Aruanne - COM(2026) 228

EN EN

EUROPEAN COMMISSION

Brussels, 13.5.2026

COM(2026) 228 final

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND

THE COUNCIL

on the implementation and results of Regulation (EU) 2021/782 on rail passengers’

rights and obligations

TABLE OF CONTENTS

1. Introduction ................................................................................................................. 2

2. Implementation and results of Regulation (EU) 2021/782 ......................................... 3

2.1. Exemptions (Article 2) ...................................................................................... 3

2.2. Equal treatment (Article 5) ................................................................................ 6

2.3. Carriage of bicycles (Article 6) ......................................................................... 7

2.4. Real-time travel information (Article 10) ......................................................... 9

2.5. Through-tickets (Article 12) ............................................................................ 11

2.6. The right to self-rerouting (Article 18(3)) ....................................................... 15

2.7. Compensation - Force majeure (Article 19(10)) ............................................. 17

2.8. Common form for reimbursement and compensation requests (Articles

18(7) and 19(6))............................................................................................... 19

2.9. Major disruptions and contingency planning (Article 20(6)) .......................... 19

2.10. Persons with disabilities or reduced mobility (Chapter V) ............................. 21

2.11. Complaint-handling and enforcement (Article 28 and Chapter VII) .............. 24

3. Conclusions ............................................................................................................... 29

ANNEX A OVERVIEW OF THE UPTAKE OF EXEMPTIONS UNDER

REGULATION (EU) 2021/782 ........................................................ 30

ANNEX B COMPARISON WITH MEMBER STATE EXEMPTIONS

UNDER REGULATION (EC) NO 1371/2007 ................................. 31

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1. INTRODUCTION

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

on rail passengers’ rights and obligations (1) (‘the Regulation’) entered into force on 7 June

2021 and has applied since 7 June 2023. It repealed and replaced Regulation (EC) No

1371/2007 on rail passengers’ rights and obligations which entered into force in 2009 (2).

The Regulation amended and introduced provisions on: exemptions (Article 2), equal

treatment (Article 5), the carriage of bicycles (Article 6), real-time travel information

(Article 10), through-tickets (Article 12), a right to self-routing (Article 18(3)), force

majeure (Article 19(10)), the common form for reimbursement and compensation requests

(Articles 18(7) and 19(6)), major disruptions and contingency plans (Article 20(6)), the

rights of persons with disabilities or reduced mobility (Chapter V) and complaint-handling

and enforcement (Article 28 and Chapter VII).

Article 39 of the Regulation requires the Commission to report by 7 June 2026 to the

European Parliament and the Council on the implementation and the results of the

Regulation. The purpose of this report is to fulfil this obligation. This report focuses on the

new elements introduced by the 2021 revision.

This report is based on information provided pursuant to the Regulation, including reports

by railway undertakings on their performance on service quality, and reports from the

Member States’ national enforcement bodies (NEBs) on their activities (3). The report is

also based on the notifications submitted by Member States to the Commission under

Articles 2(7), 11(4), 31(3) and Article 35(1) of the Regulation.

In addition, this report incorporates findings from a Commission-led supporting study (4),

which gathered data across all Member States on the implementation of the Regulation.

Since the study focused on the practices of the main railway undertaking in each Member

State, the references in this report to findings on the application of the rules in a given

Member State should be understood as referring to the practices of the main railway

undertaking in that Member State, unless stated otherwise.

The findings of this report, in particular regarding through-tickets, are also relevant in the

context of a new Commission proposal (COM(2026) 233) extending passenger rights in

case of missed rail connections performed under a single ticket bought on one platform as

part of a single transaction.

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

passengers’ rights and obligations (recast), OJ L 172, 17.5.2021, p. 1.

(2) See Article 41 of the Regulation. Only Article 6(4) related to procurement procedures for new or major

upgraded rolling stock for the carriage of bicycles applies as of 7 June 2025.

(3) It follows from Article 32(3) of the Regulation that every two years the national enforcement bodies

shall publish reports with statistics on their activity, including on penalties applied by 30 June of the

following calendar year. Those reports shall be made available on the website of the European Union

Agency for Railways.

(4) Supporting study for the Report on the implementation and results of Regulation (EU) 2021/782 on rail

passengers' rights and obligations by Ramboll Management Consulting A/S, Milieu Consulting SRL,

and Transport & Mobility Leuven.

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2. IMPLEMENTATION AND RESULTS OF REGULATION (EU) 2021/782

2.1. Exemptions (Article 2)

Article 2 of the Regulation defines its scope by setting out which rail journeys and services

fall under the Regulation. It also specifies which rail passenger services Member States

may exempt from particular rules under the Regulation. The reasons for exemptions must

be included in notifications to the Commission. The 2021 revision of the exemption regime

was intended to limit the excessive use of exemptions under the previous rules,

progressively extend the Regulation’s coverage to more services, and ensure that

passengers’ rights are more consistent and predictable. Member States must notify any

such exemptions to the European Commission and provide the reasons for granting

them (5).

An overview of exemptions per Member State under the current Regulation can be found

in Annex A. A comparison of exemptions taken up per service and per Member State

between Regulation (EU) 2021/782 and Regulation (EC) No 1371/2007 can be found in

Annex B.

Out of 27 Member States, two - Cyprus and Malta - have no railway network. Six Member

States (6) with a railway network have not made use of any exemption. The remaining 19

Member States use the exemptions: the majority to a limited extent, and a smaller group

more extensively (7).

Under Article 2(4) of Regulation (EU) 2021/782, the possibility of applying exemptions

linked to long-distance domestic rail passenger services is limited to Member States that

had already relied on a comparable exemption for those services under the previous

Regulation up until 2024. In addition, the new Regulation has reduced the number of

provisions that can be exempted for these services (8) and the extension can only be

renewed once until 2029. In principle, this would have enabled up to ten Member States to

maintain exemptions for these services until 2029 (9). However, only five Member States

have notified that they will continue to apply the exemptions until 2029 (10).

This suggests that reliance on national exemptions for domestic long-distance rail services

has significantly decreased in practice under Regulation (EU) 2021/782, which in turn

could support a broader and more consistent application of passenger rights across Member

States. At the same time, the actual scope of the exemptions varies between these five

Member States (11).

In addition, the Regulation also allows Member States – as under the previous Regulation

– to exempt (sub)urban and regional rail passenger services from the Regulation (12), but

(5) Article 2 (Scope) paragraph (7) of the Regulation.

(6) BE, EE, EL, ES, IE, SI.

(7) See Annex A.

(8) Namely, Articles 15 (Advance payments), Article 17 (Liability for delays, missed connections and

cancellations) and Article 19 (Compensation), Article 20 (Assistance), in particular points (a) and (b)

of paragraph 2 thereof, and Article 30 (Information to passengers about their rights) paragraph 2 of the

Regulation.

(9) BG, EE, HU, IE, LV, LT, PL, PT, RO, SK.

(10) BG, HU, PT, RO, SK.

(11) A comprehensive overview of the national exemptions under Regulation (EU) 2021/782 can be found

on the Commission’s website: https://transport.ec.europa.eu/transport-themes/passenger-rights/rail-

passenger-rights_en.

(12) Article 2 (Scope) paragraph 6(a) of the Regulation.

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with the exception of an increased number of mandatory core provisions from which there

is no exemption and which must always apply as a consequence (13). There are

comparatively more mandatory provisions for regional rail passenger services than for

(sub)urban services (14).

Regional rail passenger services are subject to exemptions (15) in 12 out of 25 Member

States. The same Member States have also made use of exemptions for (sub)urban rail

passenger services (16).

In this regard, at the time 18 Member States (17) made use of the possibility under

Regulation (EC) No 1371/2007 to exempt (sub)urban and regional rail passenger services.

This confirms the previously observed trend in long-distance domestic services that fewer

Member States make use of the possibilities to exempt services under the new Regulation.

Four Member States have exempted (sub)urban services from most of the Regulation’s

provisions, therefore ensuring the application of the Regulation’s core mandatory

provisions (18). In three other Member States, a similar approach to exemptions is used

(applying the core mandatory provisions), with the notable difference that some other non-

mandatory provisions also continue to apply (19). Another group of five Member States

have opted for more targeted, provision-specific exemptions (20). These trends are broadly

confirmed for the same Member States when it comes to the exemptions for regional rail

passenger services (21).

Seven Member States have exempted international rail services to third countries from

the application of the current Regulation (22), compared to eight Member States under the

previous Regulation. Moreover, 15 Member States have made use of the exemption for

services operated strictly for historic or touristic purposes (23). In all of these countries,

historic or touristic services are exempted from the application of the Regulation overall,

(13) See Article 2 (Scope) paragraph 8 of the Regulation. In particular, this concerns Article 5 (Non-

discriminatory contract conditions and tariffs), Article 11 (Availability of tickets and reservations),

Article 13 (Liability for passengers and luggage), Article 14 (Insurance and coverage of liability),

Article 21 (Right to transport), Article 22 (Information to persons with disabilities and persons with

reduced mobility), Article 27 (Personal security of passengers) and Article 28 (Complaints) of the

Regulation.

(14) Article 5 (Non-discriminatory contract conditions and tariffs), Article 6 (Bicycles), Article 11

(Availability of tickets and reservations), Article 12 (Through-tickets), Article 13 (Liability for

passengers and luggage), Article 14 (Insurance and coverage of liability), Article 18 (Reimbursement

and re-routing) paragraph 3, Article 21 (Right to transport), Article 22 (Information to persons with

disabilities and persons with reduced mobility), Article 23 (Assistance at railway stations and on board),

Article 24 (Conditions under which assistance is provided), Article 25 (Compensation in respect of

mobility equipment, assistive devices and assistance dogs), Article 26 (Staff training), Article 27

(Personal security of passengers) and Article 28 (Complaints). However, exemption of regional rail

passenger from the application of Articles 12(1) and 18(3) may apply until 7 June 2028 (see Article 2(8)

of the Regulation).

(15) AT, BG, DE, FI, FR, HU, LU, PL, PT, RO, SE, SK.

(16) AT, BG, DE, FI, FR, HU, LU, PL, PT, RO, SE, SK.

(17) AT, BG, DE, EE, EL, ES, FI, FR, HU, IE, LT, LU, LV, PL, PT, RO, SE, SK.

(18) HU, PT, RO, SK.

(19) FR, LU, PL.

(20) AT, BG, DE, FI, SE.

(21) AT is the only Member State that distinguishes between urban and suburban rail passenger services. In

Austria the exemption regime for suburban rail passenger services is generally aligned with the

exemptions for regional rail passenger services.

