How the gospel - the Political Guidelines - left the European Commission with a ticketing proposal both radical and unworkable

Ursula von der Leyen called her disciples, the Commissioners, to gather around. Holding up a bound edition of the Political Guidelines, she conferred a great responsibility onto each of them.

Beckoning disciple for transport, Apostolos Tzitzikostas, towards her, she gave him his instructions: "cross-border train travel is still too difficult for many citizens," von der Leyen said. "Ensure that Europeans can buy one single ticket on one single platform and get passengers’ rights for their whole trip!"

And so Tzitzikostas, perplexed by what von der Leyen exactly meant, nevertheless retreated to his office in the Church of Berlaymont and resolved to do what the leader had conferred on him, and worked in purgatory for two years to produce the Rail Ticketing Regulation that was finally released today, part of what is now known as the Passenger Package.

At no point did Tzitzikostas return to the leader for illumination, to find out whether the absence of an s on the word 'ticket' was simply an error of transcription or was the leader's intention, or indeed whether the leader had ever paused to consider the implications of either formulation. It was in the Political Guidelines, his staff assured him, and henceforth it has to be done, the 'single ticket' had to be born.

And that - as far as I can tell - is how we have ended up where we are today, with the European Commission having proposed a Regulation on rail ticketing that is both radical and far reaching, but also unworkable.

Putting it another way, if you take a step away from the precise text of the Political Guidelines for a moment, and ask what is the purpose of all of this, I do not think you end up with this.

I would argue (and explain in depth here) that the Regulation needs to satisfy three groups - irregular travellers that need a simple procedure for occasional cross border trips, regular travellers seeking the best price for their journey and who need to avoid losing passenger rights, and railway operators that should be burdened as little as possible.

The proposal tries to come up with a system for a single ticket, but this requires a unified booking horizon (every train ticket, everywhere, needing to be available the same number of months ahead of the trip), and thereby places an unnecessarily heavy burden on the shoulders of railway companies, although the lopsided "at least five months" in the proposal leaves some problematic wriggle room if some operators offer more - how a 'single ticket' can be assembled when some tickets are for sale and some are not is left unanswered.

Regular passengers - who may already have reduction cards and passes like Deutschlandticket - are going to be faced with the quandary of paying more to get passenger rights, or paying less and losing rights, based on how the proposal is currently formulated, because there is no obvious way to combine tickets and passes that passengers currently have with ones they will tickets they additionally have to purchase.

So the proposal fails for two of the three groups - it is burdensome for operators, and poses an issue for regular travellers.

The obligation in the Regulation that incumbent dominant sales platforms have to sell private rivals' tickets might be a boon to the EU competitiveness agenda if you think those private rail operators will help us get a more efficient railway, but here too I am not altogether sure of the passenger value of this obligation. Passengers need places where you can compare prices for any train, anywhere, and the obligation on incumbent platforms only helps passengers crossing one border, and says nothing in case a trip crosses two or more. It does of course help Flixtrain or European Sleeper, but this is supposed to be the "Passenger Package", not the "Boost Private Railway Firms Package".

As if that were not all problematic enough, tactically I struggle to see how the European Commission thinks all of this is going to make its way through the Ordinary Legislative Procedure. Two core components - the obligation on incumbent platforms to sell rivals' tickets, and the unified booking horizon to ensure everything can be bundled into the single ticket - are going to come up against massive opposition from national state-owned rail companies, and their interests will be defended by their respective Ministers in Council.

There would be another way to do all of this.

Multiple tickets rather than one single ticket looks a better bet to me, and then booked either in one transaction or in multiple transactions - but in all cases with binding minimum connecting times respected (as laid out in implementing regulation 2026/253). And then on top of that a passenger rights and compensation system between railway companies to cover passengers' costs in the case of disruption, turning the existing informal AJC into something legally binding.

When it comes to ticket sales, there would be no need for any obligation on incumbent platforms, for the Regulation already proposes the other more important obligation, namely third party access to ticketing data on fair terms (FRAND). So if DB Navigator does not want to offer me a price comparison option, but Trainline or Railfinder or someone else does, then as a passenger I could live with that.

Irregular passengers would win - platforms give them simple booking options and guaranteed passenger rights, however many tickets they get.

Regular passengers would win - because if they respect minimum connection times they can still build their trips as they wish and not lose out on compensation.

Railway companies would win - as doing it this way would not force them to unify booking horizons and fully integrate their IT systems, keeping their costs to a minimum.

But this was not the gospel.

Maybe when the Regulation ends up in the Council and the European Parliament, those institutions might think more about the fundamental purpose here, and not be so hung up on the hallowed words of the leader.