Passenger package: Multimodal booking and rail ticketing

Background

The two proposals are part of the 'one journey, one ticket, full rights' passenger package¹ adopted by the European Commission on 13 May 2026. The initiative was announced in the political guidelines for 2024‑2029, the 2022 Commission work programme and the 2020 sustainable and smart mobility strategy. The proposals aim to improve the functioning of the online ticket distribution market and enhance the appeal of passenger rail travel in the EU. The initiative is expected to promote multimodal transport and contribute to the European Green Deal's emission reduction goals.² It is in line with the Letta ³ and Draghi ⁴ reports, which highlighted the need to remove market barriers and ensure fair competition in the transport sector.

Problem definition

The IA notes that passengers face challenges in finding, comparing, combining and booking tickets for regional and long‑distance journeys in the EU, especially when combining offers from different operators or planning cross‑border train trips (IA, p. 1).

According to the 2024 Eurobarometer survey on multimodal digital mobility services (MDMS), around one third of respondents had never booked a multimodal or multi‑operator journey before. It also revealed that more than a third of those who do book such journeys experience difficulties, such as in finding a suitable combination or buying all the necessary tickets from one source, and that these challenges are greater for rail travel (IA, pp. 1, 7‑8).

The IA refers to an EU‑wide analysis of '100 origin‑destination routes',⁵ which found that while alternative multimodal travel options exist on 76 % of the routes, MDMS platforms⁶ do not always display or combine travel options. For example, 39 % of rail and coach connections were not visible or did not combine with each other on the MDMS platforms. The IA also points out that booking barriers are greater when searching for options which include more than one railway undertaking (RU) (IA, pp. 6‑7).

The IA explains that computerised reservation systems (CRSs),⁷ a specific type of MDMS, aggregate and provide information on operators' travel options to online and offline travel agents and travel management companies (business‑to‑business services, B2B). Specific rules (code of conduct) were adopted in 1989 and revised in 2009 to avoid anti‑competitive behaviour by CRSs (IA, pp. 4‑5; see Annex 9, pp. 232‑236). The 2020 evaluation ⁸ showed that the CRS code of conduct has not entirely ensured a level playing field for all participating carriers in terms of access to and use of CRS services. It has not led to a better balance in bargaining power between larger and smaller airlines in relation to CRSs. Furthermore, the transparency requirements were still considered necessary because travel agents and travel management companies depend heavily on CRS data. The evaluation found it necessary to review the need for the CRS code of conduct and its scope due to market and technological developments in the distribution of airline tickets, such as the increase in the direct distribution of flight tickets or the rise of alternative B2B channels (IA, pp. 4‑5; see also Annex 10, pp. 237‑240).

The IA defines two problems (P), which it expects to persist without further EU action (pp. 5‑16, 23‑24):

P1) Lack of transparency, unfair conditions and an uneven playing field in the online ticketing market

The IA states that increasing digitalisation has changed and diversified the online ticketing platform market for transport services. Based on the evaluation of the CRS code of conduct, it mentions, for example, the emergence of indirect distribution channels (e.g. new content aggregators), which provide similar services to travel agents as CRSs but are not subject to the same rules. In addition, new types of business‑to‑consumer (B2C) platforms are not obliged to comply with the fair treatment of transport operators or neutral display requirements (i.e. without discrimination or bias). The IA notes that these market developments raise concerns of an uneven playing field between market actors (pp. 8‑9).

The IA explains that MDMS platforms can have a significant market presence (SMP)⁹ or strategic position, making them important to transport operators of different sizes. For example, small and medium‑sized airlines depend on CRSs – which, despite a declining share of bookings via CRSs, still have a unique position in the airline ticket distribution market – to reach the networks of large travel agencies and gain visibility. The IA points out that a strategic position enables CRSs to impose restrictive terms and conditions, such as full content parity clauses.¹⁰ In addition, MDMS platforms can design search algorithms that make certain transport offers more attractive and display travel information from competing services in a less visible manner (gatekeeper effect) (IA, pp. 10‑12).

P2) Incomplete offer of rail tickets on (rail) platforms

The IA notes that although considerable progress has been made in developing the single European railway area (e.g. in terms of infrastructure and interoperability), ticketing remains a significant structural weakness. It explains that the incumbent railway undertakings (RUs) have SMP in the national transport services.¹¹ According to the ninth monitoring report on the development of the railway market, in 2022 state‑owned railway companies held an 87.4 % share of the EU market for commercial passenger rail services and a 79 % share in the public service obligation (PSO) passenger services market (IA, pp. 1‑2, 12‑16).

