“Appropriate technical means to ensure access to real-time information shall guarantee the highest possible standard of customer service”

In the context of the ongoing 2022 TAP TSI revision package, the Community of European Railway and Infrastructure Companies (CER), the European Rail Infrastructure Managers (EIM), the European Rail Industry (UNIFE), and the European Travel Tech organisation
(EUTT), are of the opinion that
o the latest proposal of the European Union Agency for Railways (ERA) for the revision of the TAP TSI Regulation to implement Article 10 of Regulation (EU) 2021/782 is not fit for purpose as it goes against smooth and flexible access to the information promoted by the Regulation to the detriment of the passenger.
o a full Impact Assessment should be conducted to demonstrate the affordability of such a proposal.

Without prejudice to the implementation of operational communications between infrastructure managers and operating railway undertakings which are necessary to operate transport services, appropriate technical means to ensure access to realtime pre-journey information and information during the journey in accordance with Article 10 of Regulation (EU) 2021/782 shall take into account the following to guarantee the highest possible standard of customer service based an industry consensus on the solution:
o infrastructure managers the necessary flexibility to offer the most appropriate technical means depending on the requester’s needs and expectations,
o ticket vendors, tour operators, and other railway undertakings to access the most complete, accurate and reliable real-time passenger information.

CER/EIM/UNIFE and EUTT recommend to continue the dialogue on real-time information, with the objective of defining the best technical solution. Through such information, distributors shall receive only real-time information which:
o is relevant to take commercial decisions actions, such as the cancellation or the recommendation of a journey.
o can be easily linked with the commercial information shared by distributors with the operating railway undertaking and the end user (e.g. train identification, locations)

In addition, CER/EIM/UNIFE recommend to further specify appropriate technical means to ensure access to real-time pre-journey information and information during the journey through the conclusion of a contract or other arrangements between concerned stakeholders, but not through additional specifications in the TAP TSI regulation.

CER/EIM/UNIFE’s and EUTT’s members’ commitment is to comprehensively implement the framework of telematics applications for passengers when developed in a sound and consistent manner taking into account sector stakeholders’ return of experience in the area of telematics communication related to planning, operation and innovative ticketing and intermodality.
Although, considering the developments brought by the recent outcomes of the TAP TSI Revision on TAP real-time data messages, CER/EIM/UNIFE and EUTT, call on European Institutions and the Member States to ensure that the 2022 TAP TSI is further shaped for the benefits of passengers, taking into account business-driven, and thus customer-oriented, return of experience from sector stakeholders.