(22) BG, CZ, FI, HU, LV, PL, RO. The scope of the exemptions and the applicability to all or specific third

countries may differ.

(23) BG, CZ, FI, FR, DE, HU, IT, LV, LT, NL, PL, PT, RO, SK, SE.

5

except for Articles 13 (Liability for passengers and luggage) and 14 (Insurance and

coverage of liability).

Six Member States have exempted the applicability of Article 10 of the Regulation because

it is not technically feasible for infrastructure managers to distribute real-time data to

railway undertakings, ticket vendors, tour operators or station managers (24). In all cases

the exemption applies until 7 June 2030 (Article 2(5) of the Regulation).

Eight Member States have made use of the possibility to apply a longer pre-notification

period of 36 hours instead of 24 hours for assistance to persons with disabilities and

persons with reduced mobility (25). In all cases the exemption applies until 30 June 2026,

in line with the maximum period allowed for this exemption under Article 24(a), third

subparagraph of the Regulation. In the majority of Member States, the maximum pre-

notification period of 24 hours has already applied since the entry into application on 7

June 2023. In Denmark, the scope of the exemption is narrower, as it applies only to cross-

border rail services to Germany rather than to all rail passenger services.

It follows from the above that the use of exemptions under the Regulation is relatively

widespread but varies significantly in scope. Several exemption options are used by a

sizeable number of Member States, notably those concerning urban, suburban and regional

services, as well as the option for rail services operated strictly for historic or touristic

purposes. By contrast, other exemption possibilities, such as those relating to long-distance

domestic rail services and international rail services to third countries, are taken up by a

smaller group of Member States.

If Member States decide to exempt certain rail services from the application of certain

provisions of this Regulation, they must inform the Commission accordingly. When

providing this information, Member States must present the reasons for granting such

exemptions. Recital 10 of the Regulation clarifies that, when informing the Commission

about exemptions that have been granted, Member States should also explain the measures

which they have taken or envisage taking to comply with the obligations under the

Regulation when the exemptions concerned expire. 26 Member States (26) have notified

the Commission of national implementing measures, including exemptions that they had

granted in accordance with the Regulation.

In comparison with the approach under the previous Regulation, this suggests a shift

towards a more structured and differentiated use of exemptions. Under the earlier

framework, exemptions were widely used across Member States and service categories,

and were frequently broad in scope, with some also renewable over long periods. Under

the current framework, exemptions continue to exist, particularly for urban, suburban and

regional services, but there is a clearer distinction between a limited group of more

extensive users (27) and a growing set of Member States making little (28) or (almost) (29)

(24) AT, HR, HU, LV, PL, RO.

(25) BG, CZ, HR, DK, DE, HU, LV, RO.

(26) Additionally, to 25 Member States with a railway network, one Member State without a railway network

(MT) notified implementing measures to the Commission, the other (CY) did not do so yet. In particular,

a NEB has to be designated to ensure the monitoring and enforcement of the obligations in the

Regulation with regard to ticket vendors and tour operators that might be established on the territory of

a Member State with no railway network.

(27) BG, HU, RO.

(28) AT, CZ, DE, FI, FR, HR, LU, LV, PL, PT, SE, SK.

(29) In particular, several Member States only exempted from the Regulation services that are strictly

operated for historic or touristic purposes.

6

no use (30) of derogations. In addition, exemptions are more often framed as targeted,

provision-specific carve-outs or time-limited postponements, rather than broad, open-

ended exclusions, which suggests a gradual narrowing of the role of exemptions and a

corresponding expansion of the Regulation’s reach in practice.

2.2. Equal treatment (Article 5)

Article 5 of the Regulation requires railway undertakings, ticket vendors and tour operators

to offer contract conditions and tariffs without direct or indirect discrimination based on

the passenger’s nationality (of a Member State) or the provider’s place of establishment in

the EU. This provision is without prejudice to social tariffs and also applies to reservations

under Article 11 of the Regulation. Similar non-discrimination provisions already existed

for other modes of transport before the entry into force of the Regulation, whereas in the

context of rail travel, recourse had to be made to the general non-discrimination provision

of the Treaty (Article 18 of the Treaty on the Functioning of the EU).The introduction of

Article 5 therefore increases legal certainty. In addition, this Article is one of the core

mandatory provisions of the Regulation which cannot be exempted for (sub)urban and

regional rail passenger services, nor can it be exempted for long-distance domestic

services.

Based on the available evidence gathered in the context of the supporting study, there

appears to be no direct discrimination based on nationality in any Member State. The

consulted railway undertakings confirmed that, while different tariffs may apply (e.g. a

social tariff, group discount, a price increase close to the date of travel, different prices

according to the ticket vendor), no discrimination or different pricing is applied on the

basis of nationality.

At the same time, there are also indications in the supporting study that non-nationals of a

Member State may be subject to different treatment in practice due to the requirements to

ensure access social tariffs, e.g. requiring national certifications. This may potentially limit

access to such discounts for passengers who are not nationals of the Member State

concerned, as even though they would usually qualify for the discount (e.g. because they

are a person with a disability or a person with reduced mobility or a student), they may not

have the national certification required to buy a discounted ticket. In accordance with the

case law of the Court of Justice of the EU (31), each case concerning social tariffs for

residents must be assessed individually and may be deemed acceptable under EU law if it

is justified by objective considerations of public interest, independent of the nationality of

the persons concerned, and the measure is proportionate to the objective pursued.

NEB reports under Article 32 of the Regulation from three Member State (32) mention

Article 5 under the description of their enforcement activities. However, there are currently

no complaints, investigations or penalties explicitly linked to Article 5 of the Regulation.

Only one NEB report (33) lists 14 complaints as ‘Discrimination of passengers based on

nationality’ out of 647 Regulation-related incidents in 2024, but there are no details on

outcomes, investigations or penalties under the Regulation. Another NEB (34) report lists

Article 5 of the Regulation under penalties but makes no mention of sanctions. This aligns

(30) BE, DK, EE, EL, ES, IE, IT, LT, NL, SI.

(31) See e.g. judgment of 1 October 2009, Gottwald, C-103/08, EU:C:2009:597, paras. 27 and 30.

(32) BE, CZ, PT.

(33) PT.

(34) BE.

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with interviews held in the context of the supporting study, indicating that discrimination

issues based directly on nationality are rare or entirely absent.

2.3. Carriage of bicycles (Article 6)

The Regulation strengthens the pre-existing right to bicycle carriage under Regulation

(EC) No 1371/2007 by establishing that passengers shall be entitled to take bicycles on

board (for a reasonable fee where appropriate). This includes the right to make a

reservation for bicycle carriage on trains for which reservations are required, and the

provision of remedies for unjustified denial of reserved spaces (re-routing under Article 18,

compensation under Article 19, assistance under Article 20(2) of the Regulation). The

Regulation further introduces stowage obligations (the use of designated spaces where

available, otherwise passenger-supervised stowage that prevents harm to others or any

hindrance to operations). Railway undertakings are also required to publish capacity limits

and conditions on websites and in stations, applying the technical specifications for

interoperability of telematics applications for passenger services. The Regulation also

introduces a requirement that, as from 7 June 2025, procurement procedures for new

rolling stock or major upgrades necessitating a new vehicle authorisation for placing on

the market (excluding restaurant, sleeping or couchette cars) must incorporate an adequate

number of dedicated spaces for assembled bicycles (as opposed to folded ones only) within

train compositions. Furthermore, Article 6(5) and (6) permit railway undertakings or

competent authorities under Regulation (EC) No 1370/2007 to adopt plans for bicycle

carriage following public consultation. In the absence of such plans or where the plans do

not determine a number of dedicated spaces for assembled bicycles, a default of at least

four dedicated spaces per train composition applies. This requirement can be subject to

objectively justified exceptions (e.g. seasonal ski demand on low-bicycle routes), while

Member States may impose higher minima for certain types of services.

The provisions of Article 6 can be exempted for urban and suburban rail passenger

services (Article 2(6)(a)), international services of which a significant part operates outside

the EU (Article 2(6)(b)), and services operated strictly for historical or touristic use (Article

2(2)). However, the provisions of Article 6 cannot be exempted and always apply fully to

regional rail passenger services (Article 2(8), second subparagraph) and long-distance rail

passenger services, which are defined as non-urban, non-suburban, and non-regional

(Article 3(15)). This ensures that bicycle carriage requirements remain mandatory for these

core network services. Overall, the possibility to exempt this provision has not been widely

used across Member States: for urban or suburban rail services, exemptions were notified

by seven Member States (35), whereas exemptions were notified by seven Member

States (36) in relation to international services of which a significant part, including at least

one scheduled station stop, is operated outside the EU.

In terms of findings, the supporting study suggests that five Member States require railway

undertakings to develop bicycle plans (37). In two Member States, railway undertakings

have developed such plans without national requirements (38). The number of bicycle

spaces is outlined in the bicycle plans of railway undertakings operating in four Member

(35) AT, BG, FR, HU, PT, RO and SK. For FR, the notified exemption does not apply to Article 6(3) and (4)

of the Regulation.

(36) BG, CZ, FI, HU, LV, PL,RO.

(37) DE (as of December 2025), ES, FR, HU, LU; Art. 6(5) of the Regulation allows Member States to

require competent authorities and railway undertakings operating on their territory to establish these

plans.

(38) NL and DE (in DE there were bicycle plans before the national legal requirement of having a plan started

to apply).

8

States (39). The supporting study indicates that these plans were established in consultation

with the public and relevant representative organisations.

Based on the available information, it also seems that one Member State (France) has

passed national legislation which sets a higher minimum number of bicycle spaces:

eight spaces for new and renovated trains destined for open access services, services of

national interest and certain regional services (40).

The supporting study also found that the minimum number of four bicycle spaces is

respected by incumbent railway undertakings operating in 17 Member States (41). In

specific circumstances, however, fewer than four bicycle spaces may be available in

services provided by railway undertakings in 14 Member States (42). This may be, for

example, due to limited capacity on certain trains, routes or services, or because of limits

set during specific seasons or when there is overcrowding. The minimum number of

bicycle spaces made available by each railway undertaking may also vary according to the

train or service. At the same time, in some situations, more than four bicycle spacesmay

be available in services provided by incumbent railway undertakings in 11 Member

States (43). This may be, for example, when newer rolling stock is deployed.

As Article 6(4) of the Regulation came into effect in June 2025, in almost all Member

States with rail services, railway undertakings which were assessed in the supporting study

appear to now take minimum bicycle space requirements into account when procuring

new rolling stock.

