On Page 29 of the draft European Parliament election programme of the German Grüne (full PDF in German here), you can find this text (my translation):

What is taken for granted when booking flights should in future also be standard for all train journeys in Europe. With a cross-provider ticketing system, we can enable booking platforms to offer end-to-end tickets, including sharing offers, for everyone. The cheapest tickets will be made easily accessible. Travellers will be provided with clear and transparent information on the costs, journey times and climate impact of each travel option and will be able to choose the best option for them. To bring Europe closer together by rail, bookings need to be made easier.

That this text is in the result of my work within the party – this proposal emerged from a workshop I ran at a congress to prepare ideas for the programme in March this year.

Anyone who has ever tried to book an international journey by train (or a combination of train and some other mode of public transport) can understand this problem, and hence why it needs to be fixed.

But while the need is clear, how exactly could this be done?

This article will sketch out the broad approach – legally and technically.

As a starting point I do not mind who builds such booking platforms – and note that the mechanism sketched out here would allow different providers, either publicly or privately owned, to have a go. That is also the reason why the text says platforms, plural.

There are four building blocks for any such platform to work, and I will examine each in turn.

  1. Journey planning
  2. Ticket purchase
  3. Live running data
  4. Passenger rights – in case something goes wrong


Journey planning

Before you come to actually buying a ticket, you need a good route – and this route might combine multiple modes of transport, and perhaps even walking and cycling too. In Germany at the moment the best tool for this is Deutsche Bahn’s Navigator App, or Reiseauskunft on the web.

The problem is that the moment you cross a border into another EU Member State things do not work so well. In most other countries you might get trains shown, but likely not buses or trams, or walking directions.

This is because DB data beyond Germany’s borders comes from UIC Merits, and that has a couple of problems as a data source – there are holes even in the rail data (as I outline here), and it has pretty much no non-rail data in it. My efforts to enquire with UIC about the missing data have been blanked until now, and the EU has shown no interest in mandating data sharing with UIC, so that looks to be a dead end.

The solution is to use data that each Member State of the European Union is mandated to publish through National Access Points. This data is either in GTFS or NeTEx format, or both.

The MOTIS Project of the Technical University of Darmstadt has shown what you can build with this data – background about the project here, and a live demo here. Having spoken to the lead developer of MOTIS, adding all EU countries to their tool would not be a complex task – it is a question of time and server resources.

So the legal and technical requirements for this block are largely already fulfilled.


Ticket purchase

A bunch of startups – Omio, Trainline, Trip.com, Raileurope, All Aboard, Railtic etc. – have been queuing up to try to solve this one, as this is where the money is theoretically to be made.

But there are three problems with these tools at the moment.

Firstly, the routing offered by these platforms is often quite horrid (as I document here) – and this negates my first point above. Secondly, there are holes in the ticketing data – where public transport operators refuse to let others sell their tickets. Third, the commission that rail companies will offer for such platforms to sell their tickets is often so low the platforms cannot survive – that was the crux of the case brought by Omio and Trainline at the German Bundeskartellamt.

There was hope that the EU would help solve the problems with ticketing data – the Multimodal Digital Mobility Services Regulation (MDMS) was due to be proposed this autumn, but failed at the European Commission’s Regulatory Scrutiny Board, so has been shelved at least until after the European Parliament Elections 2024 – at least in part due to lobbying from state incumbent railway companies dead set against data sharing.

But the need for a MDMS Regulation does not go away – and it would need to be a Regulation that makes data sharing for ticket reselling obligatory for all public transport operators, including all railways, and ticket resale terms based on fair, reasonable, and non-discriminatory (FRAND) principles.

For this block to be complete legal changes – EU wide – are needed, and a combination of the routing provided by MOTIS and the ticket reselling offered by Omio or Trainline would offer a better commercial solution in the short term than anything else on the market at the moment.


Live running data

Is my train or bus on time? And – importantly – who should tell me if there are disruptions if I had booked a ticket previously?

Traditionally this has been the preserve of the operator of the service. But if your service involves multiple modes and multiple operators, this can become messy.

Here too the Bundeskartellamt case shows how little data Deutsche Bahn is willing to share with third parties – Omio and Trainline are not allowed access to this data so as to pass it to their customers – the customers have to go to DB directly.

Yet here too MOTIS shows what is possible – click on any train on their map in Belgium (or the screenshot shown here) and you can get live running data from the NeTEx data. And from that a means to receive email or push notifications about a given train on a given day could be built.

For this block we again need legal changes – EU wide – to mandate data sharing from public transport operators. MOTIS shows that the technological solution is already in place to provide this information to end consumers if they want it.


