Author: Association of British Commuters

Last week, the government responded to a damning Transport Committee report on disabled people’s access to transport, refusing to create a national action plan for full rail accessibility, and making only a weak commitment to review the regulatory system.[1]

The report, ‘Access Denied’, had been the outcome of a two-year inquiry and extensive evidence from passengers, concluding that transport accessibility is ‘a source of national embarrassment’ and ‘must be recognised as a human right’.[2]

However, in its response, the Department for Transport (DfT) has refused to commit to work on regulatory reform– even refusing to require the Office of Rail and Road (ORR) to enforce the regulations it already has.[3] It has also refused the Committee’s key demand for a long-term national action plan ‘including metrics, actions costings and milestones’ and ‘with concrete timescales for achieving independent accessibility across the rail network’.[4] Currently, there is no integrated, national investment plan for accessibility in the UK, and this response strongly suggests that the government has no intention of creating one. In fact, accessible infrastructure investment was not even mentioned in the June Spending Review last week.

The DfT’s intention to ignore both regulatory and investment crises in rail accessibility comes after it abandoned all the previous government’s commitments for the new public body Great British Railways (GBR):

1. Socioeconomic, accessibility and environment duties at the core of GBR legislation.[5]
2. A single fund for integrated national investment in infrastructure.[6]
3. A single National Accessible Travel Policy, to be regulated by ORR.[7]
4. Disabled Persons Transport Advisory Committee (DPTAC) to be statutory advisor to GBR.[8]
5. A statutory requirement on GBR to consult disabled people.[9]
6. National Rail Accessibility Strategy, including public consultation.[10]

With its response to the Transport Committee, DfT has finally revealed its hand on rail accessibility, in a year when we will see all parts of the railway reformed through new primary legislation. The future of disabled people’s right to travel is in grave danger, and we may soon lose the opportunity to make any gains at all in the upcoming Railways Act and new public body Great British Railways (GBR).

There is just one more chance to stop this before the new primary legislation. The Equality and Human Rights Commission recently announced a new priority to prevent transport discrimination, set to be a major workstream until 2028.[11] We have therefore requested their urgent intervention, pointing to clear breaches of the United Nations Convention on the Rights of Persons with Disabilities (CRPD) in at least four areas:

Breach 1: Turn Up And Go – the fundamental right to spontaneous travel

Currently, the government is allowing breaches of domestic equality law on a grand scale – denying the right to ‘Turn Up And Go’ (TUAG) across the rail network. This is enabled by the rail regulator Office of Rail and Road (ORR), whose ‘Accessible Travel Policy’ requires a two-hour booking window to guarantee assistance. When deciding this regulation in 2019, ORR ignored the advice of the Equality and Human Rights Commission (EHRC) that disabled people had the ‘fundamental right to spontaneous travel’, and that the over-promotion of ‘Passenger Assist’ pre-booking should be considered in breach of equality law.[12] In the years since, we have seen further unlawful policies and practices enabled by this booking window, for example, ‘mobile staffing’ and a nationwide booking app.

The right to Turn Up And Go is clear under the UK’s Equality Act 2010, as well as UNCRPD rights to ‘Accessibility’ and ‘Independent Living’. In fact, not only is transport a civil right in itself, but it is also the means to most other rights: work, education, participation in social and cultural life, private and family life, and many others.

Breach 2: State duty to regulate according to equality and nondiscrimination principle

Currently, train operators and ORR are knowingly causing systemic breaches of the Equality Act 2010 across the railway network. This is a point we have repeatedly proven on this website, for example, a leaked document in which the train operator Govia Thameslink Railway admits it had ‘been in breach of equality law since 2010’ due to the combination of driver-only trains and unstaffed stations.[13] The current regulations, including the ORR’s ‘Accessible Travel Policy’, are flawed throughout, also denying the right to compensation when disabled people become victims of these discriminatory policies.[14] Current enforcement policies, as well as the regulations themselves, are openly at odds with the rights disabled people already hold under equality law.

