behind the first CRS

Code of Conduct. In the current market situation, with no airlines having a controlling right in B2B MDMSs,

provisions of the Code of Conduct relating to parent carriers are no longer relevant. The cross-sectoral EU

acquis in other areas has also changed the legal landscape. New regulatory horizontal frameworks of the digital

economy have been introduced across the EU rendering some of the provisions of the CRS Code of Conduct

redundant and/or creating problems of coherence. These include Platform to Business Regulation (P2B)95

(and related guidelines) and changes to EU competition law (e.g. the revision of Vertical Agreements Block

Exemption Regulation and Vertical Guidelines96). As regards the processing, access and storage of personal

data, the GDPR97 is directly applicable and covers most of the issues currently regulated in Article 11 of the

Code98. Beyond this, the legislation on P2B contains an obligation for OTAs to be transparent about the

parameters they use to rank offers. This applies in all situations, whereas under the Code, travel agents are

obliged to use a neutral display, which goes beyond the P2B transparency obligations99.

At the same time, technological and market developments have led to the emergence of new and alternative

business models both in B2B and B2C sectors. In the B2B sector, NCAs are taking an increasingly important

place in the market. Their growth can be explained in part by the technology they use, which gives airlines

greater flexibility compared to CRS100 and by the restrictive nature of CRS arrangements (such as parity

clauses)101. This has led to the emergence of platforms that perform similar functionalities but are not subject

to the Code of Conduct, including on neutral display obligations and related rules and thus benefit from fewer

compliance burdens. This uneven playing field may discourage investment in technological advancement

93 Ricardo et al. (2026), Study supporting the RMB and RTR Impact assessment. Most of the legacy carriers responding

to the targeted survey indicated an increase in direct “own” distribution channels while some indicated also an increase

in the share of NDC-based distribution in the period 2015-2019 94 Ricardo et al. (2026), Study supporting the RMB and RTR Impact assessment. NDC technology allows linking carriers

directly with TAs and cheaper distribution through NDC aggregators. The share of tickets distributed with NDC

technology is expected to increase as a report (Accenture, 2021) highlighted that after the outbreak of the Covid-19

pandemic, airlines have increased their investments in Direct Connect systems. 95 OJ L 186, 11.7.2019, p. 57–79. 96 OJ L 134, 11.5.2022. 97 OJ L 119, 4.5.2016, p. 1–88. 98 According to the majority of stakeholders consulted during the evaluation, the GDPR is enough to guarantee data

protection and therefore Article 11 of the Code of Conduct can be repealed. 99 Art 5(2) of the Code of Conduct states that when information is provided by a CRS to the consumer, the travel agent

(subscriber) shall use a neutral display, unless another display is required to meet a preference indicated by a consumer. 100 Airlines increasingly value customisable bundle fares and the ability to offer different services, which is limited in

CRS providers using Electronic Data Interchange for Administration, Commerce and Transport (EDIFACT) which is a

more static standard, while allowed by NDC technology used by NCAs and not always fully implemented by CRS

providers. This lack of adaptability is driving some airlines, to shift sales to NDC channels where they can retain control

over pricing and product design. 101 In the interviews a NCA explained that “A key concern is the dominance of three main CRSs in Western Europe,

which impose restrictive "full content agreements" on airlines. These agreements force airlines to offer identical content

across all sales channels, limiting their ability to tailor pricing or offers based on the channel's cost. This restriction,

coupled with technical limitations of the CRSs - such as their inability to support fare brand displays - hampers innovation

and reduces consumer choice”.

18

among CRS providers and hinder their ability to compete on equal terms. On the other hand, travel agents and

Travel Management Company (TMCs) may be disincentivised from innovating their distribution tools if this

would result in the loss of incentives. This diverging regulatory environment may reduce incentives to

modernise distribution and delay the emergence of innovations.

In the targeted survey, in which stakeholders have been asked to indicate to which extent this problem driver

sufficiently identifies the causes of Problem 1102, 26 of 65 agreed, 11 stakeholders partially disagreed and 28

stakeholders neither agreed nor disagreed (3) or did not know (25). 13 of 18 MDMS platforms surveyed

agreed, while 5 did not know. In relation to transport operators expressing a view, 11 out of 27 partially

disagreed with problem driver 1 identifying the causes of Problem 1, while 2 out of 27 agreed. Moreover, 14

out of 27 transport operators surveyed neither agreed nor disagreed (1) or did not know (13). The large number

of ‘don’t know’ can be explained by many transport operators expressing a view not being in the air sector. 7

airlines and 3 airlines associations recognised the importance of the CRS Code of Conduct, stating this plays

a vital role in protecting airlines from discriminatory practices by CRSs. Many stakeholders surveyed

nonetheless stated that the Code of Conduct needs to be revised to extend it further to reflect recent

technological developments in distribution103.

"Regarding the CRS regulation, [the air carrier organization] agrees it is a good framework but considers it

outdated and too narrow in scope. They propose repealing and replacing it with a broader regulation that

covers not only CRS but also new aggregators like Travelfusion and OTAs." An air carrier organization in

interviews

2.2.2. Problem Driver 2: Commercial incentives of MDMS platforms to promote certain

operators or products (PD2)

This problem driver links to Problem 1. MDMS platforms do not always act as neutral intermediaries, and

their display is often influenced by commercial agreements in which operators pay for prominence. This is the

case not only for indispensable MDMS platforms but also for smaller ones like for NCAs and B2C MDMS

platforms (such as OTAs and MSEs) which are not currently subject to the CRS Code of Conduct or to similar

requirements to offers displaying in an unbiased manner.

Firstly, these platforms tend to favour high-volume operators, creating more profitable partnerships, reducing

technical complexity and boosting revenues. As one-stop shops for searching, comparing, and booking travel

(especially flights) they can influence consumer choices. With no rules governing how results are displayed,

information may be incomplete or ranking algorithms biased, giving an advantage to operators who pay higher

commissions or have preferential agreements, despite rules on unfair commercial practices (as outlined in

section 1.2). Cheaper, more convenient, or complex options may be ranked lower or excluded, potentially

misleading consumers into thinking the displayed options are the best available when alternatives exist. This

risk has further developed with the increasing use of AI, as algorithmic bias could further skew results toward

certain transport modes or operators, and the lack of transparency in AI-driven rankings may undermine

consumer trust, particularly if commercial partnerships influence outcomes, with dynamic pricing and

personalised offers that risk exploiting users through opaque or discriminatory fare structures. In the context

102 Since the survey was carried out, the problem tree has evolved, reformulating the problems and drivers identified. This

paragraph summarises views of stakeholders on the following question: to what extent do you agree that this problem

driver sufficiently identifies the causes of potential distortion of competition between regulated CRS and non-regulated

B2B distribution channels performing similar functions to CRS 103 5 airlines and one other industry group advocated for the extension of the non-discrimination and neutrality provisions

to all MDMS platforms, including unregulated actors like OTAs, and emphasise the need for effective enforcement

through national authorities. These stakeholders also stated that the revision should reflect technological advancements

and ensure robust compliance mechanisms.

19

of the study supporting the evaluation of the CRS Code of Conduct104, some stakeholders have reported

concerns about MSE engaging in unfair competition and promoting options to certain websites and carriers to

the detriment of others. A key issue is the perceived bias stemming from paid prominence or from their

affiliation with controlling OTAs, which may distort fair market conditions105.

Most stakeholders who participated in the targeted survey agreed problem driver 2 sufficiently identifies the

causes linked to the problems identified106, including 18 of 31 transport operators107. Surveyed MDMS

platforms and RUs with SMP expressed stronger levels of disagreement108. 9 out of 11 national authorities

and 8 out of 11 ‘other’ stakeholders who participated in the survey also viewed problem driver 2 as significant.

However, the consumer organisation EPF stressed that the real issue lies in operator SMP and the restrictions

they impose in contractual agreements rather than in commercial bias of independent MDMS platforms. 13

MDMS platforms stated that problem driver 2 was an issue that mainly arises in the context of vertically

integrated platforms, where there is a clear incentive for self-preferencing, linking back to problem driver 4109.

The second aspect of the problem driver involves the difficulties associated with sharing data with public

authorities and the display of GHG emissions on MDMS platforms. Many MDMS platforms consider that

sharing data with public authorities is sensitive due to perceived competition (when public authorities have set

up their own MDMS platforms), and data privacy issues. In addition, MDMS platforms may lack commercial

incentives to show GHG emissions, as those might disadvantage higher-emission options of carriers with

whom they have good commercial relationships. This represents a missed opportunity for transport planners

and infrastructure management authorities to use already existing data to improve the overall performance of

the transport system. In interviews, most stakeholders underscored the importance of raising passenger

awareness regarding the environmental impact of their travel choices. MDMS platforms mostly highlighted

barriers in displaying GHG emissions linked to barriers in obtaining accurate and homogenized data110.

Counterbalancing this, rail operators have increasingly sought to demonstrate their environmental efficiency,

yet CER stressed how this effectiveness is dependent on presenting emissions in a broader multimodal context,

104 European Commission: Directorate-General for Mobility and Transport, GA&P and Ricardo, Support study for the

ex-post evaluation of regulation 80/2009 on a code of conduct for computerised reservation systems – Final report,

Publications Office, 2020 105 Reported in interviews in the context of the Support study for the ex-post evaluation of regulation 80/2009 on a code

of conduct for computerised reservation systems by CRS providers, travel agents and a technology company. 106 Since the survey was carried out, the problem tree has evolved, reformulating the problems and drivers identified. This

paragraph summarises views of stakeholders on the two following questions: to what extent do you agree that this problem

driver sufficiently identifies the causes that lead to uneven access of operators to indispensable MDMS platforms and to

limited and distorted information and access to tickets for consumers on MDMS, in particular for rail.107 Airlines’ associations, including the European Regions Airline Association (ERA), shared concerns about rankings

bias, prioritisation and limited transparency on major B2C MDMS platforms, fearing that transport operators paying

higher commissions for prominence of their offer in the display may be favoured (reported by 1 MDMS industry

association, ECTAA and Snälltåget). One airline criticised models where paid placement influences search results,

arguing instead for neutral display and against default settings which can bias user choice. One transport operator

specified that the Code of Conduct should be extended or updated to apply its core principles, such as transparency, equal

access, and fairness, to all MDMSs. Another large airline reported that CRSs, OTAs and MSEs promote certain operators

due to booking fees, incentives, or ranking manipulation. AllRail echoed those concerns in rail, noting discriminatory

practices by incumbent RUs’ platforms. They cited DB’s willingness to sell tickets from other state incumbents (e.g.

ÖBB), but not from independent RUs (like European Sleeper or Westbahn). Both WestBahn and AllRail pointed out that

DB Navigator’s default “fastest connection” setting favours DB’s high-speed services and pushes competitors down the

rankings (see Annex 11). 108 8 of 19 MDMS platforms disagreed that pd2 led to limited and distorted information on mdms platforms and 13

disagreed that it led to uneven access to indispensable MDMS platforms and 4 of 5 RUs with SMP ‘fully’ disagreed

that problem driver 2 leads to both problems. 109 A major MDMS provider and a travel agency said they have no incentive to favour specific operators, as their

models depend on comprehensive, neutral content to serve consumer needs. 110 Three interviewed MDMS providers highlighted a lack of collaboration among operators in supplying consistent greenhouse gas

data, further impeding the effectiveness of any disclosure regime. Two other MDMS highlight the difficulties stemming from diverse

calculation methodologies employed by operators, which complicate cross-border travel assessments and undermine the granularity

and comparability of available data.

20

thereby allowing passengers to weigh options appropriately.

“Yes, some MDMS platforms might cherry-pick high-margin services and exclude others, and this is a

significant issue. We advocate for regulations requiring platforms to display the full range of relevant services

without discrimination, ensuring customer choices are based solely on their preferences, not commercial

interests”. New entrant RU in an interview

“The SNCF Connect App and vending machines usually only propose high speed TGV services and ‘forget’

to mention alternative itineraries by intercity trains. One example is the trip from Nantes to Bordeaux: the

SNCF systematically proposes a TGV ticket Nantes-Paris-Bordeaux, while there is a better alternative in

terms of duration and price with the intercity line Nantes-Bordeaux”. European Passenger Federation (EPF)

2.2.3. Problem Driver 3: Imbalanced commercial relationships between indispensable MDMS and

transport operators (PD3)

This problem driver links to Problem 1. MDMS platforms with a strategic position or significant presence in

a distribution market can impose restrictive commercial terms harming competition and limiting transport

operators’ ability to access and use indispensable MDMS platforms.

Among MDMS, CRSs are intermediaries connecting airlines with hundreds of thousands of travel agents,

TMCs and OTAs worldwide. CRS providers offer financial incentives, proprietary technology, and free

training to their subscribers (travel agents), which strongly encourages travel agents to remain loyal to the CRS

(single homing). 111 Switching to another CRS would be costly, technically complex, and offer little benefit

since all CRSs typically offer the same content due to parity clauses112. Switching to new content aggregators

would be even more cumbersome as it would imply losing these benefits and incur the costs of switching to a

new technical standard. This ecosystem makes CRSs an unavoidable commercial partner for all air carriers,

travel agents and TMCs and in practice, airlines are often forced to conclude agreements with every major

CRS to tap into their large networks (see Annex 9 for further details).

Between 2019 and 2024, travel agents (including OTAs) utilising CRS platforms accounted for 45% of the

total revenues for air trips inside the European Economic Area (EEA), 70% for trips with one leg departing

from or arriving in the EEA and 85% for trips outside the EEA, respectively113. While the limited integration

of new B2B content aggregators, such as AirGateway, Duffel, Hitchhiker, Travelfusion, Verteil with TMC

systems currently constrains their reach, they are already connecting more airlines using a new connectivity

standard114, are increasing their market share and are emerging as competitive alternatives to CRSs, which

calls to extend to them the retained rules from the CRS Code of Conduct, despite their market share. These

NCAs are the new gateways to travel agents and ultimately to consumers, thus creating a strategic market

position that may allow them to restrict access to transport operators, in particular smaller transport operators.

In the B2C sector, MDMS platforms with SMP are also essential gateways to travellers. This is most obvious

in the rail sector with indispensable RU platforms who have inherited quasi-monopolistic positions in the

operational sector with strong brand recognition for distribution. Such practices lead to limited rail booking

possibilities: the 2025 T&E study115 shows that on the EU’s 30 busiest aviation routes under 1500 km, the rail

alternative is in 20% of cases not bookable at all and in 27% of cases bookable only on one RU platform.

111 According to the impact assessment support study, the average financial incentives to travel agents are approximately

around 2-3 EUR per flight segment. Lufthansa highlighted that incentives are based on how much travel agents sell or

which airline they sell, making it hard for new entrants and reducing competition, limiting innovation and keeping the

market controlled by a few players. An airline industry association stated that this creates a dependency of airlines vis-à-

vis CRSs. 112 Contractual provisions requiring airlines to provide the same flight content and prices to a CRS as to other distribution

channels, preventing airlines from offering better or differentiated terms elsewhere. 113 Ricardo et al. (2026), Study supporting the RMB and RTR Impact assessment, market report. 114 A4E-intermediaries-study_FINAL-02.pdf on the impact of online intermediaries on consumers and carriers. 115 Transport & Environment (2026). Bringing the EU’s rail ticketing regulation out of the stone age

21

During the targeted survey across stakeholders participating, 36 out of 72 agreed that problem driver 3 leads

to uneven access of operators on indispensable MDMS platforms116, 23 disagreed. Six were neutral and seven

did not know. Most stakeholder groups surveyed agreed with problem driver 3, except MDMS platforms

expressing a view, where 13 of 20 disagreed. Among transport operators surveyed, 17 out of 30 agreed and

six disagreed. 9 out of 12 national authorities surveyed and 5 out of 10 ‘other’ stakeholders surveyed agreed.

MDMS platforms expressing a view tend to reject problem driver 3, expressing disagreement in both the

survey and during interviews117. Nonetheless a majority of stakeholders from all stakeholder groups agreed

that problem driver 3 leads to limited and distorted information on MDMS platforms118. Indeed, 13 of 19

MDMS agreed, as well as 16 of 31 transport operators, 9 of 11 national authorities and 8 of 11 ‘others’.

“It is important to bear in mind that regional airlines do not benefit from the economies of scale that major

carriers enjoy, which makes it increasingly difficult for them to assert themselves in a distribution market

dominated by the major OTAs and meta-search engines. Many of these platforms operate as gatekeepers,

prioritising certain airlines based on commercial agreements and often to the detriment of smaller carriers.

This limits consumer choice and creates an uneven playing field, where regional airlines struggle to gain

visibility despite offering connectivity to peripheral, insular and remote regions across Europe”. ERA in the

targeted survey

2.2.4. Problem Driver 4: Vertical integration of railway undertakings and rail ticketing

platforms hinders wider ticket distribution (PD4)

This problem driver is specific to the rail sector and is the cause of Problem 2, that is the lack of a complete

offer of rail tickets on rail platforms and on MDMS in general. Most incumbent RUs have inherited SMP in

both the transport service and the ticket distribution market and can leverage their strength in one market to

maintain a strong position in the other119. In other words, they can weaken the position of competing platforms

by denying them access to their transport offer and can harm competitors in the transport market by denying

them presence on their ticketing platform. With progressive market opening, new-entrant RUs are expanding

their offer in the Union but lack fair access to indispensable RU platforms120. For the reasons explained above,

the latter do not necessarily behave like independent platforms seeking to provide the broadest range of travel

offers but often have an interest in not giving visibility to their direct competitors in the transport services

market, thereby forcing new entrants to rely on alternative channels, incur higher entry costs and creating a

significant barrier for smaller and new RUs121. The refusal of vertically integrated platforms to grant access to

new RUs, coupled with the refusal of incumbent RUs to share their full offer with independent platforms, is

thus the key driver limiting the development of the ticketing market in rail. The existence of this problem

driver is evidenced by the competition cases listed in Annex 11.

116 Since the survey was carried out, the problem tree has evolved, reformulating the problems and drivers identified.

However, responses from stakeholders on whether they agree with problem driver 3 as a driver leading to the old problems

are still relevant. 117 Arguing that airlines use their market power to impose unfavourable terms, including low commissions for smaller

MDMS and preferential treatment for high-volume platforms, content restrictions or surcharges leading to non-

transparent pricing. Stated by 9 MDMS including ECTAA, EU Travel Tech, FTO, SRF, Skyscanner and Welcome Travel

Group SpA. In addition, 2 CRSs and one MSE, explained in interviews that some air operators retain lighter fares or

impose surcharges, resulting in non-transparent pricing and constrained consumer choice. In contrast, larger air carriers,

which participated in the survey, argue that applying surcharges are intended to offset high CRS booking fees where full

content agreements are not in place. 118 Since the survey was carried out, the problem tree has evolved, reformulating the problems and drivers. Responses

from stakeholders on whether they agree with problem driver 3 as a driver leading to the old problems are still relevant. 119 See footnote 69. 120 During the targeted survey, new rail entrants highlighted that access to indispensable RU platforms is essential for

commercial success (statement from European Sleeper and another new entrant). 121 Statement from All Rail in interviews.

