A proposed code of practice for Great British Railways’ future online ticket business is open for consultation, with responses due by 11 December. The draft would require GBR to give other online retailers fair, transparent and non-discriminatory access to fares, products, systems and related services. It is a proposal, not a final code or a rule already in force.
The issue arises because GBR is expected to combine roles that have so far been spread across different organisations. It will run most passenger services and sell tickets itself, while also taking responsibility for market-wide retail functions that other sellers need. These include common industry information technology systems, data processing and the licensing of third-party retailers. The regulator says this combination creates potential conflicts of interest that need clear safeguards.
Why other retailers need access
Independent ticket retailers, open-access operators and devolved rail operators are expected to continue selling tickets online. They depend on access to information and systems that enable them to show fares and products and complete ticket sales. If GBR controls those shared arrangements while competing for customers through its own website and app, the terms it sets could affect its rivals’ ability to serve passengers.
The proposed code would require equivalent treatment unless differences are properly justified and proportionate. It would also expect decisions affecting the wider market to be made fairly and transparently, with attention to the effect on other sellers and passenger confidence. The aim is not to prevent GBR from selling tickets, but to set standards for how it manages functions on which competing retailers rely.
Information safeguards are part of the proposal. GBR may handle commercially sensitive information generated through market-wide functions, including data used in industry revenue settlement. The draft principles would require governance, confidentiality, security and access controls, and would bar use of such information to give GBR an undue commercial advantage. This is distinct from requiring GBR to disclose its own commercially sensitive passenger information.
How the safeguards could be enforced
The code is intended to be backed through GBR’s railway licence. Under the proposal, the Office of Rail and Road would monitor compliance and could consider formal licence enforcement if needed. The code would sit alongside competition law and other existing legal, licensing and contractual arrangements; it would not replace them.
The wider system is also relevant. The government’s model brings GBR’s own retail operation together with its passenger railway business, rather than treating it solely as a separate online shop. It says this can support joined-up services and economies of scale, while independent sellers continue to offer an alternative route to buying tickets. Because GBR would also manage shared retail infrastructure and rules, the regulator’s draft focuses on governance, access and fair decision-making.
The draft does not set out a final operating model for every future retail question, and the consultation is intended to gather views from retailers, operators, passenger and consumer groups and others with an interest. ORR expects to consider responses before a final code is prepared, with publication anticipated in spring 2027. The details could therefore change.
For passengers, the practical question is whether different retailers can continue to offer useful ways to compare and buy tickets as the rail system changes. The consultation does not itself alter today’s ticket-buying arrangements. It asks how safeguards should work when GBR assumes its future market-wide role, and whether the proposed principles are sufficient to keep access fair while allowing the new integrated railway to operate.