The supporting study also indicates that railway undertakings in nearly all Member States

require a fee to transport a bicycle onboard a train. These fixed or variable fees are typically

within the range of EUR 1.50 to EUR 7.95. Most railway undertakings also require prior

reservations, particularly for services where seat reservations are mandatory.

Most railway undertakings covered by the supporting study appear to impose some form

of operational restriction (e.g. peak hours, seasonal rules, on bus replacement services),

including in relation to the weight and dimensions of transported bicycles (e.g. restrictions

on cargo bikes or ‘fatbikes’).

In summary, there appears to be a generally good level of implementation that has also

created a positive momentum to boost the carriage of bicycles on trains.

Based on the NEB reports, there has been a low incidence of bicycle-related complaints in

the reviewed Member States. Two NEBs (44) each recorded two complaints, while another

NEB (45) recorded one complaint; one NEB (46) indicated that 0,7% of the complaints it

received were on bicycles. Another NEB (47) is monitoring whether information on bicycle

carriage is displayed on the websites of carriers and has planned enforcement activities in

the future. On the general monitoring of Article 6 of the Regulation by NEBs, continuous

(39) DE, FR, HU, NL.

(40) Code des transports, Article D1272-5, as inserted by the Décret n 2021-41 du 19 janvier 2021 relatif à

l'emport de vélos non démontés à bord des trains de voyageurs.

(41) BE, CZ, DE, DK, EE, FI, FR, HU, IE, IT, LT, LU, LV, PT, RO, SI, SK.

(42) BE, BG, DE, EL, ES, FI, FR, HU, IE, IT, NL, PL, SE, SI.

(43) BE, DE, EE, EL, FI, FR, HU, LU, LV, PL,PT.

(44) BE, PT.

(45) LT.

(46) IT.

(47) CZ.

9

monitoring is necessary and, where relevant, action must be taken on the minimum number

of bicycles on trains and the information to passengers on the conditions for the carriage

of bicycles.

2.4. Real-time travel information (Article 10)

Article 10 of the Regulation introduced the possibility to have access to real-time

information on delays, reservations and availability to make the rail ticketing market more

dynamic and to encourage the sale of more innovative tickets. This possibility should

enable different rail carriers, ticket vendors and tour operators to sell bundled tickets from

different carriers and for a variety of connections. Furthermore, the article removes the

former discrimination between passengers where only those who bought the ticket directly

from the railway undertaking obtain full information about delays (occurring in real time,

if the carrier offers such information, for example in an app) and further connection

possibilities to continue a journey.

Article 10 of the Regulation, building on Article 10 of Regulation (EC) No 1371/2007,

contains two grounds for data-sharing between different actors in the wider rail sector.

Firstly, it obliges infrastructure managers to distribute real-time train arrival/departure data

to railway undertakings, ticket vendors, tour operators and station managers. Secondly,

railway undertakings must provide other railway undertakings, ticket vendors and tour

operators that sell their services with access to minimum travel information (Annex II,

Parts I-II) and access to operations on reservation systems (Annex II Part III). As

mentioned above, Member States may exempt this Article until 7 June 2030 if it is

technically not feasible for the infrastructure manager to comply with the requirement to

share real-time traffic data according to the rules set by Article 10.

If it is technically impossible for infrastructure managers to present real-time traffic data

(i.e. this data cannot be provided to any entity), then a Member State may apply an

exemption from this obligation until 2030. However, the Member State has to re-assess the

situation and report to the European Commission every two years. This reporting

obligation was introduced to make the difficulties transparent and to help accelerate the

search for solutions to such technical problems.

In terms of the distribution of real-time data by infrastructure mangers under Article 10(1)

of the Regulation, six Member States (48) have notified the Commission of a full

exemption to this Article until 2030. Certain other Member States have notified specific

exemptions to this Article for urban and suburban services (49); regional services (50);

international services beyond the EU (51); and services for historic or touristic use (52).

In relation to the obligation imposed on infrastructure managers by Article 10(1) of the

Regulation, the supporting study indicates widespread distribution of real-time traffic

information to railway undertakings, but uneven provision of real-time information to

other actors. According to the study, infrastructure managers appear to give real-time

traffic information to railway undertakings in 22 Member States (53); to station managers

(48) AT, HR, HU, LV, PL and RO.

(49) FR, LU, PT, SK.

(50) FR, LU, PT, SK.

(51) BG, CZ, FI.

(52) BG, CZ, DE, FI, FR, IT, LT, NL, PT, SE, SK.

(53) BE, BG, CZ, DE, DK, EE, EL, ES, FI, FR, HR, HU, IE, IT, LT, LV, PL, PT, RO, SE, SI, SK.

10

in 11 Member States (54); to ticket vendors in 12 Member States (55); and tour operators in

10 Member States (56). The study also shows that infrastructure managers provide data free

of charge in 12 Member States (57). Evidence of contractual relationships for the provision

of such data was reported in some Member States (58). In France, the infrastructure

manager displays data in two forms. The first is through open data, which is free of charge

for all actors who wish to access it. In addition, the infrastructure manager also

offers different types of data which can be integrated directly into the systems of each

actor, such as ticket vendors and tour operators. This type of data is not mandatory for

these ticket distributors, although the infrastructure manager encourages its use and

availability.

As regards Article 10(2) of the Regulation, which obliges railway undertakings to

provide other railway undertakings, ticket vendors and tour operators that sell their services

with access to a minimum of travel information as set by the Regulation, it follows from

Article 2(5) of the Regulation that an exemption by a Member State extends to all the

provisions of Article 10. Hence, the same Member States that exempted Article 10(1) of

the Regulation are also exempted from the requirements of Article 10(2) of the Regulation.

The available evidence from the supporting study indicates that in eight Member States,

railway undertakings share the required information with other railway undertakings (59);

in eight Member States with ticket vendors (60) and in five Member States with tour

operators (61). The evidence further indicates that pre-journey information has been shared

in 11 Member States (62); journey-related information in seven Member States (63); and

access to the operations on reservation systems in 10 Member States (64). As regards

charges, at least some fees are imposed by railway undertakings in two Member States (65),

while access is free in 12 Member States (66). Formal contracts or other arrangements with

railway undertakings for minimum travel information have been reported in four Member

States (67).

The NEB reports indicate that some NEBs (68) have received complaints on information

without specifying whether the complaint related to real-time traffic information. One

NEB (69) has highlighted its enforcement activities on this issue in its report.

(54) BE, BG, DE, ES, FI, FR, HU, IE, RO, SE,SI.

(55) BE, CZ, DE, ES, FI, FR, HR, HU, IE, RO, SE, SI.

(56) BE, CZ, DE, ES, FI, FR, HU, IE, SE, SI.

(57) BE, BG, CZ, DK, ES, FI, IE, LT, PT, SE, SI, SK.

(58) DE, EE, PT, RO, SK, SI. For FR, whilst no information could be obtained on the matter, the fact that

the infrastructure manager charges the distribution of certain real-time data suggests that some

contractual arrangements might exist.

(59) CZ, DE, LT, LU, NL, SE, SI, SK.

(60) CZ, DE, LT, NL, PL, SE, SI,SK.

(61) CZ, DE, NL, SE, SI.

(62) BE, CZ, DE, DK, LT, LU, NL, PT, SE, SI, SK.

(63) BE, DE, NL, PL, PT, SI, SK.

(64) BE, DE, DK, LU, NL, PL, PT, SE, SI, SK.

(65) FR, NL.

(66) CZ, DK, FR, HU, LT, LU, NL, PL, RO, SE, SI, SK.

(67) LU, PT, SI, SK.

(68) BE, BG, EL, ES, HR, PL, RO.

(69) EL.

11

2.5. Through-tickets (Article 12)

2.5.1. Obligation to offer through-tickets for sole railway undertakings

Article 12(1) of the Regulation introduced a new obligation for long-distance or regional

rail passenger services operated by a ‘sole railway undertaking’ (70) to be offered as a

through-ticket (71) by those undertakings. The aim of this measure is to ensure more

comprehensive protection of passengers who are confronted with missed connections

during their journey and to increase the availability of through-tickets on the market. In

particular, passengers with a through-ticket who miss a connection between rail services

covered by that ticket have the right to be offered the choice between reimbursement of

the ticket price or journey continuation/re-routing to the final destination; the right to

compensation (except where the ticket was reimbursed); and the right to assistance

(refreshments, meals, accommodation) (72).

Findings from the supporting study show that in all Member States where rail services are

available, railway undertakings that qualify as a ‘sole railway undertaking’ generally offer

journeys on their own long-distance and regional rail passenger services as a through-

ticket. This overall compliance may be explained by the narrow scope of the obligation

which is limited to services of a ‘sole railway undertaking’, i.e. of the same railway

undertaking or of several undertakings under the same full ownership.

Furthermore, some particular features have been identified in some Member States. For

example, in Luxembourg, second-class rail travel on passenger services operated by the

main railway undertaking is free of charge and does not require a (through-)ticket (73). In

the Netherlands, a national check-in and check-out system is in place. Passengers’ journeys

start when they check in at the station of departure and end when they check out at the

station of the final destination, regardless of any transfers, the type of rail services used or

changes of railway undertaking. In practice, this appears to function as a through-ticketing

system.

2.5.2. Cooperation for other rail passenger services

For rail passenger services other than long-distance or regional services operated by sole

railway undertakings, Article 12(1) of the Regulation states that railway undertakings shall

make all reasonable efforts to offer through-tickets and shall cooperate with each other to

that end.

As regards urban and suburban rail passenger services, the findings of the supporting study

show that through-tickets are also offered for these services operated by railway

undertakings in 17 Member States (74). They even appear to be offered by the main railway

(70) The term ‘sole railway undertaking’ not only includes services of the same railway undertaking, but also

of all railway undertakings which are either wholly owned by the same owner, or which are wholly

owned subsidiary undertakings of one of the railway undertakings involved.

(71) A through-ticket is defined in Art. 3(35) of Directive 2012/34/EU of 21 November 2012 establishing a

single European railway area as ‘a ticket or tickets representing a transport contract for successive

railway services operated by one or more railway undertakings.’ See also Article 3(9) of Regulation

(EU) 2021/782.

(72) Article 12 (Through-tickets), paragraph 3 of the Regulation.

(73) Luxembourg exempted domestic regional rail passenger services from the application of Article 12(1)

of the Regulation until June 2028. See the supporting study for the Report on the implementation and

results of Regulation (EU) 2021/782 on rail passengers’ rights and obligation, Section 2.6.4.1

Availability of through tickets in the final report.

(74) BE, CZ, DE, DK, EE, EL, ES, FI, HR, HU, IE, LV, NL, RO, SE, SI, SK.