22

Limited willingness of indispensable RUs to provide their full offer on fair terms to MDMS platforms

In many cases, incumbent RUs have their own vertically integrated platform (e.g. DB Navigator and SNCF

Connect) which already provides a very large customer base and competes with third-party platforms. For

RUs with SMP, avoiding direct comparison with emerging competitors, on any platform, also helps them to

retain a strong position in the transport market. As a result, incumbent RUs have little interest in providing

their full offer to other distribution channels, since they have little to gain in terms of additional customer base

and much to lose in strengthening a competing platform. For Public Service Obligation (PSO)122 operators,

who, depending on the contract structure, are less sensitive to market demands, there is also less incentive to

have their tickets displayed and sold on third-party MDMS platforms. Finally, it is observed that some RUs

running cross-border services (e.g. Paris – Brussels) share with third-party platforms only high-value tickets

for those services, since passenger segments that are not reached through their own distribution channels, such

as international travellers, are typically expected to generate only marginal additional sales.

This reluctance to share rail ticketing content, or to share it on fair terms, has triggered competition law

enforcement at both EU and national level. In June 2023, the German competition authority found that

Deutsche Bahn had abused its market power vis-à-vis mobility platforms and ordered it to provide platforms

real-time passenger service data, remove restrictive contractual clauses, and ensure fair compensation for third-

party ticket sales, subject to further legal proceedings.

The targeted survey confirmed the relevance of the limited willingness of incumbent RUs to provide their full

offer on fair terms to MDMS platforms, as a majority of stakeholders surveyed agreed (39 of 74)123. By

contrast, only 4 of 31 transport operators participating in the survey agreed, mainly new entrant RUs, while all

large RUs with significant market presence ‘fully’ disagreed124. Of the respondents in the ‘others’ category

(including consumer organisations, NGOs and independent experts) 10 of 11 agreed125 as well as 8 of 12

national authorities. Among independent MDMS platforms, 17 of 20 respondents agreed. 13 independent

MDMS platforms and their industry associations126 stressed that dominant or incumbent transport operators

often restrict access to full content or impose unfair terms, citing practices such as withholding low fares,

applying penalties linked to look-to-book ratios, or offering very low commissions. In addition, five MDMS

platforms and associations noted that both dominant RUs and major air carriers actively shape ticket

distribution markets to favour direct sales.

A Court of Appeal case found that the latest SNCF agreements with ticket platforms for the 2023-2027 period

established a progressively decreasing fee, beginning at 3% from January 2023, then decreasing to 2.9% until

the end of 2024, 2.8% for 2025–2026, and 2.7% in 2027 for all SNCF products. This declining commission

policy appears designed to favour large sales volumes and may advantage SNCF’s own distribution

subsidiary (SNCF Connect). Furthermore, distributors individually negotiate variable commissions and may

receive discounts on the additional costs to access the SNCF offer portal; the access costs to the SNCF offer

portal are likely not borne equally among travel agencies, with some benefiting from volume-based rebates.

In Spain, the European Commission opened a formal investigation on 28 April 2023 assessing whether Renfe

abused its dominant position in the Spanish passenger rail transport market. The investigation found that

Renfe’s revenues from its tickets sold through Renfe’s direct channels accounted for 80-90% of its total online

sales, while revenues from the indirect online sales through Third-party Ticketing Platforms accounted for

122 Transport services awarded and operated in accordance with Regulation (EC) No 1370/2007. 123 Overall, 39 of the 74 respondents ‘partially’ (29) or ‘fully’ (10) agreed that problem driver contributes to problem 2. 124 The SNCF Group stated that it does not see a lack of willingness to share information, attributing the issue instead to

technical and financial barriers such as limited interoperability, high development costs and resource constraints. 125 Consumer organisation EPF also highlighted interoperability as a key obstacle to seamless EU ticketing but recognised

the limited willingness of indispensable RUs to provide their full offer on fair terms to MDMS platforms as a key issue,

particularly concerning incumbent RUs. 126 including ECTAA, EU Travel Tech, Federazione Turismo Organizzato (FTO), SRF, ADN Mobilités, Dohop, ECTAA,

Skyscanner

23

the remaining 10-20%127. In addition, the Commission expressed preliminary concerns that Renfe refuses to

supply its full Content (e.g. special fares) and real-time data to third-party ticketing platforms and that such

refusal to supply may constitute an abuse of Renfe’s dominant position prohibited by Article 102 TFEU.

Limited willingness of incumbent RUs to host their competitors’ offer on their platforms

Vertical integration also allows RUs to protect their position in the market for rail transport services by refusing

competing RUs access to the indispensable ticketing platform they own. They may also choose to include

only competitor’s services they consider complementary to their own and exclude directly competing service

offerings. This is evidenced by the competition cases quoted in Annex 11.

During interviews in the context of the impact assessment support study, independent MDMS providers, new

entrant RUs, national authorities, consumer organisations and NGOS128 largely agree with the limited

willingness of indispensable RU platforms to host their competitors’ offer. Two industry associations and one

NGO129 confirmed that this situation creates great barriers to entry for competitors on the rail market, and the

EPF qualified in interview this behaviour as protectionist and anti-consumer. On the other hand, four of five

RUs with SMP, including their industry association, disagreed with this driver, and stressed the importance of

keeping their freedom to make their own commercial agreements, to help ensure good service on their

platforms and clear responsibilities. Three RUs with SMP, including their industry association130 denied

limited willingness to fairly display competitors’ offers and assured that they aim to show all options fairly.

Overall, in the targeted survey, 38 of 70 stakeholders agreed that this driver leads to limited and distorted

information. Transport operators are the only stakeholder group with a majority of respondents opposing this

driver with 17 of 30 disagreeing, although all three new entrant RUs interviewed agreed, expressing concerns

regarding their lack of access to indispensable RUs131.

In 2019, the Swedish competition authority (Konkurrensverket) issued a decision and wrote a letter to the

Swedish Ministry of Infrastructure in relation to the dominance in ticketing of Statens Järnvägar (SJ), the

Swedish state-owned passenger incumbent RU. SJ was investigated by the Swedish Competition Authority

(SCA) over allegations of abusing its market position, specifically by refusing to sell competitors’ tickets on

its platform. In the investigation, the SCA noted that SJ’s strategy was not business neutral.

2.3. How likely is the problem to persist?

2.3.1. Problem 1: Lack of transparency, unfair conditions, and uneven playing field in the online

ticketing market

An uneven playing field in the online ticketing market is expected to persist. This is also the view of 42 of 66

stakeholders surveyed, who believed problem 1 to either remain (16) or deteriorate (26) over time. While some

Member States have introduced rules to regulate how transport operators integrate into MDMS platforms,

these frameworks differ significantly, leading to regulatory fragmentation. As a result, inconsistent or missing

national frameworks will continue to limit EU-wide service coverage and make it harder for MDMS providers

to enter the market. Without specific safeguards against abuses of market power, particularly in the rail sector,

access conditions to indispensable platforms are unlikely to improve. In B2B distribution, CRSs are expected

to remain indispensable, especially in air transport, and uneven access is likely to continue. Despite growing

use of alternative channels, airlines and travel agents still rely heavily on CRSs. Smaller carriers may continue

127 Revenues from ticket sales through the Third-party Ticketing Platforms Omio, Trainline, Rail-Europe and El Corte

Inglés accounted for 0-5%, 0-5%, 0-5% and 0-5%, respectively, of Renfe’s total revenues from online sales. 128 9 of 16 independent MDMS platforms and their industry associations, 5 of 5 new entrant RU, 7 of 10 national

authorities and 10 of 12 ‘other’ have agreed to this problem driver. 129 This statement has been outlined by T&E, ADN Mobilités and AllRail during interviews. 130 CER, Czech Railways and another RU. 131 During interviews, four new entrant RUs including their industry association (these include WestBahn, Snälltåget and

AllRail) expressed concerns over the lack of fair access to indispensable RU platforms.

24

to face competitive disadvantages with no clear indication that access conditions will improve for them

without further regulatory action132. Without further EU level intervention, distortion of competition between

regulated and non-regulated B2B channels is likely to persist. This view was shared by 29 of 66 stakeholders

in the targeted survey, who either believe the problem to remain (7) or deteriorate (22) over time. There is no

strong indication that the gradual shift toward non-CRS ticket distribution, including NCAs, will reverse.

Large airline groups are expected to continue promoting direct bookings and non-CRS aggregators, potentially

further reducing the share of bookings covered by the CRS Code of Conduct. Nonetheless, for smaller carriers,

CRSs will remain an important tool to achieve visibility and compete with the larger carriers. For large airline

groups, CRSs will remain important to reach the corporate segments and leisure travellers in markets where

the airline’s brand is not well known.

2.3.2. Problem 2: Incomplete offer of rail tickets on (rail) platforms

Without EU level action addressing the underlying drivers, the problem is expected to persist. Overall, in the

targeted survey, 44 of 67 stakeholders expect Problem 2 to remain (20) or deteriorate (24) over time. Some

MDMS platforms may expand their coverage, but only when clear business opportunities exist and if transport

operators are willing to cooperate. RUs with SMP dominate operations and distribution and have little

incentive to open their platforms to competing transport operators and supply their ticketing offer to competing

platforms. This is unlikely to change in the medium term, given the observed pace of market development

since the introduction of competition in domestic rail markets133. As a result, indispensable RU platforms are

unlikely to provide consumers a comprehensive overview of rail journeys. While some long-distance rail

services may gradually appear on independent MDMS platforms, this will not address Problem 2 until these

platforms reach a significant market share, which is also unlikely in the medium term134. Until that happens,

new entrants that rely on those platforms will face limited visibility and sales.

3. WHY SHOULD THE EU ACT?

3.1. Legal basis

Title VI (Articles 90-100) of the TFEU establishes the EU’s prerogative to make provisions for the Common

Transport Policy.

3.2. Subsidiarity: Necessity of EU action

Although some challenges in online ticket distribution and digital access to rail tickets are being addressed

nationally or regionally, their cross-border impact on long-distance intra-EU travel requires an EU-wide

approach to ensure the smooth operation of the European transport system. Discrepancies between Member

States in implementing new rules for online ticket distribution could further fragment the market, raise costs

and reduce benefits for MDMS platforms, authorities, operators and transport users. EU-level intervention is

132 Transport operators are the stakeholder group that appeared the most concerned about the persistence of this problem

over time, with 17 of 30 expecting deterioration. Non-incumbent RUs highlighted how the market will continue favouring

incumbents and worsen discrimination while two airline industry association highlighted the growing influence of large

OTAs and MSEs that will continue promoting certain operators or products based on their own commercial interests. On

the contrary, five independent MDMS platforms/ industry associations highlighted that they do not believe this problem

to reflect market reality and therefore do not foresee this problem to improve nor deteriorate. 133 11 of 16 MDMS platforms that replied to the targeted survey believe that Problem 2 will deteriorate. MDMS industry

association ADN Mobilités believes that without legislative intervention, “independent vendors will continue to struggle

and ultimately leave the European market” leading to reduced consumer choice, particularly for cross-border and

multimodal travel. 134 This analysis was not shared among incumbent rail and public transport operators, with 6 of 8 surveyed indicating that

Problem 2 is not currently a major issue, largely because industry-led initiatives like the CER Ticketing Roadmap and

OSDM implementation are already addressing cross-border ticketing and integration. In contrast, two new entrants

highlighted their lack of visibility on key ticketing platforms as a key challenge likely to persist.

25

needed to prevent divergent strategies with unintended effects.

3.3. Subsidiarity: Added value of EU action

This initiative will enable end users and, in the case of B2B services, subscribers to benefit from a greater

choice of tickets, displayed in a fair and transparent way, across transport operators and modes, in particular

for rail. This should in turn improve the functioning of the internal market, through a smoother and more

coherent booking experience for passengers, and support the EU's objective of economic, social and territorial

cohesion. Action at EU level with horizontal rules would support a better functioning of the online ticket

distribution market, removing obstacles for operators and platforms, and enhancing the attractiveness of rail

which in turn would support EU level objectives of greening the transport sector.

EU level action for B2B ticket distribution would continue to promote a level playing field in the sector. The

2020 ex-post evaluation of the CRS Code of Conduct concluded that the EU level is the right level for such

intervention, compared to national and international intervention. This is due to the multi-national nature of

both CRS providers and aviation services. If regulated at the national level, CRS providers would need to

adapt to a multitude of regulatory regimes with negative impacts on efficiency. In addition, the risk of “rule

shopping” would result in fragmentation of the EU single market. At the international level, the International

Civil Aviation Organisation (ICAO) has adopted a non-binding CRS Code of Conduct. However, the EU

CRS Code of Conduct is binding, making it more effective and adding value compared to the Member States

adopting the ICAO code.

4. OBJECTIVES: WHAT IS TO BE ACHIEVED?

4.1. General objective

The first general objective is to enhance the attractiveness of rail, by making more of the existing offers easily

available on online ticketing platforms and fostering combinations of those products, also for multi-operator

journeys, into single tickets. This is expected to encourage modal shift and thereby contribute to the Green

Deal objectives. The second general objective of these initiatives is to support a better functioning of the online

ticket distribution market (both B2B and B2C), contributing to the competitiveness and functioning of the

transport services market. This would in turn enhance the ability of passengers to compare, access, and book

tickets within and across modes, promoting collective transport and promoting multimodal trips. The

initiatives also support the two key priorities for the transport system described in the Sustainable and Smart

Mobility Strategy: decarbonisation and digitalisation of the EU transport sector. They contribute towards

SDG#3 (“Ensure healthy lives and promote wellbeing for all at all ages”), SDG#9 (“Make cities and human

settlements inclusive, safe, resilient and sustainable”) and SDG#13 (“Climate Action”) by promoting a more

multimodal and sustainable transport system.

4.2. Specific objectives

The two specific objectives (SOs) and their correspondence with the problem drivers, as well as the general

objectives, are presented in Figure 6.

26

Figure 6: Correspondence between the specific objectives and the problem drivers

SO1: Improve transparency and establish a level playing field for transport operators in terms of access

and use of indispensable MDMS. This specific objective links to problem drivers 1, 2 and 3. This initiative

aims to ensure that indispensable MDMS, which serve as key gateways for ticket sale, do not create bias or

restrict access to transport operators (in all modes) by imposing unfair conditions. In doing so, it seeks to create

a level playing field where transport operators can compete fairly in the national, EU and international markets.

Moreover, the objective is for MDMS platforms to offer clear, accurate, and unbiased information on available

routes, fares, and ticketing conditions across the EU, enabling end-users to easily find and compare various

travel options when planning and booking multimodal or multi-operator journeys. This objective is aligned

with the SSMS goals to improve the competitiveness of the EU transport sector and on “making connected

and automated multimodal mobility a reality”. Success will be defined by a measurable increase in number of

agreements between transport operators and MDMS platforms indicating a better functioning of the

distribution markets (B2B and B2C). Moreover, success will also be defined as a decrease of the average

expenditure per person for interurban mobility, due to an increase in competition resulting from better access

and use of indispensable MDMS for transport operators.

SO2: Improve completeness of rail offer on MDMS platforms, including indispensable RU platforms. This

specific objective links to problem driver 4. This initiative aims to ensure that rail offers are fully and fairly

displayed on MDMS platforms, including on indispensable RU platforms. To achieve that, it aims to remove

practices where indispensable RU platforms exclude, deprioritise or apply discriminatory conditions to rail

services not operated by the RU that owns them, even when such alternatives may offer better prices, faster

connections, or greater convenience for passengers. By doing so, the initiative intends to remove market

distortion and enhance fair competition in the railway services market and thereby facilitating seamless access

to multi-operator and cross-border rail journey options for end-users. The initiative also aims to ensure RU do

not withhold their offer from MDMS platforms to maintain the dominant position of their in-house ticket

distribution platform. Success will be defined by a measurable increase in the transport activity by rail due to

better visibility and access to these services. This is a meaningful indicator of passengers’ ability to find,

compare, and purchase rail tickets.

Problem Drivers (PD) Specific Objectives (SO)

PD1: Regulatory framework no longer fit

for purpose due to market and

technological changes in ticket

distribution

PD3: Imbalanced commercial relations

of indispensable MDMS platforms and

transport operators

SO1: Improve transparency

and establish a level playing

field for transport operators in

terms of access and use of

indispensable MDMS

PD4: Vertical integration of railway

undertakings and rail ticketing platforms

hinders wider ticket distribution

PD2: Commercial incentives of MDMS

platforms to promote certain operators or

products

SO2: Improve completeness

of rail offer on MDMS

platforms, including

indispensable RU platforms

General Objectives (GO)

GO1: Promote rail single

ticketing for multi-operator

journeys and thereby

enhance attractiveness of rail

to increase sustainability of

the transport system and

support modal shift

GO2: Better functioning of

the online ticket distribution

market, contributing to the

competitiveness and

functioning of the transport

services market

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5. WHAT ARE THE AVAILABLE POLICY OPTIONS?

5.1. What is the baseline from which options are assessed?

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

of the ‘Fit for 55’ package135 and the amendment of the European Climate Law to include a 2040 climate

target for the EU136, 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 vehicles137, the Euro 7 standards138, the revised TEN-T

Regulation139, as well as the initiatives part of the Greening Freight package140 and Roadworthiness

package141. 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 scenario assumes no further EU level intervention beyond the

ITS Directive142 and the Delegated Regulation on multimodal travel information services (MMTIS)143. The

CRS Code of Conduct144 would continue to apply. More details on the baseline scenario assumptions and

results are provided in Annex 4 (section 2). The baseline also incorporates perspectives on potential future

developments captured in the 2022 Strategic Foresight Report145 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 sector146. In particular, the projected transport activity draws on the long-term population

projections from Eurostat and GDP growth from the Ageing Report 2024147. 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 total number of passengers in the EU travelling by air, coach (excluding local and suburban public

transport), rail and waterborne transport is projected to grow from 12.9 billion in 2019 to 14 billion in 2028,

15.4 billion in 2030 and 17.8 billion in 2050 (19% increase for 2019-2030 and 38.1% increase for 2019-2050),

following the recovery from the COVID pandemic. The number of multimodal passengers is projected to

increase from 91 million in 2019 to 91.6 million in 2028, reaching 94.4 million in 2030 and 130.8 million in

2050 in the baseline scenario. The air-rail passengers represent over 60% of the total multimodal passengers,

air-coach passengers above 30%, while the share of rail-coach passengers is limited to around 1% of the total

number of multimodal passengers.

The growing digitalisation of transport services and the emergence of new business models for ticket

distribution is expected to lead to an increase in the number of MDMS platforms over time. The number of

MDMS platforms is projected to increase from 364 in 2025 to 369 in 2030, and 421 in 2050 in the baseline

scenario. The number of agreements between MDMS platforms and transport operators is also expected to

increase, from 48,624 in 2025 to 49,321 in 2030, and 56,295 in 2050. The total number of passenger tickets

sold via MDMS platforms is projected to increase from 433 million in 2019 to 520 million in 2030 and 854

million by 2050. However, their share in the total number of tickets sold is projected to remain limited in the

135 Delivering the European Green Deal - European Commission 136 COM(2025) 524 final 137 Regulation (EU) 2024/1610 138 https://eur-lex.europa.eu/eli/reg/2024/1257/oj/eng 139 Regulation - EU - 2024/1679 - EN - EUR-Lex 140 Green Deal: Greening freight for more economic gain with less environmental impact (europa.eu). 141 Updated rules for safer roads, less air pollution and digital vehicle documents 142 OJ L, 2023/2661 143 OJ L, 2024/490 144 OJ L 35, 4.2.2009, pp. 47–55.145 COM(2022) 289 final 146 https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en#explore 147 DG ECFIN, 2024 Ageing Report. Economic and Budgetary Projections for the EU Member States (2022-2070) -

Economy and Finance

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baseline scenario (7.1% in 2030 and 10.1% in 2050). The share of rail tickets sold via independent MDMS

platforms was estimated at around 3% of the total rail tickets sold in 2019 at EU level. In the baseline scenario,

this is projected to go up to 4.1% in 2030 and 7.3% in 2050. This corresponds to around 65 million rail tickets

sold via MDMS platforms in 2019, increasing to 111 million in 2030 and 230 million in 2050 due the increase

in the MDMS market share and of the total number of rail tickets sold.

