Industry sources warn that ‘Ticket Office Cuts Round Two’ is about to begin – starting with Scotrail, and ongoing stealth cuts on Southeastern and Great Western Railway (GWR). Currently, ‘all eyes are on Scotrail and Southeastern to see if they get away with it’ and if these operators succeed, similar stealth destaffing tactics will spread across the rest of Britain.
The UK and Scottish governments are directing these cuts, working together to push forward a Tory agenda first hatched in early 2022 as a ‘Plan B’ for ticket office closures. The Department for Transport (DfT) has been waiting to restart its Plan B since the collapse of its 2023 ticket office consultation, but had held back due to the level of public outrage at the time. Around Oct-Nov 2024, this agenda was restarted by the UK Labour government, which is now working with Transport Scotland to enact the Tory plans.
Our new data project proves that Scotrail is about to deregulate ticket office staffing hours at a total of 96 stations, despite publicly claiming only 31. Great Western Railway (GWR) has already completed a program of cuts at 39 stations in total secrecy, with further cuts pending. Meanwhile, Southeastern’s plans for severe cuts at 14 stations have been paused since being exposed on this website in Nov 2024, and are still awaiting a decision from the Department for Transport.
The fact that the first ‘test’ operators to try these new stealth tactics stretch across both England and Scotland, and both privately and publicly owned operators is proof in itself that this has been planned and coordinated across the entire railway. This can only be on the orders of the UK Department for Transport and with the complicity of the Scottish government.
The following report is based on months of research and freedom of information requests, as well as in-depth correspondence with Scotrail. Both the DfT and Transport Scotland declined to comment, but did not deny the allegations.
What is stealth deregulation?
The new stealth plans are based on manipulation of ‘Schedule 17’ of the Ticketing and Settlement Agreement (TSA) – one of the main issues that brought down the 2023 consultation on ticket offices due to legal threats. We call this stealth destaffing / stealth deregulation, because Schedule 17, the obligation to staff ticket offices, is the only way that any staffing hours are regulated. Therefore, when staffing hours are reduced under this system, those hours are permanently deregulated – meaning that both operator and Transport Ministry shed any duty to consult on future staff cuts.
Each of the three train operators we’ve investigated deny these staffing hours are being lost, and claim they have guaranteed station staffing to replace lost ticket office hours. However, their rebuttals only prove our point because promises of this kind can only be based on yearly business planning or trade union agreements – both of which are time limited and obviously no substitute for permanent regulatory constraints.
This report explains the stealth tactics and regulatory manipulation used by at least three train operators so far. The examples should be used to pre-empt the DfT’s next attempts at stealth destaffing, which are likely to use the Schedule 17 ‘Minor Change Process’ currently being exploited by GWR and Southeastern.
Scotrail’s manipulation of Schedule 17 ‘Major Change Process’
Scotrail has just announced it will enact a program of cuts to ticket office staffing hours, implying this will happen at just 31 stations. Our research proves this a misleading claim – the true figure where hours are being deregulated being 96 stations. It appears that this is being done by many small cuts to ‘shave’ hours from opening and closing times; however, Scotrail has obscured the data to such an extent that it is impossible to know the severity of the cuts. Scotrail refuses to provide this figure, but does not deny RMT’s estimate that this amounts to 2,800 ticket office staffing hours withdrawn per week.[1]
In Scotrail’s case, it is using the results of a Feb 2022 ‘Schedule 17’ consultation held while the operator was under private ownership, just before renationalisation that April when it became the direct responsibility of Transport Scotland. The operator is therefore relying on a consultation that is three years out of date and was strongly opposed by the Scottish public, the government having suspended those plans until they were quietly restarted in Nov 2024. Our investigation has also concluded that there was no Equality Impact Assessment (EqIA) until late last year, meaning that Scotrail’s recently published EqIA has been retrospectively applied to plans made almost three years ago.[2]
GWR’s manipulation of Schedule 17 ‘Minor Change Process’
GWR was one of the original ‘test projects’ of the Plan B for ticket office cuts using the Minor Change Process to enact a program of stealth cuts at 39 stations between 2022 and late 2024. Whereas Scotrail’s cuts have relied on a public consultation (the ‘Major Change Process’), under the Minor Change Process ticket office hours can be reduced without consultation, or any transparency whatsoever. It is in this way that the DfT’s ‘Plan B’ for ticket office cuts is supposed to proceed, ‘shaving hours’ in as many areas as possible, and leading incrementally to full closures.