12

undertaking in two Member States that notified an exemption to Article 12(1) of the

Regulation for (sub)urban services (75). These cases indicate that through-tickets may be

offered in practice more widely for these services than might be inferred from the

exemption framework alone. Conversely, through-tickets for (sub)urban services do not

seem to be available in three Member States that did not notify an exemption to Article

12(1) of the Regulation (76).

As regards domestic rail travel (i.e. within a single Member State), evidence was found of

through-ticketing schemes covering several railway undertakings in a limited number of

Member States:

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

undertakings, the entire journey is considered as a single transport contract when it

is carried out within the railway network of the country. Passenger rights for travel

disruption apply (77).

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

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

services of undertakings participating in the Deutschlandtarif, including temporary

passes such as the monthly Deutschlandticket, are considered to be a through-ticket

under the Regulation. The Deutschlandtarif mainly concerns regional and

(sub)urban rail passenger services provided by around 50 public and private

railway undertakings and does not include long-distance services from e.g. DB

Fernverkehr AG, Flixtrain or Eurostar (78).

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

including tickets for journeys covering several different railway undertakings.

Most domestic passenger rail services, however, are operated by MÁV and

GYSEV. The latter operates only some railway services in the north-west of the

country. GYSEV is also partially Hungarian state owned, like MÁV (79).

- In Poland, PKP Intercity cooperates with nine regional railway undertakings to

offer joint tickets that integrate fares (Wspolny Bilet, or WB). The WB ticket does

not extend to journeys on TLK (80) or Intercity (IC) trains in sleeper or couchette

cars, or to rail services operated by railway undertakings who decided not to take

part in this cooperation (81). In the event of delays or other obstacles causing missed

connections, passengers can obtain a delay certificate for conditional continuation

of their journey on the next available train of the participating railway undertaking,

subject to seat availability, with a right to refund or compensation from the issuing

railway undertaking for the whole integrated fare (82). The scheme does not,

(75) HU, SK.

(76) IT, LT, PL.

(77) https://oneticket.cz.

(78) See https://www.deutschlandtarifverbund.de/ueber-uns/ as well as parts A and C of the fare conditions

(Tarifbedingungen; version of 14 December 2025).

(79) https://www.mavcsoport.hu/sites/default/files/upload/page/vasuti_uzletszabalyzat_25.10.01.pdf.

(80) TLK or Twoje Linie Kolejowe are long-distance trains with more stops and lower speeds than Intercity

trains.

(81) https://kolejedolnoslaskie.pl/wp-content/uploads/2024/06/Zalacznik-nr-2-do-ZW-WB_dane-

przewoznikow.pdf.

(82)https://www.intercity.pl/pl/dokumenty/wspolny-bilet/tekst_ujednolicony_ZW-WB_zm_1-

20_2507_2025.pdf.

13

however, cover some independent railway undertakings active on the Polish market

such as RegioJet and Leo Express (83).

- In Sweden, Resplus allows passengers the possibility to combine travel with several

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

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

ends in Sweden is covered by Resplus. In case of a missed connection during a

Resplus journey, the Kom-Fram-Garanti (arrival guarantee) applies. This means

that the transport operator causing the passenger to miss their connection is liable

for: ensuring that the passenger can continue their journey; providing alternatives

for rebooking; offering accommodation, food and beverages; and giving a partial

or full reimbursement or compensation for the delay (for combined trips with a

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

Regulation (84).

Domestic cooperation between railway undertakings to offer through-tickets does not seem

to be taking place in other Member States. In some cases, this may be explained by the fact

that only one railway undertaking currently provides domestic rail passengers on their

territory.

Cooperation on cross-border rail passenger services is taking place on a voluntary basis to

offer through-tickets for some journeys with one or more connections, but this cooperation

does not seem to take place on a systematic basis within the EU (85).

2.5.3. Information to passengers on through-tickets

It follows from Article 12(2) of the Regulation that for journeys including one or more

connections, the passenger shall be informed prior to purchasing a ticket or tickets whether

that ticket or those tickets constitute a through-ticket (86). From the passenger's perspective,

this requirement is key to understanding and anticipating the level of protection associated

with the ticket(s) in case of travel disruption during a journey that affects the passenger’s

connection between different rail passenger services.

The supporting study for this report found a variety of means through which stakeholders

(mainly incumbent railway undertakings) appear to comply with this pre-purchase

information requirement. Examples mentioned by stakeholders include a label or notice at

different points in time of the online booking process (87), oral information from staff at

ticket offices, service desks or during telephone sales, and information in the railway

undertaking’s terms and conditions. At the same time, the study also reports that, in some

Member States, passengers are not informed before purchase about whether or not the

ticket or tickets constitute a through-ticket. For a couple of Member States, this may be

explained by the fact that all domestic tickets purchased in a single transaction are

considered as through-tickets, thereby reducing the need to explicitly inform passengers

before purchase (88). It also follows from the supporting study that in at least one Member

(83) Wspólny Bilet - Ministerstwo Infrastruktury - Portal Gov.pl.

(84) https://samtrafiken.se/tjanster/resplus.

(85) See SWD(2026) 233.

(86) It follows from recitals 24 and 25 of the Regulation that this information needs to be ‘clearly’ given.

(87) For example, only after the passenger has selected the journey and sometimes even only right before

payment.

(88) FI, SE.

14

State, the main railway undertaking and the passenger representative organisation

dissented on whether this information was provided before purchase (89).

It would appear, therefore, that passengers may not always be consistently informed before

purchase in a clear manner on whether the ticket or tickets they buy for a rail journey

constitute a through-ticket. The range of potential means of communication across

Member States to provide this information to passengers at different moments in the

booking process – if the information is given at all – make it difficult for passengers to

navigate the process to obtain the information and understand their rights. This is even

more problematic where a passenger performs a journey with several railway undertakings

(in the absence of an obligation to provide through-tickets), potentially across several

Member States.

One NEB report mentions a complaint related to information on through-tickets, without

giving any further details (90).

2.5.4. Liability for through-tickets

In line with Article 12(3) of the Regulation, and as already mentioned above, where a

journey including one or more connections is sold as a through-ticket, the railway

undertaking shall be liable to reimburse or reroute (91), compensate (92) and assist (93) the

passenger if they miss one or more connections.

In the supporting study, whilst most stakeholders consulted across the examined Member

States could not provide information on the issue, the available evidence, drawn primarily

from incumbent railway undertakings, suggests that the vast majority of passengers opt for

rerouting when they miss connections on journeys bought with through-tickets (94).

The Regulation also takes into account a situation where a railway undertaking, on its own

initiative, sells a combination of tickets for a journey involving railway undertakings that

are not part of the same railway undertaking, and does so in a single commercial

transaction. In that case, there is a general assumption that this constitutes a through-ticket

– unless the undertaking informs the passenger, before purchase, that the tickets represent

separate transport contracts (95).

Correct information on the rail service is also essential when passengers buy tickets from

a ticket vendor or tour operator. Where the ticket vendors or tour operators sell separate

tickets as a bundle in a single commercial transaction, they should clearly inform the

passenger before purchase that those tickets do not offer the same level of protection as

through-tickets, and that those tickets have not been issued as through-tickets by the

railway undertaking(s) providing the service. Otherwise, the ticket vendor or tour operator

shall be liable to reimburse the total amount paid in that transaction for the ticket or tickets

(89) In particular, the situation is disputed in the Netherlands: the railway undertaking reports that passengers

are informed before finalising the purchase, whereas the passenger organisation considers that they are

not systematically informed.

(90) HU.

(91) Article 18 (Reimbursement and re-routing) of the Regulation.

(92) Article 19 (Compensation) of the Regulation.

(93) Article 20 (Assistance) of the Regulation.

(94) The supporting study also found that some passengers neither ask for reimbursement nor for re-routing

but simply abandon their journey without asking for reimbursement despite being eligible. For example,

Germany estimated that: 60-70% of passengers opt for rerouting, 10-15% for reimbursement, 20-30%

for compensation and around 5% request assistance.

(95) See Article 12 (Through-tickets) paragraph 4 and recital 24 of the Regulation.

15

and, moreover, to pay compensation equivalent to 75% of that amount in the event that the

passenger misses one or more connections (96).

The findings of the supporting study seem to suggest that, in line with the conclusions

made in Section 2.5.3 above, where information on the separate contractual nature of the

tickets is given to passengers, it is done in various ways either before purchase (e.g. on a

website or during the online booking process) or after purchase by a message on the ticket.

In some Member States, no evidence could be found that this information was provided,

which may be explained in some cases by the fact that all domestic rail passenger services

in that Member State are considered as through-tickets.

To add to this complexity, the Regulation provides for an exemption regime under which

Member States may, subject to specific conditions, exempt certain rail services (97) from

the obligations in Articles 18 to 20 of the Regulation (i.e. reimbursement or rerouting,

compensation, and assistance). These exemptions apply whether or not the passenger holds

a through-ticket. As a result, there can be situations where railway undertakings are

required to offer through-tickets for a given service type under Article 12(1), while the

same service type is, to some extent, exempted from the corresponding liability rules for

missed connections under Articles 18 to 20 (98).

Some railway undertakings have entered into multilateral sector agreements to assist

passengers if they miss a connection between rail services of different undertakings which

are not covered by a through-ticket (e.g. Agreement on Journey Continuation (AJC)99),

Hop On the Next Available Train (HOTNAT) (100)). The overall legal setup on liability

and information provision to passengers appears to contribute to a situation where

passengers have difficulties in knowing their rights in the event of a missed connection

during their rail journey (101).

One NEB (102) report refers to two complaints related to liability for continuous journeys

and whether the liability for through-tickets applies. In one case, this was deemed so,

whereas this was not in the other case.

2.6. The right to self-rerouting (Article 18(3))

Article 18(3) of the Regulation introduces a right for passengers to ‘self-reroute’, which

means that passengers can not only take the initiative to find an alternative travel plan when

the railway undertaking does not (immediately) offer a viable alternative. This also means,

more importantly, that passengers can get reimbursed by the railway undertaking for the

(96) See Article 12 (Through-tickets) paragraphs 4 and 5, as well as recital 25 of the Regulation.

(97) See Article 2 (Scope) of the Regulation, and Section 2.1 above.

(98) For a more detailed analysis of the Member State exemptions applicable to through-tickets, see the

supporting study for the Report on the implementation and results of Regulation (EU) 2021/782 on rail

passengers’ rights and obligations, Section 2.6.4.3 of the final report, on liability rules in the context of

through-tickets.