Building on evidence collected from stakeholders, different trends are identified for air tickets sold via B2B

platforms and for those sold via B2C platforms. A larger share of tickets will be sold through B2C MDMS,

and B2B new content aggregators and the market share of low-cost carriers, which rely less on CRSs, is

expected to continue increasing. This is expected to further erode the share of CRSs in ticket distribution,

despite the growing number of passengers travelling by air, decreasing from 30.1% in 2019 to 16.8% in 2030

and remaining stable at that level afterwards. This corresponds to 155 million air tickets sold via CRS

platforms in 2019, going down to roughly 91 million in 2030 and increasing to 108 million in 2050 due to the

growing number of passengers travelling by air.

The share of tickets sold through B2B new content aggregators is projected to increase from 5% in 2019 to

13.4% in 2030 and remaining stable at that level afterwards, partially offsetting the decrease in the share of

tickets sold through CRSs. This corresponds to 26 million air tickets sold via non-CRS content aggregators in

2019, going up to 73 million in 2030 and 86 million in 2050. Thus, the total share of ticket sold through B2B

platforms (CRSs and new content aggregators) is projected to decrease from 35.1% in 2019 to 31.1% in 2024

and 30.2% in 2030 and remaining stable afterwards. This corresponds to 181 million tickets sold via MDMS

platforms in 2019, 164 million in 2030 and 194 million in 2050.

On the other hand, the share of air tickets sold via B2C platforms is projected to slightly increase from 18% in

2019 to 18.9% in 2030 of the total air tickets sold and remain stable over time. The number of air tickets sold

via B2C platforms is projected to increase from around 93 million in 2019, to 103 million in 2030 and 122

million by 2050. The share of coach tickets sold via MDMS platforms was 2.5% in 2019 at EU level. The

share is projected to go up to 3.5% in 2030 and 6.6% in 2050 indicating a somewhat slower ramp up compared

to that of rail transport. The number of coach tickets sold via MDMS platforms in 2019 was estimated at

around 84 million, increasing to 126 million in 2030 and 273 million in 2050 due the increase in the MDMS

market share and of the total number of coach tickets sold. The share of waterborne tickets sold via MDMS

platforms was about 2.5% in 2019, with a projected increase to 3.4% by 2030 and 6.7% in 2050 at EU level.

This corresponds to around 11 million tickets sold via MDMS platforms in 2019, increasing to 16 million in

2030 and 35 million in 2050.

Road congestion costs in the baseline scenario would increase by about 18% by 2030 and 34% by 2050,

relative to 2015. On the inter-urban network this would be the result of growing transport activity along

specific corridors, in particular where these corridors cross urban areas with heavy local traffic. On the other

hand, driven by policy in place and the assumed implementation of the Roadworthiness package, the number

of fatalities is expected to decrease by 25% by 2030, relative to 2015 (36% decrease by 2050) and the number

of injuries by 23% by 2030 (32% reduction for 2015-2050). CO2 emissions from passenger transport are

projected to be 27% lower by 2030 compared to 2015, and 96% lower by 2050. The baseline scenario shows

that the emission reductions from the passenger transport sector would contribute towards the ambition of at

least 55% emission reductions by 2030 and climate neutrality by 2050, while relying to a significant extent on

technological solutions (i.e., the uptake of low- and zero-emission vehicles and of renewable and low carbon

fuels) and carbon pricing. NOx emissions are projected to go down by 56% between 2015 and 2030 (94% by

2050), mainly driven by the electrification of the road transport. The decline in particulate matter (PM2.5)

would be slightly lower by 2030 at 34% relative to 2015 (89% by 2050).

5.2. Description of the policy measures and policy options

A comprehensive list of policy measures was established after extensive consultations with stakeholders,

expert meetings, independent research and the Commission’s own analysis. This list was screened based on

29

the likely effectiveness, efficiency and proportionality of the proposed measures in relation to the objectives,

as well as their legal and technical feasibility.

5.2.1. Discarded policy measures

Several policy measures that were considered during the IA process were discarded. More details on the

discarded policy measures and the reasons for discarding them are set out in Annex 7.

5.2.2. Retained policy measures

To understand the scope of the most stringent policy measures, the identification of indispensable MDMS

platforms and indispensable RUs is described below.

Indispensable RUs are RUs that operate: 1) PSO services, 2) cross-border services, or 3) more than 50% of

total rail services in a Member State, measured in annual passenger-kilometres, including both domestic and

cross-border services. In Commission's practice on assessment of significant market power for the purposes

of ex ante regulation148, and by analogy with the case law concerning dominance149, it has been considered

that a very large market share held by an undertaking for some time – more than 50% – is in itself, save in

exceptional circumstances, evidence of the existence of a dominant position. The higher the market share and

the longer the period over which it is held, the more likely it is that it constitutes an important preliminary

indication of significant market presence (SMP)150.

Indispensable RU platforms are the main sales channel for most rail customers and account for a

large share of rail ticket distribution. A RU platform is considered indispensable if it is owned by

a RU which (i) operates more than 50% of total rail services in a Member State, as a structural

link exists between the RU’s strong positions in passenger rail transport and its ability to leverage

this position into the downstream market for online rail ticket distribution, making the platform

an essential gateway for consumers and other RUs and (ii) it already distributes tickets of at least

one other RU (as explained in 2.1.2 and illustrated in All incumbent RUs (except in PL, see

Error! Not a valid bookmark self-reference.) have Significant Market Presence (SMP) in the

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

All of them also have one or more digital ticket sales channels, 19 of which are MDMS platforms

as they also sell tickets of other RUs or operators in other modes, while only 6 sell their own

tickets and are greyed out in the chart. The platforms owned by incumbent RUs have a very large

customer base and are the standard reference for rail ticket customers. National competition

authorities and economic studies consistently show that the vast majority of consumer searches

and online ticket sales are concentrated on the RUs with SMP’s proprietary digital channels

(websites and mobile applications), while third-party ticketing platforms account for only a

limited share of transactions. For example, the 2021 report of the Monopolkommission shows

that among major online platforms for long-distance rail tickets in Germany, about 90% of

website visits go to Bahn.de, indicating DB’s dominant position in online distribution markets.

This renders the incumbent platforms an indispensable distribution channel for any rail operator

offering transport services in the respective national market. This is particularly the case of

platforms that sell tickets of multiple RUs, as customers may not realise that their offer is

incomplete and are thus less likely to make alternative searches. On the other hand, when it is

clear for customers that they must look elsewhere to access tickets of competing RUs, they are

more likely to use competitors’ or independent platforms. Accordingly, in the rest of this

148 Guidelines on market analysis and the assessment of significant market power under the EU regulatory framework

for electronic communications networks and services, C(2018) 2374 final. 149 Judgment of 13 February 1979, Hoffmann-La Roche v Commission, Case 85/76, EU:C:1979:36, paragraph 41;

Judgment of 3 July 1991, Akzo v Commission, C-62/86, EU:C:1991:286, paragraph 60. 150 C/2018/2374

30

document, the ticketing platforms owned by incumbent RUs (the 19 in blue in Figure 4) are

referred to as ‘indispensable RU platforms’, but not when they do not sell third party tickets (the

6 in grey in Figure 4).

Figure 4). Indispensable RU platforms are thus a sub-category of indispensable MDMS platforms. Given their

vertical integration with a RU with SMP, their identification can be simplified, reducing administrative burden

on RUs. As they are also subject to specific obligations, they are presented as a separate category.

Figure 7: Overview of indispensable MDMS platforms

Indispensable MDMS platforms include (i) B2C MDMS with Significant Market Presence (SMP) and (ii)

B2B MDMS, including CRSs and NCAs, which are all essential gateways to (travel agents and ultimately to)

consumers. In the B2C distribution market, an MDMS platform is considered as having SMP if it controls at

least 10% of the EU market or 30% of a national market, based on either the total value or volume of tickets

sold in any one transport mode. For MSE, they are considered as having SMP if they have a share of 10% or

more of EU traffic. In selecting the thresholds, an assessment identified which platforms might be affected by

different policy options. The EU-level threshold measures a platform's influence across various Member

States, reflecting national market diversity. This is complemented by national thresholds which reflects

significant influence within a single Member State, indicating a capacity to impact consumer choice in that

country. Finally, the application of thresholds based on the total value and number of tickets sold enables the

identification of platforms with varying market dynamics, capturing both platforms selling large volumes of

tickets and generating substantial revenues. Overall, this method ensures a balanced assessment of platforms'

influence, aligning with regulatory standards and facilitating targeted policy measures across diverse transport

modes. It also allows for an objective and easy measurement of indispensability.

A more detailed description of the policy measures in Table 1 is provided in Annex 8.SMEs are not subject

to any of the policy measures listed below.

Table 1: Retained policy measures

PM* PD** POLICY MEASURE

PM1 PD2 Obligation for all MDMS platforms to apply neutral display obligations and for transport

operators (in all modes) to ensure that the data they submit are accurate

PM2 PD2 Obligation for all MDMS platforms to load and process data of operators with equal care

and timeliness

PM3 PD3 Obligation for all MDMS platforms to share marketing and booking data in a fair way, when

requested by transport operators and authorities

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PM* PD** POLICY MEASURE

PM4 PD1

Obligation for all B2B MDMS platforms to treat subscribers fairly and clearly identify in

their display banned airlines. Obligation for third countries B2B MDMS to ensure equal

treatment of EU air carriers

PM5 PD1 Remove provisions on data protection from CRS Code of Conduct

PM6 PD3

PD4

Obligation for Member States to appoint a national authority to settle disputes between

parties, and establish an EU enforcement network for coordination of enforcement and

implementation work, ensuring consistency throughout the EU.

PM7 PD2 Obligation for all B2C MDMS platforms to share data for mobility management

PM8 PD2

Obligation for all B2B and B2C MDMS platforms to display information on GHG or CO2

emissions of trips (when these data are provided by the operators in line with and Count

Emissions EU and Flight Emission Label)

PM9 PD3

PD4

Thresholds to identify B2C MDMS platforms and RUs with SMP:

- for RUs with SMP: within one calendar year, 50% or more of the total passenger rail

services operated in a Member State (including domestic and EU cross-border services to/from

that Member State), expressed in yearly passenger kilometres

- for B2C MDMS with SMP: for OTAs and TMCs evaluated at EU and national level, via

two proxies: total number of ticket sold and/or the total value of tickets; for MSE evaluated at

EU level based on traffic

PM10 PD3

PD4

B2C MDMS platforms with SMP: must notify national authorities or the EC about their

market presence. National authorities designate B2C MDMS platform, RUs with SMP and

indispensable RU platforms at national level, while the EC designates B2C MDMS platforms

with SMP at EU level. The EC publishes a list of MDMS platforms (including indispensable

RU platforms) and RUs with SMP at both national and EU level.

PM11 PD3

B2C MDMS platforms with SMP, indispensable RU platforms and B2B MDMS: must

respect principles on distribution fees and cannot impose highly restrictive clauses (exclusivity

clauses, unfair and unjustified conditions, marketing clauses and other technical restrictions)

when entering into commercial agreements with transport operators

PM12 PD4

Indispensable RUs (with SMP and operating PSO and cross- border services): must

respect principles on distribution fees without imposing restrictive clauses (exclusivity

clauses, marketing clauses and other technical restrictions) when entering into commercial

agreements with MDMS platforms

PM13 PD4

Indispensable RUs (with SMP and operating PSO and cross- border services):must enter

into commercial agreements with requesting MDMS platforms to enable the re-linking, resale

and/or distribution of their tickets via those platforms for the specified services (‘sharing

obligation’)

PM14 PD4

Indispensable RU platforms: must enter into commercial agreements with requesting RUs

(operating within the same geographical area in which the RU owning the indispensable RU

platform has SMP) to enable the distribution of their tickets (‘hosting obligation’)

PM15 PD4 Indispensable RU platforms: must unbundle its distribution system from the systems of its

parent operator

Note: * PM stands for the number of the policy measure; ** PD stands for the problem driver that the policy measure addresses.

5.2.3. Description of the policy options

The 15 policy measures were grouped into four policy options. PM1 to PM12 are common to all options

and focus on requirements ensuring fair treatment of information and data on MDMS platforms, alongside

rules for commercial agreements between indispensable MDMS and transport operators. The more stringent

rules, notably the obligation to share, host or unbundle drive the ambition level of the policy options and set

them apart (see Table 2).

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Table 2: Overview of the policy options and their links with the specific objectives

SO PO1 PO2 PO3 PO4

Update and extension of the CRS Code of Conduct's rules (PM1 to PM5)

Promotion of sustainable modes of transport (PM7-PM8) SO1    

Enforcement (PM6)

Identification and designation of indispensable MDMS & RU (PM9-PM10)

Commercial agreement rules (PM11-PM12)

SO1/SO2    

Obligation to share (PM13) SO2   

Obligation to host (PM14) SO2 

Obligation to unbundle (PM15) SO1/SO2 

Policy option 1 – Facilitating integration

PO1 is a minimalistic approach that targets both specific objectives. A first set of policy measures that are

common to all four policy options (PM1 to PM8), includes measures that establish minimal requirements

ensuring fair treatment of information and data on MDMS platforms. It also sets out key principles framing

all commercial agreements between indispensable MDMS platforms and transport operators, as well as

between indispensable RUs and MDMS platforms.

This option fully addresses SO1, by establishing a level playing field for MDMS and transport operators

through the extension of the CRS Code of Conduct’s rules to all MDMS providers (PM1, PM2, PM3, PM4

and PM5). With all MDMS platforms (from both B2B and B2C sectors) subject to these rules, the initiative

ensures that transport operators can compete fairly on all platforms and protects their data from being misused.

PM9 sets thresholds to identify MDMS platforms and RUs with SMP, which would be designated by national

enforcement bodies or the European Commission (EC) depending on the market in which they have SMP

(PM10). These are needed for PM11, which sets rules that protects transport operators in their commercial

agreements with indispensable MDMS platforms, including provisions that (1) safeguard commercially

sensitive data of operators, (2) prohibit the inclusion of unjustified or unnecessary contract conditions that

could prevent the conclusion of the agreement, and (3) ensure remuneration of platforms is based on objective

and transparent criteria (such as quality and level of services, annual volume of transport products distributed,

look-to-book ratios, etc). These criteria should be transparently shared with the operator or the National

Enforcement Body (NEB) upon request. Member States would be required to appoint a national authority to

settle disputes that could arise between parties (PM6) and an EU enforcement network of such authorities

would convene each year to ensure consistent enforcement across the EU. Specifically, this EU enforcement

network will allow NEBs to exchange information on their (i) monitoring, enforcement and implementation

work, (ii) decision-making principles, and (iii) administrative practices. The Commission will participate in

discussions, coordinate and support cooperation on matters of common interest and exchange of best practice.

PM8 would oblige MDMS platforms to display information on greenhouse gas emissions, when that

information is shared by the transport operator, and PM7 obliges B2C MDMS platforms to share data for

mobility management with public authorities.

To address SO2, PM12 protects MDMS providers in their commercial agreements with indispensable RU by

setting rules on distribution fees and prohibiting restrictive clauses in contracts (exclusivity clauses, unfair and

unjustified conditions, marketing clauses and other technical restrictions) allowing to address the imbalances

in bargaining power when negotiating commercial agreements.

Feedback was received on stakeholder’s positions on all policy measures and views on PMs common to all

policy options (PM1 to PM12) are only presented under PO1. In the targeted survey, stakeholders had mixed

views, expecting measures linked to neutral display and fair processing of data as mostly positive / neutral.

MDMS platforms surveyed appeared to be the most sceptical group, while most national authorities and the

‘other’ category participating in the survey find those measures effective. Transport operators surveyed did

not provide homogenous answers for those PMs.Stakeholders participating in the targeted survey commented

33

mostly on the requirements regarding neutral display (PM1)151 and on the requirements on GHG emissions

(PM8)152. These measures were strongly supported by national authorities and the ‘other’ category surveyed,

perceived as effective in promoting fair competition, enhancing consumer choice, and improving transparency

within the transport sector while sometimes advocating for more stringent rules (the NGO T&E called for

mandatory display of GHG emissions on platforms, even when data is not shared by operators). RUs and

MDMS platforms active in rail, taking part in the survey and interviews, also supported the introduction of

GHG requirements153, provided that the data are easily comparable154. Three MDMS platforms added that,

to be effective, the data must be shared by operators consistently, which remains a challenge. Three national

authorities also believed consumers might show limited interest in GHG emissions when making booking

decision.

In addition, participants of the OPC for MDMS were asked how important different measures are in their

opinion to ensure fair access for all operators to relevant multimodal digital mobility services platforms. The

outcome is far more favourable than the stakeholder survey results, especially regarding neutral display with

149 out of 169 respondents indicating that this policy measure is important to ensure fair access for operators.

Only 13 respondents found it not important. Moreover, 70 out of 80 respondents from industry indicated it to

be important versus only 7 who found it not important. During interviews, the update of the Code of Conduct

neutral display rules has been positively perceived by a majority of airlines interviewed, Westbahn and EPF,

who viewed it as an effective way to ensure a level playing field and avoid the distortion of information on

platforms155. By contrast, one airline and one OTA raised in interviews concerns about the relevance and

enforceability for B2C platforms, and that imposing neutral display requirements could paradoxically reduce

competition by homogenising offerings and eroding the ability of such platforms to differentiate. The prospect

of establishing a neutral body to oversee aspects of the MDMS ecosystem (the national body to be appointed

under PM6) was supported by stakeholders surveyed, with 36 of 71 finding PM6 effective156 in the targeted

survey. Transport operators appeared to be the most supportive group, with 19 of 29 finding it effective and

none finding it ineffective. During interviews, some stakeholders from all stakeholder groups supported the

creation of such an entity emphasizing its potential to ensure market fairness, resolve disputes efficiently,

and foster cross-border consistency in enforcement and governance157. More critically, some indispensable

151 8 of 20 MDMS platforms saw downsides to PM1, questioning the relevance and enforceability of neutral display

requirements and emphasizing that not leaving the choice of selection criteria with the user could result in negative effects

on platforms’ business models (mentioned in interviews by Skyscanner and the industry association ADN Mobilités). 11

of 30 transport operators expected it to be very or somewhat effective while 2 of 30 stakeholders expected it to be very

or somewhat ineffective. Moreover, 17 of 30 stakeholders were neutral (14) or did not know (3). 1 out of 3 of new entrant

rail operators considered it somewhat effective while 2 out of 3 replied don’t know or did not answer. 152 Nine of 20 found PM8 very ineffective, and four respondents, including EU Travel Tech and Skyscanner, supported

PM8 while emphasizing the need for standardised methods of GHG data reporting and calculation to ensure consistency

with the existing EU framework, thereby simplifying compliance and reducing confusion for consumers. 11 of 29

transport operators expected it to be very or somewhat effective (7 very effective, 4 somewhat effective). Furthermore,

10 of 29 transport operators expected it to be very ineffective. 153 Explicitly supported in interviews by CER, SNCF, rail entrant Snalltaget, the MDMS industry association ADN

Mobilités and one other MDMS platform. 154 Mentioned in interviews by two MDMS providers, two RUs - one incumbent - and an airline. 155 During interviews, one airline considered it as “the best approach to avoid situations of distorted information” while

another airline noted that the extension of CRS CoC neutral display obligation and fair treatment of transport operators

to dominant B2C MDMS is “mandatory” for the fair treatment of offers. Another airline criticised business models as

applied by Edreams, and their display policies. 156 These are views on PM6 in tackling limited and distorted information on platforms. In relation to tackling uneven

access of operators’ platforms, 36 of 71 found it effective, 14 ineffective and 21 were neutral/did not know. As in

relation to the former problem, transport operators appeared the most supportive of this measure. 157 Statement supported in interview by two new content aggregators, two airlines, two rail new entrant – WestBahn and

Snälltåget, a national authority, together with two from the ‘others’ category, including BEUC.

