Planned engineering works sometimes require temporary railway closures, with disruptions ranging from brief overnight work to extended blockades lasting several months. To maintain a passenger service, rail replacement services (usually buses or coaches) may be arranged to cover affected routes.
Passengers need to be provided with information that enables them to plan their journey in advance, taking account of the impact of the rail replacement services, and to travel with confidence on the day itself.
This report scrutinises the quality of passenger information for planned rail replacement services. Engineering work is scheduled by Network Rail well in advance, as is necessary to comply with the timetable planning process set out in its Network Code. This should enable Network Rail, National Rail Enquiries (NRE) and train operators to provide passengers with informative and timely information as they plan, book and undertake their journeys.
In November 2023 we concluded that passengers were not getting the information that they need in advance, nor on the day of travel on planned rail replacement services.
We identified some areas of good practice, most notably that passengers buying tickets online before travel were being told when rail replacement services would be in use for planned engineering work. However, we also identified several areas of concern that we asked train operators, Network Rail and NRE to address. Our key recommendations focused on:
- improving the quality of advance information provided online
- ensuring that rail replacement services are shown in live departure information at stations and online
- improving information provided about stations on NRE
- ensuring that rail replacement services display their destination on the vehicle and that passengers onboard are informed when a rail replacement service is approaching a stop
We also invited the industry to work together to explore how to make real time bus location data available to passengers.
We committed to undertaking a follow-up review in 2024 to assess industry’s progress with addressing the issues we highlighted. We hoped to find an improved experience for passengers. This report sets out our findings and highlights further activity and actions that we consider need to be taken.
Regulatory framework
Operators are subject to a number of requirements relating to the provision of rail replacement services. We hold operators to account against their obligations under the passenger information and accessible travel policy licence conditions.
The Driver and Vehicle Standards Agency (DVSA) investigate and enforce the related requirements in the Public Service Vehicles Accessibility Regulations (2000) (PSVAR) and new Public Service Vehicles (Accessible Information) Regulations (2023) (PSV(AI)R) and where appropriate, will report offences to the Traffic Commissioners.
Complementary requirements are set out in the National Rail Conditions of Travel (NRCoT), the contracts issued by the contracting authorities, and the Passenger Charter’s issued by train operators.
Passenger information licence condition
We expect train and station operators to ensure that passengers have accurate and timely information about their travel options, so that they can plan and make journeys with confidence, including during disruption. These expectations are formalised in a passenger information licence condition for train operators and a complementary licence condition for station operators (including Network Rail) and are supported by wider consumer law requirements.
All operators have adopted the industry Customer Information Pledges as their regulated passenger information Code of Practice. This sets out good practice in the information that passengers can expect to receive before, during and after their journey by train, including when there is disruption. In April 2022 we updated our regulatory guidance to support operators in adopting the pledges as their Code of Practice for passenger information, as is required under their licences.
Annex A lists those pledges that are most relevant to this work, with the codes that we use to refer to individual pledges throughout this report. For example, pledges include operators informing passengers if part of the journey will require travel on a mode of transport where it would normally be expected to be a train (Pledge D5).
Accessible Travel Policy licence condition
All operators are required, by their operating licences, to establish and comply with an Accessible Travel Policy (ATP), setting out what they will do to help disabled people use the railway. The mandatory minimum requirements are set out in our ATP Guidance.
Our ATP Guidance requires operators to provide passengers in advance of planned disruption with appropriate, accurate and timely information about the accessibility of the rail replacement transport they will be providing for the affected service and the options available to the passengers to be able to make their journey.
Public Service Vehicles Accessibility Regulations
PSVAR (2000) require drivers of regulated service vehicles to at all times display destination signs on the front or nearside of a scheduled rail replacement vehicle.
DVSA is responsible for enforcement of PSVAR. ORR has a Memorandum of Understanding with DVSA and we regularly share issues and insights.
Public Service Vehicle (Accessible Information) Regulations
Following the introduction of the Public Service Vehicle (Accessible Information) Regulations 2023, or PSV(AI)R, between 2024 and 2026 it will become mandatory for the majority of bus and coach services to meet accessible information provisions. The regulations are intended to result in all passengers having access to high-quality and accurate on-board information. This includes providing relevant information consistently in both audible and visible formats, identifying upcoming scheduled stops on the service route and - if necessary - the driver announcing information manually.