The current regulatory system is therefore in major breach of the UNCRPD, which requires States to ensure all legislation, regulation and policies are ‘without discrimination of any kind on the basis of disability’, including taking ‘all appropriate measures, including legislation, to modify or abolish existing laws, regulations, customs and practices that constitute discrimination.’[15]

Breach 3: National Action Plan to full rail accessibility

The obligation for a national action plan to full rail accessibility should be considered no less than a State obligation, especially in a country as wealthy as the UK. Under international human rights law, the UK’s duty to socioeconomic rights means it must invest to the ‘maximum of its available resources’.[16] The CRPD repeatedly advises that this should be rationalised investment for the greatest possible progress in equality, and the CRPD Committee confirms this priority in multiple authoritative opinions. This meaning logically also applies in terms of the UK’s Public Sector Equality Duty, especially considering the ongoing failures to monitor and quantify progress, also strong State obligations under the CRPD.[17]

At current rates of investment, it will take one hundred years to get a fully accessible railway – with no roadmap whatsoever towards ‘step-free’ station accessibility or ‘level access’. The Department for Transport is well aware of this, having been advised by its accessible transport advisors for years that a national action plan is imperative.[18] In its response to the Transport Committee, DfT has again refused to comply with this State obligation.

Breach 4: Duty to consult disabled people on matters affecting them

Rail accessibility and ticket retail have been exempted from consultation for many years, due to concerns for the commercial confidentiality of train companies, and competition law restrictions on collaboration.[19] The previous government recognised the importance of removing private interests from this space, treating the removal of the Rail Delivery Group from all public interest roles as a priority. However, this was found to be impossible in 2022, again due to competition law restrictions.[20]

Currently, the Rail Delivery Group remains in place and has even grown in dominance. Despite being entirely unregulated by the ORR, it is developing, using public money: the Passenger Assist booking app; a network-wide trial of Welcome Points; and many new ‘digital ticketing trials’. These are all key parts of its attempts to make stealth reforms to ticket offices, which are under the remit of the Rail Delivery Group due to its dominance of the national ticket retail system. Policies such as ‘mobile staffing’, where passengers have to go to a Help Point and wait for a staff member to travel to them, are increasingly being implemented without consultation, signed off by the ORR.

All States have a strong obligation to ‘closely consult and actively involve’ disabled people in all decisions concerning them, underlined throughout the UNCRPD, as well as an accepted principle in the UK courts. Allowing the Rail Delivery Group to stay in place, playing a central role in policy development, is a severe breach of duties to consult, as well as the UNCRPD duties to ensure equality and non-discrimination throughout the regulatory system.

Urgent demands

Our first call in this emergency is to the Equality and Human Rights Commission, whose intervention may now be the only way to get duties for accessibility back into the upcoming Railways Act.

The second is to the Transport Committee, to hold a dedicated hearing as soon as possible on transport accessibility, challenging ministers on all areas of the plans for Great British Railways.

The third is to call on all charities, trade unions, transport and equality bodies to make the strongest possible challenge on this issue and get all accessibility duties back into Great British Railways. Disabled people are currently facing overwhelming attacks on their rights from all directions, so solidarity efforts should be made by all third-sector organisations representing passenger rights in transport.

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References

[1] The DfT has said only that it has ‘approached the Law Commission’ on the possibility of a legislative review. However, the primary legislation for Great British Railways is being written right now, including the total reform of the Office of Rail and Road (ORR). There is also a serious red flag in its comment that regulation should be ‘efficient, proportionate and support growth.’ See Transport Committee, Response to Transport Minister (11 June 2025).

[2] Transport Committee, ‘Access Denied: MPs call for overhaul of laws, strategy and attitudes..’ (20 March 2025).

[3] House of Commons, Government response (13 June 2025); Transport Committee, Response to Transport Minister (11 June 2025).

[4] Transport Committee, Government pledges to review accessibility laws but its response to scale of failings ‘lacks urgency’ (13 June 2025).

[5] ABC, ‘Dept for Transport drops main public interest duties from GBR’ (24 Feb 2025). The public interest duties were previously commitments of the 2021 GBR White Paper, the 2022 consultation, the 2024 outcome to that consultation, and the 2024 draft rail reform bill of the previous government (Schedule 1, sec 4).

[6] The 2021 White Paper proposed that all funding pots for accessibility improvements would be consolidated into a single fund, including Access for All, the Stations Improvement Fund and the Customer and Communities Improvement Fund. (p 75).