34

RUs and MDMS platforms questioned the effectiveness or practical utility of such an institution158.

Finally, 31 out of 69 stakeholders surveyed expected PM11 to be effective and 36 expected PM12 have a

neutral effect. Overall, MDMS platforms surveyed appeared more sceptical towards PM11159 whereas

transport operators expressing a view questioned rather PM12160. Indeed, MDMS platforms participating in

the survey tend to question the effectiveness of imposing principles on distribution fees and rules forbidding

highly restrictive clauses on them, as they argue they would have no incentive to block access to their platform.

However, they stressed their main concerns is big operators’ unwillingness to share information with them on

fair terms161. On PM11, 15 of 27 of transport operators surveyed expected the measure to be effective in

addressing Problem 1, while 2 of 29 expected PM12 to be ineffective.A majority (21 of 29) were neutral/did

not know the effect of PM12. In the surveyseveral RUs with SMP162 including CER members expressed

concerns over the introduction of enhanced FRAND principles, especially regarding the regulation of

distribution fees. They emphasize that imposing levels of fees defined by regulation could distort the true value

of services rendered and overlook the internal costs borne by providers. While these views are acknowledged,

it is important to note that PM11 and PM12 do not impose directly levels of fees but rather ensure that the

level of fees agreed upon in a commercial agreement are justified and transparent. Eight MDMS platforms/

MDMS industry association and 14 transport operators participated in 2022 to the Multimodal Passenger

Mobility Forum (MPMF) to support the Commission in its preparatory work for this initiative. In the MPMF

final report, the need to “feature FRAND as a core standard 163” for the contractual provisions between

MDMS platforms and transport operators is outlined. In particular, the use of FRAND is mentioned as a

principle that could “guide points to calculate compensation (…), access to data, (…) look-to-book ratio and

marketing restrictions; transparency on terms and conditions164.”

Policy option 2 (PO2) – empowering requesting MDMS platforms to offer single tickets in rail

PO2 addresses SO1 in the same manner as PO1 but further addresses SO2 by mandating that indispensable

RUs enter into commercial agreements with requesting ticketing platforms to enable the sale of all their tickets,

provided that those platforms fulfil minimum requirements (PM13). The scope of this ‘sharing obligation’ is

all rail tickets and fares for: i) rail services provided by operators with SMP in the Member State in which they

hold significant market presence, ii) rail services provided under public service contract (PSO services); and

iii) cross-border rail services. The commercial agreements between indispensable RUs and MDMS platforms

would have to follow fair and reasonable conditions, as laid down in PM12. In particular, indispensable RUs

cannot prevent their tickets from being combined with tickets from other operators, allowing platforms to sell

them as single tickets. Under PO2, MDMS platforms (in particular independent ones) would be capable of

expanding their offers and ultimately provide a complete offer.

In the targeted survey, the sharing obligation (PM13) introduced in PO2 gathered support from national

authorities and the stakeholders surveyed in ‘other’ category165, moderate support from MDMS platforms166,

158 An MDMS provider recognised the theoretical benefit of a neutral body but noted that disputes rarely escalate to a

level that would need its involvement, implying that practical utility may be limited. More critically, CER and the Czech

authority questioned both the need and effectiveness of such an institution. CER and the Czech authority, for example,

argued that existing judicial and administrative bodies are sufficient for handling market disputes. The Czech authority

argued that a neutral body would add little value, given the competitiveness of the national ticketing market and the

availability of redress through existing legal mechanisms. 159 13 out of 20 MDMS platforms found PM11 ineffective. 160 Only 2 of 29 transport operators found PM13 effective, 6 ineffective and 21 were neutral/did not know. 161 During interviews, six MDMS B2C platforms and a trade association argued that the main issue is the unwillingness

from large operators to share their offer on fair terms. 162 Expressed by the industry association CER, DB, SNCF and UITP. 163 MPMF final report (2022), p.32 164 Ibid p.26 165 7 of 11 national authorities and 6 of 10 stakeholders under the category ‘other’ found it effective. 166 7 of 20 found it effective, 7 were neutral, 4 found it ineffective and 2 did not know.

35

and very limited support from transport operators surveyed167. Especially, incumbent RUs participating in the

targeted survey argued that mutual commercial interest should guide collaboration in distribution rather than

mandated access168. DB and SJ AB went further, arguing that this measure might create administrative burden

and potentially increase ticket prices. On the other hand, ALL Rail argued that a fair market requires both sides

to be regulated: RUs must share their data, and ticket vendors must sell all RUs’ tickets. Air France-KLM and

Finnair stressed that this measure should not be applied to the air sector, as the air market is already competitive

and well-functioning. Finally, 2 MDMS platforms (Skyscanner and EUTT) outlined the need to extend the

sharing obligation to air carriers as well.

Policy option 3 (PO3) – empowering requesting RU to be offered on indispensable RU platforms

PO3 addresses SO1 in the same manner as PO1 and PO2, but it further addresses SO2 by mandating that

indispensable RU platforms shall enter into agreements with requesting RUs in order to distribute tickets,

offered within the same geographical area in which the indispensable RU platform is active, including cross-

border services to and from the Member State (PM14). They must apply non-discriminatory and reasonable

contract conditions as described in PM11. PO3 would thus foster the completeness of the offer on both

independent MDMS and indispensable RU platforms, providing the traveller ample choice on all platforms,

including the ones he uses most. This is expected to address SO2 quicker than other policy options. This

obligation would not apply to incumbents’ sales channels that only sell tickets of services that they operate

directly, as these sales channels do not raise the same user expectations (see section 2.1.2). Requiring such

operators to make the necessary IT investments and enter the MDMS market would be unnecessary and

disproportionate.

The additional obligation for indispensable RU platforms to host requesting competitors (PM14), as added in

PO3, is not consensual amongst stakeholders. In interviews, 12 of 15 stakeholders who provided their views

on PM14 viewed that a more cooperative, commercially driven approach is preferable to outright regulatory

imposition169. Two incumbents and their industry association, alongside an MDMS express fear that PM14

would increase market concentration170, and the MDMS industry association ADN Mobilités stated in an

interview that full integration of competitors on those platforms would “take years”. On the contrary, the new

entrant industry association All Rail views PM14 as a “game changer” to improve effectiveness and enhance

the visibility of new entrant RUs in the EU and potentially “doubling the modal shift of rail for long-distance

travels”. Air France-KLM and Finnair stressed that this measure should not be applied to the air sector, as the

air market is already competitive and well-functioning. In the targeted survey, stakeholders also expressed

diverging views. In total, 22 out of 68 stakeholders surveyed expected it to be very (10) or somewhat effective

(12). Furthermore, 20 stakeholders surveyed expected it to be very ineffective (19) or somewhat ineffective

(1). Finally, 26 stakeholders surveyed expressed a neutral view (17) or did not know (9). 15 out of 27 transport

operators surveyed believed this obligation would be very ineffective while the MDMS platforms surveyed

thought the effect of PM14 would be either neutral (7 out of 20) or ‘very’ ineffective (5 out of 20, of which 2

vertically integrated MDMS). By contrast, 6 out of 11 national authorities surveyed and 6 out of 10 ‘other’

stakeholders surveyed found PM14 to be effective, therefore counterbalancing the position of vertically

integrated platforms and operators. OPC participants were asked whether they support an obligation for the

integration, on the basis of reasonable terms, of operators willing to be part of an MDMS platform. This

corresponds to PM14, but the OPC question was not restricted to indispensable rail platforms and referred to

all types of MDMS platforms. In the OPC, 152 out of 168 respondents who expressed an opinion found it

important while 6 did not. 77 out of 80 stakeholders from industry expressing a view found it important versus

167 8 of 30 found it ineffective, two found it effective, 2 were neutral and 17 did not know. 168 Mentioned in interviews by the industry association for RUs CER, SJ AB, DB, and UITP. 169 This included 3 MDMS providers/associations (including 1 new content aggregator, 1CRS and ADN Mobilités), 3

RUs (1 incumbents and their industry association CER, and 1 new entrant), 2 national authorities, 2 airlines/airline

association, ECTAA and UITP. 170 Stated by CER, 2 incumbents and ECTAA during interviews.

36

2 who did not.

Policy option 4 (PO4) – unbundling indispensable RU operators and platforms

PO4 addresses SO1 in the same way as PO2 but further addresses SO2 by mandating indispensable RU

platforms to unbundle their distribution services from the parent company’s transport activities (i.e. divesting)

(PM15). Removing the vertical integration of the service and ticketing branches would also remove their

mutual incentive to protect the strong position of incumbent RUs in the upstream passenger rail market.

Stakeholders participating in the targeted survey appeared to be divided regarding the benefits of unbundling,

as 22 out of 69 expected it to be effective171, 20 ineffective172 and 26 were neutral/did not know173. Half of

transport operators surveyed (15 out of 28) found the measure to be very ineffective, with the notable exception

of new entrant RUs. RUs with SMP responding (DB and CER) claimed that unbundling is disruptive and

would not bring added value to consumers and would harm functioning of rail services as ticket revenues

directly fund them. On the contrary, new entrant RUs surveyed expressed support for this PM, seen as an

effective way to ensure that passengers can see all rail options for their journeys, citing positive examples of

countries were unbundling in rail is already mandatory. A new entrant also outlined that while unbundling is

in theory a very effective measure, it might be complex to implement. Independent MDMS platforms

expressed a more nuanced view, 6 out of 20 finding the measure effective, 10 to have a neutral effect/ or did

not know174 and 4 ineffective175.

6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS?

This section summarises the main expected economic, social and environmental impacts of each policy option.

The assessment of impacts draws on multiple data sources, including the targeted stakeholders’ consultation

and open public consultation, findings from desk research, a 2024 Eurobarometer survey on ticketing176,

and the impact assessment support study (including an in-depth analysis of 100 origin-destination (OD)

routes)177. It builds on the ASTRA model and a Cost Benefit Analysis (CBA) module that is used to calculate

the costs and/or benefits of policy measures, aggregate them into options, and compare the costs and benefits

of the policy options. 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 years178. The ASTRA model is

used to estimate the impacts of the policy options on transport activity, CO2 emissions, air pollutant emissions

and other external costs of transport, as well as the impacts on user costs179.

The policy measures included in all policy options are expected to improve both the completeness and ability

to book alternative transport offerings displayed on MDMS platforms. In all policy options, platforms will be

required to present available transport options in a fair, transparent, and unbiased manner and incorporate

information on GHG emissions for trips where such data are available. Moreover, the range of transport

services displayed on MDMS platforms is expected to expand as transport operators will benefit from fairer

contractual conditions when negotiating with indispensable MDMS platforms. The availability of rail offers

is expected to expand more significantly in PO2, PO3 and PO4, as indispensable RUs that previously shared

171 10 ’very’ and 12 ’somewhat effective’. 172 19 ’very’ and 1 ’somewhat’ ineffective’. 173 17 neutral and 9 did not know. 174 7 neutral and 3 did not know. 175 2 ’very’ and 2 ’somewhat ineffective’. 176 Flash Eurobarometer 551 - Multimodal Digital Mobility Service – August – September 2024 177 Ricardo et al. (2026), Study supporting the RMB and RTR Impact assessment 178 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)474 179 To monetise the external costs savings, the unit values from the 2019 Handbook on the external costs of transport have been used

(Handbook on the external costs of transport - Publications Office of the EU).

37

their services almost exclusively through their platforms will now be visible on third‑party platforms. The

visibility and comparability of rail services are expected to improve further with PO3, as additional RUs will

acquire a better access to indispensable RUs platforms, considered as key intermediaries for RUs in expanding

their consumer reach. Similar to PO3, PO4 will enhance citizens ability to find and book rail offers, as

indispensable RUs platforms’ newly acquired independence will allow new entrant RUs to get better access

to key rail platforms. As a result, the policy options are expected to enhance the completeness and the ability

to book alternative transport offerings displayed on MDMS platforms to varying degrees.

The completeness and the ability to book service offerings is expected in turn to have an impact on modal shift

and journey time. In the first step, the maximum potential modal shift and maximum reduction in the journey

time that can be achieved due to the completeness and the ability to book service offerings has been determined

based on the 2024 Eurobarometer survey on ticketing and the in-depth analysis of 100 origin-destination (OD)

routes and have been discussed in an expert workshop and an additional stakeholders’ workshop organised in

the context of the impact assessment support study. In particular, the maximum potential modal shift was

derived from answers to Q11 of the Eurobarometer survey, capturing stated preferences on change in

behaviour among a very large and representative sample of citizens who currently never or rarely combine

different operators/ modes of transport due to their inability to purchase all tickets in one place. Since the

Eurobarometer was conducted on a statistically representative sample, its results are valid for the whole EU

population and therefore is a relatively robust basis. Assumptions based on stated preferences represent a

scientifically sound method to capture expected modal shift, especially when no real-life evidence is available

based on historical data. The maximum potential modal shift is considered to be a conservative estimate, as it

does not capture stated preferences on change in behaviour among individuals who already book such

journeys but might do so more frequently in the future, due to the improvement of the ticketing system. In

addition, the modal shift linked to the introduction of full passenger rights for rail single tickets is not accounted

for in this IA. As a result, the actual impact on modal shift of the proposed measure may outperform what is

currently estimated.

In the second step, a suite of ad-hoc tools have been developed in the context of the impact assessment support

study, as explained in Annex 4 (section 1.3), to translate the degree to which the policy options are expected

to contribute towards the maximum potential modal shift and maximum potential reduction in travel time due

to the enhanced completeness and the ability to book alternative transport offerings displayed on MDMS

platforms. Both these inputs are further feed into the ASTRA model to derive the overall impacts of the policy

options on transport activity, CO2 emissions, air pollutant emissions and other external costs of transport, as

well as the impacts on user costs. The stakeholders’ workshop was used to validate the inputs used for the

policy options in the ASTRA model. Detailed explanations on all the steps of the approach used are provided

in Annex 4 (section 1.3).

It should however be acknowledged that during the expert workshop and the stakeholders’ workshop,

participants indicated the difficulty to derive a modal shift potential linked to the ability to see all offerings on

an MDMS platform and the ability to book all visible travel options on an MDMS platform, since there have

been little relevant applications of similar initiatives that could allow to deduct lessons. Acknowledging the

uncertainty, sensitivity analysis has been performed with regard to the maximum modal shift potential due to

the completeness and the ability to book service offerings, which is presented in section 7.6.

The changes in transport activity estimated in the policy options are driven by the completeness and the ability

to book service offerings displayed on MDMS platforms. The passenger rights dimension falls outside the

scope of the analysis, but it is acknowledged that strengthened passenger confidence could support the modal

shift towards rail. The targeted revision of rail passenger rights is supported by an analytical Staff Working

Document which updates the assessment of impacts of the related policy measure.

The proposed options are 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

38

present value over the 2028- 2050 period, using a 3% discount rate. All costs and benefits are expressed in

2024 prices. Further details on the methodological approach, together with costs and costs savings results by

stakeholder group for specific years and by Member State (where relevant), are provided in Annex 4.

6.1. Economic impacts

This section provides the economic impacts of the policy options on MDMS platforms, transport operators,

national authorities and the European Commission. It also provides an assessment of impacts on small and

medium enterprises (SMEs), user costs and congestion, competitiveness, functioning of the internal market

and competition, innovation, digital by default, tourism and territorial impacts. Details on the calculation of

costs by policy measure and policy option, by stakeholder group and Member State180 are provided in Annex

4 (section 3).

6.1.1. Impacts on MDMS platforms

One-off and recurrent adjustment costs for MDMS platforms. All four policy options are expected to lead

to one-off and recurrent adjustment costs for MDMS platforms relative to the baseline (see Table 3 and Table

4 below). PM1 (neutral display), PM2 (equal care for data), PM3 (marketing and booking data sharing), PM7

(data for mobility management) and PM8 (GHG emission data) are common to all POs. Their costs are driven

by the number of projected MDMS platforms in each PO (see Table 5), the one-off cost per platform for IT

development (in PM1 to PM3 and PM8) and for setting up an Application Programming Interface (API) (in

PM7), and the recurrent cost per platform for maintaining the IT system, including display criteria and the

API.

Among the common measures the biggest costs stem from the obligation for B2C MDMS to share non-

personal data for mobility management with public authorities (PM7) and come from the set-up and

maintenance of an API181. The total one-off and recurrent costs for PM7 are estimated to be highest in PO2

(EUR 72.6 million, expressed as present value over 2028-2050 relative to the baseline, of which EUR 30

million one-off costs) due to the highest number of platforms projected in this PO, followed by PO4 (EUR

70.8 million, of which EUR 29.1 million one-off costs), PO3 (EUR 69.4 million, of which EUR 28.3 million

one-off costs) and PO1 (EUR 52.9 million, of which EUR 20.8 million one-off costs). Other important

adjustment costs common to all POs are linked to the neutral display obligations (PM1) and the obligation to

display GHG/CO2 emissions when provided by transport operators (PM8). Each of the two measures will

result in one-off and recurrent adjustment costs for MDMS platforms, related to the IT development to adjust

display criteria and their maintenance, of around EUR 16 to 17 million in PO2, PO3 and PO4 (of which

EUR 6.4 to 6.9 million one-off costs), and EUR 12 million in PO1 (of which close to EUR 5 million one-off

costs). The costs associated with PM1 are lower for CRS than other MDMS as they must already comply with

similar neutral display requirements from the Code of Conduct in the baseline182.

PO3 additionally includes one-off adjustment costs for indispensable RU platforms to enter into commercial

agreements with willing RUs (PM14), to enable the distribution of tickets, estimated at EUR 0.4 million

expressed as present value over 2028-2050 relative to the baseline. These cover the costs of negotiating new

180 Most B2B MDMS platforms operate EU-wide, and it is not possible to split the costs arising from obligations on these

platforms by Member State. On the other hand, many B2C platforms are more localised and based on desk research in

the context of the impact assessment support study it was possible to ascertain in which Member States they offer services.

Thus, for policy measures that affect B2C platforms the associated costs are also provided by Member State, while for

B2B platforms costs are provided at EU-level only in Annex 4. 181 Drawing on stakeholder feedback, the one-off adjustment cost per B2C platform for setting up an API is estimated at

EUR 117,719 in 2024 prices. The maintenance of the API is estimated at 10% of the initial setup cost (i.e. EUR 11,772). 182 In PM1 the one-off cost per MDMS platform (excluding CRS) is estimated at EUR 23,125 and the one-off cost per

CRS at EUR 7,708. Part of PM1 requirements is already met in the baseline by CRSs. In PM8 the one-off cost is the

same for CRSs and other MDMS platforms (EUR 23,125). The maintenance cost per platform is estimated at 10% of the

one-off cost.

39

agreements183. PO4 leads to significantly higher one-off adjustment costs due to the unbundling obligation

(PM15), requiring 19 indispensable RU platforms to undertake an important legal and administrative

reorganisation estimated at EUR 157.7 million.