(99) See the latest information leaflet on the AJC on the website of the International Rail Transport

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

2025/ajc_leaflet_2025-12-14_en.pdf?cid=437997 (Note: the full agreement is not public).

(100) See Railteam’s website: https://www.railteam.eu/en/services-on-your-journey/hop-on-the-next-

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

to Railteam (Deutsche Bahn, Eurostar, ÖBB, SNCF, SBB, SNCB/NMBS and NS). It only covers their

high-speed network.

(101) Targeted revision of Regulation (EU) 2021/782 on rail passengers’ rights and obligations Call for

Evidence.

(102) DK.

16

costs of making their own travel plan. In the absence of such a right, passengers who

reroute themselves would be entitled at most to reimbursement of the ticket price and

would encounter difficulties in recovering the costs of last-minute arrangements at the

applicable day rates (which may be significantly higher than the price of the original ticket

when booked).

This provision of the Regulation contains a two-step approach for passengers.

The first subparagraph of Article 18(3) of the Regulation states that the railway

undertaking may allow the passenger, at their request, to conclude contracts with other

providers of transport services which enable the passenger to reach their final destination

under comparable conditions, in which case the railway undertaking shall reimburse the

passenger for the costs incurred. This presupposes that the railway undertaking agrees to

the passenger’s request.

The second subparagraph of Article 18(3) of the Regulation introduced a new right so that

if a passenger has not been offered a timely solution by a railway undertaking within 100

minutes in the event of a disruption to their journey, the passenger can organise alternative

public transportat by rail, coach or bus and be reimbursed by the undertaking for the

‘necessary, appropriate and reasonable’ cost of the additional ticket. After 100 minutes

have elapsed, the passenger no longer needs the carrier’s consent to organise alternative

transport.

In seven Member States, regional rail services are currently explicitly exempted from the

application of Article 18(3) (103). This exemption is supposed to expire on

7 June 2028 (104). For urban and suburban services, Article 18(3) does not apply in ten

Member States (105). In six Member States (106), international rail services to third

countries are exempted from the application of Article 18.

The supporting study shows a fragmented picture of the application in practice of the first

subparagraph of Article 18(3) (i.e. where the consent of the railway undertaking to the

passenger’s request for self-rerouting is necessary). Whereas a majority of railway

undertakings examined in the study appear to allow passengers to arrange their own

alternative travel in the event of disruption, the exercise of this right and the corresponding

reimbursement of costs may be subject to certain conditions by some of these undertakings.

These include the last train of the day operating, long delays or absence of information, the

railway’s inability to offer a suitable option, or the right to reimbursement may be limited

to certain means of transport (rail or bus/coach) or to low-cost alternatives. In a couple of

Member States, it is also reported that railway undertakings seem to rely on their own

capacity to organise alternatives, and they generally do not reimburse self-arranged

transport (107). In a few Member States, differing views on the application of this new right

have been reported between railway undertakings, on the one hand, and passenger

organisations or NEBs on the other (108).

(103) BG, LU, PL, PT, RO, SK, SE (for domestic rail services covering less than 150km). An exemption to

Article 18(3) of the Regulation is only allowed until 7 June 2028, in accordance with the last

subparagraph of Article 2(8) of the Regulation.

(104) See Article 2 (Scope) paragraph 8, last subparagraph of the Regulation.

(105) BG, FR, HU, LU, PL, PT, RO, SK, SE for domestic rail services covering less than 150km and AT for

urban services.

(106) BG, CZ, FI, LV, PL, RO.

(107) FI, RO.

(108) BG, NL, SI.

17

As to the second subparagraph of Article 18(3) of the Regulation (i.e. when the railway

undertaking’s consent is no longer needed after 100 minutes), the majority of railway

undertakings claim that they reimburse passengers who exercise their right to self-

rerouting. However, the findings of the supporting study alone do not demonstrate whether

this right is actually consistently respected in practice.

These findings confirm the observations of ECC-Net pointing to challenges related to the

application of Article 18(3) of the Regulation. For example, passengers are also often

unaware of the 100-minute time limit and have identified it as impractical in last-train

scenarios, night train disruptions, and complex cross-border journeys. ECC-Net also

pointed to the lack of air travel as a valid alternative mode of transport for rerouting offers

under Article 18(3) of the Regulation (109).

One NEB (110) observed in its biennial report that there was a greater need for explanations

for enforcement, especially for Article 18. The provisions of Article 18 only provide

limited possibilities for the passenger to organise their own journey. Another NEB (111)

noticed during one event where there were several cancellations of long-distance train

journeys due to a strike or track fault, passengers were not allowed to choose cost-free re-

routing to replace the cancelled journey. After the intervention by the NEB, the railway

undertaking took measures to align itself with the rules.

Given the above, the right to self-rerouting introduced by the Regulation does not appear

to be consistently applied across the EU. The rules seem to lead to a variety of different

reimbursement practices – if they are applied at all - which reinforce the perceived lack of

clarity for passengers in relation to this right.

2.7. Compensation - Force majeure (Article 19(10))

Article 19(1) of the Regulation lays down the principle that a passenger is entitled to

compensation from the railway undertaking if he or she faces a delay between the places

of departure and final destination stated in the ticket or through-ticket for which the cost

has not been reimbursed in accordance with Article 18 of the Regulation. The Regulation

also sets the minimum compensation for delays, which is set as a percentage of the ticket

price (112). Article 19(10) of the Regulation exempts railway undertakings from paying

delay compensation in three scenarios: (1) if they prove that the delay, missed connection,

or cancellation resulted directly from extraordinary circumstances unrelated to railway

operations. These extraordinary circumstances may include extreme weather, major

natural disasters, or major public health crises like pandemics, despite taking all reasonable

measures to avoid or mitigate them; (2) the fault of the passengers; or (3) specific third-

party acts (e.g. sabotage, cable theft), not including strikes by a railway undertaking’s staff,

or acts or omissions by other railway undertakings, infrastructure managers, or station

managers. These provisions are unlike Article 17 of Regulation (EC) No 1371/2007, which

imposed a strict liability without such exemptions (as confirmed by the Court’s case

law (113)). It is also important to note that this ‘force majeure’ clause only applies to

(109) Strengthening Rail Passenger Rights in the EU | European Consumer Centers Network.

(110) DE.

(111) FI, see https://www.kkv.fi/paatokset/kuluttaja-asiat/kuluttaja-asiamiehen-ratkaisut/rautatieyrityksen-

uudelleenreitityskaytannot-kaukojunamatkojen-peruuntuessa-lakon-tai-ratavian-takia/.

(112) In particular, the minimum compensation is 25% of the ticket price for a delay of 60 to 119 minutes and

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

(113) Judgment of 26 September 2013, ÖBB Personenverkehr, C-509/11, EU:C:2013:613.

18

compensation and does not affect the application of other passenger rights, such as re-

routing and assistance.

No Member State has specifically exempted Article 19(10) of the Regulation. However,

some Member States have exempted Article 19 entirely for long-distance rail services (114);

regional rail services (115); urban and suburban rail services (116); rail services offered

strictly for historic or touristic use (117); and international services to third countries (118).

The supporting study shows that the use of this exemption varies between Member States.

It found that in 13 Member States (119) the railway undertakings analysed in the study

reportedly do not apply the exemption in practice and pay compensation even where

delays, cancellations or missed connections may be linked to extraordinary circumstances.

In 10 Member States (120), the railway undertakings examined in the study have reported

that they have invoked the exemption, with no compensation paid where delays,

cancellations or missed connections are caused by events clearly beyond their control (such

as severe weather, accidents or security threats).

The study also found that in 19 Member States passengers appear to receive compensation

from the undertakings examined when delays, cancellations and missed connections are

caused by strikes by the personnel of the railway undertaking, actions by other

undertakings using the same infrastructure, or by infrastructure and station managers (121).

In Greece, only multi‑journey card holders are explicitly mentioned as eligible for

compensation in strike situations. The study also found that the railway undertakings

examined in four Member States (122) seem to exclude such delays, cancellations and

missed connections from compensation altogether. The railway undertaking examined in

Romania offers compensation only in case of strikes, but not for other actions by third

parties on the network.

Overall, the available evidence gathered in the context of the supporting study shows that

the ‘force majeure’ clause in Article 19(10) of the Regulation is not consistently applied

across the EU. In particular, it would appear that the main railway undertakings in around

half of the Member States forego the exemption grounds for paying compensation

introduced by the revision of the Regulation in 2021 and continue to pay compensation for

the events mentioned in Article 19(10) of the Regulation. Furthermore, it would appear

that in a limited number of cases, a passenger’s right to continue to receive compensation

in the event of delays, cancellations and missed connections caused by strikes by the

personnel of the railway undertaking, actions by other undertakings using the same

infrastructure, or by infrastructure and station managers, is not applied in practice.

One NEB (123) stated in the report that the grounds for exclusion laid down in

Article 19(10) of the Regulation led passengers to lodge a complaint more frequently after

their claim for compensation was rejected.

(114) BG, HU, PT, RO, SK.

(115) AT, BG, FI, HU, LU, PL, PT, RO, SE, SK.

(116) AT, BG, FI, FR, HU, LU, PL, PT, RO, SE, SK.

(117) BG, CZ, DE, FI, FR, HU, IT, LT, LV, NL, PL, PT, RO, SE, SK.

(118) BG, CZ, FI, LV, RO.

(119) AT, BE, CZ, DK, EL, ES, FI, HR, IT, LU, NL, SE, SK.

(120) BG, DE, EE, FR, HU, LT, PL, PT, RO, SI.

(121) AT, BE, DE, DK, EE, ES, FI, FR, HU, IE, IT, LT, LU, LV, NL, PT, SE, SI, SK.

(122) BG, CZ, HR, PL.

(123) DE.

19

2.8. Common form for reimbursement and compensation requests (Articles

18(7) and 19(6))

In accordance with Articles 18(7) and 19(6) of the Regulation, passengers have the right

to submit their reimbursement and compensation requests to railway undertakings using a

common form. To this end, the Commission adopted Commission Implementing

Regulation (EU) 2024/949(124). On the basis of the Annex to that Implementing

Regulation, the Commission developed a common form in all official languages of the EU,

and which is adapted to the needs of persons with visual disabilities. It is available on the

Commission’s website (125). The common form may be submitted as a physical document

or by electronic means (126). The form is designed so that passengers can specify the nature

of request and provide the necessary details to railway undertakings.

In this respect, the Commission notes a number of specific features related to the scope of

empowerment contained in Articles 18 and 19 of Regulation (EU) 2021/782 to adopt

implementing rules on this matter.