[7] A National Accessible Travel Policy was proposed in 2022. However, this was dropped in 2024, probably due to the restrictions of competition law on train operator collaboration, such as commercial confidentiality and rules against ‘collaboration’, which is seen as an ‘anti-competitive practice’.

[8] The commitment to expand the role of DPTAC was proposed in 2022, making it into the draft rail reform legislation of 2024 (sec 11).

[9] Proposed in 2024.

[10] A proposal running from 2021 – 2024, the National Rail Accessibility Strategy consultation was on the verge of release several times in the years 2022 – 2023, being interrupted by the 2023 attempt to close every ticket office in England.

[11] Equality and Human Rights Commission, Watchdog publishes three-year plan to tackle key equality and human rights issues in Britain (Press Release: 26 March 2025)

[12] Equality and Human Rights Commission, Response to the Office of Rail and Road consultation on improving assisted travel (March 2019).

[13] ABC, Govia Thameslink Railway admits it is in breach of equality law (31 Aug 2022). ABC, Six train operators ‘in breach of legal requirements’ due to discriminatory staffing policies (22 Nov 2022).

[14] The Guardian, UK train companies could have to pay disabled passengers more compensation (18 May 2025).

[15] UNCRPD, Art 4(1)(a-i).

[16] ICESCR Art 2(1), UNCRPD Art 4(2),

[17] State obligations under Art 31 (Statistics and Data Collection); and Art 33 (National Implementation and Monitoring).

[18] Disabled Persons Transport Advisory Committee, DPTAC reference frame: working towards a fully accessible railway (14 Feb 2022).

[19] In 2024, the previous government concluded it was impossible even to make minor exemptions to the Competition Act 1998, preventing proper collaboration or co-ordination of cross-network functions. Department for Transport, Government response to GBR consultation (Feb 2024) p. 57 -59.

[20] Proven via FOI requests. See ABC Parliamentary Briefing (23 May 2025), direct download.

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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.

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[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.

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For more information: contact@abcommuters.com

*This blog has been edited since publication to add further data evidence on the Southeastern cuts.

The Association of British Commuters, Disabled People Against Cuts, National Pensioners Convention, and National Federation of the Blind of the UK have made their first challenge to the Secretary of State for Transport on the missing public interest duties from Great British Railways.

Four urgent demands were made in a letter dispatched on Wednesday:

1. Extend the Great British Railways consultation deadline to 12 weeks, with a significant outreach program to explain the impact of proposals on passengers, taxpayers, disabled people and all protected groups.
2. Provide accessibility and equality measures to ensure the widest possible participation of the 16 million disabled people in the UK.
3. Publish the cost impact assessment immediately, as is standard with such important consultations. This must show how the Department considered its Public Sector Equality Duty, since all accessibility commitments have been dropped from the new plan.
4. Restore questions on public interest duties and GBR’s founding purpose, including the previous government’s commitments to “maximise social and economic value” and consider accessibility and environment in all decisions.

Since our letter was sent, an article in Disability News Service has confirmed that the Department for Transport (DfT) has no intention of consulting on public interest duties at any point in the GBR legislative process. Our demands could not be more urgent – if the duties are not restored to the consultation now, they will be excluded from Great British Railways legislation altogether.

Why the future of accessibility depends on GBR public interest duties

1. Consulting on the accessibility duty is a chance to put civil rights such as Turn Up And Go at the heart of the GBR Licence, or even the new primary legislation itself.
2. In conjunction with the overarching socioeconomic duty, the accessibility duty could lead directly to national action plans and compliance deadlines for full infrastructure accessibility – the ‘holy grail’ of accessible transport.
3. A GBR with strong public interest duties would have to take over all ticket retail and accessibility areas currently controlled by the Rail Delivery Group, which has long been developing key accessibility technologies outside any sort of consultation, regulation or equality due process.
4. Strong accessibility duties throughout GBR would entail comprehensive regulation of accessibility – which must be a rights-based model much closer to how safety is treated by the railway. Currently, plans for regulation are vague and confused, with no clarity on whether the rail regulator, ORR will remain responsible, or whether this will be passed off to ‘passenger watchdog’ Transport Focus.

There can be no doubt of the public’s strength of feeling on these matters. The Minister for Transport must turn back from this new idea of a stripped down, deregulated GBR, and must not sacrifice the chance to create a proper equality, human rights, and climate framework for the railway.