The total one-off and recurrent adjustment costs, expressed as present value over 2028-2050 relative to the

baseline, are thus estimated to be highest in PO4 (EUR 282.3 million), followed by PO2 (EUR 127.7 million),

PO3 (EUR 122.3 million) and PO1 (EUR 92.9 million). The one-off adjustment costs due to the unbundling

obligation (PM15) represent 56% of the total adjustment costs in PO4, while the one-off and recurrent

adjustment costs for the set-up and maintenance of the API to share non-personal data for mobility

management with public authorities (PM7) represent 57% of the total adjustment costs in PO1, PO2 and PO3

and 25% of the total adjustment costs in PO4.

One-off administrative costs for MDMS platforms. In all POs, MDMS platforms need to notify national

authorities and/or the Commission upon reaching the SMP thresholds (PM10). This results in one-off

administrative costs borne by MDMS platforms reaching the SMP thresholds. Building on the Impact

Assessment of the DMA184, the assumption retained for calculating the cost incurred on MDMS platforms is

that only two full time equivalents (FTEs) would be needed to comply with the requirement. This is because

only one quantitative indicator is requested, and no further qualitative information is asked to support the

decision. The administrative burden is kept to the minimum since the designation process leverages on

information already submitted through the Rail Market Monitoring Scheme. In this context, RUs must provide

information that can support the designation process as MDMS platforms with SMP. Four MDMS platforms

are expected to reach the SMP thresholds in 2028 (the assumed year of implementation) and the one-off cost

per platform is estimated at EUR 113,053. Thus, for the purpose of ‘one in, one out’ approach and the

Calculator of Administrative Costs (AC) & Administrative Burdens (AB), the total one-off administrative costs

for MDMS platforms are estimated at EUR 0.5 million relative to the baseline.

Adjustment costs savings for MDMS platforms. In all POs, the introduction of commercial agreement rules

for indispensable MDMS platforms (PM11) and indispensable RUs (PM12) with third parties is expected to

result in recurrent adjustment cost savings for MDMS platforms as these measures are expected to streamline

the negotiation processes185. Although PM11 and PM12 are included in all policy options, the cost savings

vary significantly between options since they are calculated based on the changes in the number of new and

renegotiated commercial agreements compared to the baseline. The number of new and renegotiated

commercial agreements in each PO depends in turn on other policy measures included in each option. For

PO1 cost savings are estimated at EUR 13 million (EUR 12 million due to PM11 and EUR 1 million due to

PM12), expressed as present value over 2028-2050 relative to the baseline, as this PO does not introduce

strong incentives for the conclusion of new agreements or for the renegotiation of agreements relative to the

baseline. Conversely, PO2 introduces a sharing obligation (PM13), significantly increasing the number of

commercial agreements between indispensable RUs and MDMS platforms, resulting in the highest costs

savings for MDMS platforms, projected at EUR 149 million (EUR 136.1 million due to PM11 and EUR

12.9 million due to PM12) relative to the baseline. PO3, which additionally includes a hosting obligation

(PM14) result in adjustment cost savings of EUR 134 million (EUR 122.3 million due to PM11 and EUR

11.7 million due to PM12) relative to the baseline. The lower costs savings in PO3 are due to the lower number

of new and renegotiated agreements relative to PO2. Finally, while the unbundling requirement (PM15) in

PO4 does not mandate commercial agreements, the neutrality it fosters on indispensable rail platforms

facilitates additional agreements relative to PO3, with cost savings projected to reach EUR 142.7 million

183 The one-off cost per new agreement negotiated by indispensable RU platforms is estimated at EUR 29,772. 184 SWD(2020) 363 final. The Digital Market Act assumed 20 FTEs per ‘Gatekeeper’ for submission of relevant data to

authorities. In this case, the entities are much smaller than those regulated under the DMA (Apple, Google, etc.) and the

process is expected to be much lighter (platforms only need to notify that they have reached a threshold). 185 The cost saving per new agreement is assumed at EUR 2,000 and per renegotiated agreement at EUR 1,183, based on

input from stakeholders.

40

(EUR 130.4 million due to PM11 and EUR 12.3 million due to PM12) relative to the baseline.

Net costs/benefits for MDMS platforms. Overall, PO1 and PO4 are expected to lead to net costs, although at

varying degrees, while PO2 and PO3 are expected to deliver net benefits. PO4 shows the highest net costs,

amounting to EUR 140 million, expressed as present value over 2028-2050 relative to the baseline, primarily

due to the significant adjustment costs linked to the unbundling requirement, as outlined previously. In PO1,

the adjustment cost savings are not sufficient to offset the adjustment and administrative costs, leading to net

costs of EUR 80.4 million relative to the baseline. In PO2, the introduction of a sharing obligation (PM13)

leads to the highest adjustment cost savings related to streamlined negotiation processes (PM11 and PM12),

resulting in net benefits of EUR 20.9 million relative to the baseline. PO3 also results in net benefits, estimated

at EUR 11.3 million relative to the baseline.

Table 3: One-off and recurrent costs, and costs savings for MDMS platforms in the POs relative to the baseline

(EU27), expressed as present value over 2028-2050, in million EUR (2024 prices) Difference to baseline

PO1 PO2 PO3 PO4

Adjustment costs 92.9 127.7 122.3 282.3

PM1 (Neutral display) 12.0 16.5 15.8 16.1

PM2 (Equal care for data) 9.0 12.4 11.8 12.1

PM3 (Marketing and booking data sharing) 6.9 9.5 9.1 9.3

PM7 (Data for mobility management) 52.9 72.6 69.4 70.8

PM8 (GHG emission data) 12.1 16.7 15.9 16.3

PM14 (Obligation to host) 0.0 0.0 0.4 0.0

PM15 (Obligation to unbundle) 0.0 0.0 0.0 157.7

Administrative costs 0.5 0.5 0.5 0.5

PM10 (Designation of indispensable MDMS and RUs) 0.5 0.5 0.5 0.5

Adjustment cost savings 13.0 149.0 134.0 142.7

PM11 (Commercial agreement rules indispensable MDMS) 12.0 136.1 122.3 130.4

PM12 (Commercial agreement rules indispensable RUs) 1.0 12.9 11.7 12.3

Net costs (-) or net benefits (+) -80.4 20.9 11.3 -140.0

Source: Ricardo et al. (2026), Impact assessment support study

Table 4: One-off costs for MDMS platforms in the POs relative to the baseline (EU27), expressed as present

value over 2028-2050, in million EUR (2024 prices) Difference to baseline

PO1 PO2 PO3 PO4

Adjustment costs 36.5 52.8 50.1 208.9

PM1 (Neutral display) 4.7 6.9 6.4 6.6

PM2 (Equal care for data) 3.5 5.1 4.8 5.0

PM3 (Marketing and booking data sharing) 2.7 3.9 3.7 3.8

PM7 (Data for mobility management) 20.8 30.0 28.3 29.1

PM8 (GHG emission data) 4.8 6.9 6.5 6.7

PM14 (Obligation to host) 0.0 0.0 0.4 0.0

PM15 (Obligation to unbundle) 0.0 0.0 0.0 157.7

Administrative costs 0.5 0.5 0.5 0.5

PM10 (Designation of indispensable MDMS and RUs) 0.5 0.5 0.5 0.5

Total one-off costs 37.0 53.3 50.6 209.3

Source: Ricardo et al. (2026), Impact assessment support study

A change in the number of MDMS platforms is not a policy objective. However, the projected number of

platforms in each policy option, as well as the number of agreements between the MDMS platforms and the

41

transport operators, are provided below to facilitate the understanding of the costs. The number of platforms

is projected to increase in all policy options relative to the baseline due to the enhanced ability of MDMS

platforms to display more travel options, promoting competition in the online ticketing market. This is

assumed to imply an increase in the number of MDMS platforms although it should be acknowledged that

existing platforms could also improve their offerings, which could lead to a consolidation towards a lower

number of platforms. Such consolidation is assumed to take place towards 2050 in the projections. However,

it should be acknowledged that the consolidation could also take place earlier. Thus, the costs for the MDMS

platforms should be regarded as the upper bound.

PO1 is projected to result in the lowest number of additional MDMS platforms relative to the baseline (10 in

2030, 45 in 2040 and 19 in 2050) for all time horizon under assessment. In 2030, the sharing obligation (PM13)

provides more opportunities for new platforms than in PO1. The effect is the highest in PO2 relative to the

baseline (29 additional platforms in 2030), since in PO3 some platforms would anticipate a broader offer by

the incumbents due to the hosting obligation (PM14) and see less margin for an alternative offer and thus new

platforms (26 additional platforms relative to the baseline in 2030). The effect in PO4 is between that of PO2

and PO3 (27 additional platforms relative to the baseline in 2030) because the new platforms are expected to

perceive the unbundled platform as a less strong competitor, once it is no longer tied to the incumbent rail

operators. In 2040, in PO2 the incumbent platforms are expected to continue to show a limited offer, and new

platforms would exploit the opportunities that this creates. PO2 thus results in 282 additional platforms relative

to the baseline in 2040. In PO3, incumbent platforms provide a full offer, and customers have no reason to

switch. The number of new additional platforms is thus expected to be lower than in PO2 (235 additional

platforms relative to the baseline in 2040). PO4 sits between PO2 and PO3, since the unbundled platforms are

not as strong as the vertically integrated ones and leave more space for the new platform (258 additional

platforms relative to the baseline in 2040). By 2050, the market is expected to converge towards the same

number of platforms in PO2, PO3 and PO4 (209 additional platforms relative to the baseline). In PO2, the

strong competition between platforms is expected to erode the legacy advantage of the incumbents. This

creates an intense competition leading to a consolidation of the sector. In PO3 no change is expected relative

to 2040, while in PO4 some consolidation also takes place but to a lesser extent than in PO2.

Table 5: Projected number of MDMS platforms across EU27 in the baseline and policy options in 2028, 2030,

2040 and 2050 2028 2030 2040 2050

Baseline

B2B platforms 98 99 106 113

B2C platforms 266 270 289 308

Total 364 369 395 421

PO1

B2B platforms 98 102 118 118

B2C platforms 266 277 322 322

Total 364 379 440 440

PO2

B2B platforms 98 107 182 169

B2C platforms 266 291 495 461

Total 364 398 677 630

PO3

B2B platforms 98 106 169 169

B2C platforms 266 289 461 461

Total 364 395 630 630

PO4

B2B platforms 98 106 175 169

B2C platforms 266 290 478 461

Total 364 396 653 630

Source: Ricardo et al. (2026), Impact assessment support study

42

Similarly, the number of agreements between MDMS platforms and transport operators is projected to

increase in all policy options relative to the baseline. As shown in the table below, this increase is expected to

be significantly higher in PO2, PO3 and PO4 compared to PO1 (around 5% increase relative to the baseline

in 2050 in PO1 against 97% in PO2, PO3 and PO4 – all compared to the baseline). PO2 shows the highest

impact in 2030 and 2040 with respectively 20,511 and 66,241 additional agreements relative to the baseline

due to the highest number of additional platforms in this policy option relative to the baseline.

Table 6: Projected number of agreements between MDMS platforms and transport operators across EU in

the baseline and policy options in 2028, 2030, 2040 and 2050 2028 2030 2040 2050

Baseline 48,624 49,321 52,808 56,295

PO1 48,624 50,671 58,862 58,862

difference to baseline 0 1,350 6,054 2,567

% difference to baseline 0% 3% 11% 5%

PO2 63,870 69,832 119,049 110,673

difference to baseline 15,246 20,511 66,241 54,378

% difference to baseline 31% 42% 125% 97%

PO3 63,883 69,248 110,686 110,686

difference to baseline 15,259 19,927 57,878 54,391

% difference to baseline 31% 40% 110% 97%

PO4 64,402 69,519 114,842 110,673

difference to baseline 15,778 20,198 62,034 54,378

% difference to baseline 32% 41% 117% 97%

Source: Ricardo et al. (2026), Impact assessment support study

6.1.2. Impacts on transport operators

The number of transport operators in the scope of this initiative is provided in Annex 4 (section 2.2.3) and is

assumed to remain constant over time in the baseline scenario and across policy options.

One-off adjustment costs for transport operators. PO2, PO3 and PO4 are expected to lead to one-off

adjustment costs for transport operators relative to the baseline (see Table 7). These costs are driven by the

requirement for RUs to allow the distribution of their tickets (PM13) and calculated based on the projected

number of new commercial agreements between MDMS platforms and RUs186. PO2 is expected to show the

highest number of new agreements and thus also the highest one-off costs expressed as present value over

2028-2050 relative to the baseline (EUR 48.2 million), followed by PO4 (EUR 45.2 million) and PO3 (EUR

42.2 million).

One-off administrative costs for transport operators. In all policy options, for the purpose of ‘one in, one out’

approach and the Calculator of Administrative Costs (AC) & Administrative Burdens (AB), low one-off

administrative costs of EUR 1,356 at EU level are expected for RUs with SMP (see Table 8)187. These costs

relate to informing national authorities about their parent platforms (opened to other RUs) in view of

considering them as indispensable RU platforms (PM10).

Adjustment costs savings for transport operators. In all policy options, the introduction of commercial

agreement rules for indispensable MDMS platforms (PM11) and indispensable RUs (PM12) with third parties

186 The one-off adjustment costs for indispensable RUs due to PM13 cover two elements: (i) the cost of negotiating the

agreement; and (ii) the cost of facilitating data exchange for distribution. These two elements translate into a one-off cost

of onboarding a new third-party platform estimated at EUR 29,772 per agreement. 187 It is assumed that 2 hours are needed per RU with SMP for this task. The cost per RU is estimated at EUR 71.4,

considering the hourly rates for the ISCO3 category (technicians and associate professionals) from the ‘Eurostat Structure

of earnings survey. The total one-off administrative costs at EU level are estimated at EUR 1,356 in 2028 taking into

account the 19 RUs in scope of PM10.

43

is expected to result in cost savings for transport operators (see Table 7) as these measures are expected to

streamline negotiation processes188. Although PM11 and PM12 are included in all policy options, the cost

savings vary significantly between options since they are calculated based on the projected number of new

and renegotiated commercial agreements compared to the baseline. As explained in section 6.1.1, the number

of new and renegotiated commercial agreements in each PO depends in turn on other policy measures included

in each option. For PO1 cost savings are estimated at EUR 13 million (EUR 12 million due to PM11 and EUR

1 million due to PM12), expressed as present value over 2028-2050 relative to the baseline, as this PO does

not introduce strong incentives for the conclusion of new agreements or for the renegotiation of agreements.

Conversely, PO2 introduces a sharing obligation (PM13), significantly increasing the number of commercial

agreements between indispensable RUs and MDMS platforms, resulting in the highest cost savings for

transport operators, projected at EUR 149 million (EUR 136.1 million due to PM11 and EUR 12.9 million

due to PM12) expressed as present value over 2028-2050 relative to the baseline. PO3 additionally

incorporates a hosting obligation (PM14) leading however to lower adjustment cost savings of EUR 134

million (EUR 122.3 million due to PM11 and EUR 11.7 million due to PM12) relative to the baseline. This is

because of the lower number of new and renegotiated agreements projected in PO3 relative to PO2. Finally,

while the unbundling requirement (PM15) in PO4 does not mandate commercial agreements, the neutrality it

fosters on indispensable RU platforms facilitates a higher number of agreements relative PO3, with cost

savings projected to reach EUR 142.7 million (EUR 130.4 million due to PM11 and EUR 12.3 million due to

PM12) relative to the baseline.

Net benefits for transport operators. All policy options are expected to result in net benefits for transport

operators, although to varying degrees (see Table 8). PO2 shows the highest net benefits (EUR 100.9 million),

expressed as present value over 2028-2050 relative to the baseline, followed by PO4 (EUR 97.6 million) and

PO3 (EUR 91.8 million). The highest net benefits in PO2 are because the introduction of a sharing obligation

(PM13) considerably increases the adjustment cost savings related to the commercial agreement rules (PM11

and PM12). PO1 results in considerably lower net benefits for transport operators, estimated at EUR 13 million

relative to the baseline.

Table 7: One-off costs and costs savings for transport operators in the POs relative to the baseline (EU27),

expressed as present value over 2028-2050, in million EUR (2024 prices) Difference to baseline

PO1 PO2 PO3 PO4

Adjustment costs 0.0 48.2 42.2 45.2

PM13 (Obligation to share) 0.0 48.2 42.2 45.2

Administrative costs 0.001 0.001 0.001 0.001

PM10 (Designation of indispensable MDMS and RUs) 0.001 0.001 0.001 0.001

Adjustment cost savings 13.0 149.0 134.0 142.7

PM11 (Commercial agreement rules indispensable MDMS) 12.0 136.1 122.3 130.4

PM12 (Commercial agreement rules indispensable RUs) 1.0 12.9 11.7 12.3

Net costs (-) or net benefit (+) 13.0 100.9 91.8 97.6

Source: Ricardo et al. (2026), Impact assessment support study

Table 8: One-off costs for transport operators in the POs relative to the baseline (EU27), expressed as present

value over 2028-2050, in million EUR (2024 prices) Difference to baseline

PO1 PO2 PO3 PO4

Adjustment costs 0.0 48.2 42.2 45.2

PM13 (Obligation to share) 0.0 48.2 42.2 45.2

Administrative costs 0.001 0.001 0.001 0.001

PM10 (Designation of indispensable MDMS and RUs) 0.001 0.001 0.001 0.001

188 The cost saving per new agreement is assumed at EUR 2,000 and per renegotiated agreement at EUR 1,183, based on

input from stakeholders.

44

Total one-off costs 0.0 48.2 42.2 45.2

Source: Ricardo et al. (2026), Impact assessment support study

6.1.3. Impacts on national authorities

Recurrent enforcement costs for national authorities. All policy options are expected to lead to recurrent

enforcement costs for national authorities, estimated at EUR 106.5 million, expressed as present value over

2028-2050 relative to the baseline. These costs are driven by PM6 which requires national authorities to

monitor the online ticketing market for potential entities with SMP as well as the correct implementation of

the legislation (see Table 9)189.

One-off and recurrent administrative costs for national authorities. All policy options are expected to lead

to recurrent administrative costs for national authorities for settling disputes (PM6). Based on feedback from

stakeholders, one FTE is assumed to be needed per national authority. For the purpose of the Calculator of

Administrative Costs (AC) & Administrative Burdens (AB), recurrent administrative costs are estimated at

EUR 1.53 million per year from 2028 onwards190 (or EUR 25.8 million expressed as present value over 2028-

2050 relative to the baseline). In addition, one-off administrative costs for national authorities are expected in

relation to the obligation to process notifications from platforms with SMP and submit this information to the

Commission in 2028 (PM10) (see Table 10). The one-off effort required is estimated at 2 FTEs per Member

State in 2028. The one off-costs for the purpose of the Calculator of Administrative Costs (AC) &

Administrative Burdens (AB) are estimated at EUR 3.1 million191.Efforts have been made to keep these costs

as low as possible, but they remain unavoidable, as they are essential to ensure settling disputes, the processing

of notifications from platforms with SMP and the submission of this information to the Commission.

Net costs for national authorities. All policy options include a similar designation and enforcement process

and result in net costs of EUR 135.4 million for national authorities, expressed as present value over 2028-

2050 relative to the baseline (see Table 9). Enforcement costs represent 79% of the total costs in all policy

options.