First, the common form can only be used in relation to railway undertakings and not ticket

vendors and tour operators, who may also be liable to reimburse and compensate

passengers under the very specific conditions described in Article 12 of Regulation (EU)

2021/782. This is because that provision does not contain an empowerment for the

Commission to adopt implementing rules on the matter under that Regulation.

Secondly, railway undertakings may have their own online form or similar system in place

on their website or via a mobile application to process reimbursement or compensation

requests. These integrated forms or systems should allow for a more efficient and timely

handling of requests. At the same time, the empowerment to adopt implementing rules

contained in Articles 18 and 19 of the Regulation only allows for the creation of a separate

form by the Commission (127) and does not provide a basis for regulating the content and

presentation of the forms produced by railway undertakings.

One NEB (128) mentioned the common form under the enforcement activities in their

report.

2.9. Major disruptions and contingency planning (Article 20(6))

Under Article 20(6) of the Regulation, where contingency plans are established pursuant

to Article 13a(3) of Directive 2012/34/EU (129), the railway undertakings shall coordinate

with station managers and infrastructure managers in order to prepare them for major

disruption and long delays leading to a considerable number of passengers being stranded

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

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

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

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

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

(126) Article 1 of Commission Implementing Regulation (EU) 2024/949.

(127) In the period of 1 July 2024 to 30 March 2026, these reports have been downloaded 1.718 times on the

Commission website, with most of downloads taking place over the last twelve months of this period.

(128) EL.

(129) Under that provision, Member States shall require railway undertakings operating passenger services to

put in place contingency plans and shall ensure that these contingency plans are properly coordinated to

provide assistance to passengers, in the sense of Article 18 of Regulation (EC) No 1371/2007, in the

event of a major disruption to services.

20

in the station. Such contingency plans shall include requirements for the accessibility of

alert and information systems.

In terms of exemptions, while long-distance rail services cannot be exempted from the

obligation under Article 20(6) of the Regulation, regional rail services have been exempted

in eight Member States (130); urban and suburban rail services have been exempted in ten

Member States (131); historical or touristic services have been exempted in 15 Member

States (132); and international services to third countries have been exempted in seven

Member States (133).

The available evidence gathered for the supporting study indicates that railway

undertakings in 18 Member States (134) appear to coordinate with station and infrastructure

managers on contingency plans for major disruption, also formally accounting for the

accessibility of persons with disabilities and persons with reduced mobility in alert and

information systems. In four Member States, railway undertakings appear to coordinate

with station and infrastructure managers, but lack either formal contingency plans or do

not consider the issue of accessibility within them (135). In four other Member States (136)

there are no contingency plans in place, or no clear information on the subject was

obtained.

Such contingency plans are essential to ensure rapid, coordinated and passenger‑focused

responses to disruption, including timely information, assistance, and, where necessary,

alternative transport arrangements. The question was also raised in the December 2025

meeting of the Expert Group on Passenger Rights (subgroup for the NEBs for rail

passenger rights), where NEBs suggested sharing best practices as to how contingency

plans are developed in their respective Member State (137). Sharing best practice is

important for strengthening the quality and consistency of contingency planning across

Member States, and for enhancing the overall resilience of the rail system. Contingency

planning is an ongoing process rather than a one-off exercise, and several recent accidents

in the rail sector have underlined the importance of having robust, tested contingency plans

in place, both to protect passengers and to ensure continuity of services when serious

disruption occurs.

Contingency planning is mentioned by several NEBs in their reports, referring to

monitoring duties for contingency plans (138) as well as planned enforcement activities for

the upcoming reporting period (139). One NEB (140) provided information about its activity

to compare and examine the relationship between the Regulation and other EU and national

legislation that sets requirements for contingency plans.

(130) BG, HU, LU, PL, PT, RO, SE, SK.

(131) AT, BG, FR, HU, LU, PL, PT, RO, SE, SK.

(132) BG, CZ, DE, FI, FR, HU, IT, LT, LV, NL, PL, PT, RO, SE, SK.

(133) BG, CZ, FI, HU, LV, PL, RO.

(134) AT, BE, BG, CZ, DE, DK, ES, FR, HU, LI, LT, LU, LV, NL, PL, PT, SI, SK.

(135) EE, HR, IT, SE.

(136) EL, FI, IE, RO.

(137) See the Register of Commission expert groups and other similar entities , Expert group on Passenger

Rights (E02861/5).

(138) DE, EL.

(139) CZ.

(140) FI.

21

2.10. Persons with disabilities or reduced mobility (Chapter V)

One central principle of the EU passenger rights legislation, including rail passenger rights,

is to give persons with disabilities and persons with reduced mobility opportunities for

travel comparable to other people by establishing rules for non-discrimination and on

assistance during their journey (141). Several new provisions in the Regulation enhance the

pre-existing provisions on assistance for persons with disabilities and persons with reduced

mobility travelling by rail under Regulation (EC) No 1371/2007. Such assistance —

provided by railway undertakings and station managers — is indispensable, given that

many stations and trains across the EU remain inaccessible to this group. Until full

accessibility is achieved across European rail networks, these passengers will continue to

depend on dedicated assistance in order to travel.

In order to ensure that appropriate assistance is provided, railway undertakings and station

managers often need time to deploy trained staff and proper equipment. Therefore, they

may require persons with disabilities and persons with reduced mobility to pre-notify their

assistance needs. A railway undertaking or station manager is only responsible for

guaranteeing that a person with a disability or a person with reduced mobility can board

the train, to transfer to a connecting rail service for which they have a ticket, or alight from

the train if this person pre-notifies their assistance needs in due time. One of the main

achievements of the revision of the Regulation in 2021 was to halve the pre-notification

time from 48 hours to 24 hours (142). To allow railway undertakings and station managers

to prepare for this change, the Regulation provides for a transition period: Member States

may decide to apply a longer pre-notification period of up to 36 hours until 30 June 2026.

To this end, they had to notify the Commission of this exemption while also providing

information on the measures taken or envisaged to reduce the pre-notification period to 24

hours(143) . Eight Member States (144) notified the Commission that they were using this

exemption. Conversely, the supporting study found that several railway undertakings

require prenotification times that are less than 24 hours (145). However, organisations

representing persons with disabilities that replied to the stakeholder consultation

undertaken in the context of the supporting study indicated that prenotification processes

are often cumbersome and ineffective for many railway undertakings.

(141) See recital 27 of the Regulation. See also the Communication from the Commission to the European

Parliament and the Council - A European vision for Passengers: Communication on Passenger Rights in

all transport modes (COM(2011) 898 final).

(142) See Article 24(a), first subparagraph of the Regulation.

(143) See Article 24(a), last subparagraph of the Regulation.

(144) BG, CZ, HR, DE, HU, LV and RO made full use of this exemption, while DK used it only for cross-

border rail services to DE. In case of DE the exemption generally refers to international journeys where

different notification period among Member States might have been set. In practice this exemption is

applied in difficult individual cases.

However, the BG and CZ incumbent railway undertakings require persons with disabilities and persons

with reduced mobility to pre-notify their assistance needs even 48 or (in case of certain trains in BG)

more hours before their journey.

EE did not make use of this exemption, however its incumbent railway undertaking still requires persons

with disabilities and persons with reduced mobility to notify assistance needs 36 hours in advance.

(145) For example, the Belgian incumbent railway company requires three hours prenotification for services

departing from or arriving at the 41 most important railway stations, the Austrian incumbent railway

company requires 12 hour prenotification for all domestic services, the Luxembourg incumbent railway

company requires one hour prenotification for domestic services (but for evening and night services it

requires prenotification no later than 20h30 for same-day departures). In the Netherlands, the incumbent

railway company requires one hour for domestic services, but at least 24 hours for international services

and 36 hours for services to Germany. In Spain, prenotification of assistance needs is required 30

minutes to 12 hours before departure, depending on the type of station.

22

The Regulation also introduced the requirement that where a railway undertaking

requires that a person with a disability or a person with reduced mobility be

accompanied on board a train, which is permitted only where strictly necessary to

comply with the railway undertaking’s non-discriminatory access rules, such as for safety

reasons, the accompanying person is entitled to travel free of charge and where

feasible, be seated next to the person they are accompanying (Article 23(1)(b) read in

conjunction with Article 21(2) of the Regulation). Persons with disabilities and persons

with reduced mobility may transport their assistance dogs free of charge, in compliance

with the relevant national law (Article 23(1)(c) of the Regulation). Stakeholders who

responded to the consultation were broadly in agreement that these two provisions had

been fully implemented.

The Regulation also provides that where there is no ticket office or no accessible ticketing

machine in the station of departure and no other accessible means to purchase a ticket in

advance, persons with disabilities are entitled to buy tickets on board the train at no

extra cost (Article 11(4), first subparagraph of the Regulation). Although railway

undertakings could limit or deny this right on justifiable grounds related to security or

compulsory train reservation, most of the railway undertakings examined by the

supporting study implemented this obligation without any restrictions (146). Only in

Member States where all railway stations are equipped with accessible ticket

machines (147), or where the railway undertaking offers several other alternatives

(purchase of tickets online, on the phone, or in convenience stores in or near railway

stations) (148), the railway undertakings do not allow anyone (not even persons with

disabilities) to buy tickets on board the train.

The Regulation requires railway undertakings and station managers to pay compensation

for lost or damaged mobility equipment (149) based on the replacement or repair cost of

the equipment (Article 25(1) of the Regulation), and rapidly make all reasonable efforts to

provide immediately necessary temporary replacements for mobility equipment (Article

25(2) of the Regulation). While all the railway undertakings and station managers

examined by the supporting study respected the obligation to pay compensation, most

incumbent railway undertakings admitted that they cannot offer temporary replacements

of mobility equipment.

The Regulation requires railway undertakings and station managers to provide disability

awareness training to all customer-facing staff. Those who regularly provide direct

assistance to passengers with disabilities or reduced mobility must additionally receive

targeted training, equipping them with the skills needed to meet these passengers' specific

needs (Article 26(1) of the Regulation). While the railway undertakings and station

managers examined by the supporting study did implement such training, organisations

representing persons with disabilities frequently raise concerns about the quality of the

training. They also note that the Regulation does not require railway undertakings or station

managers to involve them in designing or delivering these training programmes. Although

no such obligation exists, most incumbent railway companies reported cooperating with

(146) AT, BE, BG, CZ, DE, DK, EE, EL, ES, FI, FR, HR, HU, IE, IT, LT, LU, LV, PL, PT, RO, SI, SK.

(147) The incumbent railway company in NL.

(148) SE.

(149) They also have to pay compensation for the loss of, or injury to, assistance dogs used by persons with

disabilities and persons with reduced mobility (See also Article 25 (Compensation in respect of mobility

equipment, assistive devices and assistance dogs) paragraph 1 of the Regulation).