In addition to operating the majority of passenger services, incumbent RUs also own established ticketing platforms.¹² These can be used to discriminate against competing online ticket providers by selectively distributing information and offers, or by not selling tickets from competing railway companies on the main online ticketing service. This hampers price comparability, transparency and competition, and creates barriers for smaller railway undertakings due to their limited visibility. In addition, consumers may find it difficult to buy train tickets when travelling cross‑border or when trying to purchase single ticket journeys involving several railway undertakings. These difficulties make rail travel less accessible and attractive to passengers and limit its potential to contribute to a more sustainable and multimodal transport system (IA, pp. 12‑16).

The IA illustrates P2 further by describing decisions and rulings concerning anti‑competitive practices with regard to rail ticket distribution in several EU Member States in Annex 11 (pp. 241‑243).

The IA identifies four problem drivers (D), linked to the defined problems (pp. 16‑23):

The problem definition draws on several data sources, such as the ex‑post evaluation of the CRS code of conduct, the IA supporting study, the 2024 Eurobarometer survey, stakeholder consultation and court cases. As required in the BRG, the IA defines the problems and problem drivers, illustrating their nature and scale with examples and quantified estimates. However, the IA could have further discussed the potential impacts of technological development on transparency and a level playing field (e.g. using AI to search for offers).

Subsidiarity/proportionality

The IA considers Articles 90 to 100 (Title VI) of the Treaty on the Functioning of the European Union (TFEU) the legal basis (common transport policy).

It briefly substantiates the necessity of EU action by the need to ensure the seamless operation of European transport given the cross‑border dimension of long‑distance travel. In addition, the IA refers to many court cases, especially in the rail sector, based on Article 102 of the TFEU, which prohibits abuse of dominance and stresses the need for EU‑level intervention (pp. 2‑3, 24‑25).

Regarding the initiative's added value, the IA expects consumers to benefit from improved transparency, greater ticket choice and an easier, more coherent booking experience. Furthermore, removing obstacles for operators and platforms would facilitate a level playing field and better functioning of the online ticket distribution market. Overall, the IA considers that the initiative promotes multimodal transport.

The IA does not provide a subsidiarity grid. Subsidiarity and proportionality aspects are discussed in the comparison of policy options and in the context of the preferred option (IA, pp. 65‑67, 70).

No reasoned opinions were submitted by the subsidiarity check deadline of 3 September 2026 for the national parliaments relating to the proposal on multimodal booking or the proposal on rail ticketing.

Objectives of the initiative

The IA defines two general objectives (GO) for the initiative (pp. 25‑26):

It breaks the GOs down into two specific objectives (SO) which address the problem drivers (D) (pp. 25‑26):

The IA presents four operational objectives in relation to the preferred options, linked to the specific objectives and monitoring indicators (Annex 12, pp. 244‑245).

The objectives largely appear to be in line with the Better Regulation SMART criteria (specific, measurable, achievable, relevant and time‑bound) (Tool#15). According to the IA, the initiative would also contribute to the United Nations sustainable development goals (SDGs; notably 3, 9 and 13) (IA, p. 25; Annex 3, p. 107; see Tool#19).

Range of options

In line with the BRG (see also Tool#60), the IA describes the baseline, which is further explained in Annex 4 (pp. 152‑164). Following Tool#16, it depicts 15 retained policy measures, based on stakeholder consultation and expert feedback and research, grouped into four policy options. In addition, it provides information on the discarded measures (IA, pp. 27‑36, 221‑223 and 225‑231).

While the IA provides an informative description of the policy options against the baseline, it does not offer self‑standing alternative policy options. Although multiple options are presented, they do not actually offer much choice. All policy options are identical regarding 12 out of the 15 policy measures (PM1 to PM12) and differ only in terms of certain requirements for indispensable RUs (PM13 to PM15). The IA explains that option 1 sets out policy measures common to all options. Building on option 1, options 2 to 4 add PM13, option 3 adds PM14 and option 4 PM15. This approach to policy option building, where options are built around each other, is contrary to the Better Regulation recommendations (Tool#16), as it weakens the impact analysis and favours measures included in all options. In addition, Tool#11 stresses that the options should provide alternative ways to address the specific objectives.

Assessment of impacts

As required in the BRG, the IA assesses the policy options' economic, environmental and social impacts (pp. 36‑59). It assumes the option measures would be implemented as of 2028 and sets the assessment period for 2028 to 2050.