Table 9: One-off and recurrent costs for national authorities in the POs relative to the baseline (EU27),

expressed as present value over 2028-2050, in million EUR (2024 prices) Difference to baseline

PO1 PO2 PO3 PO4

Enforcement cost 106.5 106.5 106.5 106.5

PM6 (Enforcement authority) 106.5 106.5 106.5 106.5

Administrative costs 28.9 28.9 28.9 28.9

PM6 (Enforcement authority) 25.8 25.8 25.8 25.8

PM10 (Designation of indispensable MDMS and RUs) 3.1 3.1 3.1 3.1

Net costs 135.4 135.4 135.4 135.4

Source: Ricardo et al. (2026), Impact assessment support study

Table 10: One-off costs for national authorities in the POs relative to the baseline (EU27), expressed as

present value over 2028-2050, in million EUR (2024 prices) Difference to baseline

PO1 PO2 PO3 PO4

Administrative costs 3.1 3.1 3.1 3.1

189 Based on stakeholder feedback this is expected to require maximum 4 full time equivalents (FTEs) per Member State.

For monetising the labour costs, the hourly rates for the ISCO3 category (technicians and associate professionals) from

the ‘Eurostat Structure of earnings survey, Labour Force Survey data’ have been used. In addition, the number of working

hours per day is assumed at 7.2 hours, and the number of working days per year at 220. 190 One full time equivalent (FTE) is assumed to be needed per national authority, with recurrent administrative costs

estimated at EUR 56,527 per national authority. 27 national authorities are considered for calculating the total recurrent

costs. 191 The one-off administrative costs per Member State are estimated at EUR 113,053.

45

Difference to baseline

PO1 PO2 PO3 PO4

PM10 (Designation of indispensable MDMS and RUs) 3.1 3.1 3.1 3.1

Total one-off costs 3.1 3.1 3.1 3.1

Source: Ricardo et al. (2026), Impact assessment support study

6.1.4. Impacts on the European Commission

Recurrent adjustment costs for the European Commission. All policy options lead to recurrent adjustment

costs for the European Commission, estimated in total at EUR 5.3 million, expressed as present value over

2028-2050 relative to the baseline (see Table 11). These are due to the obligation for the European

Commission to designate B2C MDMS platforms with SMP at European level and deal with potential

complaints (PM10)192, estimated at EUR 4 million, and due to the support for the coordination of enforcement

with an EU-wide enforcement network and monitoring of the market (PM6)193, estimated at EUR 1.3 million.

Table 11: Recurrent adjustment costs for the European Commission in the POs relative to the baseline (EU27),

expressed as present value over 2028-2050, in million EUR (2024 prices) Difference to baseline

PO1 PO2 PO3 PO4

Adjustment costs 5.3 5.3 5.3 5.3

PM6 (Enforcement authority) 1.3 1.3 1.3 1.3

PM10 (Designation of indispensable MDMS and RUs) 4.0 4.0 4.0 4.0

Net costs 5.3 5.3 5.3 5.3

Source: Ricardo et al. (2026), Impact assessment support study

6.1.5. Impacts on SMEs

The SME check has been performed and is presented in Annex 6. SMEs are not directly affected by any of

the policy options and do not incur any cost. However, SME MDMS platforms and SME transport operators

are expected to benefit from the introduction of commercial agreement rules for indispensable MDMS

platforms (PM11) and indispensable RUs (PM12) in all policy options. These rules will streamline negotiation

processes through a more harmonized approach that reduces commercial negotiation efforts and guarantees a

fairer access to key offers and platforms. Thus, adjustment costs savings are expected for both SME MDMS

platforms and SME transport operators in all policy options.

Adjustment costs savings for SME MDMS platforms. SME MDMS platforms will benefit from adjustment

cost savings linked to the introduction of commercial agreement rules (PM11 and PM12)194. As explained in

section 6.1.1, although PM11 and PM12 are included in all policy options, the cost savings vary between

them, since they are calculated based on the projected number of new and renegotiated commercial

agreements relative to the baseline. The highest adjustment costs savings, expressed as present value over

2028-2050 relative to the baseline, would be achieved in PO2 (EUR 101 million) due to the synergies with

PM13 (obligation to share) that leads to a significantly higher number of new and renegotiated commercial

agreements relative to the baseline. PO4 and PO3 also result in significant adjustment costs savings for SME

MDMS platforms (EUR 95.7 million in PO4 and EUR 90.5 million in PO3), while PO1 is expected to result

192 This is assumed to require 2 full time equivalents (FTE) per year from 2028 onwards. The cost per FTE was assumed

at EUR 118,326 at AD5 level, including overheads. 193 The European Commission is assumed to organise one meeting of the EU‑wide enforcement network per year from

2028 onwards, to exchange best practices. The average cost for a two-day in-person meeting hosted by EC, where

participants are reimbursed by the EC, is around EUR 30,000. In addition, each two years from 2030 onwards, a

Eurobarometer survey is assumed to be conducted. The costs for the Eurobarometer survey, are assumed at EUR 100,000

per year based on the costs of the Eurobarometer survey conducted in 2024. 194 The cost saving per new agreement is assumed at EUR 2,000 and per renegotiated agreement at EUR 1,183, based on

input from stakeholders.

46

in lower costs savings (EUR 9.2 million).

Table 12: Recurrent adjustment costs savings for SME MDMS platforms in the POs relative to the baseline

(EU27), expressed as present value over 2028-2050, in million EUR (2024 prices) Difference to baseline

PO1 PO2 PO3 PO4

Adjustment cost savings 9.2 101.0 90.5 95.7

PM11 (Commercial agreement rules indispensable MDMS) 8.6 93.7 83.9 88.8

PM12 (Commercial agreement rules indispensable RUs) 0.5 7.3 6.6 6.9

Net benefit 9.2 101.0 90.5 95.7

Source: Ricardo et al. (2026), Impact assessment support study

Adjustment costs savings for SME transport operators. As for SME MDMS platforms, in all policy options,

SME transport operators will also benefit from the introduction of commercial agreement rules for

indispensable MDMS platforms (PM11) and indispensable RUs (PM12). As for SME MDMS platforms,

adjustment costs savings for SME transport operators, expressed as present value over 2028-2050 relative to

the baseline, are estimates to be the highest in PO2 (EUR 107 million), followed by PO4 (EUR 102.5 million),

PO3 (EUR 96.1 million) and PO1 (EUR 9.4 million).

Table 13: Recurrent adjustment costs savings for SME transport operators in the POs relative to the baseline

(EU27), expressed as present value over 2028-2050, in million EUR (2024 prices) Difference to baseline

PO1 PO2 PO3 PO4

Adjustment cost savings 9.4 107.0 96.1 102.5

PM11 (Commercial agreement rules indispensable MDMS) 9.4 106.2 95.4 101.8

PM12 (Commercial agreement rules indispensable RUs) 0.1 0.8 0.7 0.7

Net benefits 9.4 107.0 96.1 102.5

Source: Ricardo et al. (2026), Impact assessment support study

Net benefits for SMEs. Total net benefits for SMEs (MDMS platforms and transport operators) are estimated

at EUR 208 million in PO2, EUR 198.2 million in PO4, EUR 186.6 million in PO3, and EUR 18.6 million in

PO1 expressed as present value over 2028-2050 relative to the baseline. As explain above, the obligations

included in the policy options do not apply to SMEs and SMEs are only expected to indirectly benefit from

them.

SMEs views were considered via stakeholder consultation activities, including the targeted survey and

interviews conducted in the context of the impact assessment support study, and the OPC. Overall, SMEs

expressed favourable views on the policy options, with strong support for the introduction of binding rules

and the introduction of commercial agreement rules. An overview of SMEs’ views is provided in the SME

check, in Annex 6.

6.1.6. Impacts on user costs and congestion

The proposed policy options are expected to benefit transport users through three channels: (i) a reduction of

search costs for travellers; (ii) an increase in competition in the platform market; (iii) an increase in competition

in the transport market.

The reduction of search costs for travellers. The most direct effect would be the reduction in search cost, as

travellers would be able to find, compare and purchase tickets in a single place without having to perform

longer searches and visit multiple platforms. In the baseline scenario, travellers must dedicate time and effort

to search for the most convenient offer in terms of fares, comfort and travel time, with no guarantee that they

will manage to find the offer that best matches their preferences. Under the various policy options, and to the

extent that the measures included in each option will provide customers with a complete ticketing offer in a

single place, travellers will most certainly save time on searches, but possibly also gain in terms of travel time

47

and more convenient fares. The assessment below considers them jointly as ‘reduction of search costs’.

This effect would be present in PO1, thanks to neutral display requirements that would make convenient offers

more visible to potential customers. However, the impact would be limited, since there are no provisions in

this option that have the effect of widening the offer of platforms and guaranteeing that a complete ticketing

offer becomes available on single platforms. In PO2, the addition of the ‘sharing obligation’ (PM13) would

enable a complete ticketing offer on willing platforms. The effect would thus be stronger than PO1 but still be

limited to the customer base of independent platforms, since indispensable RU platforms have shown no

willingness to host the full offer of competitors. In PO3, the further addition of the ‘hosting obligation’ (PM14)

would make a substantial difference, since now the possibility to access a complete ticketing offer would be

extended to the customers of indispensable RU platforms that have by far the largest reach. The reduction in

search cost would be highest in this case. In PO4, the unbundling of vertically integrated platforms would

remove the perverse incentives to limit their ticketing offer. Accordingly, the magnitude of the reduction in

search cost for consumers would be similar to PO3 but it is likely to be achieved with a certain delay due to

the need for restructuring processes.

Implications for consumers of increased competition in the platform market. Increased competition in the

platform market would lead to greater innovation efforts, widening of services available on platforms,

improvements in the overall ticketing experience, and possibly reduction of transaction costs for users. PO1

would not substantially affect competition in the platform market, since, broadly speaking, it will neither affect

the content, nor the incentives of platforms, but only the presentation of existing offers. PO2 would have an

impact on the content of independent platforms, making them a more attractive distribution channel for

consumers. This will improve their position vis à vis the indispensable platforms and increase overall

competition in the platform market. The inertia in consumer behaviour might however dampen the effect as

many consumers would remain loyal to indispensable platforms. PO3 would oblige indispensable RU

platforms to host a complete ticketing offer (PM14). This is likely to reinforce their appeal in the market, but

at the same time would deprive them of any possibility of abusing behaviour (by virtue of the common

measures included in all options, PM1 to PM12) or denying access to competitors (PM14). This would change

the incentives for indispensable platforms, inducing a behaviour that is closer to that of ‘normal’ platforms

that seek to maximise market intermediation. This, in turn, might elicit even stronger innovation efforts from

competing independent platforms. Indeed, in the baseline, PO1 and, partly, PO2, platforms have near ‘captive’

customers (incumbent operators for the incumbent platforms and new entrants for the independent

platforms195) and competition is affected by access limitations to both content and distribution channels. Under

PO3, the sharing and hosting obligation provide all operators with full access to tickets and platforms. This is

likely to push platforms to compete more strongly on innovation, user experience, customer care and

additional services, since they can no longer rely on exclusive content. Similar considerations can be made for

PO4, although the impact might take longer to manifest. Altogether, it is expected that PO3 would produce

greater benefits for consumers from competition in the platform market, followed by PO4.

Implications for consumers of increased competition in the transport market. Greater competition in the

transport market would tend to lower prices and increase the quality and frequency of transport services. The

amount of pressure exercised by competition would be proportional to the number of customers being able to

easily find, compare and purchase the most convenient travel offers. PO1 would improve visibility and fair

representation of existing offers on online platforms, but it would not broaden their ticketing offer. This would

promote competition in the transport market, but not as substantially as the other policy options. PO2 would

affect the content of independent platforms, giving them access to indispensable tickets. Customers of

independent platforms would therefore be able to compare the offers of different transport operators and opt

for the most convenient. Initially, the competitive pressure on the transport market would only be exercised

through the customers of independent platforms. However, the effect would become stronger if consumers

195 Independent platforms might be the only available sale channel for new entrant rail operators, since, as already

indicated, many indispensable RU platforms are not willing to sell tickets of new entrants.

48

begin switching to independent platforms attracted by their broader offer. PO3 would oblige indispensable

platforms to host a complete ticketing offer (PM14). In this case, nearly all consumers would be able to

compare directly the offers of transport operators and buy the most convenient one. As argued in Section 6.1.8

on the functioning of the internal market and on competition, this is likely to lead to stronger price competition

between RUs. Accordingly, PO3 would have the largest effect on consumers through competition in the

transport market. PO4 is likely to lead to a situation similar to that of PO3, meaning a situation in which

indispensable platforms host a complete ticketing offer. However, this outcome is likely to materialise with a

certain delay with respect to PO3, due to the necessary restructuring processes.

Overall assessment of impacts on user costs. The policy options are expected to generate significant benefits

for consumers by reducing search costs and fostering greater competition in both the platform and transport

markets. While the resulting enhanced “trust” in rail as an easy, accessible, modern and reliable user-

friendly mode of transport is difficult to the quantify, the most immediate and tangible effect across all

options is the reduction of search costs. By enabling travellers to find, compare, and purchase tickets in a single

location, the policy options would eliminate the need to conduct lengthy searches across multiple platforms.

This simplification of the purchasing process enhances convenience, transparency, and efficiency for

consumers.

The overall impact on consumers’ costs would be the strongest, as well as the quickest to materialise, in the

case of PO3. PO4 would come second in terms of overall impact and but its effects would unfold more

gradually, due to the need to restructure the business of indispensable platforms following unbundling. PO2

would have a more moderate impact, since the cost reduction would be generated by the action of independent

platforms that have a smaller customer base, although this would grow in time. Finally, only a negligeable

impact on transport cost can be expected to result from PO1, which would change the presentation, but not

the scope of the ticketing offer on the platforms.

The table below presents the impacts on average expenditure per person for interurban mobility in the policy

options relative to the baseline. It shows that the impacts are highest in PO3 (0.27% reduction in 2040 and

0.34% reduction in 2050 relative to the baseline), followed by PO4 and PO2, while the impacts of PO1 are

negligible. These impacts do not consider the reduced search costs for the most convenient offer in terms of

fares, comfort and travel time, which are difficult to quantify and thus only assessed qualitatively.

Table 14: Impacts on average expenditure per person for interurban mobility, at EU27 level (% change

relative to the baseline) Average expenditure per person for interurban mobility (% change to

the baseline)

2030 2040 2050

PO1 -0.01% -0.03% -0.05%

PO2 -0.03% -0.16% -0.24%

PO3 -0.06% -0.27% -0.34%

PO4 -0.04% -0.19% -0.28%

Source: Ricardo et al. (2026), Impact assessment support study; ASTRA model

The reduction of congestion associated with modal shift. By improving the completeness and accuracy of

service information, the ability to book service offerings and travel time, as well as reducing user costs of

railway transport, the policy options would also generate, to varying degree, modal shift away from road and

aviation. In turn, this would reduce congestion costs associated with road traffic relative to the baseline. The

impact on congestion costs of the various policy options mirrors the impact on modal shift, with PO3 having

the strongest effect (EUR 6.4 billion congestion costs savings, expressed as present value over 2028-2050

relative to the baseline), followed by PO4 (EUR 4.8 billion congestion costs savings), PO2 (EUR 4.4 billion

49

congestion costs savings) and PO1 (EUR 1.8 billion congestion costs savings)196.

Table 15: Impacts on external costs of road congestion in the POs relative to the baseline (EU27), expressed

as present value over 2028-2050, in million EUR (2024 prices)

Difference to baseline

PO1 PO2 PO3 PO4

Savings in external costs of road congestion 1,758 4,352 6,438 4,833

Source: Ricardo et al. (2026), Impact assessment support study; ASTRA model

6.1.7. Impacts on competitiveness

This proposal is a key enabler of Europe’s green competitiveness agenda, directly reinforcing the European

Green Deal and the Commission’s 2024-2029 priorities by accelerating a shift towards sustainable transport

modes, rail in particular, while strengthening the EU’s economic resilience in an increasingly digital mobility

landscape. All policy options deliver improved operational efficiency and increase in the transport activity by

rail and coach due to better visibility and access to these services. In particular, PO2, PO3 and PO4, introduce

the obligation to share tickets for indispensable RUs (PM13), unlocking new competitive services and

sustainable travel alternatives for passengers, directly addressing the market barriers highlighted in the Draghi

Report197. When coupled with the obligation to neutrally display offers (PM1), these measures will support

fairer competition of operators on all MDMS platforms, and especially indispensable RU platforms – a

necessity underlined by the Letta Report198’s call for an EU-wide, integrated framework to prevent

discriminatory practices in ticket distribution.

Cost competitiveness. The policy options have different impacts on the cost competitiveness of affected

businesses. Across all policy options, the common measures increase regulatory clarity and transparency. By

extending the CRS Code of Conduct rules, requiring neutral display, ensuring fair data processing and

establishing enforcement mechanisms, the initiative reduces legal uncertainty and dispute risk. Streamlined

negotiation processes (PM11 and PM12) reduce contractual transaction costs for both MDMS platforms and

transport operators in all policy options. Under PO1, the introduction of fair principles improve predictability

in commercial negotiations. While agreements remain voluntary, a harmonised framework can reduce

inefficient negotiation cycles and lower compliance risks, particularly in cross-border contexts. Under PO2,

PO3 and PO4, stronger regulatory obligations increase compliance costs for regulated entities. However, these

obligations are expected to improve the completeness and efficiency of integration between operators and

platforms. The net effect depends on the balance between compliance costs and efficiency gains (i.e. costs

savings).

For MDMS platforms, as explained in section 6.1.1, all policy options are expected to lead to adjustment costs

and some limited administrative costs. Total costs, expressed as present value over 2028-2050 relative to the

baseline, are estimated to be highest in PO4 (EUR 282.7 million) primarily due to the significant adjustment

costs linked to the unbundling requirement, followed by PO2 (EUR 128.1 million), PO3 (EUR 122.7 million)

and PO1 (EUR 93.4 million). At the same time, the streamlined negotiation processes (PM11 and PM12)

deliver significant adjustment costs savings in PO3, PO4 and PO2 in synergy with other measures included in

these options that increase the number of new and renegotiated commercial agreements that benefit of the

streamlined processes. Overall, PO2 and PO3 lead to net benefits of EUR 20.9 million and EUR 11.3 million,

respectively, expressed as present value over 2028-2050 relative to the baseline. On the other hand, PO4 and

PO1 result in net costs (EUR 140 million in PO4 and EUR 80.4 million in PO1).

For transport operators, as explained in section 6.1.2, PO2, PO3 and PO4 are expected to lead to adjustment

196 The 2019 Handbook on external costs of transport (Handbook on the external costs of transport - Publications Office

of the EU (europa.eu)) has been used to monetise the external costs savings. 197 Draghi, Mario - The Future of European Competitiveness: In-Depth Analysis and Recommendations. 2024, p. 213 198 Letta, Enrico. Much More Than a Market. Council of the European Union, 2024, p. 85

50

costs related to the obligation to share and all options are expected to require very limited administrative costs

for the designation of indispensable RUs. Total costs, expressed as present value over 2028-2050 relative to

the baseline, are estimated to be highest in PO2 (EUR 48.2 million), followed by PO4 (EUR 45.2 million),

PO3 (EUR 42.2 million) and PO1 with negligible costs. The streamlined negotiation processes (PM11 and

PM12) deliver adjustment costs savings in all policy options that outweigh the costs. Net benefits for transport

operators, expressed as present value over 2028-2050 relative to the baseline, are estimated at EUR 100.9

million in PO2, EUR 97.6 million in PO4, EUR 91.8 million in PO3 and are more limited in PO1 (EUR 13

million).

By reducing search and booking frictions and improving the visibility of transport offers, the policy options

enhance the efficiency of the rail and multimodal transport sectors, strengthening the competitive position of

rail and coach services within the multimodal passenger transport market. Improved integration of rail services

in MDMS platforms can increase the attractiveness of rail-based itineraries relative to car-only or aviation

trips.