23

disability organisations for this purpose, or involving their own staff with disabilities in

such training.

The Regulation requires railway undertakings and station managers to make ‘reasonable

efforts’ to enable persons with disabilities and persons with reduced mobility to

access rail transport at railway stations where there are no staff trained to provide

assistance to them, and the trains they want to board or alight from are also not

accompanied by such staff (Article 23(1)(g) of the Regulation). According to organisations

representing persons with disabilities this has not led to meaningful improvements in

practice. These groups also criticise the Regulation for not requiring continuous assistance

at stations staffed with personnel trained to assist persons with disabilities and persons with

reduced mobility whenever trains are running. Instead, help is only required when trained

personnel are on duty. The organisations argue that this severely restricts the rights of

persons with disabilities and persons with reduced mobility to equal, independent rail

travel and their freedom to choose any train (150).

A number of national enforcement bodies have pointed out that certain provisions

concerning assistance for persons with disabilities and persons with reduced mobility lack

clarity, which in turn hampers their effective enforcement. The ambiguities highlighted

include the definition of a station manager, the criteria for determining when a station or a

train can be considered staffed (Article 23(1)(d) to (g)) (151), and the precise meaning of

the provision guaranteeing free transport for a personal assistant accompanying a person

with disabilities (Article 21(1)(a)).

Since the adoption of the previous Regulation on rail passenger rights, the fulfilment of

railway undertakings’ and station managers’ assistance obligations has been significantly

shaped by their non-discriminatory access rules (Article 23(2)), which must be

developed with the active participation of representatives of persons with disabilities

(Article 21(1)). The publication of such non-discriminatory access rules could ensure that

persons with disabilities can readily familiarise themselves with access and enforce their

rights. The supporting study noted, on the basis of desk research conducted by an

organisation representing persons with disabilities, that only a handful of railway

undertakings and station managers have made the non-discriminatory access rules publicly

available on their websites.

A railway undertaking, station manager, ticket vendor or tour operator must provide

information (including in accessible formats), upon request, about the accessibility of

stations and their associated facilities such as parking spaces and shops, as well as trains.

In addition, at unstaffed stations accessible information must be displayed so that the

passenger knows how to obtain assistance and where the next accessible station can be

found (Article 22 of the Regulation). The supporting study’s desk research of several

railway undertakings' webpages and apps revealed that they provide accessibility

information to varying degrees, though organisations representing persons with disabilities

were highly critical during the stakeholder consultation of the implementation of Article

22. Only a few (mostly national or regional) organisations representing persons with

disabilities took part in the targeted consultation organised in the context of the study,

focusing primarily on the practices of incumbent railway undertakings in their Member

State. They highlighted multiple issues: incomplete coverage (e.g. details on the

(150) https://www.edf-feph.org/content/uploads/2021/06/EDF-analysis-of-the-adopted-Rail-Passengers-

Righs-Regulation-2021.pdf.

(151)See the Register of Commission expert groups and other similar entities, Expert group on Passenger

Rights (E02861/5).

24

accessibility of stations but not trains), railway homepages are inaccessible to visually

impaired users, information is hard to locate on the railway undertaking's homepage, and

there is far more content in the Member State's official language(s) than in other languages.

As the participation of disability organisations in the consultation was limited, broader

input would be necessary to fully evaluate the effectiveness of the implementation of the

Regulation’s rules in this area.

A core principle of disability inclusion is the involvement of persons with disabilities in

decisions affecting their lives and leveraging their experiences. Accordingly, the amended

service quality standards require railway undertakings to consult organisations

representing persons with disabilities and persons with reduced mobility on how assistance

is provided (152). The latest reports by railway undertakings about the implementation of

their service quality standards that only nine incumbent railway undertakings and one new

entrant fulfilled this obligation. Most of them have established permanent platforms for

cooperation (153), some limit cooperation to investigate together the accessibility of

stations and trains (154) or involve the organisations in the disability assistance training

offered to railway staff (155).

Member States may require station managers and railway undertakings operating on their

territory to cooperate in establishing and operating Single Points of Contact for persons

with disabilities and persons with reduced mobility. These Single Points of Contact

would be responsible for receiving requests for assistance, forwarding them to the relevant

station managers and railway undertakings, and providing information on accessibility.

Such an arrangement would ensure that passengers with disabilities or reduced mobility

are not required to submit multiple assistance requests, even where their journey involves

several railway undertakings (Article 24(f) of the Regulation). So far only one Member

State (156) has notified to the Commission the national legislation requiring station

managers and railway undertakings operating in its territory to establish Single Points of

Contacts (157).

In their activity reports, almost half of the NEBs (158) indicate that they carried out

monitoring or enforcement activities (e.g. inspection of information about the accessibility

of stations, the provision of assistance at railway station, information on the websites of

railway undertakings, disability assistance training), while nine NEBs (159) reported

receiving complaints about alleged breaches of the rights of persons with disabilities and

persons with reduced mobility.

2.11. Complaint-handling and enforcement (Article 28 and Chapter VII)

2.11.1. Complaint handling by railway undertakings,

station managers and ticket vendors/tour operators (Article 28)

The Regulation introduced an improved enforcement framework including new rules on

handling complaints, such as clear deadlines (Article 28 (2)) and an obligation for legal

entities other than railway undertakings to have a procedure to handle complaints,

(152) See the last point of Annex III of the Regulation.

(153) The incumbent railway companies of AT, BE, DE, DK, FR, LU, NL, SK .

(154) The LV incumbent railway company.

(155) An ES new entrant railway company, Ouigo Spain.

(156) DE.

(157) Art 10(a) of the German Railways Act - Allgemeines Eisenbahngesetz.

(158) BE, BG, DE, DK, EL, FR, HR, HU, IT, PT, RO, SK.

(159)AT, DE, EL, ES, HR, IT, PL, PT, SE.

25

including for managers of stations that handle more than 10 000 passengers per day on

average over a one-year period (Article 28 (1)). According to Article 28(1) of the

Regulation, passengers may submit a complaint to any railway undertaking or station

manager concerning the rights and obligations covered by this Regulation in their

respective fields of responsibility. Such a complaint must be submitted within three months

of the incident in question. Within one month of receiving the complaint, the addressee

shall either give a reasoned reply or, in justified cases, inform the passenger that they will

receive a reply within three months of the date of receipt of the complaint. Railway

undertakings and station managers shall keep the data necessary to assess the complaint

for the duration of the entire procedure to handle the complaint, including the procedures

referred to in Articles 33 and 34, and must make that data available to national enforcement

bodies upon request. Details of the procedure to handle complaints must be accessible to

the public, including to persons with disabilities and to persons with reduced mobility.

The supporting study found that in 15 Member States (160) complaints must be submitted

within three months of the incident that it concerns. In three Member States (161), the

incumbent railway undertakings have set a one-year deadline to receive a complaint.In

three Member States (162), railway undertakings have not set a deadline to submit

complaints. In one Member State (163), national law establishes a six-month deadline for

filing claims regarding domestic transport, but a consumer organisation consulted for the

study noted that a three-month deadline is applied in practice. In one Member State (164),

the deadline to submit a request for reimbursement or compensation in case of delay is 30

days, according to the general conditions of carriage of the incumbent railway undertaking.

Four Member States (165) have never made use of an extension period of up to three months

for replying to a complaint, 15 Member States (166) have used this option only rarely, three

Member States (167) have sometimes used the extension and one Member State (168) uses

the extension regularly.

2.11.2. Establishment of national enforcement bodies (Article 31)

Article 31(1) of the Regulation requires that each Member State designates a body or

bodies responsible for the enforcement of this Regulation. Each body shall take the

measures necessary to ensure that the rights of passengers are respected. All Member States

but one (169) have designated one or several NEBs for the enforcement of rail passenger

rights. The designated NEBs should be independent in their organisation, funding

decisions, legal structure and decision-making of any infrastructure manager, charging

(160) BE, CZ, DE, EL, ES, FR, HR, HU, IT, LT, LV, PL, RO, SE, SI. In Belgium, however, the three-month

deadline regarding the incumbent railway undertaking in Belgium concerns international services and

compensation for delays. Other complaints concerning national services have no fixed deadline. In Italy,

however, according to a passengers’ association the deadline may vary according to the railway

undertaking concerned.

(161) AT, LU, SK.

(162) FI, IE, NL.

(163) BG.

(164) PT.

(165) AT, HR, LT, LU.

(166) BG, CZ, DE, DK, EE, FI, FR, IE, LV, NL, PL, RO, SE, SI, SK.

(167) ES, HU, IT.

(168) PT.

(169) CY. Even though it has no railway network on its territory (like MT), it still needs to monitor and enforce

the rules of the Regulation on ticket vendors and tour operators. See Article 31(4) of the Regulation.

26

body, allocation body or railway undertaking (170). A list of the NEBs responsible for the

application of Regulation (EU) 2021/782 is available on the Commission’s website (171).

2.11.3. Enforcement by NEBs (Article 32)

According to Article 32(2) of the Regulation national enforcement bodies shall closely

monitor compliance with this Regulation. Railway undertakings, station managers,

infrastructure managers, ticket vendors and tour operators shall provide the national

enforcement bodies with relevant documents and information at their request without

undue delay and, in any event, within one month from receipt of the request. Railway

undertakings shall give their contact details to the national enforcement body or bodies of

the Member States in which they operate (Article 32(4) of the Regulation). The

Commission has received no information from NEBs about non-compliance with these

requirements.

2.11.3.1. Reporting

Article 32(3) of the Regulation sets the requirement for national enforcement bodies to

publish biennial reports with statistics on their activity, including on penalties applied.

Those reports shall be made available on the website of the European Union Agency for

Railways (172). The same website also displays the service quality reports (173) of railway

undertakings, as already required under Regulation (EC) No 1371/2007. NEBs have also

to monitor whether railway undertakings establish service quality standards and implement

a quality management system to maintain service quality. The supporting study found that

most of the service quality standards listed in Annex III are widely covered in the service

quality reports of the analysed railway undertakings. The study findings also suggest that

railway undertakings operating in 23 EU Member States (174) have implemented a quality

management system to maintain service quality.

Service quality standards reports are an important tool for enforcement. Several NEBs (175)

reported that they refer to the service quality reports when monitoring the implementation

of the Regulation and addressing passenger complaints. Other NEBs did not cover this

aspect in their reports. More generally, NEBs are encouraged to monitor these reports and

should ensure that undertakings publish them in a regular and timely fashion.