GWR’s stealth plan was hatched in June 2022, leading to cuts at 39 stations to date. Our FOI requests and data analysis prove that this amounted to 344 ticket office staffing hours cut per week. Most of these were the ‘shaving’ of an hour or two from morning and afternoon/evening staffing hours, however 17 of these stations were single-staffed, potentially causing severe impacts. All 39 cuts have now been enacted and most would have taken place in 2022-2023, though some as late as Dec 2024, GWR refusing to confirm the exact dates. No Equality Impact Assessment was conducted at any point.[3]
Southeastern’s manipulation of Schedule 17 ‘Minor Change Process’
Southeastern was the very first test project of the Tory ‘Plan B’ for ticket offices, which began in January 2022 with a ‘Minor Change Notice’ for severe cuts at 14 stations – in the worst cases up to 50% of opening hours. Our data analysis proves this to be a total withdrawal of 555 hours per week.
Southeastern’s program of stealth cuts began in October 2024 but was paused in November after being exposed on this website. Only two of the 14 cuts have taken place so far, while the other twelve are paused awaiting a decision from the DfT.
Urgent warning from industry sources of further cuts
We have tracked the DfT’s stealth plans for ticket office cuts since 2022, and know that they have been waiting to begin Plan B since the scandalous collapse of ticket office closure consultations 18 months ago. Our sources confirm that this back up plan has now begun, urging us to warn passengers – especially disabled passengers – before ‘Ticket Office Cuts Round Two’ begins.
[1] The RMT estimates that the Scotrail cuts amount to 2,800 ticket office staffing hours removed per week. Scotrail has not disputed this figure. For the evidence behind our claim that 96 stations will be partially deregulated via Schedule 17, click here.
[2] Scotrail’s Equality Impact Assessment (EqIA) has just been published, but we dispute the original date on the document of Dec 2022. In fact, an FOI request shows that even as of mid-2023, there had been no equality impact process. Going by the other dates shown on the new EqIA, this can only mean the first version was produced in Nov 2024. Scotrail has not responded on this point, except to say: “With regard to ScotRail’s requirements under the Public Sector Equality Duty (PSED), ScotRail is content that it has undertaken an EQIA at the appropriate points. ScotRail reject any characterisation of our approach as being procedurally defective at any point.”
Scotrail also disputes our point about deregulation and “does not recognise the characterisation of ‘deregulation’ referred to nor that requirements for future consultation have been dispensed with.” Though we acknowledge that regulatory regimes in Scotland are generally superior to England, this does not change our position – the regulatory requirement to consult has been lost for those hours because those are the rules under Schedule 17 for all ticket offices in Britain.
[3] GWR admits the cuts but says ‘this is not reflective of total station staffing and opening hours; and all changes were consulted on and communicated [in 2022], as per our regulatory requirements.’ However, it did not provide any evidence for the latter claim except to say this was ‘communicated through posters at the stations concerned.’ GWR says that commitments have been kept at all 39 locations on staffing, however, this makes no difference to the stealth deregulation point, which means staffing levels for those hours are not secured in any way for the future. Full data evidence of the GWR cuts, including the ‘Ten Worst Affected Stations’ can be downloaded here. The original June 2022 ‘Minor Change Notice’ for the cuts can be downloaded here.
For more information: contact@abcommuters.com
*This blog has been edited since publication to add further data evidence on the Southeastern cuts.
abcommuters.com 