The European Passengers’ Federation has called on EU Member States to take more time to assess the proposed Multimodal Booking Regulation (MBR), warning that rushing towards an agreement could undermine passenger choice and the objectives of the Passenger Package.
In a letter sent on 20 October 2026 to representatives of the Member States, EPF Chairman Josef Schneider reiterated EPF’s strong support for the overall objectives of the Passenger Package: enabling passengers to discover, compare and book journeys across transport operators and modes, make informed choices and enjoy seamless end-to-end travel.
With Council discussions progressing rapidly, EPF is concerned that the push to reach an agreement could come at the expense of passengers’ interests. While recognising the importance of moving forward, EPF stresses that getting the legislation right must take priority over speed. EPF therefore highlighted several shortcomings in the current MBR proposal and urges Member States to carefully assess its implications before agreeing on a General Approach.
Neutral ranking must protect passengers without unnecessarily restricting choice
EPF supports neutral, transparent and non-discriminatory presentation of transport offers. Default rankings should not be influenced by undisclosed criteria or commercial arrangements that unfairly favour particular operators. However, neutrality should not prevent platforms from using other relevant criteria to help passengers find the best options for their needs. Factors such as punctuality, cancellation rates, transfer times, customer ratings and the diversity of results can make rankings more useful, especially when comparing the many possible itineraries in a multimodal context.
We therefore support mandatory filter options that allow passengers to rank results according to their own priorities, including price, journey duration, departure time and emissions. At the same time, platforms should remain free to present default rankings based on a broader combination of relevant, transparently disclosed criteria, provided these do not discriminate between operators. This would safeguard fair competition while preserving flexibility, innovation and meaningful passenger choice. This approach is consistent with the recommendations of the Multimodal Passenger Mobility Forum, whose 2023 final report was developed through extensive stakeholder discussions.
Emissions-based ranking must not penalise sustainable transport
EPF supports reliable environmental information to help passengers make informed, sustainable choices. However, ranking offers with missing or incomplete emissions data lower could have the opposite effect. Rail services, particularly those operated by smaller providers, may not systematically provide emissions data despite often being more sustainable. They could therefore be pushed down search results simply because data is missing. Instead, priority should be given to ensuring comparable emissions information across modes through consistent data-sharing obligations or a harmonised methodology where operator-specific data is unavailable. Missing data should not, in itself, disadvantage transport options that may be among the most sustainable.
Clear rules on advertising without undermining useful booking services
EPF supports clearly labelled advertising that distinguishes paid placements from ordinary search results. However, requiring sponsored results to appear only upon explicit user request – a step few passengers are likely to take – risks undermining the business models of independent comparison and booking platforms, whose advertising revenue helps fund free journey-comparison services. Overly restrictive rules could cause useful platforms to disappear, reducing rather than increasing consumer choice.
Recognising that search-result placement can influence passenger decisions, we encourage Member States to consider proportionate safeguards – for example, limiting paid placements among the first results rather than effectively prohibiting them by default. The aim should be to ensure transparency and curb undue commercial influence while preserving useful services and a diverse, competitive market.
The Passenger Package must deliver a coherent multimodal framework
Despite its name, the Mulitmodal Booking proposal does not yet provide a comprehensive framework for comparing and booking journeys across transport modes. Environmental information is of limited value if passengers cannot meaningfully compare alternatives across modes.
The proposal also falls short of its original aim of addressing market barriers. Unlike the Rail Ticketing Regulation, it does not apply fair, reasonable and non-discriminatory (FRAND) obligations consistently across modes. EPF calls for FRAND data-sharing obligations to cover all operators and platforms, regardless of market share or business model, with data sharing and a willingness to conclude distribution agreements as the default.
Finally, the MBR must be considered alongside the Rail Ticketing Regulation and the proposals on rail and multimodal passenger rights. These interlinked initiatives should be assessed together to ensure a coherent and balanced outcome for passengers.
