On 13 May, the European Commission published its long-awaited “Passenger Package”: three legislative proposals aimed at improving rail passenger protection, rail ticketing, and multimodal digital mobility services. Together, these proposals seek to make multimodal and, in particular, multi-operator rail travel, easier to plan and book, while also strengthening rail passenger rights throughout the journey.

Following our initial reaction published at the end of May (available here), EPF has now submitted more detailed feedback to the Commission via the ‘Have Your Say’ portal on 31 July (available here):

EU rules on multimodal digital mobility services and single digital booking & ticketing

• EPF strongly supports the objective of enabling passengers to find, compare, combine and purchase multi-operator rail tickets through the channel of their choice.
• The proposed five-month booking horizon for rail is welcome, but it must be reliable in practice. Differences in booking horizons must not result in different levels of passenger protection.
• EPF’s long-standing position is that data sharing and readiness to conclude distribution agreements between operators and Multimodal Digital Mobility Services (MDMS) – on fair, reasonable and non-discriminatory (FRAND) terms – should be the default approach and become the norm.
• Such obligations are introduced for rail, but not for other modes, despite similar competition concerns, particularly in aviation. As a result, passengers are likely to continue facing difficulties when trying to compare and book seamless, door-to-door multimodal journeys.
• Puzzlingly, MDMS are limited to information and distribution of transport products from different operators within the same mode. This is a missed opportunity to support modal shift by enabling passengers to compare and book multimodal journeys.
• Environmental information will only be meaningful if available for comparison across multiple modes and if emissions data is consistently available.

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

• EPF warmly welcomes this ambitious proposal, which is a major step forward in strengthening passenger rights when travelling with multiple operators.
• The “single transaction” criterion leaves important gaps and should be replaced by a “single journey” approach.
• Existing journey continuation agreements should be strengthened and made mandatory as a basis for robust re-routing guarantees.
• Minimum Connection Times should be transparent, subject to independent oversight, and based on realistic operating conditions.
• Operators, ticket vendors and intermediaries should have clearly defined responsibilities for providing information, handling complaints and assisting passengers with re-routing.

➡️ Passenger Package – EPF response (31.07.2026)