Passenger rights

An area of nightmarish complexity at the moment, with the railway companies pushing Railteam hop on the next available train (HOTNAT) and the Agreement on Journey Continuation (AJC) as alternatives to legally binding rules to help passengers in the case of disruption. I tried to get my head around these agreements in this post and diagram, and I am not sure I have it all right.

The crux is this: even if your booking was made with one financial transaction, you might be left stranded in the case that your journey has multiple tickets from multiple operators.

The solution here is a hop on the next available train legal right, regardless of operator – and for this as well new EU law would be needed.

There might be times when this is practically not possible – a train is full to overflowing for example. And some rail operators might be the ones causing more problems, while others are the ones picking up the problems – and all of this might need a financial compensation mechanism between operators. But given that most rail routes, even now, have only one operator, it is simply unacceptable that a passenger is left stranded or out of pocket if something went wrong earlier in their journey chain.

Rail firms have long insisted a “through ticket” is the solution here – that if I have a single ticket for my trip everything is OK. But you cannot even get that within some countries of the EU, let alone when crossing borders. And trying to get the decrepit IT systems of some European railways to spit out a through ticket is never going to work. An insistence on through tickets is hence a recipe for inaction by the railway firms.

In the meantime there is a partial solution that platforms could offer – to borrow the concept of virtual interlining from airlines. If a platform were to sell me – say – a Madrid-Strasbourg journey with Madrid-Lyon on a Renfe train, and Lyon-Strasbourg on a SNCF train, by default I would have no rights to take a later Lyon-Strasbourg if I missed my connection. But a virtual interlining solution – essentially an insurance product on top of the ticket sale – would mean the ticket seller would re-book me onto the later train at their costs rather than mine.

This block also needs legal changes, although a virtual interlining solution would offer a partial short term fix.


So there you have it. Want platforms that allow passengers to book any multi-modal public transport trip, even cross border? You need quite some legal changes, EU wide, to make it work, although in the meantime a clever combination of some existing tools and borrowing a concept from the airline industry could help a little.


[Update 31.10.2023, 17:10]
The text of the paragraph about National Access Points and the data they provide was amended slightly – because data is normally published in GTFS and NeTEx formats – I had erroneously assumed it was only the latter.


  1. Luis Sánchez García


    It is a great proposal and I think that implemented it would help a great deal to make trans european travel easier.

    I wonder though what could be the advantage of the national access points in comparison to Merits.

    On the other hand, I think that in the tick purchasing section, a more explicit mention to seat reservations should be made.



    • National Access Points data is more complete than Merits – it is complete for the whole of the EU, and Merits – stupidly – is not (look at the data gaps in Spain for example), and furthermore other public transport data (buses, metros, trams) is in there too, and that is mostly not there in Merits. UIC could of course begin to fix this, but has not shown any inclination to do so – hence my conclusion to better work with an alternative.

      And seat reservations – if a train is compulsory reservation that is there in the data as well. No problem at all on that point.

  2. On this topic, I keep thinking about the European Rail Timetable publisher. I know we discussed this, Jon, and you didn’t see much of a role for it; and I agree that the publisher- an old friend of mine- has a very analogue mindset; but somehow they, uniquely at this time, are gathering and storing all the data. It just seems to me a bit sad that we cannot somehow utilise it, and that eventually the ERT will be blown away by a digital solution that may or may not be 100% superior. I wonder whether we couldn’t somehow connect the ERT and the Uni. Darmstadt people?

    • Sorry, but I still do not see ERT as much use here. They’re basically doing by hand what the National Access Points have already gathered, digitally. If they want to keep producing that in a book or PDF form, then fine, good luck to them. But I do not see it as the solution I am looking for. Apologies!

  3. No need to apologise to someone who had no idea what National Access Points are????

    I just wish I could encourage and help them digitise and avoid oblivion; you know there’s a certain cohort of traveller that will miss it very much and will find the digital thing that replaces it, wanting.

    PS on my new Substack I’m bigging up your Night Sleeper manifesto



  4. Matthias Blume

    Yes, finding the right tickets and buying them is one the biggest hurdles to increasing the market share of rail together with comparably high prices.

    Journey planning
    Among the steps, this one is the easiest to implement to a large extend (not completely I agree, with local buses being more nice to have; long distance buses are a different story)

    Ticket purchase
    With dynamic pricing being offered almost everywhere and requiring a real time connection, the basic purchase is already a big challenge. Then you also want “special” features like night trains, bikes, seat maps, which are even difficult in your home country.
    But the real nightmare starts with foreign or even cross border (partial) cancellations, reimbursement, exchange and some special cases.

    Live running data
    The technical side of this has been in the workings for a while. Unfortunately live running data are seen as a differentiator of the providers and are used in a protectionist way — until they are forced to open up like in other areas before.

    Maybe global warming is an easier challenge 😉

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