As regards SMEs competitiveness, they would also benefit from better market conditions: creating a level

playing field for all stakeholders could be particularly beneficial for small businesses or start-ups. New entrant

SMEs in the rail transport market would particularly benefit from the obligation for indispensable RU

platforms to enter into commercial agreement with willing RUs (PM14). New entrant RUs face the problem

of how to establish their brand and typically must resort to costly advertising campaigns, which can be

prohibitive for SMEs. PM14 would allow them to benefit from indispensable RU platforms’ brand visibility

and reach immediately the very high share of customers that use those platforms. In PO4, the obligation for

indispensable RUs to unbundle their distribution and operation services (PM15) will also provide better

visibility and consumer reach to new entrant RUs, albeit to a lesser extent than PM14. Indeed, the complete

unbundling process is expected to be complex and would likely require an extended adjustment period. These

newly independent platforms would also not be obliged to negotiate with new rail entrants, therefore

decreasing slightly the positive impact on SME competitiveness compared to PM14. Finally, the prohibition

of restrictive contractual clauses by indispensable RUs and indispensable MDMS platforms and the

introduction of fairer distribution fee principles (PM11 and PM12) in all POs would facilitate agreements

between platforms and operators, directly targeting gatekeeping behaviour, curbing anti-competitive

practices, and enhancing transparency and fairness. This would therefore greatly support smaller MDMSs and

operators in concluding contractual agreements with players benefiting from a strategic position in the market.

The analysis shows that all policy options lead to increases in rail and coach activity relative to the baseline

(see section 6.1.8), reflecting improved supply-demand matching and reduced transaction costs. The relative

magnitude of these increases in activity differs across options, being highest in PO3, followed by PO4 and

PO2.

The entire economy is likely to benefit from these developments since transport represents a significant share

of household expenditure and is a critical input for many economic sectors, notably tourism. A better

functioning of the transport sector would free resources for additional consumption and investment. This might

result in knock-on effects throughout the entire economy in the long term, leveraging the initial impact on the

transport sector.

International competitiveness. All policy options apply equally to EU and non-EU platforms when operating

within the EU market and do not differentiate by nationality. They therefore do 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.

6.1.8. Impacts on the functioning of the internal market and on competition

All policy options enhance the functioning of the internal market compared to the baseline. They do so by

reducing regulatory fragmentation across the EU and promoting a level playing field for ticket distribution in

51

both B2C and B2B markets.

PO1 extends neutral display rules to all B2B actors and introduces rules governing commercial agreements

with indispensable B2B and B2C platforms and railway undertakings (RUs), but it does not require any

structural changes. Indispensable RUs and platforms would not be obliged to share ticket content or host other

RUs, meaning the current market structure would largely remain unchanged. As a result, while PO1 is

expected to have a positive impact in promoting a level playing field in B2B distribution, its overall effect

would be limited. By focusing on fairness without mandating access, it is unlikely to significantly enhance

competition or expand consumer choice. Overall, the measures included in PO1 are projected to lead to 1%

increase in rail activity in 2030 and 1.8% increase by 2050 relative to the baseline.

Building on PO1, PO2 introduces a ‘sharing obligation’, requiring indispensable RUs to share their tickets for

distribution on willing platforms. Most RUs already sell their tickets through third party platforms, although

they do not always provide a complete offer in terms of connections and fares, especially when they reserve

some offers for the clients of their vertically integrated platform. The ‘sharing obligation’ would fill this gap

by requiring that RUs share their complete offer. This would not alter the business model, whereby RUs

normally pay a distribution fee to platforms that sell their tickets, but PO2 would ensure that distribution

agreements are concluded on the basis of fair, reasonable and non-discriminatory (FRAND) conditions. It

should be noted that RUs would inevitably incur distribution costs whether the service is provided in-house or

by a third party. Thanks to greater competition in the platform market, streamlined negotiation processes, and

application of FRAND conditions, distribution costs may even decrease for RUs in PO2 relative to the

baseline. Accordingly, the sharing obligation would not imply any structural change in business models or

market structure, but, by ensuring broader access to the ticket offer, it improves the level playing field in the

distribution market. However, a key limitation in PO2 is that indispensable RUs (those covering most rail

operations in a Member State) retain significant influence on rail ticket distribution in the short to medium

term. They could still restrict other RUs’ access to their own popular distribution channels, undermining

competition. The expected impact is stronger than in PO1 as this option directly influences supply, demand,

pricing, and competitive dynamics. Overall, the measures included in PO2 are projected to lead to 1.7%

increase in rail activity in 2030 and 3.7% increase by 2050 relative to the baseline.

PO3 takes a bolder step by adding a ‘hosting obligation’, compelling indispensable RU platforms to sell tickets

of requesting RUs. The result is a guaranteed pathway for new RUs to reach customers through established,

high traffic platforms, removing a major barrier to entry. Increased competition, in turn, drives innovation and

better pricing. Also in this case, there would not be a change in business models of operators. Indispensable

RUs platforms would only be caught by the ‘hosting obligation’ when they have already hosted third party

offers, which shows that they have the means, technical expertise and contractual experience to provide such

service: the hosting obligation would just ensure that this service is provided on non-discriminatory basis to

all requesting RUs, but would not require engaging in a new activity.

There is a hypothetical risk that vertically integrated platforms would seek to avoid regulation by withdrawing

from the ‘platform’ market and halting the sale of any other companies’ tickets. This would present the wide

customer base of that platform with an even reduced offer. To avoid this, the criterion that will be used to

establish whether the platform of a railway undertaking with significant market presence falls under the

hosting obligation in PO3 is whether it has sold tickets of other companies in the past five years. There is also

a risk that railway undertakings would use cooperation agreements between RUs to evade regulation, claiming

that selling these tickets constitutes sale of only their own tickets. To avoid this risk, the sale of tickets for

services that are offered in cooperation between two or more RUs (e.g. cross-border services, which are often

operated under different RU licenses in different Member States) is considered as sale of tickets of another

operator.

While PO3 would not require vertically integrated platforms to provide services to third parties that they had

not already offered in the past, the changes in market dynamics would nevertheless be more substantial in PO3

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than in PO2. The joint application of the sharing and hosting obligation will potentially provide all platforms

with a complete ticketing offer, and as platforms can no longer rely on preferential access to ticket offers, they

are expected to compete more vigorously on aspects like journey planning, ease of search and user experience,

customer care, and additional services. The railway service market will be impacted to a much greater extent

in PO3 than in PO2, since new railway entrants will have access to a much broader set of potential customers.

Indeed, the initial impact of the hosting and sharing obligation would be broadly proportional to the respective

size of the customer base of the incumbent and independent platforms. PO3 will thus me more effective in

strengthening competition in the railway services market and attract more passenger to this mode of transport,

providing a net benefit to the whole sector, although some operators may lose the rents that they still profit

from in non-competitive markets.

By fundamentally reshaping market dynamics, this approach ensures fair access to indispensable RU

platforms, fostering a more open and competitive railway ecosystem and leading to 2.5% increase in rail

activity in 2030 and 4.8% increase by 2050 in PO3 relative to the baseline.

PO4 obligates vertically integrated distribution RU platforms to unbundle from their operators, eliminating

inherent conflicts of interest. While it does not impose a hosting obligation, breaking these ties aligns

incentives with independent platforms, reducing market distortions caused by dominant players favouring

their own services. However, the complexity of implementation (including legal, operational, and transitional

challenges) could undermine its efficiency. The expected impact is comparable to that of PO3 (it achieves a

fairer, more neutral market) but may do so less efficiently due to the practical difficulties of restructuring

established systems. Overall, the measures included in PO4 are projected to lead to 1.9% increase in rail

activity in 2030 and 4% increase by 2050 relative to the baseline.

A more detailed assessment of the impacts of the policy options on competition is included in Annex 13.

Table 16: Impact on transport activity in passenger-kilometres at EU level (percentage change relative to the

baseline)

Percentage change to baseline

PO1 PO2 PO3 PO4

Car

2030 -0.2% -0.3% -0.4% -0.3%

2040 -0.3% -0.7% -1.0% -0.7%

2050 -0.3% -0.8% -1.1% -0.8%

Coach

2030 0.6% 0.9% 1.3% 1.0%

2040 1.4% 2.1% 2.7% 2.2%

2050 1.3% 2.1% 2.8% 2.3%

Rail

2030 1.0% 1.7% 2.5% 1.9%

2040 1.7% 3.4% 4.7% 3.7%

2050 1.8% 3.7% 4.8% 4.0%

Air

2030 -0.1% -0.2% -0.2% -0.2%

2040 -0.2% -0.5% -0.7% -0.6%

2050 -0.4% -0.9% -1.0% -1.0%

Waterborne

2030 0.0% 0.0% 0.01% 0.0%

2040 0.0% 0.01% 0.01% 0.01%

2050 0.0% 0.01% 0.01% 0.01%

Source: Ricardo et al. (2026), Impact assessment support study; ASTRA model

6.1.9. Impacts on innovation

By addressing key barriers in ticket distribution, all policy options create an environment where MDMS

platforms and transport operators can develop more integrated, user-friendly, and competitive solutions. PO3

53

is expected to have the biggest impact, as it best addresses the key barriers of access to platforms and access

to tickets. A major driver of innovation stems from greater transparency and equitable conditions on MDMS

platforms, combined with improved access for platforms to indispensable transport offers and to indispensable

platforms for RUs. Measures enhancing transparency and fairness on MDMS platforms, including

indispensable ones (PM1, PM2, PM3, PM4, PM11 and PM14) incentivise new entrants and smaller operators

to innovate, as they gain equal visibility alongside established players. The neutral display obligations (PM1)

retain flexibility, allowing MDMS platforms to offer alternative display criteria as long as the end user retains

choice. The principles for commercial agreements (PM11) protect smaller operators from unfair bargaining

power, enabling them to compete on service quality rather than market clout. Likewise, the possibility for

MDMS platforms to integrate indispensable RUs (PM13) and ensure that these do not impose unfair contract

terms (PM12) reduce entry barriers, encouraging start-ups and SMEs MDMS to develop new services.

PO1 shares PM1 till PM12 with PO3 and thus also benefits from their positive impact on innovation. This is

however limited by the fact that it does not rebalance the market dynamics in the same manner; the lack of

access to ticket offers means there is (a lot) less to innovate with. PO2 is better in this regard as it does address

this issue through PM13, though still not as effectively as PO3 (which adds PM14). PO3 is expected to

particularly boost innovation in the platform market for the reasons explained in Section 6.1.6: PO3 would

oblige indispensable RU platforms to host a complete ticketing offer, which is likely to reinforce their appeal

in the market, but at the same time would deprive them of any possibility of discrimination. This is likely to

induce a behaviour that is closer to that of ‘normal’ platforms that seek to maximise market intermediation.

This, in turn, might elicit even stronger innovation efforts from competing independent platforms. Indeed, in

the baseline, PO1 and, partly, PO2, there is a duality in the platform market, where both incumbent and

independent platforms have near ‘captive’ customers (incumbent operators for the incumbent platforms and

new entrants for the independent platforms) and competition is affected by access limitations to both content

and distribution channels. Under PO3, the sharing and hosting obligation provide all operators with full access

to tickets and platforms. This is likely to push platforms to compete more strongly on innovation, user

experience, customer care and additional services, since they can no longer rely on exclusive content. PO4 has

a similar potential to innovation as PO2; its more fundamental rebalancing potential offset by the time delay

associated with restructuring the market though unbundling.

6.1.10. Digital by default

All policy options are fundamentally aligned with the 'digital by default' principle, aiming to foster a robust

digital ecosystem within the transport sector. Key measures include the obligations to load and process data

with equal care and timeliness (PM2), and to uphold fair principles in commercial agreements (PM11 and

PM12). These provisions are included in all options and are designed to encourage fairer and more efficient

data exchanges between involved parties, thereby streamlining digital operations and enhancing user

experience. The initiative's digital focus is further reinforced by the obligations to share non-personal data with

public transport authorities (PM7), present in all four policy options. This will substantially increase the

availability and utilisation of mobility data by public authorities, leading to enriched data-driven decision-

making and improved service delivery within the transport system. Additionally, the requirement to respect

the rules on marketing and booking data (PM3) is instrumental in promoting fair and efficient data sharing

practices. By mandating non-discriminatory sharing of marketing, booking, and sales data, all policy options

ensure that MDMS platforms facilitate the anonymisation and responsible use of data, fostering a more

equitable digital marketplace for all transport operators. Overall, these measures aim to eliminate barriers in

acquiring, sharing, combining, and reusing data assets, while maintaining coherent data governance and

continuous data management. This approach is thoroughly aligned with the horizontal legal framework

established at EU level through the Data Act199. Enhanced data sharing plays a key role in enabling the

development of innovative multimodal services, ultimately contributing to the establishment of a common

European Mobility Data Space and a common European Tourism Data Space. By prioritising digital

199 OJ L 2023/2854, 22.12.2023

54

integration and data accessibility, all policy options pave the way for technological advancements that

streamline operations, elevate service standards, and drive sustainable growth across the European transport

network.

6.1.11. Impact on tourism

All policy options support the transformation of the tourism sector by unlocking seamless travel experiences

for tourists across Europe. Central to this are several measures designed to promote smooth and integrated

travel planning and execution. In all policy options, the sharing of non-personal data (PM7) with public

transport authorities will facilitate improved management of transport services, allowing tourists to easily

connect between various modes of transport. This harmonisation is essential for creating an interconnected

transport network that enhances fluid transfers between travel modes. In PO2, PO3 and PO4, the introduction

of a sharing obligation (PM13) will empower MDMS platforms to offer broader access to diverse transport

services, enabling tourists to book integrated and greener travel itineraries with ease. In PO3, the hosting

obligation (PM14) further strengthens service integration by ensuring that indispensable RU platforms foster

rail services, facilitating a seamless booking experience for travellers wishing to undertake rail journeys. PM14

enhances the ability of the most popular rail platforms to present tourists with unified travel solutions that cater

for their specific needs. Therefore, PO3 contributes most to the development of a user-centric travel ecosystem

that enhances accessibility, convenience, and efficiency for tourists.

6.1.12. Territorial impacts

All policy options are expected to strengthen territorial cohesion by creating a more inclusive and integrated

multimodal transport system across all EU regions. Central to this are measures designed to ensure fair access

and visibility for transport operators of all sizes. In all policy options, the obligation for MDMS platforms to

ensure neutral display of transport offers (PM1) guarantees that all operators, including those in peripheral or

less-connected areas, receive equal visibility alongside larger providers. In PO2 and PO3, additional measures

significantly enhance territorial cohesion. The obligation to share tickets for indispensable RUs (including

cross-border and PSO services) is expected to improve the connectivity (PM13). Most importantly, the access

to indispensable RU platforms (PM14) in PO3 guarantees that even smaller regional providers can be

integrated into major booking platforms. PO3 is therefore expected to have the highest impact on territorial

cohesion and create a transport system where all regions, from major cities to remote areas, have equal

opportunity to participate in the digital mobility market. This balanced approach supports economic

development across all territories while preventing the concentration of mobility services in already well-

connected areas.

6.2. Social impacts

6.2.1. Impacts on health

All policy options are projected to have a positive impact on health, relative to the baseline, due to the higher

use of more sustainable transport options. This is expected to result in reduced air pollutant emissions and

subsequent positive impacts on health. These impacts are higher in PO2, PO3 and PO4, since the measures

included in these policy options are specifically supporting access to rail offers. The savings in external costs

of air pollutants, expressed as present value over 2028-2050 relative to the baseline, are estimated at EUR 455

million in PO2, EUR 670 million in PO3 and EUR 502 million in PO4. On the other hand, PO1 shows more

limited savings in external costs of air pollutant emissions, estimated at EUR 218 million expressed as present

55

value over 2028-2050 relative to the baseline200.

Table 17: Impacts on external costs of air pollution emissions in the POs relative to the baseline (EU27),

expressed as present value over 2028-2050, in million EUR (2024 prices) Difference to baseline

PO1 PO2 PO3 PO4

Savings in external costs of air pollutant emissions 218 455 670 502

Source: Ricardo et al. (2026), Impact assessment support study; ASTRA model

6.2.2. Impacts on employment

All policy options are anticipated to positively affect employment, primarily by promoting the use of collective

transport means, such as trains and coaches. This is expected to indirectly foster job creation within the

transport sector. Notably, the impacts of PO2, PO3 and PO4 are expected to be higher than those of PO1, due

to the higher increase in the use of collective transport means in these options relative to the baseline. The

limited changes in the air transport activity relative to the baseline suggests that the overall employment in the

air transport sector is likely to remain unchanged relative to the baseline. Moreover, the development and

deployment of additional MDMS platforms will likely create further employment opportunities within the

EU, as these new platforms will require skilled professionals for their implementation, maintenance, and

management. Overall, all policy options have the potential to stimulate investment in innovation, as

competition between MDMS platforms increases. This is expected to have a knock-on effect of potentially

increasing employment levels as sectors adapt and evolve to incorporate new technological and service-based

innovations. Increased investment in innovation often translates into the need for skilled professionals and

personnel to understand, implement, and support these advancements.

6.2.3. Impacts on safety

In all policy options, the reduction in the passenger car transport activity induced by more offers and

information available to users to make more sustainable choices, is expected to result in a decrease in the

number of fatalities and injuries relative to the baseline. The decrease in the number of fatalities and injuries

relative to the baseline is a direct result of the reduction in the passenger car transport activity and not affected

by any other drivers in the assessment. Cumulatively over 2028-2050, PO1 is estimated to lead to 731 lives

saved and 49 thousand injuries avoided, while PO2, PO3 and PO4 would have significantly higher positive

impact (1,480 lives saved and close to 95 thousand injuries avoided in PO2, 2,113 lives saved and close to 137

thousand injuries avoided in PO3 and 1,616 lives saved and 107 thousand injuries avoided in PO4) with PO3

showing the highest positive impact. All policy options contribute towards Sustainable Development Goal

SDG#9 (“Make cities and human settlements inclusive, safe, resilient and sustainable”).

Table 18: Expected reduction in the number of fatalities and injuries in the POs relative to the baseline, in

2030, 2040 and 2050, and cumulative reduction over the period 2028-2050 2030 2040 2050 Cumulative over 2028-

2050

% change to baseline

Fatalities

PO1 18 38 39 731 0.2%

PO2 33 76 84 1,480 0.4%

PO3 49 109 117 2,113 0.5%

PO4 36 83 92 1,616 0.4%

Injuries

PO1 1,313 2,465 2,489 49,421 0.2%

200 The impacts on air pollution emissions have been quantified with the help of the ASTRA model. The unit costs from

the 2019 Handbook on external costs of transport (Handbook on the external costs of transport - Publications Office of

the EU) have been used to monetise the external costs.

56

2030 2040 2050 Cumulative over 2028-

2050

% change to baseline

PO2 2,211 4,748 5,232 94,945 0.5%

PO3 3,270 6,913 7,341 136,909 0.7%

PO4 2,484 5,367 5,929 107,317 0.5%

Source: Ricardo et al. (2026), Impact assessment support study; ASTRA model

The reduction in external costs of accidents, expressed as present value over 2028-2050 relative to the baseline,

is estimated to be the highest in PO3 (EUR 21.3 billion), followed by PO4 (EUR 16.5 billion), PO2 (EUR

14.8 billion) and PO1 (EUR 7.6 billion)201.

