EPF has submitted its response to the European Commission’s call for evidence on the targeted revision of Regulation (EU) 2021/782. Our message is clear, passengers must be better protected when disruption occurs, especially on multi-operator journeys, and their rights must be enforceable, easy to access, and consistent across Europe.

EPF priorities on passenger protection in the event of disruption

To restore trust and encourage more people to choose rail, EPF sets out three priorities for when things go wrong: (1) a journey continuation guarantee, so passengers can reach their final destination at the earliest opportunity and at no extra cost; (2) access to practical, up-to-date information and support, ideally from informed staff and supplemented by online/telephone support; and (3) straightforward, appropriate compensation and reimbursement for additional expenses, with simple, transparent claims processes and support for automation where relevant.

Close the gaps for multi-operator journeys

Today, key rights such as re-routing, compensation and assistance are often limited to holders of a through ticket. In practice, passengers booking multi-leg trips with different operators, even in a single transaction, can be left without protection if a missed connection is caused by disruption. EPF supports the objective of the revision to ensure passengers are granted their rights when travelling with multiple railway undertakings with tickets purchased as part of a single transaction. Sold connections must come with guaranteed protection.

Journey continuation must be a core right

Railway undertakings must be required to cooperate so that passengers can continue their journey on the next available train, at no extra cost, when a connection is missed due to disruption. Existing voluntary arrangements, such as HOTNAT and the CER/CIT Agreement on Journey Continuation (AJC), are steps in the right direction but remain inconsistently implemented and difficult for passengers and staff to navigate. If voluntary measures cannot deliver a consistent guarantee, regulatory intervention will be essential to uphold this fundamental right across Europe.

Clarify the role of intermediaries

Intermediaries are key actors in today’s distribution ecosystem, yet their responsibilities in disruption remain unclear. EPF calls for clear and enforceable rules to define how responsibilities are shared between operators and intermediaries, especially when tickets are purchased via a one-stop-shop, covering at minimum: real-time disruption information, proactive communication of rights and how to claim them, assistance with re-routing or refunds, and serving as the first point of contact for passengers (e.g., for complaint handling).

Enforcement and cross-modal consistency

Passengers’ rights only matter if they can be fully exercised. EPF therefore urges stronger mandates and resourcing for National Enforcement Bodies (NEBs), truly dissuasive sanctions, mandatory participation in Alternative Dispute Resolution (ADR) with binding decisions, automatic reimbursement/compensation where feasible, and strict complaint-handling deadlines. National exemptions should be removed so commuters on suburban and regional services receive equal protection. Rail passengers should also have clear protection in cases of schedule changes or cancellations announced in advance, and a right to self-cancellation in major crises, consistent with cross-modal approaches.

Cost-based objections to stronger rights must be tested against actual avoidable costs.

The marginal cost of carrying additional passengers is usually minimal, while better guarantees can increase ridership and revenues. Ultimately, to make informed choices and be properly protected, passengers must be able to plan, book and pay in a one-stop-shop and benefit from access to comprehensive travel data and ticket distribution on FRAND (fair, reasonable, and non-discriminatory) terms, because without access to information and ticketing, rights remain theoretical. Integrated information, seamless ticketing and strong rights must be delivered together.

▶️ Read our full response here