The IA assesses the economic impacts on MDMS platforms, transport operators, consumers, national authorities and the European Commission. Regarding one‑off and recurrent costs for MDMS platforms, it expects PO4 to generate the highest net costs, of €140 million, due to the unbundling requirement (PM15), while PO2 would bring the highest net benefits, of €20.9 million, from the 'sharing obligation' (PM13). All options would bring net benefits to transport operators (highest savings under PO2, of €100.9 million, and lowest under PO1, with €13.0 million). Consumers are expected to benefit from a reduction in search costs (when purchasing tickets) and increased competition (price level and quality of services). Based on a qualitative comparison of options, the IA finds PO3 to have the greatest impact. The IA illustrates the costs for users in inter‑urban mobility with quantified estimates, but explains that not all costs could be quantified. The options would generate a modal shift away from road transport, thereby reducing congestion costs associated with road traffic. PO3 would bring the biggest savings, of €6.4 billion, and PO1 the smallest, of €1.8 billion. National authorities would incur administrative and enforcement net costs amounting to €135.4 million in all options. The estimated net adjustment costs for the European Commission would be €5.3 million under all options (IA, pp. 38‑49).

The IA considers social impacts in terms of health, i.e. reduced air pollutant emissions from greater use of more sustainable transport options. The savings in external costs of air pollutants are deemed the highest under PO4 (€502 million). Moreover, the initiative is expected to enhance job creation due to greater use of public transport, deployment of additional MDMS platforms and increased investment in innovation, although no quantitative estimates are presented. It also considers that less car travel would decrease the number of road fatalities and injuries. The external costs of accidents would be most reduced under PO3, with savings estimated at €21.3 billion (IA, pp. 54‑57).

The IA states that the policy options would have no negative impacts on fundamental rights, specifically the level of data protection (pp. 55‑56).

The IA finds that options PO2, PO3 and PO4 would address the demands of young people by enhancing a transport system that offers a more digital, climate‑conscious and user‑centric approach (pp. 56‑57).

All options are in line with the environmental objectives and the 'no significant harm' principle. The IA assesses CO₂ emissions, air pollutant emissions and noise emissions, and finds that PO3 would generate the greatest savings in the external costs of these emissions, for example, €6.8 billion relating to CO₂ emissions (pp. 57‑58).

According to the IA, all options would enhance territorial cohesion, as all operators, including those from less connected and remote areas, would have equal visibility. PO3 would have the highest impact on territorial cohesion as it imposes an obligation of access on indispensable RU platforms (PM14), which ensures that smaller regional providers would be integrated into major booking platforms (p. 54).

In its assessment, the IA finds that while all options would positively contribute to tourism, PO3 would best promote the development of user‑centric travel services due to its 'hosting obligation' (p. 54).

The IA considers that the 'digital by default' principle is embedded in all options with the aim of promoting well‑functioning digital services in the transport sector (pp. 53‑54).

The policy options are compared against their effectiveness, efficiency, coherence, subsidiarity and proportionality in terms of achieving the general and specific objectives. The IA finds PO3 to be the most effective option, due to its hosting requirement, and the most efficient option (costs/benefits), as it offers the highest benefit‑to‑cost ratio. All options perform equally well in the coherence analysis. The options are also scored against subsidiarity and proportionality (although only as a combined criterion, not two different criteria): options 1, 2 and 3 are considered equally good and better than PO4, which would lead to higher costs due to its unbundling requirement (IA, pp. 60‑70). The IA concludes that the preferred option is PO3.

Monitoring and evaluation

The IA provides information on the initiative's monitoring and evaluation plans in Annex 12 (pp. 244‑245). It describes four operational objectives, six monitoring indicators and data sources (e.g. national enforcement authorities, European Commission, Eurobarometer surveys), and identifies their links to the defined specific objectives. Regarding evaluation, it notes that the Commission would conduct an evaluation at least five years after the start of the legislation's implementation.

Stakeholder consultation

In accordance with the BRG (see also Tool#54), the IA provides a summary of the extensive stakeholder consultation in Annex 2 (pp. 86‑102), which covers several consultations from 2020 to 2025. It identifies the stakeholder groups in question, namely industry (e.g. MDMS providers, including CRSs, transport operators and intermediaries), public authorities, citizens and other stakeholders.