Table 19: Impacts on external costs of accidents in the POs relative to the baseline (EU27), expressed as

present value over 2028-2050, in million EUR (2024 prices) Difference to baseline

PO1 PO2 PO3 PO4

Savings in external costs of accidents 7,606 14,807 21,297 16,470

Source: Ricardo et al. (2026), Impact assessment support study; ASTRA model

6.2.4. Impacts on fundamental rights

The level of data protection for businesses and consumers is a key element when considering the impacts of

the policy options on fundamental rights. Data protection for B2C MDMS platform users is provided by the

GDPR, which allows for harmonised protection of individuals. Also, for B2B MDMS, the entry into

application of the GDPR is a key consideration prompting the revision and repeal of the CRS Code of

Conduct´s rules on data protection in all policy options (PM5). As a result of this regulatory simplification, the

duplication of rules will be removed and there would thus be no more room for potential inconsistencies. The

intervention would not have any negative material impact on fundamental rights, and data protection

specifically.

6.2.5. Impacts on youth

All policy options support the transformation of the transport systems in ways that resonate strongly with

young Europeans, who are increasingly demanding sustainable, connected, and affordable mobility solutions.

Central to this shift are key measures designed to align with youth needs, and in particular seamless travel

experiences as reflected by POLIS in the targeted survey conducted in 2025202. A Eurobarometer conducted

in 2024 shows youths give more importance to the environmental impact of their trips and adapt their journey

more frequently but also indicate they cannot always afford more sustainable options. Youths more often

search for information on multimodal or multi-operator trips and more often find suitable combinations, but

they also indicate more often that they did not book the journey because they could not book all tickets in one

place.203 By ensuring access to all RU offers (PM13), PO2, PO3 and PO4 eliminate fragmented booking

systems and can directly impact younger people204. Moreover, PO2, PO3 and PO4 expand access to

multimodal and low-carbon options, directly addressing youth demand, as the Eurobarometer shows that use

of trains and coaches is highest among respondents aged 15-24, used respectively by 68% and 48% of this age

group. PO2, PO3 and PO4 particularly foster a transport system that mirrors youth values: digital-first, climate-

201 The impacts on fatalities and injuries have been quantified with the help of the ASTRA model. The 2019 Handbook

on the external costs of transport (Handbook on the external costs of transport - Publications Office of the EU) has been

used to monetise the costs. 202 POLIS underlined that younger groups use digital services more frequently and would therefore benefit the most

from having better information and accessibility to tickets in a digital way. 203 Flash Eurobarometer 551 - Multimodal Digital Mobility Service – August – September 2024 204 In the targeted survey, ALL RAIL underlined that the impact would likely be more immediate for younger passengers,

who are more familiar with using MDMS platforms to search and book their trips. This group is particularly sensitive to

fragmented offers and tends to compare options across operators. Making all services visible and bookable on the same

platforms would improve their access to better prices and combinations, especially for regional and cross-border travel.

57

conscious, and user-centric.

6.3. Environmental impacts

The analysis of environmental impacts covers tank-to-wheel CO2 emissions, air pollutant emissions

(particulate matter (PM2.5) and nitrogen oxides (NOx)) and noise emissions. The ASTRA model has been

used to quantify the impact of the policy options on emissions, based on the modal shift each option is expected

to achieve.

Impacts on CO2 emissions. The use of more sustainable transport means, especially trains, is expected to

reduce CO2 emissions relative to the baseline. PO2, PO3 and PO4 are projected to achieve higher reductions

in CO2 emissions than PO1, with PO3 anticipated to deliver the highest decrease. PO1 results in relatively

limited modal shift when compared to the other POs. Thus, the reduction in CO2 emissions for PO1 is more

limited and estimated at 8.3 million tonnes cumulatively over 2028-2050 relative to the baseline. PO3 results

in the highest impact among the options, cumulatively over 2028-2050 relative to the baseline, estimated at

23.8 million tonnes, followed by PO4 (18.1 million tonnes) and PO2 (16.5 million tonnes). Cumulatively over

2028-2050, PO3 is expected to result in 0.5% reduction in CO2 emissions relative to the baseline, PO4 and

PO2 in 0.3% reduction and PO1 in 0.2% reduction. As shown in the table below, the reduction in CO2

emissions relative to the baseline is projected to reduce over time in all policy options. This is because of the

decarbonisation of the transport sector over time in the baseline. The savings in external costs of CO2

emissions, expressed as present value over 2028-2050 relative to the baseline, are estimated to be highest in

PO3 (EUR 6.8 billion), followed by PO4 (EUR 5.2 billion), PO2 (EUR 4.7 billion) and PO1 (EUR 2.4

billion)205.

Impacts on air pollutant emissions. Similarly to CO2 emissions, the reduction in air pollutant emissions is

mainly driven by the higher use of more sustainable transport means and optimised trips. Cumulatively over

2028-2050, the highest reduction in NOx emissions relative to the baseline is projected in PO3 (23.9 thousand

tonnes), followed by PO4 (17.9 thousand tonnes), PO2 (16.2 thousand tonnes) and PO1 (7.7 thousand tonnes).

This represents a decrease by 0.2% relative to the baseline in PO3 and around 0.1% in PO4, PO2 and PO1.

As for CO2 emissions and NOx emissions, the highest reduction in particulate matter (PM2.5) emissions,

cumulatively over 2028-2050, is estimated for PO3 (1.5 thousand tonnes), followed by PO4 (1.1 thousand

tonnes), PO2 (1 thousand tonnes) and PO1 (0.4 thousand tonnes). Thus, the savings in external costs of air

pollution emissions, expressed as present value over 2028-2050 relative to the baseline, are projected at EUR

218 million in PO1, EUR 455 million in PO2, EUR 670 million in PO3 and EUR 502 million in PO4206.

Table 20: Impact on CO2 emissions and air pollutant emissions (thousand tonnes of CO2 emissions avoided

and tonnes of NOx and PM2.5 avoided relative to the baseline in 2030, 2040 and 2050, and cumulative over

2028-2050; % change in cumulative CO2 emissions and air pollution emissions relative to the baseline) 2030 2040 2050 Cumulative over 2028-

2050

% change to baseline

CO2 emissions (thousand tonnes of CO2 avoided)

PO1 541 370 17 8,319 0.2%

PO2 992 761 37 16,468 0.3%

PO3 1,458 1,106 52 23,794 0.5%

PO4 1,091 838 41 18,148 0.3%

NOx emissions (tonnes of NOx avoided)

PO1 485 377 93 7,727 0.1%

PO2 986 749 194 16,221 0.1%

205 The unit costs from the 2019 Handbook on external costs of transport (Handbook on the external costs of transport -

Publications Office of the EU (europa.eu)) have been used to monetise the external costs. 206 The unit costs from the 2019 Handbook on external costs of transport (Handbook on the external costs of transport -

Publications Office of the EU (europa.eu)) have been used to monetise the external costs.

58

2030 2040 2050 Cumulative over 2028-

2050

% change to baseline

PO3 1,532 1,142 271 23,929 0.2%

PO4 1,097 833 212 17,911 0.1%

PM2.5 emissions (tonnes of PM avoided)

PO1 27 19 4 437 0.1%

PO2 57 43 12 980 0.2%

PO3 89 65 19 1,498 0.2%

PO4 63 47 13 1,080 0.2%

Source: Ricardo et al. (2026), Impact assessment support study; ASTRA model

Impacts on external costs of noise emissions. The savings in external costs ofnoise emissions, expressed as

present value over 2028-2050 relative to the baseline, are also estimated to be highest in PO3 (EUR 2.1 billion),

followed by PO4 (EUR 1.7 billion), PO2 (EUR 1.5 billion) and PO1 (EUR 0.7 billion) 207.

Table 21: Impacts on external costs of CO2 emissions, air pollution emissions and noise emissions in the POs

relative to the baseline (EU27), expressed as present value over 2028-2050, in million EUR (2024 prices) Difference to baseline

PO1 PO2 PO3 PO4

Savings in external costs of CO2 emissions 2,367 4,696 6,778 5,176

Savings in external costs of air pollution emissions 218 455 670 502

Savings in external costs of noise emissions 735 1,509 2,146 1,663

Source: Ricardo et al. (2026), Impact assessment support study; ASTRA model

All policy options are consistent with the environmental objectives of the European Green Deal and the

European Climate Law208. All policy options contribute towards Sustainable Development Goal

SDG#13 (“Climate Action”) and SDG#3 (“Ensure healthy lives and promote wellbeing for all at all ages”,

including target 3.9: By 2030, substantially reduce the number of deaths and illnesses from hazardous

chemicals and air, water and soil pollution and contamination.). No significant harm is expected on the

environment in any of the policy options.

6.4. Summary of the economic, social and environmental impacts

The table below provides a summary of the comparison of the options against the baseline scenario in terms

of economic, social and environmental impacts. The following ranking symbols have been used: from ‘0’ (no

impact relative to the baseline), to '+' (more positive than the baseline) and '+++' (much more positive than the

baseline).

Table 22: Comparison of options in terms of economic, social and environmental impacts relative to the

baseline PO1 PO2 PO3 PO4

Economic impacts + ++ ++/+++ ++

MDMS platforms (in EUR million, expressed as present

value over 2028-2050 relative to the baseline)

- + + --

Adjustment costs 92.9 127.7 122.3 282.3

Administrative costs 0.5 0.5 0.5 0.5

Adjustment cost savings 13.0 149.0 134.0 142.7

Net costs (-) or net benefits (+) for MDMS platforms -80.4 20.9 11.3 -140.0

Transport operators (in EUR million, expressed as

present value over 2028-2050 relative to the baseline)

+ ++ ++ ++

207 The unit costs from the 2019 Handbook on external costs of transport (Handbook on the external costs of transport -

Publications Office of the EU (europa.eu)) have been used to monetise the external costs. 208 Regulation (EU) 2021/1119 establishing the framework for achieving climate neutrality.

59

PO1 PO2 PO3 PO4

Adjustment costs 0.0 48.2 42.2 45.2

Administrative costs0.001 0.001 0.001 0.001

Adjustment cost savings13.0 149.0 134.0 142.7

Net benefits for transport operators 13.0 100.9 91.8 97.6

National authorities in EUR million, expressed as

present value over 2028-2050 relative to the baseline)

-- -- -- --

Enforcement costs 106.5 106.5 106.5 106.5

Administrative costs 28.9 28.9 28.9 28.9

Net costs for national authorities 135.4 135.4 135.4 135.4

European Commission (in EUR million, expressed as

present value over 2028-2050 relative to the baseline)

- - - -

Adjustment costs 5.3 5.3 5.3 5.3

Net costs for European Commission 5.3 5.3 5.3 5.3

Impacts on SMEs* (in EUR million, expressed as present

value over 2028-2050 relative to the baseline)

+ ++ ++ ++

Adjustment cost savings for SME MDMS platforms 9.2 101.0 90.5 95.7

Net benefits for SME MDMS platforms 9.2 101.0 90.5 95.7

Adjustment cost savings for SME transport operators 9.4 107.0 96.1 102.5

Net benefits for SME transport operators 9.4 107.0 96.1 102.5

Impacts on user costs and congestion (in EUR million,

expressed as present value over 2028-2050 relative to the

baseline)

++ ++ +++ +++

Savings in external costs of road congestion 1,758 4,352 6,438 4,833

Impacts on competitiveness + ++ ++ ++

Impact on the functioning of the internal market and

competition

+ ++ ++ ++

Impact on innovation + ++ +++ ++

Digital by default ++ ++ ++ ++

Impact on tourism + ++ +++ ++

Territorial impacts + ++ +++ ++

Social impacts + ++ ++/+++ ++

Impacts on health (in EUR million, expressed as present

value over 2028-2050 relative to the baseline)

+ ++ +++ ++

Savings in external costs of air pollutant emissions218 455 670 502

Impacts on employment + ++ ++ ++

Impact on safety + ++ +++ ++

Fatalities reduction (number of lives saved, cumulative over

2028-2050 relative to the baseline)

731 1,480 2,113 1,616

Injuries reduction (number of injuries avoided, cumulative

over 2028-2050 relative to the baseline)

49,421 94,945 136,909 107,317

Impacts on fundamental rights + + + +

Impacts on youth + ++ ++ ++

Environmental impacts + ++ ++/+++ ++

CO2 emissions saved (in million tonnes, cumulative over

2028-2050 relative to the baseline)

8.3 16.5 23.8 18.1

Air pollutant emissions saved (in thousand tonnes,

cumulative over 2028-2050 relative to the baseline)

7.7 (NOx)

0.4 (PM2.5)

16.2 (NOx)

1 (PM2.5)

23.9 (NOx)

1.5 (PM2.5)

17.9 (NOx)

1.1 (PM2.5)

Savings in external costs of noise emissions (in EUR

million, expressed as present value over 2028-2050 relative

to the baseline)

735 1,509 2,146 1,663

Note: *Impacts on SMEs overlap with impacts on MDMS platforms and transport operators. This is because part of

MDMS platforms and transport operators are SMEs.

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7. HOW DO THE OPTIONS COMPARE?

7.1. Effectiveness

The assessment of effectiveness looks at the extent to which the policy options meet the general and specific

objectives (SO) of the intervention. Table 23 presents the link between the policy objectives and the

assessment criteria.

Table 23: Link between objectives and assessment criteria General objectives Specific objectives Assessment criteria

GO1 – Promote rail single ticketing

for multi-operator journeys and

thereby enhance attractiveness of rail

to increase sustainability of the

transport system and support modal

shift

GO2 – Better functioning of the

ticket distribution market,

contributing to the competitiveness

and the functioning of the transport

services market

SO1 – Improve transparency and

establish a level playing field for

transport operators in terms of access

and use of indispensable MDMS

- Increase in the number of

agreements between platforms and

transport operators indicating a

better functioning of the

distribution markets (B2B and

B2C)

- Decrease in average expenditure

per person for interurban mobility,

due to increase in competition

resulting from better access and

use of indispensable MDMS for

transport operators

SO2 – Improve completeness of rail

offer on MDMS platforms, including

indispensable RU platforms

- Increase in the transport activity

by rail due to better visibility and

access to these services

Overall, all policy options are expected to contribute to the general objectives of promoting rail single

ticketing for multi-operator journeys and better functioning of the online ticket distribution market

although to various degrees.

Concerning SO1 (Improve transparency and establish a level playing field for transport operators in terms of

access and use of indispensable MDMS), the number of agreements between MDMS platforms and transport

operators compared to the baseline can provide a relevant indication of the extent to which operators are

integrated on indispensable MDMS platforms (both B2B and B2C). All policy options show an increase in

the number of agreements between platforms and transport operators in the period 2030-2050. PO2 shows the

highest increase relative to the baseline in 2030 and 2040 (42% increase in 2030 and 125% in 2040), followed

by PO4 (41% increase in 2030 and 117% increase in 2040) and PO3 (40% increase in 2030 and 110% increase

in 2040). In 2050, PO2, PO3 and PO4 show similar increase in the number of agreements relative to the

baseline (97% increase). The contribution of PO1 towards SO1 is much more limited (3% increase in 2030,

11% increase in 2040 and 5% in 2050). In addition, the decrease in the average expenditure per person for

interurban mobility can reflect an increase in competition resulting from better access and use of indispensable

MDMS and indispensable RU platforms for transport operators. PO3 shows the highest decrease in the

average expenditure per person compared to the baseline (0.06% in 2030 and 0.34% in 2050), followed by

PO4 (0.04% decrease in 2030 and 0.28% in 2050) and PO2 (0.03% decrease in 2030 and 0.24% in 2050).

PO1 shows limited impacts (0.01% decrease in 2030 and 0.05% in 2050). Thus, PO2, PO3 and PO4 contribute

significantly towards SO1, while the contribution of PO1 is more limited.

Concerning SO2 (Improve completeness of rail offer on MDMS platforms, including indispensable RU

platforms), the increase in the transport activity by rail, compared to the baseline, can serve as a meaningful

indicator of passengers’ ability to find, compare, and purchase rail tickets. PO3 shows the highest contribution

towards SO2 with a 2.5% increase in transport activity by rail in 2030, and 4.8% in 2050, relative to the

baseline. The combined effect of the obligation for indispensable RU platforms to integrate requesting

operators (PM14) with the obligation for indispensable RUs to share their tickets (PM13), only included in

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PO3 can explain this result. The sharing obligation is necessary to allow platforms to create a complete

overview of the rail services offer for passengers – in terms of both connections and fares – to sell tickets and

to combine tickets of different operators into single journeys. Such complete ticketing offer is likely to

materialise on independent platforms, whose business model is to sell their services to any RU and attract as

many users as possible. Incumbent platforms, on the other hand, could already host a larger number of

operators, but decide not to do so and are unlikely to change their behaviour because of the sharing obligation.

In this context, if passengers were able to easily compare the platforms’ offers and detect which ones are

incomplete and what is missing; if they were willing to modify their purchasing habits; and if they were ready

to trust the reliability and security of alternative online distribution services, the sharing obligation would go a

long way towards providing passengers with a satisfactory solution. However, in most Member States,

notwithstanding the presence of independent platforms, the platform owned by the incumbent RU is still the

go-to platform for passengers wishing to buy a ticket. Where these websites sell tickets of some other

companies, but not all, it is difficult for passengers to see that they are being presented with an incomplete

offer, making it unlikely that passengers would switch to another platform. Even if the use of AI tools would

help passengers in revealing more convenient offers, habits are not easily changed and confidence in

alternative purchasing channels is not easily established. Against this background, it is unlikely that third-party

platforms would quickly gain the necessary size to challenge the role of the incumbent platform and to be able

to offer a meaningful alternative to RUs wishing to have their tickets distributed. Whilst the sharing obligation

will support the longer-term development of independent ticketing platforms, the hosting obligation is

important to ensure that passengers and new entrant operators can already find the intermediation services

they need in the short-term.

In PO4 and PO2 the impacts are more limited (1.9% increase in the transport activity by rail in 2030 and 4%

in 2050 relative to the baseline in PO4; and 1.7% increase in the transport activity by rail in 2030 and 3.7% in

2050 relative to the baseline in PO2) and thus also the contribution towards SO2. PO1 shows limited impact

(1% increase in the transport activity by rail in 2030 and 1.8% in 2050 relative to the baseline) and thus

contribution towards SO2.

To conclude, PO3 is the most effective option, since it achieves not only a higher modal shift than PO2 by

about 30% by 2050, but is expected to achieve a 40% higher modal shift than PO2 by 2030 bringing not only

more benefit, but also attaining them earlier in time.

7.2. Efficiency

Efficiency concerns the ‘extent to which objectives can be achieved for a given cost (cost effectiveness)’. The

costs and benefits in this section are presented in two alternative ways: excluding external costs savings and

including external costs savings due to modal shift. This approach is used for acknowledging the uncertainty

related to the estimated modal shift. It should however be noted that excluding external costs savings represents

an extremely conservative approach. As indicated in section 6.1.6, modal shift is largely induced by the

various type of savings that consumers might be able to achieve thanks to the policy measures: less time spent

on search engines, shorter travel time thanks to better travel connections and more convenient fares. These

combined savings make railways a comparatively more attractive option than other modes. Because of the

uncertain quantification of these savings, a choice was made of providing a qualitative assessment, but not a

quantified estimate. Accordingly, only the external cost savings of the modal shift were quantified, or, in other

words only the benefits to society but not those to individual users. This already produces a very conservative

estimate and likely underestimation of the benefits from modal shift. In addition, sensitivity analysis regarding

the potential modal shift has been performed and it is presented in section 7.6.

The estimates of costs and benefits excluding external costs savings are summarised in Table 24.

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Table 24: Summary of costs and benefits of policy options, excluding external costs savings - present value

over 2028-2050 compared to the baseline (in million EUR, 2024 prices) Difference to baseline

PO1 PO2 PO3 PO4

MDMS platforms

Adjustment costs 92.9 127.7 122.3 282.3