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For more information: contact@abcommuters.com

Last week, the Department for Transport (DfT) launched a consultation on the legislation for Great British Railways (GBR). It has since become clear that the DfT dropped GBR’s headline ‘public interest duties’ from the plan – a major setback for socioeconomic value, accessibility, and environment.

The following explains why the Secretary of State for Transport must take control and immediately restore all public interest duties to the GBR consultation. As the most important rail consultation since privatisation, it must also be extended to at least 12 weeks to give any chance of a meaningful public response.

An ‘overarching’ public interest duty to ‘maximise social and economic value’.

The headline promise of the previous government was that Great British Railways (GBR) would be ‘a guiding mind…responsible for running the railways safely and efficiently to maximise social and economic value.’  This ‘overarching’ ‘public interest duty’ was to be set out in the GBR Licence, alongside other core duties towards accessibility and environment, all monitored and enforced by the Office of Rail and Road (ORR). It was a headline commitment from the 2021 White Paper on GBR until the Feb 2024 Plan for Rail.

Responses to the last GBR consultation showed the public interest duties were ‘widely welcomed’ and ‘the duty for accessibility in particular was strongly welcomed’ by the public. Therefore, in 2024, these commitments were strengthened even further; in recognition of ‘the critical importance of an accessibility duty within the licence’ over and above existing obligations in the Public Sector Equality Duty and Human Rights Act 1998, to ‘ensure that GBR puts accessibility at the core of its strategic decisions.’

Why is the Labour Government going in the opposite direction?

The new GBR consultation picks up where the previous government’s Plan left off – except there is no mention that the headline public interest duties ever existed, let alone that they received such widespread support from the public. The DfT now appears to be going in the opposite direction, with the new consultation stating that “GBR will…be subject to a substantively streamlined and simplified licence” under “a guiding principle…focused on the minimum viable set of conditions that are required for safety, performance (i.e. reliability and cancellations), efficiency, and passenger experience…. substantially reducing the regulatory burden.”

Accessibility is hit the hardest by these new plans, where the government has dropped several other key pledges: for the Disabled Persons Transport Committee (DPTAC) to become a statutory advisor to GBR; as well as “a condition in the…licence to require GBR to consult with disabled passengers…directly and through representative organisations.” Proposals for regulating accessibility are also extremely vague, with no clarity on whether this duty will fall to Office of Rail and Road (rail regulator), or Transport Focus (passenger watchdog).

The new GBR consultation contains no questions whatsoever on passenger experience, nor any of the transport policy issues of most concern to passengers, for example: fare reductions; ticket office closures, or disabled people’s right to ‘Turn Up And Go’. This continues the trend started by the Conservative government, which exempted all passenger issues from consultation, and failed to conduct the urgent consultations that should have come first, such as: fares and ticketing reform; the National Rail Accessibility Strategy; the National Accessible Travel Policy; and the accessibility audit of railway infrastructure. In fact, the only consultation on passenger-facing issues that has occurred in this period was the 2023 attempt to close every ticket office in England – plans that eventually collapsed due to public outrage and breaches of equality law.

In conclusion, the entire consultation document is about the technical aspects of regulation and competition law issues, making the details incomprehensible to all but those already expert in the relevant legislation. It is therefore, a consultation for industry rather than the public, with industrial and private interests sure to be the loudest voice. Most concerning of all, the sudden launch and too-short length of this consultation suggests the DfT is trying to get new primary legislation through as quickly as possible, rather than taking the time to meaningfully consult.

Urgent Demands to the DfT

1. Currently the consultation is being held for just 8 weeks, and over the Easter holidays. This must be extended to at least 12 weeks – with significant outreach from the DfT to explain the impact of their proposals on passengers and taxpayers.
2. The consultation was published without impact assessments, which should have accompanied the document and spelled out the thought process behind any changes. The DfT must publish these immediately, explaining the cost-benefit risks and impacts, and whether it has considered its Public Sector Equality Duty in the new plan.
3. The DfT must restore questions on GBR’s public interest duties to the consultation and reissue the document, subject to an extended 12 week deadline. Its only reported comment on this so far is that ‘the government welcomes views on whether there should be such a duty’ – it is of course impossible for the public to give such input if there is no sign in the document that the duties ever existed.

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For more information: contact@abcommuters.com