2.11.3.2. Submission and publication within the deadline

The first set of reports were due on 7 June 2025. One NEB from one Member State sent

the report within the deadline (176), the NEBs of 25 other Member States sent their reports

before the end of 2025 (177), and no report was received from one Member State (178).

(170) See Article 31(2) of the Regulation.

(171) National enforcement bodies (NEB) - Mobility and Transport.

(172) National Enforcement Bodies (NEBs) Reports │ European Union Agency for Railways.

(173) Railway Undertakings Service Quality Reports │ European Union Agency for Railways.

(174) AT, BE, BG, CZ, DE, EE, ES, FI, FR, HR, HU, IE, IT, LT, LU, LV, NL, PL, PT, RO, SE, SI and SK –

i.e. not in DK, EL, CY and MT.

(175) HR, PL, BG, IE, HU, RO.

(176)BE.

(177) AT, BG, CZ, DE, DK, EE, EL, ES, FI, FR, HR, HU, IE, IT, LT, LU, LV, MT, NL, PL, PT, RO, SE, SI.

(178)CY.

27

2.11.3.3. Content of the reports

These regular submissions play an important role in ensuring a consistent and transparent

enforcement system. They allow both the Commission and the NEBs to maintain a cross-

cutting, EU-wide perspective on how rail passengers’ rights are being implemented,

monitored, and enforced on the ground. This broader overview is essential for identifying

trends, improving coordination, and strengthening the overall effectiveness of the

regulatory framework. The reports supplement annual expert group meetings on rail

passenger rights organised by the Commission, where NEBs exchange their experiences

on enforcement practices, emerging issues and possible solutions.

The first set of reports received in 2025 reveals several trends. NEBs are increasingly

moving beyond purely reactive complaint handling towards a more proactive enforcement

model based on inspections, audits and thematic checks (for example on delays and

cancellations, information obligations and assistance to persons with disabilities and with

reduced mobility). Complaint data are being used more systematically to identify recurring

problems, with delays, missed connections, cancellations and compensation emerging as

the most frequent sources of disputes, alongside persistent shortcomings in the provision

of information and, to a lesser extent, accessibility. Some NEBs have been using structured

online forms and hotlines to categorise complaints, distinguish between issues covered and

not covered by the Regulation, and target investigations on areas with patterns of

non-compliance.

The Commission has provided a template for the report which NEBs can use on a

voluntary basis. Few NEBs used the template when preparing their 2025 report but several

NEBs summarised the information per section as suggested in the template. The

suggestions on what could be included in the report were aligned, when feasible, with

recommended reporting templates for bus and coach, and waterborne passenger rights. The

Commission stresses that having common reporting requirements helps to provide

qualitative and comparable information for the enforcement of rail passenger rights. Also,

the regular reporting cycles in the coming years will help to track the emerging

enforcement trends more precisely, to monitor whether penalty regimes remain effective,

proportionate and dissuasive in practice, and to provide greater visibility of problems on

the ground, including cases where further guidance, coordination or legislative adjustment

may be needed.

2.11.4. Complaint-handling by national enforcement bodies and other

bodies (Article 33)

The supporting study shows that most NEBs receive documents electronically (via email,

online platforms or official correspondence) and that the reply from the NEB to the

passenger’s complaint is provided within ten working days to one month, with the

possibility to extend to up to three months in complex cases (179). A smaller group operates

with very short deadlines by default, such as ten to fifteen days (180), while others set case-

by-case or agreed timeframes (181). The practice is less clear in only in a few systems,

because there have been no cases so far (182).

(179) AT, BG, CZ, FR, HR, IT, PT.

(180) EE, HU, LT, PT, RO.

(181) AT, EL, FI, LV, NL.

(182) Research suggests this is the case in seven Member States (IE, LU, LT, LV, NL, SI, SK).

28

Based on the supporting study, an alternative dispute resolution body also appears to be

available for passengers in 21 Member States (183).

2.11.5. Exchange of information and cross-border

cooperation between NEBs (Article 34)

Article 33, paragraphs (4), (5) and (6) and Article 34 of the Regulation reinforce an

obligation for cooperation between the National Enforcement Bodies: where different

bodies are designated under Articles 31 and 33 the exchange of information between them

must be ensured. Across the Member States, cross-border cooperation between NEBs

appears to remain limited in practice. This may be due to the fact that the cross-border rail

market constitutes around 7% of all rail traffic in the EU(184), slightly above the rate of 6%

in 2013 (185). The supporting study found that only three NEBs (186) reported concrete

difficulties in determining which Member State’s NEB should handle a cross-border

complaint, while 19 NEBs indicate that they did not experience such issues (187). Only one

transfer of complaint to another Member State’s NEB was reported (188).

(183) AT, BE, BG, CZ, DE, DK, EE, EL, FI, FR, HU, IE, IT, LU, LV, NL, PL, PT, RO, SE, SK. It should be

noted, however, that stakeholders consulted provided different answers about whether an alternative

dispute resolution in Ireland handles transport related complaints.

(184) Ninth monitoring report on the development of the rail market under Article 15(4) of Directive

2012/34/EU of the European Parliament and of the Council, COM(2025) 439 final, p. 4.

(185) Report on the Application of Regulation (EC) No 1371/2007 of the European Parliament and of the

Council of 23 October 2007 on Rail Passengers’ Rights and Obligations, COM(2013) 587 final, p. 3.

(186) AT, BE, DE.

(187)BG, CZ, DK, EE, ES, FR, HR, HU, IE, IT, LT, LV, PL, PT, RO, SE, SI, SK.

(188) CZ.

29

3. CONCLUSIONS

The application of the Regulation is still relatively recent as it only took effect on

7 June 2023, and many of its intended effects will necessarily take time to materialise in

practice. The findings to date should therefore be regarded as preliminary only.

Nevertheless, it appears that the pattern of exemptions has become more structured and

more limited than under the previous Regulation. While derogations do still exist,

especially for urban, suburban and regional services, they are now more often targeted,

time‑limited and specific to certain provisions. This indicates a gradual narrowing of

exemptions and a corresponding expansion of the Regulation’s effective scope in practice.

The Regulation’s effects also appear to have led to an improved environment for rail

passengers in the EU. The application of the expanded rules on the carriage of bicycles on

board trains shows that the minimum requirements for bicycle spaces on trains are

attainable in most Member States. Increased sharing of travel and traffic information

between different actors also serves the interests of passengers, in particular where they

need real-time information about their journey. The recently adopted Commission

Implementing Regulation on TEL TSI, which sets different milestones until 2029, will also

support actors in achieving this goal (189). Furthermore, thanks to the common form, whose

use needs to be further promoted, passengers now also have an additional tool to demand

their rights. Findings show that work is also underway in most Member States to prepare

contingency plans for major disruption.

Nonetheless, certain areas where more rapid progress could reasonably be expected have

not yet shown sufficient improvement. In particular, issues linked to ticketing and through-

tickets continue to persist and require action in the short term. Therefore, this report is

accompanied by a proposal for a targeted revision of the Regulation to ensure that

passengers who buy a single ticket for a journey with one or more connections operated

by several railway undertakings are ensured a level of protection similar to those

passengers with a through-ticket (190). The application of the rules on non-discriminatory

contract conditions and tariffs, the right to self-rerouting and on the exemption to the right

to compensation (force majeure) also warrant further scrutiny. Continued attention will

also be necessary to ensure that persons with disabilities and persons with reduced mobility

will be in a position to travel in a manner comparable to other passengers.

More generally, this report also shows the need for improved monitoring of the rules at

Member State-level. Effective and consistent enforcement will also be essential to ensure

that the different actors – railway undertakings, station managers, ticket vendors and tour

operators – properly apply the rules so that the Regulation’s objectives are actually

achieved in practice. The Commission will continue to oversee the implementation of the

Regulation and take action where required.

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

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

sharing in rail transport (TEL TSI) and repealing Regulations (EU) No 454/2011 (TAP TSI) and (EU)

No 1305/2014 (TAF TSI), OJ L, 2026/253, 10.2.2026, ELI:

http://data.europa.eu/eli/reg_impl/2026/253/oj. See in particular the milestones under Appendix G

thereof.

(190) COM(2026) 233.

30

Annex A Overview of the uptake of exemptions under Regulation (EU) 2021/782(191)

Exemption category AT BE BG CZ DE DK EE EL ES FI FR HR HU IE IT LT LU LV NL PL PT RO SI SK SE Total

Long-distance     √                   √               √ √   √   5

Urban/suburban √   √   √         √ √   √       √     √ √ √   √ √ 12

Regional √   √   √         √ √   √       √     √ √ √   √ √ 12

Historic or touristic use     √ √ √         √ √   √   √ √   √ √ √ √ √   √ √ 15

International to third

countries     √ √           √     √         √   √   √       7

Access to traffic and

travel information √                     √ √         √   √ √       6

Pre-notification

period for persons

with disabilities

and reduced mobility

    √ √ √ √           √ √         √       √       8

Total 3 0 6 3 4 1 0 0 0 4 3 2 7 0 1 1 2 4 1 5 4 7 0 4 3  

(191) Legend: √ - Exemption used.

31

Annex B Comparison with Member State exemptions under Regulation (EC) No 1371/2007(192)

Regulation (EU) 2021/782 on rail passengers’ rights and obligations (exemptions applicable at the time of publication of the report)

Exemption category per

service AT BE BG CZ DE DK EE EL ES FI FR HR HU IE IT LT LU LV NL PL PT RO SI SK SE Total

Urban/suburban √ √ √ √ √ √ √ √ √ √ √ √ 12

Regional √ √ √ √ √ √ √ √ √ √ √ √ 12

International to third

countries √ √ √ √ √ √ √ 7

Long-distance domestic √ √ √ √ √ 5

Total 2 0 4 1 2 0 0 0 0 3 2 0 4 0 0 0 2 1 0 3 3 4 0 3 2

Regulation (EC) No 1371/2007 on rail passengers’ rights and obligations (exemptions applicable at the time of its repeal on 7 June 2023)

Exemption category per

service AT BE BG CZ DE DK EE EL ES FI FR HR HU IE IT LT LU LV NL PL PT RO SI SK SE Total

Urban/suburban √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ 18

Regional √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ 18

International to third

countries √ √ √ √ √ √ √ 8

Long-distance/domestic √ √ √ √ √ √ √ √ √ √ 11

Total 2 0 3 0 2 0 4 0 2 3 2 0 4 3 0 4 2 4 0 4 3 4 0 3 2

(192) The comparison was carried out on the basis of the information available to the Commission. Only exemptions common to both Regulations are shown.

Legend: √ - Exemption used by Member State.