These regulations took effect on 1 October 2023 but the date from which they apply will depend on when the operator’s vehicles were first used on local services. As set out in DfT’s guidance, newer vehicles must comply more quickly. Vehicles first used from 1 October 2019 need to comply from 1 October 2024 (and so therefore after our fieldwork was completed). Vehicles first used from between the 1 October 2014 and 30 September 2019 have until 1 October 2025 to comply. Older vehicles (dating from 1973 to 2014) have until October 2026 to comply with the regulations. As for PSVAR, DVSA is responsible for enforcement of PSV(AI)R. More information is set out in the next steps section of this report about how we work with the DVSA.
In October 2024, a Technical Exemption was granted by DfT for coaches used for Rail Replacement services. Buses used for rail replacement are not covered by the exemption.
The Technical Exemption for rail replacement coaches require vehicles to meet the ‘spirit’ of the regulations by:
- displaying journey information, including stops the vehicle will make and the destination
- making audio announcements on the Public Address system (where fitted)
- providing alternative transport where a passenger requires announcements about the stops a journey might make that cannot be otherwise provided
Other obligations
The NRCoT form part of the ticket contract between the train operator and the passenger. Section 27 sets out the arrangements that apply when rail replacement services are in use.
The contracts with train operators may include requirements to provide rail replacement services in the event of planned or unplanned disruption.
Train operators publish a Passenger’s Charter that sets out their commitments to passengers and the standards that they are expected to comply with. The Charters include obligations when rail replacement services are in use.
Our evidence base
Information request
We issued an information request to 23 train operators who operate rail replacement services (Heathrow Express were excluded as they do not operate rail replacement services). Operators provided qualitative information about their rail replacement services and processes. This included responses to questions about information they provide to passengers ahead of the engineering works and how they work with Network Rail. There were also questions on information they provide during the engineering works at stations, on trains and rail replacement vehicles.
Summary of 2024 fieldwork
We assessed the passenger information relating to rail replacement services for 17 planned line closures for 12 operators across England and Wales from May to August 2024. All assessments were for journeys made on weekdays. A full list of the rail replacement services we travelled on is available in Annex B.
Our assessments were based on requirements set out in the Customer Information Pledges and ATP Guidance and informed by our findings from our fieldwork conducted in 2023.
We gathered evidence from the NRE website and app, Network Rail’s website, train operator websites and apps, and from our observations as we travelled.
We acknowledge our fieldwork covered a small sample of operators across 17 trips and did not cover Scotland. However, we consider our findings in conjunction with our information request sufficient to indicate where there are potential concerns with passenger experience that warrant further investigation. We outline a summary of our findings in the following sections of this report.
Review of information provided by operators on the accessibility of rail replacement vehicles
We carried out a review of all operators’ websites in relation to the provision of information about the accessibility of rail replacement vehicles. We looked at:
- information provided to passengers about the accessibility of their rail replacement vehicles on their accessible travel and rail replacement FAQs pages
- information provided in operators’ ATP documents
Smarter Information Smarter Journey’s Programme (SISJ)
We have previously challenged the industry to develop a single, transparent strategy to deliver improvements in passenger information. In response, the industry established the Smarter Information Smarter Journey (SISJ) programme, which is jointly led by the Rail Delivery Group (RDG) and Network Rail.
The SISJ programme now plays a central role in enabling change that requires cross-industry collaboration. SISJ was key to the launch of the Customer Information Pledges in December 2021 and are leading initiatives on the live status of rail replacement services and production of short information videos for planned engineering works that are discussed in this report.
ORR’s Consumer Expert Panel
We sought advice from ORR’s Consumer Expert Panel on our emerging findings and recommendations. The panel provides independent advice and plays a key role in bringing a consumer perspective to our policy and regulatory decisions. It was supportive of our recommendations, recognising the potential for harm when passengers are not provided clear and accurate information throughout each stage of the passenger journey.
This report
This follow-up report identifies what progress Network Rail, operators and NRE have made in improving the quality of passenger information for planned rail replacement services following our 2023 recommendations.
The structure of the report is as follows: