EUROPEAN COMMISSION

Brussels, 13.5.2026

SWD(2026) 300 final

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT REPORT

Accompanying the documents

Proposal for a
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
on multimodal booking and repealing Regulation (EC) No 80/2009

Proposal for a



REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL



on rail ticketing

{COM(2026) 231 final} - {COM(2026) 232 final} - {SEC(2026) 300 final} - {SWD(2026) 301 final}

Table of Contents

Glossary

1.Introduction: Political and legal context

1.1.Political context

1.2.Legal context

1.3.Synergies with other EU policy instruments

1.4.Evaluation of the Regulation on a Code of Conduct for CRS

2.Problem definition

2.1.What are the problems?

2.2.What are the problem drivers?

2.3.How likely is the problem to persist?

3.Why should the EU act?

3.1.Legal basis

3.2.Subsidiarity: Necessity of EU action

3.3.Subsidiarity: Added value of EU action

4.Objectives: What is to be achieved?

4.1.General objective

4.2.Specific objectives

5.What are the available policy options?

5.1.What is the baseline from which options are assessed?

5.2.Description of the policy measures and policy options

6.What are the impacts of the policy options?

6.1.Economic impacts

6.2.Social impacts

6.3.Environmental impacts

6.4.Summary of the economic, social and environmental impacts

7.How do the options compare?

7.1.Effectiveness

7.2.Efficiency

7.3.Coherence

7.4.Subsidiarity and proportionality

7.5.Summary of the effectiveness, efficiency, coherence, subsidiarity and proportionality

7.6.Sensitivity analysis

8.Preferred option

8.1.Identification of the preferred policy option and stakeholder views

8.2.REFIT (simplification and improved efficiency)

8.3.Application of the ‘one in, one out’ approach

9.How will actual impacts be monitored and evaluated

Annex 1: Procedural information    

Annex 2: Stakeholder consultation (Synopsis report)    

Annex 3: Who is affected and how?    

Annex 4: Analytical methods    

Annex 5: Competitiveness check    

Annex 6: SME Check    

Annex 7: Discarded policy measures    

Annex 8: Retained policy measures    

Annex 9: Background on the Code of Conduct on Computerised Reservation Systems and air market    

Annex 10: Links between conclusions of the ex-post evaluation of the CRS Code of Conduct and the impact assessment    

Annex 11: Decisions and rulings concerning anti-competitive practices on rail ticket distribution    

Annex 12: Monitoring and evaluation    

Annex 13: Detailed assessment of impact on competition    

Glossary

1.Introduction: Political and legal context

This Impact Assessment (IA) accompanies two new legislative proposals seeking to improve the functioning of the online ticket distribution market for passenger transport in the EU and foster the availability of single tickets in rail.

The RMB proposal includes the repeal of Regulation (EC) No 80/2009 on a Code of Conduct for Computerised Reservation Systems (‘CRS Code of Conduct’ 1 ) whilst updating and integrating the provisions that remain relevant.

These initiatives are needed because, as highlighted in the political guidelines for the European Commission 2024−2029 2 , it is currently difficult for travellers to find, compare, combine and book tickets for regional and long-distance journeys in the EU 3 . This becomes significantly more difficult when combining offers from multiple operators and is particularly challenging in the case of cross-border train travel, which limits the attractiveness of rail for such journeys. A 2024 Eurobarometer survey on ticketing 4  showed that a third of all respondents have never booked a multimodal journey (e.g. combining trains, planes or coaches), and over a third of respondents who booked such journeys reported difficulties in doing so. Barriers included the inability to find a suitable combination, lack of information on where to search for such offers and not being able to buy all the tickets in one place. According to the survey these barriers were higher for journeys involving multiple railway undertakings. Another major concern for rail passengers is that they often do not enjoy passenger rights when their journey involves different RUs. While the passenger rights dimension falls outside the scope of this IA, since it does not concern ticket distribution and is addressed through a targeted revision of the Rail Passenger Rights Regulation, which will ensure that tickets purchased in a single transaction on one platform are treated as “single tickets”, thereby granting passengers full rights for the entire journey. This targeted revision is supported by an analytical Staff Working Document which updates the assessment of impacts from 2017 of the related policy measure. To maximise the effectiveness of both initiatives, SDBTR will ensure that RUs cannot withhold platforms from combining their tickets into “single tickets”. These complementary initiatives are all expected to strengthen passenger confidence and help unlock the potential for a modal shift towards rail.

1.1.Political context

These initiatives aim to promote a more multimodal and sustainable transport system and contribute to Sustainable Development Goals SDG#3 (“Ensure healthy lives and promote wellbeing for all at all ages”), SDG#9 (“Make cities and human settlements inclusive, safe, resilient and sustainable”), SDG#13 (“Climate Action”). The European Green Deal 5 sets a goal of reducing transport-related greenhouse gas emissions by 90% by 2050, compared to 1990 levels, and the Sustainable and Smart Mobility Strategy (SSMS) refers to simpler multimodal ticketing and possible regulatory action on multimodal digital mobility services (MDMS), together with an initiative on ticketing, including rail ticketing (Action 37) as supporting actions to achieve this ambition 6 .

After four legislative railway packages, the Single European Rail Area has been opened to competition, resulting in a more diverse, improved and more affordable offer to passengers 7 . In 2024, passenger rail km grew by 5.8%, driven by strong consumer demand and the launch of new services, including by new entrants. However, whilst significant progress has been made on other fundamental elements of the Single European Railway Area, such as common infrastructure development, improved interoperability and capacity management, rail ticketing remains a significant structural weakness. The digital revolution in retail, experienced in other sectors (hotels, flights) has not materialised for rail. Incumbent companies act as gatekeepers, who operate the vast majority of services while also owning the established ticket platforms. They can leverage incumbency to disadvantage competing platforms by sharing data and offers selectively and exclude competing operators by refusing to sell their tickets on the main platform. This situation limits price transparency and makes new operators commercially invisible, undermining the business case for new rail services that would drive affordability and induce a modal shift. For new operators, ticket distribution is key to reaching customers.

Directive 2012/34/EU 8 recognised the importance of market-developed common information and through-ticketing systems 9 , which should be interoperable and non-discriminatory and enable passengers to plan journeys and book tickets across the EU. Improving rail ticketing is also highlighted as a priority in the Communication on connecting Europe through high-speed rail 10 and the Action plan to boost long-distance and cross-border passenger rail 11 .

The Council also underlines digitalisation as a key driving force to EU transport competitiveness and stresses that multimodality depends on interoperable travel information, ticketing and payment systems 12 . The Letta Report on the Future of the Single Market 13 highlights that “to facilitate new entrants' access to service facilities and ensure fair competition in the railway sector, especially in relation to ticket vending, there is a pressing need for an EU-wide, integrated, multimodal information, ticketing, and payment services framework. In that field, significant advancements in developing interoperable and non-discriminatory sector-led initiatives are still ongoing, while a conducive regulatory environment for such services is still lacking”. The Draghi Report on the Future of European Competitiveness 14  also states that “market barriers remain for new entrants who in some cases face high track access charges and difficulties in accessing equipment and ticketing systems. This weakens the ability of providers to scale up and operate across borders”.

1.2.Legal context

Article 102 of the Treaty on the Functioning of the European Union (TFEU) prohibits abuse of dominance. In line with this provision, the Commission, as well as national courts and competition authorities across the EU, have investigated online ticket distribution practices, in particular in the rail sector, such as restricting access to ticketing data, and imposing unreasonable fees and technical requirements to third-party platforms. The large number of cases shows that the issue is systemic and further outlines the necessity of an EU-wide regulatory intervention. Member States have also adopted legislation to support the development of MDMS.

1.3.Synergies with other EU policy instruments

Digital Transport policies: The ITS Directive 22  establishes a framework for the deployment of Intelligent Transport Systems in the road sector and its interfaces with other modes of transport. Under the Delegated Regulation on multimodal travel information services (MMTIS) 23  Member States must establish national access points constituting a single point of access for data users to the static, historic, observed and dynamic travel and traffic data of different transport modes, for the purpose of providing multimodal travel information services. Developing MDMS platforms capable of reservations, bookings, or ticketing however requires additional data (e.g. real-time fares).

Under the rail interoperability Directive (EU) 2016/797 24 , the Commission developed functional and technical specifications for telematics applications (TEL TSI) 25  supporting the interoperability of data sharing in rail transport.

Horizontal data policies: To complement the general principles of the Digital Markets Act 26 in relation to MDMS platforms, sectorial measures are considered in the RMB proposal. These ensure that they do not impose general conditions that would be unfair or lead to discrimination. They complement the rules of the DMA applying to gatekeepers as MDMS platforms fall below the DMA’s thresholds. The RMB proposal is also complementary to the Digital Services Act 27 (DSA) provisions as it also supports a safe, predictable, and trusted online environment. The Data Act 28 (DA) has synergies with the RMB proposal, through harmonised rules on data sharing including rules on Business to Government (B2G) data sharing and rules on unfair contractual agreement terms. In addition, the rules on Artificial Intelligence 29 complement the RMB proposal by establishing rules on AI systems used by MDMS platforms, ensuring safety, transparency, and respect of fundamental rights. 

Commercial practices policies: The revised Directive on Unfair Commercial Practices prohibits undisclosed advertising and paid promotion for higher ranking of products within search results on MDMS 30 . The RMB proposal complements these acts with measures that ensure that search results on MDMS platforms are displayed in a neutral way (setting out a list of mandatory ranking criteria and indicating which criterion was used for display), prohibit self-preferencing and paid prominence, allowing advertised content only under certain conditions.

Passenger rights policy: The recast Regulation on rail passengers’ rights and obligations 31  entered into force in June 2021 and applies from June 2023. It replaces the initial EU rules in the domain that applied since 2009. The Regulation improves real-time travel information, introduces data-sharing rules for operators and third parties (including ticket vendors and other RU) when they have an agreement, adds a self-rerouting right, and requires RU under the same ownership to offer through-tickets. A targeted revision of this Regulation is being undertaken in parallel to this initiative to increase rights for rail passengers holding a single ticket for a single journey with multiple RUs, booked on a single platform in a single transaction. SDBTR complements this revision by creating the conditions for rail travellers to book these single tickets. The Commission adopted a proposal in 2023 for passenger rights in the context of multimodal journeys 32 that puts forward rules to ensure the protection of passengers when switching between different transport modes. It proposes that passengers with single contracts for a multimodal journey should be assisted in the event of travel disruptions and suggests a specific liability regime for intermediaries who combine separate tickets into a multimodal journey that the passenger buys from them in a single transaction.

Other initiatives: The CountEmissions EU 33  and Flight Emission Label 34  initiatives set out a common framework to calculate and report transport-related greenhouse gas emissions. Transparent information applied across modes will enable passengers to choose the most sustainable options for their trips. The Transition Pathway for Tourism 35 sets up a common European data space for tourism with the objectives to facilitate stakeholder cooperation and to encourage the active sharing of tourism-related data including mobility data. The Report from the Commission to the Council on the implementation of the European Tourism Agenda 2030 36  mentions multimodality as a key enabler of competitiveness in the sector.

1.4.Evaluation of the Regulation on a Code of Conduct for CRS

A particular type of MDMS, active in the business-to-business (B2B) segment, are the Computerised Reservation Systems (CRSs) 37 . These were created by airlines in the 1960s, to grant travel agents access to air offers. Specific rules were adopted in 1989 38 to avoid risks of anti-competitive behaviour by CRSs. These were later revised in 2009 39 to regulate the business-to-business transactions between the providers of CRSs and air and rail carriers, and travel agents. The CRS Code of Conduct was evaluated in 2020 40 to assess whether, in light of market and technological changes in air B2B ticket distribution, it is still relevant in achieving the objectives of (i) preventing distortion of competition between CRSs owned by parent carriers, and (ii) ensuring fair and effective competition between carriers; and, whether it remains fit for purpose given broader horizontal legislation. The evaluation concluded that the Code has not fully ensured a level playing field for all participating carriers, as regards access to, and use of CRS services, since it did not lead to better balancing of the bargaining power of different-sized air carriers vis-à-vis CRSs. Some carriers expressed concerns about specific clauses in their contracts with CRS providers, reducing the ability of airlines to use alternative booking systems or technology. Moreover, the evaluation concluded that the transparency requirements, in the form of the neutral display, remain important, since travel agents, both offline and online, and travel management companies still heavily rely on CRS data especially for business travel. The evaluation also concluded that specific sectoral treatment of traditional CRS providers may no longer be justified in view of market and technological developments in air ticket distribution (increased internet penetration, the rise of other channels and divestment of airlines from CRSs). More details on the evaluation, and its links with this impact assessment, are presented in Annex 10.

2.Problem definition

2.1.What are the problems?

The problems, problem drivers and consequences identified are presented in  Figure 1 .

Figure 1: Problem tree

This initiative identifies 4 problem drivers and addresses two market failures in online ticket distribution, which are described in more detail in Problem 1: Lack of transparency, unfair conditions, and uneven playing field in the online ticketing market and Problem 2: Incomplete offer of rail tickets on (rail) platforms . These problems have consequences in the operational rail service market and means consumers do not find all travel choices on online platforms. The latter limits their ability to compare and combine travel options and fares, including on their environmental impact. To better understand the magnitude of the consequences on consumers, including the potential for behavioural change and their ability to make more sustainable travel choices, several questions must be considered:

1)Do alternative travel options exist?

2)Are travellers willing to changes their habits?

3)Is travellers’ ability to make alternative choices impaired?

To answer the first question an EU-wide analysis of 100 origin-destination routes (performed in the context of the impact assessment support study 41 ) assessed the level of completeness of information and tickets on B2C MDMS platforms across modes. The routes were selected to represent different levels of (1) attractiveness 42 , (2) traffic intensity and (3) distance, and ensure (4) good geographical balance and (5) matching availability of transport modes with modal split data on EU passenger traffic from Eurostat. The analysis compared the options shown on Omio 43 with a fuller set of possibilities identified through Google Maps (for land and sea) and Google Flight (for air) 44 , and found that multimodal options were available on 76% of the routes, yet today, even though some MDMS platforms show options in different modes, these are rarely combined. In fact, in the analysis 39% of possible rail or coach connections were not visible on the MDMS platform, let alone being combined. This is worse for rail options, which were entirely absent from the MDMS platform in 29% of cases, but visible on at least one rail platform. Looking at coach only 7% of routes had missing connections. Furthermore, for 17% of the routes faster connections existed on operators’ platforms and in 34% of the routes, cheaper connections were available on operator websites, though the latter finding was not sufficiently robust to include in the quantitative analysis as a possible cost saving  45 . The 100 origin-destination analysis illustrates that alternative travel options, including multimodal ones, exist, yet these options are neither displayed nor combined by MDMS platforms. The problem is bigger when looking for options that include more than one RU.

The best way to answer the two remaining questions is to ask travellers directly: a 2024 Eurobarometer survey on Multimodal Digital Mobility Services asked almost 26,000 citizens about their online booking experiences 46 . The Eurobarometer survey was designed to be representative for the EU population. More than three-quarters of respondents reply that environmental impact is important to them when planning a regional or long-distance journey. Nonetheless, while 21% of respondents report that this means they adapt their journey accordingly, 22% find it difficult to change their habits, and another 22% find it difficult to find sustainable alternatives. More specifically, over a third of respondents who have experience with booking multimodal journeys (e.g. combining trains, planes or coaches), report that these journeys are difficult to book 47 and 31% of all respondents have never booked such journeys. The same holds for journeys combining different operators in one mode: more than a third of respondents who intended to book such journeys found them difficult to book 48 and 36% of all respondents have never booked such journeys. When asked why they had never or rarely booked combined journeys, 17% of respondents said they couldn’t find a suitable combination, 5% lacked information, and another 5% could not buy all the tickets in one place. Confirming these results, in the open public consultation (OPC) for this impact assessment, 174 of the 226 respondents highlighted that they had difficulties booking and purchasing tickets combining different modes. The most common issue identified was that they had to visit multiple sites to find the information needed.

Concluding, travellers care about the environmental impact of their journeys and while one fifth already changes their habits today, another fifth finds it difficult to find, or buy, sustainable alternatives. So, what if travellers had the ability to see all (rail) offerings on MDMS platforms and could book all legs of their journeys on a single MDMS platform? Based on the answers from the Eurobarometer related to travellers’ ability or difficulties in booking tickets, we can estimate the magnitude of the consequences for consumers. We start by looking only at respondents which, despite travelling by train in the last two years, indicated they rarely (13.2%) or never (16.9%) combined in one single journey two or more rail legs (connecting trains), operated by different rail operators. Next, we eliminate from that group (30.1% of citizens) all those that indicated they simply did not need to combine two operators on their journey(s), leaving us with 17.3% of citizens. Within that group we look at which reasons were given for not combining two rail operators and find that 8% of citizens either did not know it was possible, did not know where to search for such travel information, could not find a suitable combination or could not buy all tickets they needed in one place.

This means that up to 8% of people experience ticketing issues when trying to book multi-operator rail journeys in a single ticket. This however does not mean that if all ticketing issues were resolved and single tickets were widely available, all travellers experiencing those issues would change their habits and purchase those single tickets. They may still opt for other modes of transport, such as the car. Therefore, we only consider respondents that indicated they could not buy all tickets they needed in one place (1.7%). This group most clearly represents travellers who already knew which tickets they needed, and intended to buy them, but were prevented from doing so by ticketing barriers. Though not all of them would necessarily complete the purchase if the barriers were removed, it is also reasonable to assume that some respondents in the larger group of 8% which experienced ticketing barriers would also buy single tickets if these barriers were removed.

2.1.1.Problem 1: Lack of transparency, unfair conditions, and uneven playing field in the online ticketing market

The growing digitalisation and broad access to internet has changed the online ticketing market for transport services, which is becoming increasingly diversified and includes a wider than ever range of stakeholders, in both the B2C and B2B domains (see  Figure 3 ). Multimodal Digital Mobility Services (MDMS) are platforms providing traffic and travel information (e.g., schedules, tariffs and availability of services) and enabling the distribution of tickets, directly or via re-linking, for two or more transport operators, operating in one or more transport modes. Online distribution channels of transport operators – used exclusively for the distribution of their own transport services 50 without offering third party tickets – are not considered to be in the ‘platform market’ and do not qualify as MDMS within the meaning of this initiative, therefore falling out of its scope. Similarly, online search engines that direct end-users to different types of websites, including but not limited to websites where transport products are sold, do not qualify as MDMS, therefore also falling out of its scope. Finally, multimodal travel information services that provide journey planning to end users, but do not facilitate booking, whether directly or via re-linking (e.g. Google Maps, City Mappers), do not qualify as MDMS.

Figure 3: The online ticketing landscape 51

This diversification creates opportunities to offer better and more tailored services to consumers but also raises issues when a level playing field between all actors is not ensured. The evaluation of the CRS Code of Conduct found that the rise of indirect distribution channels, such as New Content Aggregators (NCAs) that offer similar services as CRSs to travel agents, but without being subject to similar rules, presents a risk of distortion of competition between B2B MDMS platforms. In addition, the platform market has significantly changed and diversified over-time, with a wide range of new type of B2C platforms (see Figure above) that currently do not have to comply with neutral display requirements nor fair treatment of transport operators. These market developments, combined with the blurring boundaries between B2B and B2C distribution, drive the need to (i) update the relevant provisions of the CRS Code of Conduct, and (ii) extend them to alternative business models in all modes.

In the interviews and targeted survey conducted in 2025 in the context of the impact assessment support study, one MDMS, four airlines / airline associations including A4E, one region and three CRS providers raised concerns about uneven regulatory treatment of B2B air ticket intermediation services and its potential risks of distortion of competition. Six airlines and the three CRSs, indicated that, while the Code is still relevant for traditional CRSs, it no longer reflects current market realities, including the growing role of other MDMS platforms (where transport tickets can be booked directly or via a re-linking feature), not subject to neutral display rules 52 . Across all stakeholder groups, 36 of 74 respondents to the targeted survey agreed with the problem as stated 53 , whereas 7 disagreed. The remaining 31 neither agreed nor disagreed (7) or did not know (24). Among MDMS platforms, 13 of 19 respondents agreed (6 Online Travel Agents (OTAs), 2 CRSs, 2 NCAs and others MDMS providers), while 4 disagreed (2 OTAs, 1 rail platform and 1 Meta search engine (MSE)) and 4 did not know (rail platforms). CRS providers agreed, stressing that they face stricter rules despite handling a declining share of ticket sales, while views among NCAs were mixed 54 . Among transport operators, 11 of 31 agreed, while three partially disagreed. Four airlines, including airline associations, called for an update of the Code of Conduct, noting that it predates the rise of NCAs and airline websites and highlighting that OTAs, MSEs and other MDMS platforms playing a role in distribution are not subject to comparable rules. One operator suggested extending core principles – transparency, equal access and fairness – to all MDMS platforms. Among national authorities, 6 of 13 agreed, 1 disagreed, and 6 were neutral or did not know. Other responding stakeholders mostly agreed with the problem and A4E found that the regulation should reflect technological developments and ensure transparent, unbiased consumer access across all transport modes.

Indeed, MDMS platforms may design search algorithms to prioritise certain transport services and relegate competing services to less visible positions, display journey times or prices in a way that makes some services appear more attractive or exclude travel options to promote services for which they receive financial incentives, or which are sold by their parent company. During an interview, an association of airlines expressed concern that OTAs and MSEs (whose business consist of displaying travel information and price of several transport operators to end-users, re-linking them to the websites where they would be able to book their journey) tend to promote operators or products based on commercial interests rather than objective consumer value. Similarly, MDMS platforms (both OTAs and MSEs) do not always display available information on GHG emissions, which would allow users to compare the environmental impact of their travel choice.

In the targeted survey, two medium-sized airline operators raised concerns about major OTAs selectively promoting certain operators or adding non-transparent fees, which misleads consumers and distorts competition. The European Regions Airline Association mentioned that regional airlines in particular struggle to compete fairly due to limited economies of scale and the prioritisation of major carriers by gatekeeping platforms, reducing consumer choice especially for connectivity to peripheral areas in Europe. In this sense, eight stakeholders 55 called for stronger regulation to ensure neutral display obligations, prevent discrimination and mandate transparency in how content is presented on MDMS platforms. Conversely, MDMS platforms detailing their views in the survey pointed out to unfair practices from transport operators leading to distorted information on platforms. An OTA stated that certain airlines “limit the comparability, availability and attractiveness of their services on indirect distribution channels”, which “harms consumer choice and competition.” Another OTA reported that “some operators restrict the information that can be shown on MDMS platforms creating barriers to providing accurate and comprehensive content".

Finally, MDMS platforms, can have such Significant Market Presence (SMP) or strategic position that they become essential gateways to consumers. Access to such platforms is thus crucial for transport operators. When two transport operators compete with similar services (e.g. connections between the same two airports / train stations) and one of them does not have access to the dominant platform for the distribution of such services, then its access to the service market is also restricted. Transport operators, and in particular different sized air carriers, enjoy uneven access to and use of CRSs. Despite the decline in the share of total tickets sold in the EU air ticket market through CRSs - selling approximately 22% of those tickets in 2024 57 , CRSs still hold a strategic position in the air ticket distribution market thanks to the symbiotic relationship between CRSs and traditional travel agents and dynamics such as single homing 58 of travel agents. Partially compensating for the decline in market share from CRSs, sales through non-CRS B2B channels increased from 5% to 9% between 2019 and 2024. As a result, in 2024 B2B MDMS distribution remains relevant at approximately 31% of the overall air tickets sold in the EU. At the same time, 73% of all ticket selling channels are connected through a CRS 59 , which thus continue to occupy a unique position, particularly for small and medium sized airlines which rely on CRSs to effectively reach large travel agents’ networks and be visible for consumers. Between 2019 and 2024, the average CRS’s booking fee reached around EUR 8.4 per flight segment 60 and airlines argue they should be able to withhold certain fares (notably cheapest fares) from these channels when distribution costs exceed the benefits 61 . However, the strategic position could allow CRSs to (i) impose highly restrictive terms and conditions (such as full content parity clauses 62 ) in exchange for lower fees 63 ; (ii) and apply biased display practices, if the current legislation on CRSs were to be repealed. Small airlines are directly and most severely affected by the problem as they do not have the financial ability to develop Direct Connect systems 64  or set-up alternative distribution channels through new content aggregators. This ability, combined with the CRSs’ need to provide a comprehensive offer to remain an attractive partner for travel agents, allows large airlines to negotiate better conditions. Despite that, CRSs hold a strong position in the business travel segment 65 and in the long-haul leisure travel segment in EU markets outside the operators’ home market, as well as extra EU markets which makes all airlines still dependent from CRS in these segments.

In the targeted survey, the surveyed transport operators agreeing with the potential distortion of competition between CRSs and non-regulated B2B platforms performing similar functions to CRSs included 11 airlines / airline associations, alleging “the exploitative practices by dominant CRS providers” 66 . One airline’s association and eight airlines argue that removing safeguard provisions such as fair treatment could expose airlines, in particular smaller ones, to discriminatory practices. One operator mentioned that regional airlines in particular struggle to compete fairly, due to the prioritisation of major carriers by MDMS, reducing consumer choice especially for connectivity to peripheral areas in Europe. One airline association, eight airlines out of 11 and BEUC (the European Consumer Organisation) raised concerns over full content parity clauses 67 , which may reinforce the market power of established CRS and MDMS platforms. On the contrary, the three main CRS providers disagreed with Problem 1 outlining that they viewed access decisions as commercially rational rather than discriminatory 68 , with difficulties arising from operator behaviour withholding content or market structure rather than MDMS practices. One MDMS provider added that if it costs too much to connect or there isn’t enough customer demand, they may not add a transport offer. 9 out of 20 MDMS providers, including two associations, highlighted that the real challenge lies in gaining access to operator information.

2.1.2.Problem 2: Incomplete offer of rail tickets on (rail) platforms

All incumbent RUs (except in PL, see Error! Not a valid bookmark self-reference. ) have Significant Market Presence (SMP) in the national transport service market, i.e. a market share above 50% in terms of passenger kilometres. All of them also have one or more digital ticket sales channels, 19 of which are MDMS platforms as they also sell tickets of other RUs or operators in other modes, while only 6 sell their own tickets and are greyed out in the chart. The platforms owned by incumbent RUs have a very large customer base and are the standard reference for rail ticket customers. National competition authorities and economic studies consistently show that the vast majority of consumer searches and online ticket sales are concentrated on the RUs with SMP’s proprietary digital channels (websites and mobile applications), while third-party ticketing platforms account for only a limited share of transactions 69 . For example, the 2021 report of the Monopolkommission 70  shows that among major online platforms for long-distance rail tickets in Germany, about 90% of website visits go to Bahn.de, indicating DB’s dominant position in online distribution markets 71 . This renders the incumbent platforms an indispensable distribution channel for any rail operator offering transport services in the respective national market. This is particularly the case of platforms that sell tickets of multiple RUs, as customers may not realise that their offer is incomplete and are thus less likely to make alternative searches. On the other hand, when it is clear for customers that they must look elsewhere to access tickets of competing RUs, they are more likely to use competitors’ or independent platforms. Accordingly, in the rest of this document, the ticketing platforms owned by incumbent RUs (the 19 in blue in Figure 4) are referred to as ‘indispensable RU platforms’, but not when they do not sell third party tickets (the 6 in grey in Figure 4).

Figure 4: Incumbent market share (in terms of pkm) in the passenger service market per Member State (2022)

Source: Rail market monitoring (RMMS), July 2025

Indispensable RU platforms often display only the offer of certain train services, excluding competing offers despite those services being cheaper or more convenient for passengers. The exclusion of competing RUs or other transport operators may also arise due to stringent integration requirements or high service fees 72 . Evidence supports the concern of uneven access: the French transport authority (ART) found 73  that new entrants receive no visibility on incumbent rail platforms, which mainly display the incumbent’s own services and those of its partners. For example, SNCF Connect does not display the offers of Trenitalia France. Similar issues have been identified in Sweden in 2019, the Swedish Competition Authority examined allegations that Statens Järnvägar (SJ) abused its dominant position in ticketing by excluding competitors’ tickets and altering search visibility (see Annex 11). The large customer base, incomplete offer and lack of transparency of indispensable RU platforms leads to many consumers not being aware of relevant offers: the 2025 FNAUT Opinion Way survey 74 shows that in France, despite over four years of operations, 55% of respondents have never heard of Trenitalia and only 15% of respondents know it well. Similarly, 68% of respondents have never heard of Renfe and just 11% know it well.

The targeted survey conducted in 2025, in the context of the impact assessment support study, revealed opposing views between independent MDMS platforms and indispensable RU platforms, and other stakeholders on whether they agree with problem 2 75 . Most independent MDMS platforms that responded to the survey (14 of 20) disagreed with problem 2, as did most indispensable RU platforms that replied (4 of 5) 76 , outlining that their business model relies on offering a broad range of content and that any absence of operators results from restrictive or economically unviable contractual terms imposed by those operators, or, in rare cases, concerns about service quality. By contrast, only 8 of 31 transport operators – of which 4 own an indispensable RU platform – disagreed with Problem 2 77 in the targeted survey, while 16 agreed 78 . In addition, 8 out of 13 national authorities that replied confirmed that some transport operators face uneven access to platforms. Similarly, 7 out of 11 NGOs and consumer organisations surveyed agreed, noting that platforms owned by railway incumbents dominate national markets and often restrict competitor access 79 .

MDMS platforms willing to sell do not have access to all (rail) offers

Passengers struggle to find and compare alternatives offered by RUs and are often unable to book their entire journey through a single platform. The 2024 Eurobarometer survey on Multimodal Digital Mobility Services shows that ticketing barriers are higher for rail journeys involving multiple RUs: 23% of respondents could not find a suitable combination, 11% did not know how to find information and 9% could not buy all tickets in one place. The higher barriers to finding single ticket journeys involving different RUs makes rail less accessible and attractive for passengers and limits its potential to contribute to a more sustainable and multimodal transport system. It is therefore essential that platforms have access to tickets that RUs might not have an interest in sharing, but that are necessary to establish a critical mass of travel offers, in view of the number and scope of these connections and/or the lack of alternatives. This is the case of rail tickets for services provided by a RU that has a very large market share in a geographical area (see  Figure 5 ) 80 or under a Public Service Obligation (PSO) contract 81 as well as in the case of cross-border services 82 . Accordingly, in the rest of this document, operators of these services are referred to as “indispensable RUs”.

Figure 5: Market share of rail operators in 2022

Source: Rail market monitoring (RMMS), July 2025

A 2021 study conducted by St. Pölten University of Applied Sciences 83 examined the bookability of international rail journeys and found that approximately one third of customers fail to successfully purchase international train tickets. The study involved 76 participants who attempted 46 European routes on 20 ticketing platforms. Rail bookings failed ten times more often than flights and generally took 15-30 minutes to complete, compared to 5-10 minutes for flights.

In 2024, UFC Que Choisir compared train ticket offers on seven booking platforms in France 84 and eleven RU platforms across the EU 85 , analysing 24 routes 86 . No platform showed all available train options. Even the most complete platforms, such as SNCF Connect and Trainline, lacked key international alternatives such as Trenitalia and ÖBB night trains. Availability, prices, and key details such as class differences or discounts varied widely and were often unclear until late in the booking process. Price differences for the same journey could exceed 85%, and inconsistencies were also observed between platforms of partner RUs, such as SNCF and Deutsche Bahn on the Paris-Frankfurt line.

A T&E study from 2025 compared special rail fares offered by RUs platforms and those available on independent MDMS platforms in four Member States. It showed that operator-specific promotional fares are often not accessible on third-party platforms, resulting in significantly higher prices for passengers who book outside the operators’ own websites. The analysis covered routes in the Netherlands, Belgium, Denmark and Italy and found substantial price differences. In the Netherlands and Belgium, tickets purchased via independent platforms were on average 1.7 to 1.9 times more expensive than the special fares available directly from the railway undertakings. In Denmark, the difference was even more pronounced, with platform prices reaching up to six times the operator’s promotional fare. In Italy, where one special fare was partially available on some platforms, prices were still around 16% higher on platforms that did not provide access to the discounted offer.

A poll conducted by YouGov for the NGO Transport and Environment 87 outlines similar results. The study surveyed 10,514 adults across seven European countries 88 . Overall, 61% of long-distance rail users surveyed faced difficulties while booking tickets. In total, 42% of participants wish to access more travel options on booking platforms, and 45.6% of respondents wish to be able to book a trip easily and combine tickets of different RUs on a single website. In addition, 43% of long-distance rail passengers surveyed state that they would book more rail travel if ticket booking was easier.

In the targeted survey, there was a distinct split in views, with incumbent RUs participating in the survey mostly disagreeing with the above-mentioned problem while there was broad support from respondents in other stakeholder groups 89 . Only six transport operators out of 30 participating in the survey agreed with Problem 2, mostly new entrant RUs, while one large national RU argued that offers should be displayed only if they provide for a positive business case. On the other hand, all 20 independent MDMS platforms responding to the survey agreed with Problem 2 as did all 11 ‘other’ stakeholders (including consumer organisations, NGOs, individual experts). Consumer groups BEUC and EPF (European Passengers’ Federation) highlighted issues in international rail travel, as it involves multiple national RUs with different booking systems, data standards, ticketing rules, refund policies, and real-time information protocols. Among national authorities, 10 out of 13 responding to the survey agreed with the problem.

2.2.What are the problem drivers?

Four problem drivers were identified which are considered exhaustive – addressing them is expected to tackle problems related to competition in the online ticket distribution market and foster completeness of the rail offer on MDMS platforms. Nevertheless, it should be acknowledged that the objectives of promoting multimodality and modal shift are also linked to other challenges, particularly those concerning infrastructure use and development, interoperability, as well as passenger rights. These issues are being addressed through other initiatives, for example, the 2023 proposal on the use of railway infrastructure capacity in the SERA 90 , and infrastructure development under TEN-T 91 , while data exchange and standardisation have been addressed through the functional and technical specifications for telematics applications (TEL TSI) 92 .

2.2.1.Problem Driver 1: Regulatory framework no longer fit for purpose due to market and technological changes in air ticket distribution (PD1)

This problem driver links to Problem 1 and reflects market and technological developments in air ticket distribution since the 1980s, when the first Code of Conduct was adopted. At the time, air ticket distribution was dominated by CRSs, whereas today it is a multi-pronged sector. The rise of sales through direct distribution channels (by 4 percentage points from 2019 to 2024) is driven by increased internet penetration, enabling EU consumers to book more easily via airline websites 93 and indirectly through MSEs or OTAs. The rise of direct connect systems (DCs) and NCAs is due to other technological and market developments 94 (see Annex 9).

Concerns arising from airline ownership of CRS providers was the original driving force behind the first CRS Code of Conduct. In the current market situation, with no airlines having a controlling right in B2B MDMSs, provisions of the Code of Conduct relating to parent carriers are no longer relevant. The cross-sectoral EU acquis in other areas has also changed the legal landscape. New regulatory horizontal frameworks of the digital economy have been introduced across the EU rendering some of the provisions of the CRS Code of Conduct redundant and/or creating problems of coherence. These include Platform to Business Regulation (P2B) 95  (and related guidelines) and changes to EU competition law (e.g. the revision of Vertical Agreements Block Exemption Regulation and Vertical Guidelines 96 ). As regards the processing, access and storage of personal data, the GDPR 97 is directly applicable and covers most of the issues currently regulated in Article 11 of the Code 98 . Beyond this, the legislation on P2B contains an obligation for OTAs to be transparent about the parameters they use to rank offers. This applies in all situations, whereas under the Code, travel agents are obliged to use a neutral display, which goes beyond the P2B transparency obligations 99 .

At the same time, technological and market developments have led to the emergence of new and alternative business models both in B2B and B2C sectors. In the B2B sector, NCAs are taking an increasingly important place in the market. Their growth can be explained in part by the technology they use, which gives airlines greater flexibility compared to CRS 100 and by the restrictive nature of CRS arrangements (such as parity clauses) 101 . This has led to the emergence of platforms that perform similar functionalities but are not subject to the Code of Conduct, including on neutral display obligations and related rules and thus benefit from fewer compliance burdens. This uneven playing field may discourage investment in technological advancement among CRS providers and hinder their ability to compete on equal terms. On the other hand, travel agents and Travel Management Company (TMCs) may be disincentivised from innovating their distribution tools if this would result in the loss of incentives. This diverging regulatory environment may reduce incentives to modernise distribution and delay the emergence of innovations.

In the targeted survey, in which stakeholders have been asked to indicate to which extent this problem driver sufficiently identifies the causes of Problem 1 102 , 26 of 65 agreed, 11 stakeholders partially disagreed and 28 stakeholders neither agreed nor disagreed (3) or did not know (25). 13 of 18 MDMS platforms surveyed agreed, while 5 did not know. In relation to transport operators expressing a view, 11 out of 27 partially disagreed with problem driver 1 identifying the causes of Problem 1, while 2 out of 27 agreed. Moreover, 14 out of 27 transport operators surveyed neither agreed nor disagreed (1) or did not know (13). The large number of ‘don’t know’ can be explained by many transport operators expressing a view not being in the air sector. 7 airlines and 3 airlines associations recognised the importance of the CRS Code of Conduct, stating this plays a vital role in protecting airlines from discriminatory practices by CRSs. Many stakeholders surveyed nonetheless stated that the Code of Conduct needs to be revised to extend it further to reflect recent technological developments in distribution 103 . 

2.2.2.Problem Driver 2: Commercial incentives of MDMS platforms to promote certain operators or products (PD2)

This problem driver links to Problem 1. MDMS platforms do not always act as neutral intermediaries, and their display is often influenced by commercial agreements in which operators pay for prominence. This is the case not only for indispensable MDMS platforms but also for smaller ones like for NCAs and B2C MDMS platforms (such as OTAs and MSEs) which are not currently subject to the CRS Code of Conduct or to similar requirements to offers displaying in an unbiased manner.

Firstly, these platforms tend to favour high-volume operators, creating more profitable partnerships, reducing technical complexity and boosting revenues. As one-stop shops for searching, comparing, and booking travel (especially flights) they can influence consumer choices. With no rules governing how results are displayed, information may be incomplete or ranking algorithms biased, giving an advantage to operators who pay higher commissions or have preferential agreements, despite rules on unfair commercial practices (as outlined in section 1.2). Cheaper, more convenient, or complex options may be ranked lower or excluded, potentially misleading consumers into thinking the displayed options are the best available when alternatives exist. This risk has further developed with the increasing use of AI, as algorithmic bias could further skew results toward certain transport modes or operators, and the lack of transparency in AI-driven rankings may undermine consumer trust, particularly if commercial partnerships influence outcomes, with dynamic pricing and personalised offers that risk exploiting users through opaque or discriminatory fare structures. In the context of the study supporting the evaluation of the CRS Code of Conduct 104 , some stakeholders have reported concerns about MSE engaging in unfair competition and promoting options to certain websites and carriers to the detriment of others. A key issue is the perceived bias stemming from paid prominence or from their affiliation with controlling OTAs, which may distort fair market conditions 105 .

Most stakeholders who participated in the targeted survey agreed problem driver 2 sufficiently identifies the causes linked to the problems identified 106 , including 18 of 31 transport operators 107 . Surveyed MDMS platforms and RUs with SMP expressed stronger levels of disagreement 108 . 9 out of 11 national authorities and 8 out of 11 ‘other’ stakeholders who participated in the survey also viewed problem driver 2 as significant. However, the consumer organisation EPF stressed that the real issue lies in operator SMP and the restrictions they impose in contractual agreements rather than in commercial bias of independent MDMS platforms. 13 MDMS platforms stated that problem driver 2 was an issue that mainly arises in the context of vertically integrated platforms, where there is a clear incentive for self-preferencing, linking back to problem driver 4 109 .

The second aspect of the problem driver involves the difficulties associated with sharing data with public authorities and the display of GHG emissions on MDMS platforms. Many MDMS platforms consider that sharing data with public authorities is sensitive due to perceived competition (when public authorities have set up their own MDMS platforms), and data privacy issues. In addition, MDMS platforms may lack commercial incentives to show GHG emissions, as those might disadvantage higher-emission options of carriers with whom they have good commercial relationships. This represents a missed opportunity for transport planners and infrastructure management authorities to use already existing data to improve the overall performance of the transport system. In interviews, most stakeholders underscored the importance of raising passenger awareness regarding the environmental impact of their travel choices. MDMS platforms mostly highlighted barriers in displaying GHG emissions linked to barriers in obtaining accurate and homogenized data 110 . Counterbalancing this, rail operators have increasingly sought to demonstrate their environmental efficiency, yet CER stressed how this effectiveness is dependent on presenting emissions in a broader multimodal context, thereby allowing passengers to weigh options appropriately.

2.2.3.Problem Driver 3: Imbalanced commercial relationships between indispensable MDMS and transport operators (PD3)

This problem driver links to Problem 1. MDMS platforms with a strategic position or significant presence in a distribution market can impose restrictive commercial terms harming competition and limiting transport operators’ ability to access and use indispensable MDMS platforms.

Among MDMS, CRSs are intermediaries connecting airlines with hundreds of thousands of travel agents, TMCs and OTAs worldwide. CRS providers offer financial incentives, proprietary technology, and free training to their subscribers (travel agents), which strongly encourages travel agents to remain loyal to the CRS (single homing).  111  Switching to another CRS would be costly, technically complex, and offer little benefit since all CRSs typically offer the same content due to parity clauses 112 . Switching to new content aggregators would be even more cumbersome as it would imply losing these benefits and incur the costs of switching to a new technical standard. This ecosystem makes CRSs an unavoidable commercial partner for all air carriers, travel agents and TMCs and in practice, airlines are often forced to conclude agreements with every major CRS to tap into their large networks (see Annex 9 for further details).

Between 2019 and 2024, travel agents (including OTAs) utilising CRS platforms accounted for 45% of the total revenues for air trips inside the European Economic Area (EEA), 70% for trips with one leg departing from or arriving in the EEA and 85% for trips outside the EEA, respectively 113 . While the limited integration of new B2B content aggregators, such as AirGateway, Duffel, Hitchhiker, Travelfusion, Verteil with TMC systems currently constrains their reach, they are already connecting more airlines using a new connectivity standard 114 , are increasing their market share and are emerging as competitive alternatives to CRSs, which calls to extend to them the retained rules from the CRS Code of Conduct, despite their market share. These NCAs are the new gateways to travel agents and ultimately to consumers, thus creating a strategic market position that may allow them to restrict access to transport operators, in particular smaller transport operators.

In the B2C sector, MDMS platforms with SMP are also essential gateways to travellers. This is most obvious in the rail sector with indispensable RU platforms who have inherited quasi-monopolistic positions in the operational sector with strong brand recognition for distribution. Such practices lead to limited rail booking possibilities: the 2025 T&E study 115 shows that on the EU’s 30 busiest aviation routes under 1500 km, the rail alternative is in 20% of cases not bookable at all and in 27% of cases bookable only on one RU platform. 

During the targeted survey across stakeholders participating, 36 out of 72 agreed that problem driver 3 leads to uneven access of operators on indispensable MDMS platforms 116 , 23 disagreed. Six were neutral and seven did not know. Most stakeholder groups surveyed agreed with problem driver 3, except MDMS platforms expressing a view, where 13 of 20 disagreed. Among transport operators surveyed, 17 out of 30 agreed and six disagreed. 9 out of 12 national authorities surveyed and 5 out of 10 ‘other’ stakeholders surveyed agreed. MDMS platforms expressing a view tend to reject problem driver 3, expressing disagreement in both the survey and during interviews 117 . Nonetheless a majority of stakeholders from all stakeholder groups agreed that problem driver 3 leads to limited and distorted information on MDMS platforms 118 . Indeed, 13 of 19 MDMS agreed, as well as 16 of 31 transport operators, 9 of 11 national authorities and 8 of 11 ‘others’. 

2.2.4.Problem Driver 4: Vertical integration of railway undertakings and rail ticketing platforms hinders wider ticket distribution (PD4)

This problem driver is specific to the rail sector and is the cause of Problem 2, that is the lack of a complete offer of rail tickets on rail platforms and on MDMS in general. Most incumbent RUs have inherited SMP in both the transport service and the ticket distribution market and can leverage their strength in one market to maintain a strong position in the other 119 . In other words, they can weaken the position of competing platforms by denying them access to their transport offer and can harm competitors in the transport market by denying them presence on their ticketing platform. With progressive market opening, new-entrant RUs are expanding their offer in the Union but lack fair access to indispensable RU platforms 120 . For the reasons explained above, the latter do not necessarily behave like independent platforms seeking to provide the broadest range of travel offers but often have an interest in not giving visibility to their direct competitors in the transport services market, thereby forcing new entrants to rely on alternative channels, incur higher entry costs and creating a significant barrier for smaller and new RUs 121 . The refusal of vertically integrated platforms to grant access to new RUs, coupled with the refusal of incumbent RUs to share their full offer with independent platforms, is thus the key driver limiting the development of the ticketing market in rail. The existence of this problem driver is evidenced by the competition cases listed in Annex 11.

Limited willingness of indispensable RUs to provide their full offer on fair terms to MDMS platforms

In many cases, incumbent RUs have their own vertically integrated platform (e.g. DB Navigator and SNCF Connect) which already provides a very large customer base and competes with third-party platforms. For RUs with SMP, avoiding direct comparison with emerging competitors, on any platform, also helps them to retain a strong position in the transport market. As a result, incumbent RUs have little interest in providing their full offer to other distribution channels, since they have little to gain in terms of additional customer base and much to lose in strengthening a competing platform. For Public Service Obligation (PSO) 122 operators, who, depending on the contract structure, are less sensitive to market demands, there is also less incentive to have their tickets displayed and sold on third-party MDMS platforms. Finally, it is observed that some RUs running cross-border services (e.g. Paris – Brussels) share with third-party platforms only high-value tickets for those services, since passenger segments that are not reached through their own distribution channels, such as international travellers, are typically expected to generate only marginal additional sales.

This reluctance to share rail ticketing content, or to share it on fair terms, has triggered competition law enforcement at both EU and national level. In June 2023, the German competition authority found that Deutsche Bahn had abused its market power vis-à-vis mobility platforms and ordered it to provide platforms real-time passenger service data, remove restrictive contractual clauses, and ensure fair compensation for third-party ticket sales, subject to further legal proceedings.

The targeted survey confirmed the relevance of the limited willingness of incumbent RUs to provide their full offer on fair terms to MDMS platforms, as a majority of stakeholders surveyed agreed (39 of 74) 123 . By contrast, only 4 of 31 transport operators participating in the survey agreed, mainly new entrant RUs, while all large RUs with significant market presence ‘fully’ disagreed 124 . Of the respondents in the ‘others’ category (including consumer organisations, NGOs and independent experts) 10 of 11 agreed 125 as well as 8 of 12 national authorities. Among independent MDMS platforms, 17 of 20 respondents agreed. 13 independent MDMS platforms and their industry associations 126 stressed that dominant or incumbent transport operators often restrict access to full content or impose unfair terms, citing practices such as withholding low fares, applying penalties linked to look-to-book ratios, or offering very low commissions. In addition, five MDMS platforms and associations noted that both dominant RUs and major air carriers actively shape ticket distribution markets to favour direct sales.

Limited willingness of incumbent RUs to host their competitors’ offer on their platforms

Vertical integration also allows RUs to protect their position in the market for rail transport services by refusing competing RUs access to the indispensable ticketing platform they own. They may also choose to include only competitor’s services they consider complementary to their own and exclude directly competing service offerings. This is evidenced by the competition cases quoted in Annex 11.

During interviews in the context of the impact assessment support study, independent MDMS providers, new entrant RUs, national authorities, consumer organisations and NGOS 128 largely agree with the limited willingness of indispensable RU platforms to host their competitors’ offer. Two industry associations and one NGO 129 confirmed that this situation creates great barriers to entry for competitors on the rail market, and the EPF qualified in interview this behaviour as protectionist and anti-consumer. On the other hand, four of five RUs with SMP, including their industry association, disagreed with this driver, and stressed the importance of keeping their freedom to make their own commercial agreements, to help ensure good service on their platforms and clear responsibilities. Three RUs with SMP, including their industry association 130 denied limited willingness to fairly display competitors’ offers and assured that they aim to show all options fairly. Overall, in the targeted survey, 38 of 70 stakeholders agreed that this driver leads to limited and distorted information. Transport operators are the only stakeholder group with a majority of respondents opposing this driver with 17 of 30 disagreeing, although all three new entrant RUs interviewed agreed, expressing concerns regarding their lack of access to indispensable RUs 131 . 

2.3.How likely is the problem to persist?

2.3.1.Problem 1: Lack of transparency, unfair conditions, and uneven playing field in the online ticketing market

An uneven playing field in the online ticketing market is expected to persist. This is also the view of 42 of 66 stakeholders surveyed, who believed problem 1 to either remain (16) or deteriorate (26) over time. While some Member States have introduced rules to regulate how transport operators integrate into MDMS platforms, these frameworks differ significantly, leading to regulatory fragmentation. As a result, inconsistent or missing national frameworks will continue to limit EU-wide service coverage and make it harder for MDMS providers to enter the market. Without specific safeguards against abuses of market power, particularly in the rail sector, access conditions to indispensable platforms are unlikely to improve. In B2B distribution, CRSs are expected to remain indispensable, especially in air transport, and uneven access is likely to continue. Despite growing use of alternative channels, airlines and travel agents still rely heavily on CRSs. Smaller carriers may continue to face competitive disadvantages with no clear indication that access conditions will improve for them without further regulatory action 132 . Without further EU level intervention, distortion of competition between regulated and non-regulated B2B channels is likely to persist. This view was shared by 29 of 66 stakeholders in the targeted survey, who either believe the problem to remain (7) or deteriorate (22) over time. There is no strong indication that the gradual shift toward non-CRS ticket distribution, including NCAs, will reverse. Large airline groups are expected to continue promoting direct bookings and non-CRS aggregators, potentially further reducing the share of bookings covered by the CRS Code of Conduct. Nonetheless, for smaller carriers, CRSs will remain an important tool to achieve visibility and compete with the larger carriers. For large airline groups, CRSs will remain important to reach the corporate segments and leisure travellers in markets where the airline’s brand is not well known. 

2.3.2.Problem 2: Incomplete offer of rail tickets on (rail) platforms

Without EU level action addressing the underlying drivers, the problem is expected to persist. Overall, in the targeted survey, 44 of 67 stakeholders expect Problem 2 to remain (20) or deteriorate (24) over time. Some MDMS platforms may expand their coverage, but only when clear business opportunities exist and if transport operators are willing to cooperate. RUs with SMP dominate operations and distribution and have little incentive to open their platforms to competing transport operators and supply their ticketing offer to competing platforms. This is unlikely to change in the medium term, given the observed pace of market development since the introduction of competition in domestic rail markets 133 . As a result, indispensable RU platforms are unlikely to provide consumers a comprehensive overview of rail journeys. While some long-distance rail services may gradually appear on independent MDMS platforms, this will not address Problem 2 until these platforms reach a significant market share, which is also unlikely in the medium term 134 . Until that happens, new entrants that rely on those platforms will face limited visibility and sales.

3.Why should the EU act?

3.1.Legal basis

Title VI (Articles 90-100) of the TFEU establishes the EU’s prerogative to make provisions for the Common Transport Policy.

3.2.Subsidiarity: Necessity of EU action

Although some challenges in online ticket distribution and digital access to rail tickets are being addressed nationally or regionally, their cross-border impact on long-distance intra-EU travel requires an EU-wide approach to ensure the smooth operation of the European transport system. Discrepancies between Member States in implementing new rules for online ticket distribution could further fragment the market, raise costs and reduce benefits for MDMS platforms, authorities, operators and transport users. EU-level intervention is needed to prevent divergent strategies with unintended effects.

3.3.Subsidiarity: Added value of EU action

This initiative will enable end users and, in the case of B2B services, subscribers to benefit from a greater choice of tickets, displayed in a fair and transparent way, across transport operators and modes, in particular for rail. This should in turn improve the functioning of the internal market, through a smoother and more coherent booking experience for passengers, and support the EU's objective of economic, social and territorial cohesion. Action at EU level with horizontal rules would support a better functioning of the online ticket distribution market, removing obstacles for operators and platforms, and enhancing the attractiveness of rail which in turn would support EU level objectives of greening the transport sector.

EU level action for B2B ticket distribution would continue to promote a level playing field in the sector. The 2020 ex-post evaluation of the CRS Code of Conduct concluded that the EU level is the right level for such intervention, compared to national and international intervention. This is due to the multi-national nature of both CRS providers and aviation services. If regulated at the national level, CRS providers would need to adapt to a multitude of regulatory regimes with negative impacts on efficiency. In addition, the risk of “rule shopping” would result in fragmentation of the EU single market. At the international level, the International Civil Aviation Organisation (ICAO) has adopted a non-binding CRS Code of Conduct. However, the EU CRS Code of Conduct is binding, making it more effective and adding value compared to the Member States adopting the ICAO code.

4.Objectives: What is to be achieved?

4.1.General objective

The first general objective is to enhance the attractiveness of rail, by making more of the existing offers easily available on online ticketing platforms and fostering combinations of those products, also for multi-operator journeys, into single tickets. This is expected to encourage modal shift and thereby contribute to the Green Deal objectives. The second general objective of these initiatives is to support a better functioning of the online ticket distribution market (both B2B and B2C), contributing to the competitiveness and functioning of the transport services market. This would in turn enhance the ability of passengers to compare, access, and book tickets within and across modes, promoting collective transport and promoting multimodal trips. The initiatives also support the two key priorities for the transport system described in the Sustainable and Smart Mobility Strategy: decarbonisation and digitalisation of the EU transport sector. They contribute towards SDG#3 (“Ensure healthy lives and promote wellbeing for all at all ages”), SDG#9 (“Make cities and human settlements inclusive, safe, resilient and sustainable”) and SDG#13 (“Climate Action”) by promoting a more multimodal and sustainable transport system.

4.2.Specific objectives

The two specific objectives (SOs) and their correspondence with the problem drivers, as well as the general objectives, are presented in Figure 6 . 

Figure 6: Correspondence between the specific objectives and the problem drivers

SO1: Improve transparency and establish a level playing field for transport operators in terms of access and use of indispensable MDMS. This specific objective links to problem drivers 1, 2 and 3. This initiative aims to ensure that indispensable MDMS, which serve as key gateways for ticket sale, do not create bias or restrict access to transport operators (in all modes) by imposing unfair conditions. In doing so, it seeks to create a level playing field where transport operators can compete fairly in the national, EU and international markets. Moreover, the objective is for MDMS platforms to offer clear, accurate, and unbiased information on available routes, fares, and ticketing conditions across the EU, enabling end-users to easily find and compare various travel options when planning and booking multimodal or multi-operator journeys. This objective is aligned with the SSMS goals to improve the competitiveness of the EU transport sector and on “making connected and automated multimodal mobility a reality”. Success will be defined by a measurable increase in number of agreements between transport operators and MDMS platforms indicating a better functioning of the distribution markets (B2B and B2C). Moreover, success will also be defined as a decrease of the average expenditure per person for interurban mobility, due to an increase in competition resulting from better access and use of indispensable MDMS for transport operators.

SO2: Improve completeness of rail offer on MDMS platforms, including indispensable RU platforms. This specific objective links to problem driver 4. This initiative aims to ensure that rail offers are fully and fairly displayed on MDMS platforms, including on indispensable RU platforms. To achieve that, it aims to remove practices where indispensable RU platforms exclude, deprioritise or apply discriminatory conditions to rail services not operated by the RU that owns them, even when such alternatives may offer better prices, faster connections, or greater convenience for passengers. By doing so, the initiative intends to remove market distortion and enhance fair competition in the railway services market and thereby facilitating seamless access to multi-operator and cross-border rail journey options for end-users. The initiative also aims to ensure RU do not withhold their offer from MDMS platforms to maintain the dominant position of their in-house ticket distribution platform. Success will be defined by a measurable increase in the transport activity by rail due to better visibility and access to these services. This is a meaningful indicator of passengers’ ability to find, compare, and purchase rail tickets.

5.What are the available policy options?

5.1.What is the baseline from which options are assessed?

In line with the Better Regulation toolbox (Tool #60), the baseline has been designed to include the initiatives of the ‘Fit for 55’ package 135 and the amendment of the European Climate Law to include a 2040 climate target for the EU 136 , of reducing the EU's net greenhouse gas emissions by 90% by 2040 relative to 1990, with a limited contribution towards the 2040 target of high-quality international credits. It also reflects the CO2 emission performance standards for heavy-duty vehicles 137 , the Euro 7 standards 138 , the revised TEN-T Regulation 139 , as well as the initiatives part of the Greening Freight package 140 and Roadworthiness package 141 . It also reflects the National Energy and Climate Plans prepared by the Member States under the Regulation 2018/1999 on the Governance of the Energy Union and Climate Action and submitted to the Commission during 2024-2025. The baseline scenario assumes no further EU level intervention beyond the ITS Directive 142 and the Delegated Regulation on multimodal travel information services (MMTIS) 143 . The CRS Code of Conduct 144 would continue to apply. More details on the baseline scenario assumptions and results are provided in Annex 4 (section 2). The baseline also incorporates perspectives on potential future developments captured in the 2022 Strategic Foresight Report 145 and during a foresight workshop organised by DG MOVE and JRC on 10 February 2025, analysing the impacts of the megatrends and drivers of change on the EU transport sector 146 . In particular, the projected transport activity draws on the long-term population projections from Eurostat and GDP growth from the Ageing Report 2024 147 . An increasingly connected world with high levels of access to digital products and services and in which new services, business models, life and work patterns emerge is the background against which the initiative is assessed.

The total number of passengers in the EU travelling by air, coach (excluding local and suburban public transport), rail and waterborne transport is projected to grow from 12.9 billion in 2019 to 14 billion in 2028, 15.4 billion in 2030 and 17.8 billion in 2050 (19% increase for 2019-2030 and 38.1% increase for 2019-2050), following the recovery from the COVID pandemic. The number of multimodal passengers is projected to increase from 91 million in 2019 to 91.6 million in 2028, reaching 94.4 million in 2030 and 130.8 million in 2050 in the baseline scenario. The air-rail passengers represent over 60% of the total multimodal passengers, air-coach passengers above 30%, while the share of rail-coach passengers is limited to around 1% of the total number of multimodal passengers.

The growing digitalisation of transport services and the emergence of new business models for ticket distribution is expected to lead to an increase in the number of MDMS platforms over time. The number of MDMS platforms is projected to increase from 364 in 2025 to 369 in 2030, and 421 in 2050 in the baseline scenario. The number of agreements between MDMS platforms and transport operators is also expected to increase, from 48,624 in 2025 to 49,321 in 2030, and 56,295 in 2050. The total number of passenger tickets sold via MDMS platforms is projected to increase from 433 million in 2019 to 520 million in 2030 and 854 million by 2050. However, their share in the total number of tickets sold is projected to remain limited in the baseline scenario (7.1% in 2030 and 10.1% in 2050). The share of rail tickets sold via independent MDMS platforms was estimated at around 3% of the total rail tickets sold in 2019 at EU level. In the baseline scenario, this is projected to go up to 4.1% in 2030 and 7.3% in 2050. This corresponds to around 65 million rail tickets sold via MDMS platforms in 2019, increasing to 111 million in 2030 and 230 million in 2050 due the increase in the MDMS market share and of the total number of rail tickets sold.

Building on evidence collected from stakeholders, different trends are identified for air tickets sold via B2B platforms and for those sold via B2C platforms. A larger share of tickets will be sold through B2C MDMS, and B2B new content aggregators and the market share of low-cost carriers, which rely less on CRSs, is expected to continue increasing. This is expected to further erode the share of CRSs in ticket distribution, despite the growing number of passengers travelling by air, decreasing from 30.1% in 2019 to 16.8% in 2030 and remaining stable at that level afterwards. This corresponds to 155 million air tickets sold via CRS platforms in 2019, going down to roughly 91 million in 2030 and increasing to 108 million in 2050 due to the growing number of passengers travelling by air.

The share of tickets sold through B2B new content aggregators is projected to increase from 5% in 2019 to 13.4% in 2030 and remaining stable at that level afterwards, partially offsetting the decrease in the share of tickets sold through CRSs. This corresponds to 26 million air tickets sold via non-CRS content aggregators in 2019, going up to 73 million in 2030 and 86 million in 2050. Thus, the total share of ticket sold through B2B platforms (CRSs and new content aggregators) is projected to decrease from 35.1% in 2019 to 31.1% in 2024 and 30.2% in 2030 and remaining stable afterwards. This corresponds to 181 million tickets sold via MDMS platforms in 2019, 164 million in 2030 and 194 million in 2050.

On the other hand, the share of air tickets sold via B2C platforms is projected to slightly increase from 18% in 2019 to 18.9% in 2030 of the total air tickets sold and remain stable over time. The number of air tickets sold via B2C platforms is projected to increase from around 93 million in 2019, to 103 million in 2030 and 122 million by 2050. The share of coach tickets sold via MDMS platforms was 2.5% in 2019 at EU level. The share is projected to go up to 3.5% in 2030 and 6.6% in 2050 indicating a somewhat slower ramp up compared to that of rail transport. The number of coach tickets sold via MDMS platforms in 2019 was estimated at around 84 million, increasing to 126 million in 2030 and 273 million in 2050 due the increase in the MDMS market share and of the total number of coach tickets sold. The share of waterborne tickets sold via MDMS platforms was about 2.5% in 2019, with a projected increase to 3.4% by 2030 and 6.7% in 2050 at EU level. This corresponds to around 11 million tickets sold via MDMS platforms in 2019, increasing to 16 million in 2030 and 35 million in 2050.

Road congestion costs in the baseline scenario would increase by about 18% by 2030 and 34% by 2050, relative to 2015. On the inter-urban network this would be the result of growing transport activity along specific corridors, in particular where these corridors cross urban areas with heavy local traffic. On the other hand, driven by policy in place and the assumed implementation of the Roadworthiness package, the number of fatalities is expected to decrease by 25% by 2030, relative to 2015 (36% decrease by 2050) and the number of injuries by 23% by 2030 (32% reduction for 2015-2050). CO2 emissions from passenger transport are projected to be 27% lower by 2030 compared to 2015, and 96% lower by 2050. The baseline scenario shows that the emission reductions from the passenger transport sector would contribute towards the ambition of at least 55% emission reductions by 2030 and climate neutrality by 2050, while relying to a significant extent on technological solutions (i.e., the uptake of low- and zero-emission vehicles and of renewable and low carbon fuels) and carbon pricing. NOx emissions are projected to go down by 56% between 2015 and 2030 (94% by 2050), mainly driven by the electrification of the road transport. The decline in particulate matter (PM2.5) would be slightly lower by 2030 at 34% relative to 2015 (89% by 2050).

5.2.Description of the policy measures and policy options

A comprehensive list of policy measures was established after extensive consultations with stakeholders, expert meetings, independent research and the Commission’s own analysis. This list was screened based on the likely effectiveness, efficiency and proportionality of the proposed measures in relation to the objectives, as well as their legal and technical feasibility.

5.2.1.Discarded policy measures

Several policy measures that were considered during the IA process were discarded. More details on the discarded policy measures and the reasons for discarding them are set out in Annex 7.

5.2.2.Retained policy measures 

To understand the scope of the most stringent policy measures, the identification of indispensable MDMS platforms and indispensable RUs is described below.

Indispensable RUs are RUs that operate: 1) PSO services, 2) cross-border services, or 3) more than 50% of total rail services in a Member State, measured in annual passenger-kilometres, including both domestic and cross-border services. In Commission's practice on assessment of significant market power for the purposes of ex ante regulation 148 , and by analogy with the case law concerning dominance 149 , it has been considered that a very large market share held by an undertaking for some time – more than 50% – is in itself, save in exceptional circumstances, evidence of the existence of a dominant position. The higher the market share and the longer the period over which it is held, the more likely it is that it constitutes an important preliminary indication of significant market presence (SMP) 150 .

Indispensable RU platforms are the main sales channel for most rail customers and account for a large share of rail ticket distribution. A RU platform is considered indispensable if it is owned by a RU which (i) operates more than 50% of total rail services in a Member State, as a structural link exists between the RU’s strong positions in passenger rail transport and its ability to leverage this position into the downstream market for online rail ticket distribution, making the platform an essential gateway for consumers and other RUs and (ii) it already distributes tickets of at least one other RU (as explained in 2.1.2 and illustrated in All incumbent RUs (except in PL, see Error! Not a valid bookmark self-reference. ) have Significant Market Presence (SMP) in the national transport service market, i.e. a market share above 50% in terms of passenger kilometres. All of them also have one or more digital ticket sales channels, 19 of which are MDMS platforms as they also sell tickets of other RUs or operators in other modes, while only 6 sell their own tickets and are greyed out in the chart. The platforms owned by incumbent RUs have a very large customer base and are the standard reference for rail ticket customers. National competition authorities and economic studies consistently show that the vast majority of consumer searches and online ticket sales are concentrated on the RUs with SMP’s proprietary digital channels (websites and mobile applications), while third-party ticketing platforms account for only a limited share of transactions. For example, the 2021 report of the Monopolkommission   shows that among major online platforms for long-distance rail tickets in Germany, about 90% of website visits go to Bahn.de, indicating DB’s dominant position in online distribution markets. This renders the incumbent platforms an indispensable distribution channel for any rail operator offering transport services in the respective national market. This is particularly the case of platforms that sell tickets of multiple RUs, as customers may not realise that their offer is incomplete and are thus less likely to make alternative searches. On the other hand, when it is clear for customers that they must look elsewhere to access tickets of competing RUs, they are more likely to use competitors’ or independent platforms. Accordingly, in the rest of this document, the ticketing platforms owned by incumbent RUs (the 19 in blue in Figure 4) are referred to as ‘indispensable RU platforms’, but not when they do not sell third party tickets (the 6 in grey in Figure 4).

Figure 4 ). Indispensable RU platforms are thus a sub-category of indispensable MDMS platforms. Given their vertical integration with a RU with SMP, their identification can be simplified, reducing administrative burden on RUs. As they are also subject to specific obligations, they are presented as a separate category. 

Figure 7: Overview of indispensable MDMS platforms

Indispensable MDMS platforms include (i) B2C MDMS with Significant Market Presence (SMP) and (ii) B2B MDMS, including CRSs and NCAs, which are all essential gateways to (travel agents and ultimately to) consumers. In the B2C distribution market, an MDMS platform is considered as having SMP if it controls at least 10% of the EU market or 30% of a national market, based on either the total value or volume of tickets sold in any one transport mode. For MSE, they are considered as having SMP if they have a share of 10% or more of EU traffic. In selecting the thresholds, an assessment identified which platforms might be affected by different policy options. The EU-level threshold measures a platform's influence across various Member States, reflecting national market diversity. This is complemented by national thresholds which reflects significant influence within a single Member State, indicating a capacity to impact consumer choice in that country. Finally, the application of thresholds based on the total value and number of tickets sold enables the identification of platforms with varying market dynamics, capturing both platforms selling large volumes of tickets and generating substantial revenues. Overall, this method ensures a balanced assessment of platforms' influence, aligning with regulatory standards and facilitating targeted policy measures across diverse transport modes. It also allows for an objective and easy measurement of indispensability.

A more detailed description of the policy measures in Table 1 is provided in Annex 8. SMEs are not subject to any of the policy measures listed below. 

Table 1: Retained policy measures

Note: * PM stands for the number of the policy measure; ** PD stands for the problem driver that the policy measure addresses.

5.2.3.Description of the policy options

The 15 policy measures were grouped into four policy options. PM1 to PM12 are common to all options and focus on requirements ensuring fair treatment of information and data on MDMS platforms, alongside rules for commercial agreements between indispensable MDMS and transport operators. The more stringent rules, notably the obligation to share, host or unbundle drive the ambition level of the policy options and set them apart (see Table 2 ).

Table 2: Overview of the policy options and their links with the specific objectives

Policy option 1 – Facilitating integration

PO1 is a minimalistic approach that targets both specific objectives. A first set of policy measures that are common to all four policy options (PM1 to PM8), includes measures that establish minimal requirements ensuring fair treatment of information and data on MDMS platforms. It also sets out key principles framing all commercial agreements between indispensable MDMS platforms and transport operators, as well as between indispensable RUs and MDMS platforms.

This option fully addresses SO1, by establishing a level playing field for MDMS and transport operators through the extension of the CRS Code of Conduct’s rules to all MDMS providers (PM1, PM2, PM3, PM4 and PM5). With all MDMS platforms (from both B2B and B2C sectors) subject to these rules, the initiative ensures that transport operators can compete fairly on all platforms and protects their data from being misused. PM9 sets thresholds to identify MDMS platforms and RUs with SMP, which would be designated by national enforcement bodies or the European Commission (EC) depending on the market in which they have SMP (PM10). These are needed for PM11, which sets rules that protects transport operators in their commercial agreements with indispensable MDMS platforms, including provisions that (1) safeguard commercially sensitive data of operators, (2) prohibit the inclusion of unjustified or unnecessary contract conditions that could prevent the conclusion of the agreement, and (3) ensure remuneration of platforms is based on objective and transparent criteria (such as quality and level of services, annual volume of transport products distributed, look-to-book ratios, etc). These criteria should be transparently shared with the operator or the National Enforcement Body (NEB) upon request. Member States would be required to appoint a national authority to settle disputes that could arise between parties (PM6) and an EU enforcement network of such authorities would convene each year to ensure consistent enforcement across the EU. Specifically, this EU enforcement network will allow NEBs to exchange information on their (i) monitoring, enforcement and implementation work, (ii) decision-making principles, and (iii) administrative practices. The Commission will participate in discussions, coordinate and support cooperation on matters of common interest and exchange of best practice. PM8 would oblige MDMS platforms to display information on greenhouse gas emissions, when that information is shared by the transport operator, and PM7 obliges B2C MDMS platforms to share data for mobility management with public authorities.

To address SO2, PM12 protects MDMS providers in their commercial agreements with indispensable RU by setting rules on distribution fees and prohibiting restrictive clauses in contracts (exclusivity clauses, unfair and unjustified conditions, marketing clauses and other technical restrictions) allowing to address the imbalances in bargaining power when negotiating commercial agreements.

Feedback was received on stakeholder’s positions on all policy measures and views on PMs common to all policy options (PM1 to PM12) are only presented under PO1. In the targeted survey, stakeholders had mixed views, expecting measures linked to neutral display and fair processing of data as mostly positive / neutral. MDMS platforms surveyed appeared to be the most sceptical group, while most national authorities and the ‘other’ category participating in the survey find those measures effective. Transport operators surveyed did not provide homogenous answers for those PMs. Stakeholders participating in the targeted survey commented mostly on the requirements regarding neutral display (PM1) 151  and on the requirements on GHG emissions (PM8) 152 . These measures were strongly supported by national authorities and the ‘other’ category surveyed, perceived as effective in promoting fair competition, enhancing consumer choice, and improving transparency within the transport sector while sometimes advocating for more stringent rules (the NGO T&E called for mandatory display of GHG emissions on platforms, even when data is not shared by operators). RUs and MDMS platforms active in rail, taking part in the survey and interviews, also supported the introduction of GHG requirements 153 , provided that the data are easily comparable 154 . Three MDMS platforms added that, to be effective, the data must be shared by operators consistently, which remains a challenge. Three national authorities also believed consumers might show limited interest in GHG emissions when making booking decision.

In addition, participants of the OPC for MDMS were asked how important different measures are in their opinion to ensure fair access for all operators to relevant multimodal digital mobility services platforms. The outcome is far more favourable than the stakeholder survey results, especially regarding neutral display with 149 out of 169 respondents indicating that this policy measure is important to ensure fair access for operators. Only 13 respondents found it not important. Moreover, 70 out of 80 respondents from industry indicated it to be important versus only 7 who found it not important. During interviews, the update of the Code of Conduct neutral display rules has been positively perceived by a majority of airlines interviewed, Westbahn and EPF, who viewed it as an effective way to ensure a level playing field and avoid the distortion of information on platforms 155 . By contrast, one airline and one OTA raised in interviews concerns about the relevance and enforceability for B2C platforms, and that imposing neutral display requirements could paradoxically reduce competition by homogenising offerings and eroding the ability of such platforms to differentiate. The prospect of establishing a neutral body to oversee aspects of the MDMS ecosystem (the national body to be appointed under PM6) was supported by stakeholders surveyed, with 36 of 71 finding PM6 effective 156 in the targeted survey. Transport operators appeared to be the most supportive group, with 19 of 29 finding it effective and none finding it ineffective. During interviews, some stakeholders from all stakeholder groups supported the creation of such an entity emphasizing its potential to ensure market fairness, resolve disputes efficiently, and foster cross-border consistency in enforcement and governance 157 . More critically, some indispensable RUs and MDMS platforms questioned the effectiveness or practical utility of such an institution 158 .  

Finally, 31 out of 69 stakeholders surveyed expected PM11 to be effective and 36 expected PM12 have a neutral effect. Overall, MDMS platforms surveyed appeared more sceptical towards PM11 159 whereas transport operators expressing a view questioned rather PM12 160 . Indeed, MDMS platforms participating in the survey tend to question the effectiveness of imposing principles on distribution fees and rules forbidding highly restrictive clauses on them, as they argue they would have no incentive to block access to their platform. However, they stressed their main concerns is big operators’ unwillingness to share information with them on fair terms 161 . On PM11, 15 of 27 of transport operators surveyed expected the measure to be effective in addressing Problem 1, while 2 of 29 expected PM12 to be ineffective. A majority (21 of 29) were neutral/did not know the effect of PM12. In the survey several RUs with SMP 162 including CER members expressed concerns over the introduction of enhanced FRAND principles, especially regarding the regulation of distribution fees. They emphasize that imposing levels of fees defined by regulation could distort the true value of services rendered and overlook the internal costs borne by providers. While these views are acknowledged, it is important to note that PM11 and PM12 do not impose directly levels of fees but rather ensure that the level of fees agreed upon in a commercial agreement are justified and transparent. Eight MDMS platforms/ MDMS industry association and 14 transport operators participated in 2022 to the Multimodal Passenger Mobility Forum (MPMF) to support the Commission in its preparatory work for this initiative. In the MPMF final report, the need to “feature FRAND as a core standard  163 ” for the contractual provisions between MDMS platforms and transport operators is outlined. In particular, the use of FRAND is mentioned as a principle that could “guide points to calculate compensation (…), access to data, (…) look-to-book ratio and marketing restrictions; transparency on terms and conditions 164 .”

Policy option 2 (PO2) – empowering requesting MDMS platforms to offer single tickets in rail

PO2 addresses SO1 in the same manner as PO1 but further addresses SO2 by mandating that indispensable RUs enter into commercial agreements with requesting ticketing platforms to enable the sale of all their tickets, provided that those platforms fulfil minimum requirements (PM13). The scope of this ‘sharing obligation’ is all rail tickets and fares for: i) rail services provided by operators with SMP in the Member State in which they hold significant market presence, ii) rail services provided under public service contract (PSO services); and iii) cross-border rail services. The commercial agreements between indispensable RUs and MDMS platforms would have to follow fair and reasonable conditions, as laid down in PM12. In particular, indispensable RUs cannot prevent their tickets from being combined with tickets from other operators, allowing platforms to sell them as single tickets. Under PO2, MDMS platforms (in particular independent ones) would be capable of expanding their offers and ultimately provide a complete offer.

In the targeted survey, the sharing obligation (PM13) introduced in PO2 gathered support from national authorities and the stakeholders surveyed in ‘other’ category 165 , moderate support from MDMS platforms 166 , and very limited support from transport operators surveyed 167 . Especially, incumbent RUs participating in the targeted survey argued that mutual commercial interest should guide collaboration in distribution rather than mandated access 168 . DB and SJ AB went further, arguing that this measure might create administrative burden and potentially increase ticket prices. On the other hand, ALL Rail argued that a fair market requires both sides to be regulated: RUs must share their data, and ticket vendors must sell all RUs’ tickets. Air France-KLM and Finnair stressed that this measure should not be applied to the air sector, as the air market is already competitive and well-functioning. Finally, 2 MDMS platforms (Skyscanner and EUTT) outlined the need to extend the sharing obligation to air carriers as well.

Policy option 3 (PO3) – empowering requesting RU to be offered on indispensable RU platforms

PO3 addresses SO1 in the same manner as PO1 and PO2, but it further addresses SO2 by mandating that indispensable RU platforms shall enter into agreements with requesting RUs in order to distribute tickets, offered within the same geographical area in which the indispensable RU platform is active, including cross-border services to and from the Member State (PM14). They must apply non-discriminatory and reasonable contract conditions as described in PM11. PO3 would thus foster the completeness of the offer on both independent MDMS and indispensable RU platforms, providing the traveller ample choice on all platforms, including the ones he uses most. This is expected to address SO2 quicker than other policy options. This obligation would not apply to incumbents’ sales channels that only sell tickets of services that they operate directly, as these sales channels do not raise the same user expectations (see section 2.1.2). Requiring such operators to make the necessary IT investments and enter the MDMS market would be unnecessary and disproportionate.

The additional obligation for indispensable RU platforms to host requesting competitors (PM14), as added in PO3, is not consensual amongst stakeholders. In interviews, 12 of 15 stakeholders who provided their views on PM14 viewed that a more cooperative, commercially driven approach is preferable to outright regulatory imposition 169 . Two incumbents and their industry association, alongside an MDMS express fear that PM14 would increase market concentration 170 , and the MDMS industry association ADN Mobilités stated in an interview that full integration of competitors on those platforms would “take years”. On the contrary, the new entrant industry association All Rail views PM14 as a “game changer” to improve effectiveness and enhance the visibility of new entrant RUs in the EU and potentially “doubling the modal shift of rail for long-distance travels”. Air France-KLM and Finnair stressed that this measure should not be applied to the air sector, as the air market is already competitive and well-functioning. In the targeted survey, stakeholders also expressed diverging views. In total, 22 out of 68 stakeholders surveyed expected it to be very (10) or somewhat effective (12). Furthermore, 20 stakeholders surveyed expected it to be very ineffective (19) or somewhat ineffective (1). Finally, 26 stakeholders surveyed expressed a neutral view (17) or did not know (9). 15 out of 27 transport operators surveyed believed this obligation would be very ineffective while the MDMS platforms surveyed thought the effect of PM14 would be either neutral (7 out of 20) or ‘very’ ineffective (5 out of 20, of which 2 vertically integrated MDMS). By contrast, 6 out of 11 national authorities surveyed and 6 out of 10 ‘other’ stakeholders surveyed found PM14 to be effective, therefore counterbalancing the position of vertically integrated platforms and operators. OPC participants were asked whether they support an obligation for the integration, on the basis of reasonable terms, of operators willing to be part of an MDMS platform. This corresponds to PM14, but the OPC question was not restricted to indispensable rail platforms and referred to all types of MDMS platforms. In the OPC, 152 out of 168 respondents who expressed an opinion found it important while 6 did not. 77 out of 80 stakeholders from industry expressing a view found it important versus 2 who did not.

Policy option 4 (PO4) – unbundling indispensable RU operators and platforms

PO4 addresses SO1 in the same way as PO2 but further addresses SO2 by mandating indispensable RU platforms to unbundle their distribution services from the parent company’s transport activities (i.e. divesting) (PM15). Removing the vertical integration of the service and ticketing branches would also remove their mutual incentive to protect the strong position of incumbent RUs in the upstream passenger rail market.

Stakeholders participating in the targeted survey appeared to be divided regarding the benefits of unbundling, as 22 out of 69 expected it to be effective 171 , 20 ineffective 172 and 26 were neutral/did not know 173 . Half of transport operators surveyed (15 out of 28) found the measure to be very ineffective, with the notable exception of new entrant RUs. RUs with SMP responding (DB and CER) claimed that unbundling is disruptive and would not bring added value to consumers and would harm functioning of rail services as ticket revenues directly fund them. On the contrary, new entrant RUs surveyed expressed support for this PM, seen as an effective way to ensure that passengers can see all rail options for their journeys, citing positive examples of countries were unbundling in rail is already mandatory. A new entrant also outlined that while unbundling is in theory a very effective measure, it might be complex to implement. Independent MDMS platforms expressed a more nuanced view, 6 out of 20 finding the measure effective, 10 to have a neutral effect/ or did not know 174 and 4 ineffective 175 . 

6.What are the impacts of the policy options?

This section summarises the main expected economic, social and environmental impacts of each policy option. The assessment of impacts draws on multiple data sources, including the targeted stakeholders’ consultation and open public consultation, findings from desk research, a 2024 Eurobarometer survey on ticketing 176 , and the impact assessment support study (including an in-depth analysis of 100 origin-destination (OD) routes) 177 . It builds on the ASTRA model and a Cost Benefit Analysis (CBA) module that is used to calculate the costs and/or benefits of policy measures, aggregate them into options, and compare the costs and benefits of the policy options. The ASTRA model is a well-established model that has been used for numerous impact assessments in the energy, transport and climate action fields for the past 15 years 178 . The ASTRA model is used to estimate the impacts of the policy options on transport activity, CO2 emissions, air pollutant emissions and other external costs of transport, as well as the impacts on user costs 179 .

The policy measures included in all policy options are expected to improve both the completeness and ability to book alternative transport offerings displayed on MDMS platforms. In all policy options, platforms will be required to present available transport options in a fair, transparent, and unbiased manner and incorporate information on GHG emissions for trips where such data are available. Moreover, the range of transport services displayed on MDMS platforms is expected to expand as transport operators will benefit from fairer contractual conditions when negotiating with indispensable MDMS platforms. The availability of rail offers is expected to expand more significantly in PO2, PO3 and PO4, as indispensable RUs that previously shared their services almost exclusively through their platforms will now be visible on third‑party platforms. The visibility and comparability of rail services are expected to improve further with PO3, as additional RUs will acquire a better access to indispensable RUs platforms, considered as key intermediaries for RUs in expanding their consumer reach. Similar to PO3, PO4 will enhance citizens ability to find and book rail offers, as indispensable RUs platforms’ newly acquired independence will allow new entrant RUs to get better access to key rail platforms. As a result, the policy options are expected to enhance the completeness and the ability to book alternative transport offerings displayed on MDMS platforms to varying degrees.

The completeness and the ability to book service offerings is expected in turn to have an impact on modal shift and journey time. In the first step, the maximum potential modal shift and maximum reduction in the journey time that can be achieved due to the completeness and the ability to book service offerings has been determined based on the 2024 Eurobarometer survey on ticketing and the in-depth analysis of 100 origin-destination (OD) routes and have been discussed in an expert workshop and an additional stakeholders’ workshop organised in the context of the impact assessment support study. In particular, the maximum potential modal shift was derived from answers to Q11 of the Eurobarometer survey, capturing stated preferences on change in behaviour among a very large and representative sample of citizens who currently never or rarely combine different operators/ modes of transport due to their inability to purchase all tickets in one place. Since the Eurobarometer was conducted on a statistically representative sample, its results are valid for the whole EU population and therefore is a relatively robust basis. Assumptions based on stated preferences represent a scientifically sound method to capture expected modal shift, especially when no real-life evidence is available based on historical data. The maximum potential modal shift is considered to be a conservative estimate, as it does not capture stated preferences on change in behaviour among individuals who already book such journeys but might do so more frequently in the future, due to the improvement of the ticketing system. In addition, the modal shift linked to the introduction of full passenger rights for rail single tickets is not accounted for in this IA. As a result, the actual impact on modal shift of the proposed measure may outperform what is currently estimated.

In the second step, a suite of ad-hoc tools have been developed in the context of the impact assessment support study, as explained in Annex 4 (section 1.3), to translate the degree to which the policy options are expected to contribute towards the maximum potential modal shift and maximum potential reduction in travel time due to the enhanced completeness and the ability to book alternative transport offerings displayed on MDMS platforms. Both these inputs are further feed into the ASTRA model to derive the overall impacts of the policy options on transport activity, CO2 emissions, air pollutant emissions and other external costs of transport, as well as the impacts on user costs. The stakeholders’ workshop was used to validate the inputs used for the policy options in the ASTRA model. Detailed explanations on all the steps of the approach used are provided in Annex 4 (section 1.3).

It should however be acknowledged that during the expert workshop and the stakeholders’ workshop, participants indicated the difficulty 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, since there have been little relevant applications of similar initiatives that could allow to deduct lessons. Acknowledging the uncertainty, sensitivity analysis has been performed with regard to the maximum modal shift potential due to the completeness and the ability to book service offerings, which is presented in section 7.6.

The changes in transport activity estimated in the policy options are driven by the completeness and the ability to book service offerings displayed on MDMS platforms. The passenger rights dimension falls outside the scope of the analysis, but it is acknowledged that strengthened passenger confidence could support the modal shift towards rail. The targeted revision of rail passenger rights is supported by an analytical Staff Working Document which updates the assessment of impacts of the related policy measure.

The proposed options are assumed to be implemented from 2028 onwards, so the assessment has been undertaken for the 2028-2050 period and covers the EU Member States. Costs and benefits are expressed as present value over the 2028- 2050 period, using a 3% discount rate. All costs and benefits are expressed in 2024 prices. Further details on the methodological approach, together with costs and costs savings results by stakeholder group for specific years and by Member State (where relevant), are provided in Annex 4.

6.1.Economic impacts

This section provides the economic impacts of the policy options on MDMS platforms, transport operators, national authorities and the European Commission. It also provides an assessment of impacts on small and medium enterprises (SMEs), user costs and congestion, competitiveness, functioning of the internal market and competition, innovation, digital by default, tourism and territorial impacts. Details on the calculation of costs by policy measure and policy option, by stakeholder group and Member State 180  are provided in Annex 4 (section 3).

6.1.1.Impacts on MDMS platforms

One-off and recurrent adjustment costs for MDMS platforms. All four policy options are expected to lead to one-off and recurrent adjustment costs for MDMS platforms relative to the baseline (see Table 3 and Table 4  below). PM1 (neutral display), PM2 (equal care for data), PM3 (marketing and booking data sharing), PM7 (data for mobility management) and PM8 (GHG emission data) are common to all POs. Their costs are driven by the number of projected MDMS platforms in each PO (see Table 5 ), the one-off cost per platform for IT development (in PM1 to PM3 and PM8) and for setting up an Application Programming Interface (API) (in PM7), and the recurrent cost per platform for maintaining the IT system, including display criteria and the API. 

Among the common measures the biggest costs stem from the obligation for B2C MDMS to share non-personal data for mobility management with public authorities (PM7) and come from the set-up and maintenance of an API 181 . The total one-off and recurrent costs for PM7 are estimated to be highest in PO2 (EUR 72.6 million, expressed as present value over 2028-2050 relative to the baseline, of which EUR 30 million one-off costs) due to the highest number of platforms projected in this PO, followed by PO4 (EUR 70.8 million, of which EUR 29.1 million one-off costs), PO3 (EUR 69.4 million, of which EUR 28.3 million one-off costs) and PO1 (EUR 52.9 million, of which EUR 20.8 million one-off costs). Other important adjustment costs common to all POs are linked to the neutral display obligations (PM1) and the obligation to display GHG/CO2 emissions when provided by transport operators (PM8). Each of the two measures will result in one-off and recurrent adjustment costs for MDMS platforms, related to the IT development to adjust display criteria and their maintenance, of around EUR 16 to 17 million in PO2, PO3 and PO4 (of which EUR 6.4 to 6.9 million one-off costs), and EUR 12 million in PO1 (of which close to EUR 5 million one-off costs). The costs associated with PM1 are lower for CRS than other MDMS as they must already comply with similar neutral display requirements from the Code of Conduct in the baseline 182 . 

PO3 additionally includes one-off adjustment costs for indispensable RU platforms to enter into commercial agreements with willing RUs (PM14), to enable the distribution of tickets, estimated at EUR 0.4 million expressed as present value over 2028-2050 relative to the baseline. These cover the costs of negotiating new agreements 183 . PO4 leads to significantly higher one-off adjustment costs due to the unbundling obligation (PM15), requiring 19 indispensable RU platforms to undertake an important legal and administrative reorganisation estimated at EUR 157.7 million.

The total one-off and recurrent adjustment costs, expressed as present value over 2028-2050 relative to the baseline, are thus estimated to be highest in PO4 (EUR 282.3 million), followed by PO2 (EUR 127.7 million), PO3 (EUR 122.3 million) and PO1 (EUR 92.9 million). The one-off adjustment costs due to the unbundling obligation (PM15) represent 56% of the total adjustment costs in PO4, while the one-off and recurrent adjustment costs for the set-up and maintenance of the API to share non-personal data for mobility management with public authorities (PM7) represent 57% of the total adjustment costs in PO1, PO2 and PO3 and 25% of the total adjustment costs in PO4.

One-off administrative costs for MDMS platforms. In all POs, MDMS platforms need to notify national authorities and/or the Commission upon reaching the SMP thresholds (PM10). This results in one-off administrative costs borne by MDMS platforms reaching the SMP thresholds. Building on the Impact Assessment of the DMA 184 , the assumption retained for calculating the cost incurred on MDMS platforms is that only two full time equivalents (FTEs) would be needed to comply with the requirement. This is because only one quantitative indicator is requested, and no further qualitative information is asked to support the decision. The administrative burden is kept to the minimum since the designation process leverages on information already submitted through the Rail Market Monitoring Scheme. In this context, RUs must provide information that can support the designation process as MDMS platforms with SMP. Four MDMS platforms are expected to reach the SMP thresholds in 2028 (the assumed year of implementation) and the one-off cost per platform is estimated at EUR 113,053. Thus, for the purpose of ‘one in, one out’ approach and the Calculator of Administrative Costs (AC) & Administrative Burdens (AB), the total one-off administrative costs for MDMS platforms are estimated at EUR 0.5 million relative to the baseline.

Adjustment costs savings for MDMS platforms. In all POs, the introduction of commercial agreement rules for indispensable MDMS platforms (PM11) and indispensable RUs (PM12) with third parties is expected to result in recurrent adjustment cost savings for MDMS platforms as these measures are expected to streamline the negotiation processes 185 . Although PM11 and PM12 are included in all policy options, the cost savings vary significantly between options since they are calculated based on the changes in the number of new and renegotiated commercial agreements compared to the baseline. The number of new and renegotiated commercial agreements in each PO depends in turn on other policy measures included in each option. For PO1 cost savings are estimated at EUR 13 million (EUR 12 million due to PM11 and EUR 1 million due to PM12), expressed as present value over 2028-2050 relative to the baseline, as this PO does not introduce strong incentives for the conclusion of new agreements or for the renegotiation of agreements relative to the baseline. Conversely, PO2 introduces a sharing obligation (PM13), significantly increasing the number of commercial agreements between indispensable RUs and MDMS platforms, resulting in the highest costs savings for MDMS platforms, projected at EUR 149 million (EUR 136.1 million due to PM11 and EUR 12.9 million due to PM12) relative to the baseline. PO3, which additionally includes a hosting obligation (PM14) result in adjustment cost savings of EUR 134 million (EUR 122.3 million due to PM11 and EUR 11.7 million due to PM12) relative to the baseline. The lower costs savings in PO3 are due to the lower number of new and renegotiated agreements relative to PO2. Finally, while the unbundling requirement (PM15) in PO4 does not mandate commercial agreements, the neutrality it fosters on indispensable rail platforms facilitates additional agreements relative to PO3, with cost savings projected to reach EUR 142.7 million (EUR 130.4 million due to PM11 and EUR 12.3 million due to PM12) relative to the baseline.

Net costs/benefits for MDMS platforms. Overall, PO1 and PO4 are expected to lead to net costs, although at varying degrees, while PO2 and PO3 are expected to deliver net benefits. PO4 shows the highest net costs, amounting to EUR 140 million, expressed as present value over 2028-2050 relative to the baseline, primarily due to the significant adjustment costs linked to the unbundling requirement, as outlined previously. In PO1, the adjustment cost savings are not sufficient to offset the adjustment and administrative costs, leading to net costs of EUR 80.4 million relative to the baseline. In PO2, the introduction of a sharing obligation (PM13) leads to the highest adjustment cost savings related to streamlined negotiation processes (PM11 and PM12), resulting in net benefits of EUR 20.9 million relative to the baseline. PO3 also results in net benefits, estimated at EUR 11.3 million relative to the baseline.

Table 3: One-off and recurrent costs, and costs savings for MDMS platforms in the POs relative to the baseline (EU27), expressed as present value over 2028-2050, in million EUR (2024 prices)

Source: Ricardo et al. (2026), Impact assessment support study

Table 4: One-off costs for MDMS platforms in the POs relative to the baseline (EU27), expressed as present value over 2028-2050, in million EUR (2024 prices)

Source: Ricardo et al. (2026), Impact assessment support study

A change in the number of MDMS platforms is not a policy objective. However, the projected number of platforms in each policy option, as well as the number of agreements between the MDMS platforms and the transport operators, are provided below to facilitate the understanding of the costs. The number of platforms is projected to increase in all policy options relative to the baseline due to the enhanced ability of MDMS platforms to display more travel options, promoting competition in the online ticketing market. This is assumed to imply an increase in the number of MDMS platforms although it should be acknowledged that existing platforms could also improve their offerings, which could lead to a consolidation towards a lower number of platforms. Such consolidation is assumed to take place towards 2050 in the projections. However, it should be acknowledged that the consolidation could also take place earlier. Thus, the costs for the MDMS platforms should be regarded as the upper bound.

PO1 is projected to result in the lowest number of additional MDMS platforms relative to the baseline (10 in 2030, 45 in 2040 and 19 in 2050) for all time horizon under assessment. In 2030, the sharing obligation (PM13) provides more opportunities for new platforms than in PO1. The effect is the highest in PO2 relative to the baseline (29 additional platforms in 2030), since in PO3 some platforms would anticipate a broader offer by the incumbents due to the hosting obligation (PM14) and see less margin for an alternative offer and thus new platforms (26 additional platforms relative to the baseline in 2030). The effect in PO4 is between that of PO2 and PO3 (27 additional platforms relative to the baseline in 2030) because the new platforms are expected to perceive the unbundled platform as a less strong competitor, once it is no longer tied to the incumbent rail operators. In 2040, in PO2 the incumbent platforms are expected to continue to show a limited offer, and new platforms would exploit the opportunities that this creates. PO2 thus results in 282 additional platforms relative to the baseline in 2040. In PO3, incumbent platforms provide a full offer, and customers have no reason to switch. The number of new additional platforms is thus expected to be lower than in PO2 (235 additional platforms relative to the baseline in 2040). PO4 sits between PO2 and PO3, since the unbundled platforms are not as strong as the vertically integrated ones and leave more space for the new platform (258 additional platforms relative to the baseline in 2040). By 2050, the market is expected to converge towards the same number of platforms in PO2, PO3 and PO4 (209 additional platforms relative to the baseline). In PO2, the strong competition between platforms is expected to erode the legacy advantage of the incumbents. This creates an intense competition leading to a consolidation of the sector. In PO3 no change is expected relative to 2040, while in PO4 some consolidation also takes place but to a lesser extent than in PO2.

Table 5: Projected number of MDMS platforms across EU27 in the baseline and policy options in 2028, 2030, 2040 and 2050

Source: Ricardo et al. (2026), Impact assessment support study

Similarly, the number of agreements between MDMS platforms and transport operators is projected to increase in all policy options relative to the baseline. As shown in the table below, this increase is expected to be significantly higher in PO2, PO3 and PO4 compared to PO1 (around 5% increase relative to the baseline in 2050 in PO1 against 97% in PO2, PO3 and PO4 – all compared to the baseline). PO2 shows the highest impact in 2030 and 2040 with respectively 20,511 and 66,241 additional agreements relative to the baseline due to the highest number of additional platforms in this policy option relative to the baseline.

Table 6: Projected number of agreements between MDMS platforms and transport operators across EU in the baseline and policy options in 2028, 2030, 2040 and 2050

Source: Ricardo et al. (2026), Impact assessment support study

6.1.2.Impacts on transport operators 

The number of transport operators in the scope of this initiative is provided in Annex 4 (section 2.2.3) and is assumed to remain constant over time in the baseline scenario and across policy options.

One-off adjustment costs for transport operators. PO2, PO3 and PO4 are expected to lead to one-off adjustment costs for transport operators relative to the baseline (see  Table 7 ). These costs are driven by the requirement for RUs to allow the distribution of their tickets (PM13) and calculated based on the projected number of new commercial agreements between MDMS platforms and RUs 186 . PO2 is expected to show the highest number of new agreements and thus also the highest one-off costs expressed as present value over 2028-2050 relative to the baseline (EUR 48.2 million), followed by PO4 (EUR 45.2 million) and PO3 (EUR 42.2 million).  

One-off administrative costs for transport operators. In all policy options, for the purpose of ‘one in, one out’ approach and the Calculator of Administrative Costs (AC) & Administrative Burdens (AB), low one-off administrative costs of EUR 1,356 at EU level are expected for RUs with SMP (see Table 8 ) 187 . These costs relate to informing national authorities about their parent platforms (opened to other RUs) in view of considering them as indispensable RU platforms (PM10).

Adjustment costs savings for transport operators. In all policy options, the introduction of commercial agreement rules for indispensable MDMS platforms (PM11) and indispensable RUs (PM12) with third parties is expected to result in cost savings for transport operators (see Table 7 ) as these measures are expected to streamline negotiation processes 188 . Although PM11 and PM12 are included in all policy options, the cost savings vary significantly between options since they are calculated based on the projected number of new and renegotiated commercial agreements compared to the baseline. As explained in section 6.1.1, the number of new and renegotiated commercial agreements in each PO depends in turn on other policy measures included in each option. For PO1 cost savings are estimated at EUR 13 million (EUR 12 million due to PM11 and EUR 1 million due to PM12), expressed as present value over 2028-2050 relative to the baseline, as this PO does not introduce strong incentives for the conclusion of new agreements or for the renegotiation of agreements. Conversely, PO2 introduces a sharing obligation (PM13), significantly increasing the number of commercial agreements between indispensable RUs and MDMS platforms, resulting in the highest cost savings for transport operators, projected at EUR 149 million (EUR 136.1 million due to PM11 and EUR 12.9 million due to PM12) expressed as present value over 2028-2050 relative to the baseline. PO3 additionally incorporates a hosting obligation (PM14) leading however to lower adjustment cost savings of EUR 134 million (EUR 122.3 million due to PM11 and EUR 11.7 million due to PM12) relative to the baseline. This is because of the lower number of new and renegotiated agreements projected in PO3 relative to PO2. Finally, while the unbundling requirement (PM15) in PO4 does not mandate commercial agreements, the neutrality it fosters on indispensable RU platforms facilitates a higher number of agreements relative PO3, with cost savings projected to reach EUR 142.7 million (EUR 130.4 million due to PM11 and EUR 12.3 million due to PM12) relative to the baseline.

Net benefits for transport operators. All policy options are expected to result in net benefits for transport operators, although to varying degrees (see Table 8 ). PO2 shows the highest net benefits (EUR 100.9 million), expressed as present value over 2028-2050 relative to the baseline, followed by PO4 (EUR 97.6 million) and PO3 (EUR 91.8 million). The highest net benefits in PO2 are because the introduction of a sharing obligation (PM13) considerably increases the adjustment cost savings related to the commercial agreement rules (PM11 and PM12). PO1 results in considerably lower net benefits for transport operators, estimated at EUR 13 million relative to the baseline.

Table 7: One-off costs and costs savings for transport operators in the POs relative to the baseline (EU27), expressed as present value over 2028-2050, in million EUR (2024 prices)

Source: Ricardo et al. (2026), Impact assessment support study

Table 8: One-off costs for transport operators in the POs relative to the baseline (EU27), expressed as present value over 2028-2050, in million EUR (2024 prices)

Source: Ricardo et al. (2026), Impact assessment support study

6.1.3.Impacts on national authorities

Recurrent enforcement costs for national authorities. All policy options are expected to lead to recurrent enforcement costs for national authorities, estimated at EUR 106.5 million, expressed as present value over 2028-2050 relative to the baseline. These costs are driven by PM6 which requires national authorities to monitor the online ticketing market for potential entities with SMP as well as the correct implementation of the legislation (see Table 9 ) 189 . 

One-off and recurrent administrative costs for national authorities. All policy options are expected to lead to recurrent administrative costs for national authorities for settling disputes (PM6). Based on feedback from stakeholders, one FTE is assumed to be needed per national authority. For the purpose of the Calculator of Administrative Costs (AC) & Administrative Burdens (AB), recurrent administrative costs are estimated at EUR 1.53 million per year from 2028 onwards 190 (or EUR 25.8 million expressed as present value over 2028-2050 relative to the baseline). In addition, one-off administrative costs for national authorities are expected in relation to the obligation to process notifications from platforms with SMP and submit this information to the Commission in 2028 (PM10) (see Table 10 ). The one-off effort required is estimated at 2 FTEs per Member State in 2028. The one off-costs for the purpose of the Calculator of Administrative Costs (AC) & Administrative Burdens (AB) are estimated at EUR 3.1 million 191 . Efforts have been made to keep these costs as low as possible, but they remain unavoidable, as they are essential to ensure settling disputes, the processing of notifications from platforms with SMP and the submission of this information to the Commission.

Net costs for national authorities. All policy options include a similar designation and enforcement process and result in net costs of EUR 135.4 million for national authorities, expressed as present value over 2028-2050 relative to the baseline (see Table 9 ). Enforcement costs represent 79% of the total costs in all policy options.

Table 9: One-off and recurrent costs for national authorities in the POs relative to the baseline (EU27), expressed as present value over 2028-2050, in million EUR (2024 prices)

Source: Ricardo et al. (2026), Impact assessment support study

Table 10: One-off costs for national authorities in the POs relative to the baseline (EU27), expressed as present value over 2028-2050, in million EUR (2024 prices)

Source: Ricardo et al. (2026), Impact assessment support study

6.1.4.Impacts on the European Commission 

Recurrent adjustment costs for the European Commission. All policy options lead to recurrent adjustment costs for the European Commission, estimated in total at EUR 5.3 million, expressed as present value over 2028-2050 relative to the baseline (see Table 11 ). These are due to the obligation for the European Commission to designate B2C MDMS platforms with SMP at European level and deal with potential complaints (PM10) 192 , estimated at EUR 4 million, and due to the support for the coordination of enforcement with an EU-wide enforcement network and monitoring of the market (PM6) 193 , estimated at EUR 1.3 million.

Table 11: Recurrent adjustment costs for the European Commission in the POs relative to the baseline (EU27), expressed as present value over 2028-2050, in million EUR (2024 prices)

Source: Ricardo et al. (2026), Impact assessment support study

6.1.5.Impacts on SMEs

The SME check has been performed and is presented in Annex 6. SMEs are not directly affected by any of the policy options and do not incur any cost. However, SME MDMS platforms and SME transport operators are expected to benefit from the introduction of commercial agreement rules for indispensable MDMS platforms (PM11) and indispensable RUs (PM12) in all policy options. These rules will streamline negotiation processes through a more harmonized approach that reduces commercial negotiation efforts and guarantees a fairer access to key offers and platforms. Thus, adjustment costs savings are expected for both SME MDMS platforms and SME transport operators in all policy options.

Adjustment costs savings for SME MDMS platforms. SME MDMS platforms will benefit from adjustment cost savings linked to the introduction of commercial agreement rules (PM11 and PM12) 194 . As explained in section 6.1.1, although PM11 and PM12 are included in all policy options, the cost savings vary between them, since they are calculated based on the projected number of new and renegotiated commercial agreements relative to the baseline. The highest adjustment costs savings, expressed as present value over 2028-2050 relative to the baseline, would be achieved in PO2 (EUR 101 million) due to the synergies with PM13 (obligation to share) that leads to a significantly higher number of new and renegotiated commercial agreements relative to the baseline. PO4 and PO3 also result in significant adjustment costs savings for SME MDMS platforms (EUR 95.7 million in PO4 and EUR 90.5 million in PO3), while PO1 is expected to result in lower costs savings (EUR 9.2 million).  

Table 12: Recurrent adjustment costs savings for SME MDMS platforms in the POs relative to the baseline (EU27), expressed as present value over 2028-2050, in million EUR (2024 prices)

Source: Ricardo et al. (2026), Impact assessment support study

Adjustment costs savings for SME transport operators. As for SME MDMS platforms, in all policy options, SME transport operators will also benefit from the introduction of commercial agreement rules for indispensable MDMS platforms (PM11) and indispensable RUs (PM12). As for SME MDMS platforms, adjustment costs savings for SME transport operators, expressed as present value over 2028-2050 relative to the baseline, are estimates to be the highest in PO2 (EUR 107 million), followed by PO4 (EUR 102.5 million), PO3 (EUR 96.1 million) and PO1 (EUR 9.4 million).

Table 13: Recurrent adjustment costs savings for SME transport operators in the POs relative to the baseline (EU27), expressed as present value over 2028-2050, in million EUR (2024 prices)

Source: Ricardo et al. (2026), Impact assessment support study

Net benefits for SMEs. Total net benefits for SMEs (MDMS platforms and transport operators) are estimated at EUR 208 million in PO2, EUR 198.2 million in PO4, EUR 186.6 million in PO3, and EUR 18.6 million in PO1 expressed as present value over 2028-2050 relative to the baseline. As explain above, the obligations included in the policy options do not apply to SMEs and SMEs are only expected to indirectly benefit from them.

SMEs views were considered via stakeholder consultation activities, including the targeted survey and interviews conducted in the context of the impact assessment support study, and the OPC. Overall, SMEs expressed favourable views on the policy options, with strong support for the introduction of binding rules and the introduction of commercial agreement rules. An overview of SMEs’ views is provided in the SME check, in Annex 6.

6.1.6.Impacts on user costs and congestion 

The proposed policy options are expected to benefit transport users through three channels: (i) a reduction of search costs for travellers; (ii) an increase in competition in the platform market; (iii) an increase in competition in the transport market.

The reduction of search costs for travellers. The most direct effect would be the reduction in search cost, as travellers would be able to find, compare and purchase tickets in a single place without having to perform longer searches and visit multiple platforms. In the baseline scenario, travellers must dedicate time and effort to search for the most convenient offer in terms of fares, comfort and travel time, with no guarantee that they will manage to find the offer that best matches their preferences. Under the various policy options, and to the extent that the measures included in each option will provide customers with a complete ticketing offer in a single place, travellers will most certainly save time on searches, but possibly also gain in terms of travel time and more convenient fares. The assessment below considers them jointly as ‘reduction of search costs’.

This effect would be present in PO1, thanks to neutral display requirements that would make convenient offers more visible to potential customers. However, the impact would be limited, since there are no provisions in this option that have the effect of widening the offer of platforms and guaranteeing that a complete ticketing offer becomes available on single platforms. In PO2, the addition of the ‘sharing obligation’ (PM13) would enable a complete ticketing offer on willing platforms. The effect would thus be stronger than PO1 but still be limited to the customer base of independent platforms, since indispensable RU platforms have shown no willingness to host the full offer of competitors. In PO3, the further addition of the ‘hosting obligation’ (PM14) would make a substantial difference, since now the possibility to access a complete ticketing offer would be extended to the customers of indispensable RU platforms that have by far the largest reach. The reduction in search cost would be highest in this case. In PO4, the unbundling of vertically integrated platforms would remove the perverse incentives to limit their ticketing offer. Accordingly, the magnitude of the reduction in search cost for consumers would be similar to PO3 but it is likely to be achieved with a certain delay due to the need for restructuring processes.

Implications for consumers of increased competition in the platform market. Increased competition in the platform market would lead to greater innovation efforts, widening of services available on platforms, improvements in the overall ticketing experience, and possibly reduction of transaction costs for users. PO1 would not substantially affect competition in the platform market, since, broadly speaking, it will neither affect the content, nor the incentives of platforms, but only the presentation of existing offers. PO2 would have an impact on the content of independent platforms, making them a more attractive distribution channel for consumers. This will improve their position vis à vis the indispensable platforms and increase overall competition in the platform market. The inertia in consumer behaviour might however dampen the effect as many consumers would remain loyal to indispensable platforms. PO3 would oblige indispensable RU platforms to host a complete ticketing offer (PM14). This is likely to reinforce their appeal in the market, but at the same time would deprive them of any possibility of abusing behaviour (by virtue of the common measures included in all options, PM1 to PM12) or denying access to competitors (PM14). This would change the incentives for indispensable platforms, inducing a behaviour that is closer to that of ‘normal’ platforms that seek to maximise market intermediation. This, in turn, might elicit even stronger innovation efforts from competing independent platforms. Indeed, in the baseline, PO1 and, partly, PO2, platforms have near ‘captive’ customers (incumbent operators for the incumbent platforms and new entrants for the independent platforms 195 ) and competition is affected by access limitations to both content and distribution channels. Under PO3, the sharing and hosting obligation provide all operators with full access to tickets and platforms. This is likely to push platforms to compete more strongly on innovation, user experience, customer care and additional services, since they can no longer rely on exclusive content. Similar considerations can be made for PO4, although the impact might take longer to manifest. Altogether, it is expected that PO3 would produce greater benefits for consumers from competition in the platform market, followed by PO4. 

Implications for consumers of increased competition in the transport market. Greater competition in the transport market would tend to lower prices and increase the quality and frequency of transport services. The amount of pressure exercised by competition would be proportional to the number of customers being able to easily find, compare and purchase the most convenient travel offers. PO1 would improve visibility and fair representation of existing offers on online platforms, but it would not broaden their ticketing offer. This would promote competition in the transport market, but not as substantially as the other policy options. PO2 would affect the content of independent platforms, giving them access to indispensable tickets. Customers of independent platforms would therefore be able to compare the offers of different transport operators and opt for the most convenient. Initially, the competitive pressure on the transport market would only be exercised through the customers of independent platforms. However, the effect would become stronger if consumers begin switching to independent platforms attracted by their broader offer. PO3 would oblige indispensable platforms to host a complete ticketing offer (PM14). In this case, nearly all consumers would be able to compare directly the offers of transport operators and buy the most convenient one. As argued in Section 6.1.8 on the functioning of the internal market and on competition, this is likely to lead to stronger price competition between RUs. Accordingly, PO3 would have the largest effect on consumers through competition in the transport market. PO4 is likely to lead to a situation similar to that of PO3, meaning a situation in which indispensable platforms host a complete ticketing offer. However, this outcome is likely to materialise with a certain delay with respect to PO3, due to the necessary restructuring processes.

Overall assessment of impacts on user costs. The policy options are expected to generate significant benefits for consumers by reducing search costs and fostering greater competition in both the platform and transport markets. While the resulting enhanced “trust” in rail as an easy, accessible, modern and reliable user-friendly mode of transport is difficult to the quantify, the most immediate and tangible effect across all options is the reduction of search costs. By enabling travellers to find, compare, and purchase tickets in a single location, the policy options would eliminate the need to conduct lengthy searches across multiple platforms. This simplification of the purchasing process enhances convenience, transparency, and efficiency for consumers.

The overall impact on consumers’ costs would be the strongest, as well as the quickest to materialise, in the case of PO3. PO4 would come second in terms of overall impact and but its effects would unfold more gradually, due to the need to restructure the business of indispensable platforms following unbundling. PO2 would have a more moderate impact, since the cost reduction would be generated by the action of independent platforms that have a smaller customer base, although this would grow in time. Finally, only a negligeable impact on transport cost can be expected to result from PO1, which would change the presentation, but not the scope of the ticketing offer on the platforms.

The table below presents the impacts on average expenditure per person for interurban mobility in the policy options relative to the baseline. It shows that the impacts are highest in PO3 (0.27% reduction in 2040 and 0.34% reduction in 2050 relative to the baseline), followed by PO4 and PO2, while the impacts of PO1 are negligible. These impacts do not consider the reduced search costs for the most convenient offer in terms of fares, comfort and travel time, which are difficult to quantify and thus only assessed qualitatively.

Table 14: Impacts on average expenditure per person for interurban mobility, at EU27 level (% change relative to the baseline)

Source: Ricardo et al. (2026), Impact assessment support study; ASTRA model

The reduction of congestion associated with modal shift. By improving the completeness and accuracy of service information, the ability to book service offerings and travel time, as well as reducing user costs of railway transport, the policy options would also generate, to varying degree, modal shift away from road and aviation. In turn, this would reduce congestion costs associated with road traffic relative to the baseline. The impact on congestion costs of the various policy options mirrors the impact on modal shift, with PO3 having the strongest effect (EUR 6.4 billion congestion costs savings, expressed as present value over 2028-2050 relative to the baseline), followed by PO4 (EUR 4.8 billion congestion costs savings), PO2 (EUR 4.4 billion congestion costs savings) and PO1 (EUR 1.8 billion congestion costs savings) 196 .

Table 15: Impacts on external costs of road congestion in the POs relative to the baseline (EU27), expressed as present value over 2028-2050, in million EUR (2024 prices)

Source: Ricardo et al. (2026), Impact assessment support study; ASTRA model

6.1.7.Impacts on competitiveness

This proposal is a key enabler of Europe’s green competitiveness agenda, directly reinforcing the European Green Deal and the Commission’s 2024-2029 priorities by accelerating a shift towards sustainable transport modes, rail in particular, while strengthening the EU’s economic resilience in an increasingly digital mobility landscape. All policy options deliver improved operational efficiency and increase in the transport activity by rail and coach due to better visibility and access to these services. In particular, PO2, PO3 and PO4, introduce the obligation to share tickets for indispensable RUs (PM13), unlocking new competitive services and sustainable travel alternatives for passengers, directly addressing the market barriers highlighted in the Draghi Report 197 . When coupled with the obligation to neutrally display offers (PM1), these measures will support fairer competition of operators on all MDMS platforms, and especially indispensable RU platforms – a necessity underlined by the Letta Report 198 ’s call for an EU-wide, integrated framework to prevent discriminatory practices in ticket distribution.

Cost competitiveness. The policy options have different impacts on the cost competitiveness of affected businesses. Across all policy options, the common measures increase regulatory clarity and transparency. By extending the CRS Code of Conduct rules, requiring neutral display, ensuring fair data processing and establishing enforcement mechanisms, the initiative reduces legal uncertainty and dispute risk. Streamlined negotiation processes (PM11 and PM12) reduce contractual transaction costs for both MDMS platforms and transport operators in all policy options. Under PO1, the introduction of fair principles improve predictability in commercial negotiations. While agreements remain voluntary, a harmonised framework can reduce inefficient negotiation cycles and lower compliance risks, particularly in cross-border contexts. Under PO2, PO3 and PO4, stronger regulatory obligations increase compliance costs for regulated entities. However, these obligations are expected to improve the completeness and efficiency of integration between operators and platforms. The net effect depends on the balance between compliance costs and efficiency gains (i.e. costs savings).

For MDMS platforms, as explained in section 6.1.1, all policy options are expected to lead to adjustment costs and some limited administrative costs. Total costs, expressed as present value over 2028-2050 relative to the baseline, are estimated to be highest in PO4 (EUR 282.7 million) primarily due to the significant adjustment costs linked to the unbundling requirement, followed by PO2 (EUR 128.1 million), PO3 (EUR 122.7 million) and PO1 (EUR 93.4 million). At the same time, the streamlined negotiation processes (PM11 and PM12) deliver significant adjustment costs savings in PO3, PO4 and PO2 in synergy with other measures included in these options that increase the number of new and renegotiated commercial agreements that benefit of the streamlined processes. Overall, PO2 and PO3 lead to net benefits of EUR 20.9 million and EUR 11.3 million, respectively, expressed as present value over 2028-2050 relative to the baseline. On the other hand, PO4 and PO1 result in net costs (EUR 140 million in PO4 and EUR 80.4 million in PO1).

For transport operators, as explained in section 6.1.2, PO2, PO3 and PO4 are expected to lead to adjustment costs related to the obligation to share and all options are expected to require very limited administrative costs for the designation of indispensable RUs. Total costs, expressed as present value over 2028-2050 relative to the baseline, are estimated to be highest in PO2 (EUR 48.2 million), followed by PO4 (EUR 45.2 million), PO3 (EUR 42.2 million) and PO1 with negligible costs. The streamlined negotiation processes (PM11 and PM12) deliver adjustment costs savings in all policy options that outweigh the costs. Net benefits for transport operators, expressed as present value over 2028-2050 relative to the baseline, are estimated at EUR 100.9 million in PO2, EUR 97.6 million in PO4, EUR 91.8 million in PO3 and are more limited in PO1 (EUR 13 million).

By reducing search and booking frictions and improving the visibility of transport offers, the policy options enhance the efficiency of the rail and multimodal transport sectors, strengthening the competitive position of rail and coach services within the multimodal passenger transport market. Improved integration of rail services in MDMS platforms can increase the attractiveness of rail-based itineraries relative to car-only or aviation trips.

As regards SMEs competitiveness, they would also benefit from better market conditions: creating a level playing field for all stakeholders could be particularly beneficial for small businesses or start-ups. New entrant SMEs in the rail transport market would particularly benefit from the obligation for indispensable RU platforms to enter into commercial agreement with willing RUs (PM14). New entrant RUs face the problem of how to establish their brand and typically must resort to costly advertising campaigns, which can be prohibitive for SMEs. PM14 would allow them to benefit from indispensable RU platforms’ brand visibility and reach immediately the very high share of customers that use those platforms. In PO4, the obligation for indispensable RUs to unbundle their distribution and operation services (PM15) will also provide better visibility and consumer reach to new entrant RUs, albeit to a lesser extent than PM14. Indeed, the complete unbundling process is expected to be complex and would likely require an extended adjustment period. These newly independent platforms would also not be obliged to negotiate with new rail entrants, therefore decreasing slightly the positive impact on SME competitiveness compared to PM14. Finally, the prohibition of restrictive contractual clauses by indispensable RUs and indispensable MDMS platforms and the introduction of fairer distribution fee principles (PM11 and PM12) in all POs would facilitate agreements between platforms and operators, directly targeting gatekeeping behaviour, curbing anti-competitive practices, and enhancing transparency and fairness. This would therefore greatly support smaller MDMSs and operators in concluding contractual agreements with players benefiting from a strategic position in the market.

The analysis shows that all policy options lead to increases in rail and coach activity relative to the baseline (see section 6.1.8), reflecting improved supply-demand matching and reduced transaction costs. The relative magnitude of these increases in activity differs across options, being highest in PO3, followed by PO4 and PO2.

The entire economy is likely to benefit from these developments since transport represents a significant share of household expenditure and is a critical input for many economic sectors, notably tourism. A better functioning of the transport sector would free resources for additional consumption and investment. This might result in knock-on effects throughout the entire economy in the long term, leveraging the initial impact on the transport sector.

International competitiveness. All policy options apply equally to EU and non-EU platforms when operating within the EU market and do not differentiate by nationality. They therefore do not introduce trade distortions. The impact on international competitiveness is expected to be neutral. The economic effects are confined to improving efficiency and performance within the EU passenger transport market.

6.1.8.Impacts on the functioning of the internal market and on competition

All policy options enhance the functioning of the internal market compared to the baseline. They do so by reducing regulatory fragmentation across the EU and promoting a level playing field for ticket distribution in both B2C and B2B markets.

PO1 extends neutral display rules to all B2B actors and introduces rules governing commercial agreements with indispensable B2B and B2C platforms and railway undertakings (RUs), but it does not require any structural changes. Indispensable RUs and platforms would not be obliged to share ticket content or host other RUs, meaning the current market structure would largely remain unchanged. As a result, while PO1 is expected to have a positive impact in promoting a level playing field in B2B distribution, its overall effect would be limited. By focusing on fairness without mandating access, it is unlikely to significantly enhance competition or expand consumer choice. Overall, the measures included in PO1 are projected to lead to 1% increase in rail activity in 2030 and 1.8% increase by 2050 relative to the baseline.

Building on PO1, PO2 introduces a ‘sharing obligation’, requiring indispensable RUs to share their tickets for distribution on willing platforms. Most RUs already sell their tickets through third party platforms, although they do not always provide a complete offer in terms of connections and fares, especially when they reserve some offers for the clients of their vertically integrated platform. The ‘sharing obligation’ would fill this gap by requiring that RUs share their complete offer. This would not alter the business model, whereby RUs normally pay a distribution fee to platforms that sell their tickets, but PO2 would ensure that distribution agreements are concluded on the basis of fair, reasonable and non-discriminatory (FRAND) conditions. It should be noted that RUs would inevitably incur distribution costs whether the service is provided in-house or by a third party. Thanks to greater competition in the platform market, streamlined negotiation processes, and application of FRAND conditions, distribution costs may even decrease for RUs in PO2 relative to the baseline. Accordingly, the sharing obligation would not imply any structural change in business models or market structure, but, by ensuring broader access to the ticket offer, it improves the level playing field in the distribution market. However, a key limitation in PO2 is that indispensable RUs (those covering most rail operations in a Member State) retain significant influence on rail ticket distribution in the short to medium term. They could still restrict other RUs’ access to their own popular distribution channels, undermining competition. The expected impact is stronger than in PO1 as this option directly influences supply, demand, pricing, and competitive dynamics. Overall, the measures included in PO2 are projected to lead to 1.7% increase in rail activity in 2030 and 3.7% increase by 2050 relative to the baseline.

PO3 takes a bolder step by adding a ‘hosting obligation’, compelling indispensable RU platforms to sell tickets of requesting RUs. The result is a guaranteed pathway for new RUs to reach customers through established, high traffic platforms, removing a major barrier to entry. Increased competition, in turn, drives innovation and better pricing. Also in this case, there would not be a change in business models of operators. Indispensable RUs platforms would only be caught by the ‘hosting obligation’ when they have already hosted third party offers, which shows that they have the means, technical expertise and contractual experience to provide such service: the hosting obligation would just ensure that this service is provided on non-discriminatory basis to all requesting RUs, but would not require engaging in a new activity.

There is a hypothetical risk that vertically integrated platforms would seek to avoid regulation by withdrawing from the ‘platform’ market and halting the sale of any other companies’ tickets. This would present the wide customer base of that platform with an even reduced offer. To avoid this, the criterion that will be used to establish whether the platform of a railway undertaking with significant market presence falls under the hosting obligation in PO3 is whether it has sold tickets of other companies in the past five years. There is also a risk that railway undertakings would use cooperation agreements between RUs to evade regulation, claiming that selling these tickets constitutes sale of only their own tickets. To avoid this risk, the sale of tickets for services that are offered in cooperation between two or more RUs (e.g. cross-border services, which are often operated under different RU licenses in different Member States) is considered as sale of tickets of another operator.

While PO3 would not require vertically integrated platforms to provide services to third parties that they had not already offered in the past, the changes in market dynamics would nevertheless be more substantial in PO3 than in PO2. The joint application of the sharing and hosting obligation will potentially provide all platforms with a complete ticketing offer, and as platforms can no longer rely on preferential access to ticket offers, they are expected to compete more vigorously on aspects like journey planning, ease of search and user experience, customer care, and additional services. The railway service market will be impacted to a much greater extent in PO3 than in PO2, since new railway entrants will have access to a much broader set of potential customers. Indeed, the initial impact of the hosting and sharing obligation would be broadly proportional to the respective size of the customer base of the incumbent and independent platforms. PO3 will thus me more effective in strengthening competition in the railway services market and attract more passenger to this mode of transport, providing a net benefit to the whole sector, although some operators may lose the rents that they still profit from in non-competitive markets.

By fundamentally reshaping market dynamics, this approach ensures fair access to indispensable RU platforms, fostering a more open and competitive railway ecosystem and leading to 2.5% increase in rail activity in 2030 and 4.8% increase by 2050 in PO3 relative to the baseline.

PO4 obligates vertically integrated distribution RU platforms to unbundle from their operators, eliminating inherent conflicts of interest. While it does not impose a hosting obligation, breaking these ties aligns incentives with independent platforms, reducing market distortions caused by dominant players favouring their own services. However, the complexity of implementation (including legal, operational, and transitional challenges) could undermine its efficiency. The expected impact is comparable to that of PO3 (it achieves a fairer, more neutral market) but may do so less efficiently due to the practical difficulties of restructuring established systems. Overall, the measures included in PO4 are projected to lead to 1.9% increase in rail activity in 2030 and 4% increase by 2050 relative to the baseline.

A more detailed assessment of the impacts of the policy options on competition is included in Annex 13.

Table 16: Impact on transport activity in passenger-kilometres at EU level (percentage change relative to the baseline)