Review of train operators' revenue protection practices: Terms of Reference

Components

Purpose 

The review will: 

  1. Review and assess operators’ revenue protection enforcement practices, including the use of prosecutions.
  2. Review whether ticket conditions are clear and effectively communicated, and that systems are correctly applying conditions, including at the point of sale.
  3. Where appropriate, make recommendations to the industry and government for the benefit of passengers, operators and taxpayers.  

Scope  

The review will gather evidence to draw conclusions and make recommendations as it sees fit, including but not limited to:

  • Retailing information - including passengers’ access to accurate and complete information, and whether this is clearly and effectively communicated during the sales process; including online, at ticket vending machines and ticket offices. 
  • Ticketing terms and conditions – the clarity of ticketing terms and conditions, including within the National Rail Conditions of Travel (NRCoT), railcard T&Cs, and other ticketing conditions. 
  • Non-compliance with ticketing rules – the classification of ticket non-compliance, and how different types of ticket non-compliance should be addressed, considering proportionality and severity. 
  • Revenue protection enforcement practices – the appropriateness of the enforcement approach, and the options available for operators to enforce revenue protection. 
  • Operator assurance and accountability – assessing current assurance and accountability processes which operators have in place, and systems for revenue protection enforcement. 
  • Communication of enforcement approach – the appropriateness and proportionality of communication with passengers, including at the point of sale, and through enforcement practices e.g. letters. 
  • Prosecution process – the circumstances in which prosecution is appropriate to the offence. This includes the requirements on prosecutors e.g. the Full Code Test. 
  • Operator and taxpayer need to protect revenue – whether the correct balance is being struck between the need to treat passengers fairly, while ensuring fare evasion and fraud are adequately deterred, to protect operator and taxpayer interests.

The following should be in scope:

  • The main National Rail retailers – including operators and third-party ticket retailers, and multiple channels e.g. online, ticket offices and ticket vending machines. 
  • Train Operating Companies – including all DfT contracted operators, and devolved operators, where appropriate.
  • Review outputs – findings may include recommendations, targeted actions, proposals for improved consumer practices, regulatory and or legislative changes.

The following is out of scope: 

  • Wider fares and ticketing reform. The Government is already committed to reviewing the overcomplicated fares system, with a view to simplifying it and exploring options for expanding ticketing innovations, like delivering pay as you go across the network.

Structure, process and timeline of the review 

The Review will consist of the following:

  1. Evidence gathering from passengers, passenger representative groups, including Transport Focus and London TravelWatch, the Rail Ombudsman, the Rail Delivery Group, the rail industry, government, and relevant experts.
  2. Analysis of the items referenced in scope above, and their underlying causes. Generating evidence-led findings and noting areas of good and poor retailing and revenue protection practices.  
  3. Production of a final report which may include recommendations for change or highlighting areas for consideration or action.  

The Office of Rail and Road will provide regular progress updates to the Department for Transport, with a final report no later than 15 May 2025.

Governance

The Office of Rail and Road may appoint an Expert Advisory Panel to give input to the review, which is being conducted under Section 51 of the Railways Act 2005, which permits ORR to provide information, advice and assistance to national rail authorities. 

The work is in response to a request made by the Secretary of State for Transport on the 13 November and will be conducted by the ORR under the statutory framework that assures its independence from government or any other authority.