The ‘Better protection for passengers and their rights’ initiative aims to consolidate and simplify the passenger rights regulatory framework and to enhance its crisis resilience, ensuring a better application and enforcement and addressing a number of ‘horizontal issues’ currently not covered for all transport modes, such as rules on the role of intermediaries and adequate insolvency protection.

Key takeways for EPF

  1. Air passengers need better protection against the risk of a liquidity crisis or an insolvency, aligning passenger rights under the Air Passenger Rights’ Regulation and under the Package Travel Directive.
  2. The role of intermediaries needs to be clarified – for air travel, but also for multimodal travel – in terms of information provision, complaint handling, re-routing, reimbursement, compensation and assistance. To be effective, B2C obligations would need to be complemented by clear rules addressing B2B responsibilities and deadlines.
  3. Passengers who booked a standalone flight should be able to cancel their flight, just like passengers who booked the same flight as part of a Package Travel – in case of a major crisis (official travel warnings should count as such) without having to pay a fee.
  4. To make multimodal travel a convenient, reliable and safe choice, in principle, all core passenger rights should also apply to multimodal trips. For EPF, the top priorities are (i) journey continuation guarantee; (ii) practical information, advice and support; (iii) straightforward and appropriate compensation.
  5. Monitoring and enforcement of passenger rights should be strengthened across the EU – for all modes. Passengers also need to be better informed and procedures for complaint handling, reimbursement and compensation requests should be simplified.

For EPF, the Better Protection for Passengers and their Rights initiative should consider all modes, to ensure it is future-proof and that multimodality is covered in all its facets. As horizontal topics, the role of intermediaries and the right to self-cancellation in case of a major crisis, notably, are relevant not only to air, but also to multimodal travel.

Measures to further harmonize passenger rights across modes seem to be missing so far. In such effort, the highest level of consumer protection should be aimed for or maintained.

Read the position paper here.