Overall, the summary gives a good overview of the consultation activities. These covered calls for evidence on the revision of the CRS code of conduct (9 July to 4 September 2020) and the initiative on MDMS (5 October to 2 November 2021). Furthermore, open public consultations (OPCs) were conducted on the CRS code of conduct (23 February to 18 May 2021) and on MDMS (1 December 2021 to 23 February 2022). These met the Better Regulation 12‑week requirement. In addition, targeted consultations were carried out in the form of online surveys, interviews and workshops. The IA explains that after the Regulatory Scrutiny Board's negative opinion on 13 September 2023 on the draft IA (MDMS), the initiative was divided into two legislative proposals on multimodal booking (RMB) and rail ticketing (RTR). Consequently, additional targeted consultations were carried out on this basis (from January to June 2025). As part of the consultation process and strategy, the IA also references the 2024 Eurobarometer survey and the multimodal passenger mobility forum expert group.

The IA describes the stakeholder groups' views on the policy measures and integrates them throughout the assessment. The consultation shows that stakeholders have divergent opinions on the initiative and policy measures. Regarding the preferred option (PO3) and particularly the hosting obligation, most respondents from national authorities viewed the measure positively, while the majority of transport operators opposed it. Most MDMS platforms considered the measure's effect neutral or very ineffective. Some indispensable RUs pointed to the risk of increased market concentration of railway undertakings, whereas new entrant RUs supported the hosting obligation as 'a game changer, potentially doubling the modal shift of rail for long‑distance travel' (pp. 71, 101).

Supporting data and analytical methods used

In its qualitative and quantitative analysis, the IA draws on the ex‑post evaluation of the CRS code of conduct, the IA supporting study (Ricardo et al., 2026), an in‑depth analysis of '100 origin‑destination routes', stakeholder consultation, the 2024 Eurobarometer, and literature and court cases in the policy field.

The IA explains the analytical methods used in Annex 4 (pp. 108‑212). For example, it describes the PRIMES‑TREMOVE transport model (the baseline scenario) included in the European Commission's modelling inventory and knowledge management system (MIDAS), the ASTRA model (policy options) and the assumptions and data inputs. It also mentions an Excel‑based tool, drawing on the standard cost model (Tool#58), which was developed to feed into the cost‑benefit analysis (CBA) module.

The IA openly acknowledges the uncertainty, expressed by stakeholders, in terms of being able to 'derive a modal shift potential linked to the ability to see all offerings on an MDMS platform and the ability to book all visible travel options on an MDMS platform', as there have been few similar initiatives that could allow lessons to be deduced (p. 37). The IA includes a sensitivity analysis carried out on the maximum modal shift potential (IA, pp. 37, 67‑70).

While the data sources are generally well‑referenced, some clarification in relation to the supporting study would have been helpful, as the study is cited in different ways. It is mostly referred to throughout the IA as 'Ricardo et al. (2026), study supporting the RMB and RTR impact assessment', but also as 'Ricardo et al. (2026), study supporting the MDMS and SDBTR impact assessment' (p. 6), and 'Ricardo et al. (2026), impact assessment study'. As these are not hyperlinked and due references not provided, it is unclear whether the IA is referring to one or more studies. Moreover, it is not obvious from the IA whether the supporting study or studies are publicly available, which further weakens transparency.

Follow‑up to the Commission Regulatory Scrutiny Board opinion

The Regulatory Scrutiny Board (RSB) issued a negative opinion on the draft IA on 13 September 2023, due to significant weaknesses in the draft IA. On 13 April 2026, the RSB gave a positive opinion with reservations on the revised draft IA. While recognising improvements, it still flagged some significant shortcomings, stressing the need to clarify the scope of the initiative and the magnitude of the problems. It also called for consideration of methodological limitations, further assessment of the proportionality of the preferred option and the impact on competition, and distribution of costs and benefits between market actors.

As requested in the BRG, in Annex 1 (pp. 75‑85) the IA explains how the RSB's feedback was considered in the revised IA. Although an effort appears to have been made to address the RSB's comments, the scale of P1 could have been discussed in more detail with regard to technological developments (in particular the use of AI). It is, however, difficult to ascertain all the improvements made to the revised version of the IA, as the previous draft IA is not publicly available.

Coherence between the Commission's legislative proposal and the IA

The legislative proposals follow the IA's approach. The proposal on multimodal booking introduces an additional measure which would oblige MDMS providers (B2C and B2B) to rank the transport products or combinations thereof based on defined criteria (Article 7).