GBTA Supports Ambitious Multimodal Digital Mobility Services (MDMS) Regulation

GBTA continues to advocate for the EU Commission to maintain its ambitious scope for Multimodal Digital Mobility Services (MDMS) regulation, to promote sustainable travel and meet EU climate goals.  

Initial MDMS policy vision  

In 2020, the EU Commission set out its Mobility Strategy including its vision for MDMS Regulation: 

“Planning and buying tickets for multimodal journeys is much too often much too cumbersome for travellers”, which is why the “EU needs to transform its legal framework to support multimodal travel information, booking and ticketing services”.It was noted that these services facilitate access to “information, booking and payment of mobility” and thus “improve the sustainability, resilience, efficiency and comfort of the transport system”. 

Such objectives are as simple as they are crucial. By making tickets more accessible through convenient online booking channels, the MDMS Regulation could:  

• Facilitate the modal shift to rail and thus reduce transport emissions, as the benefits of sustainable travel will be shown in plain view. 
• Ensure that travellers are well-informed, get the best deals and can make more sustainable choices.  
• Lead to a more efficient European transport system, as multimodal connections, otherwise invisible, will become bookable. 
• The initial policy vision of the MDMS Regulation was aimed at making travel for European citizens simpler and greener and the transport system more competitive. Among the many Green Deal policies, MDMS is a rare case that would not restrict consumer’s behaviours but rather offer more convenience and choice.  

How to achieve the vision?  

To implement this vision, a clear set of policy tools was identified early on by DG MOVE, many of them supported by a large majority of stakeholders in the Multimodal Passenger Mobility Forum (MPMF) expert group:  

• Operators with a significant importance to European travellers should be obliged to make all their relevant tickets available for re- sale/distribution, based on fair, reasonable and non-discriminatory (FRAND) terms.  
• FRAND terms would ensure a wide availability of tickets under fair conditions for all involved, protecting the player with less bargaining power in each interaction.  
• Reciprocally, MDMS platforms should have obligations to ensure that operators can compete fairly on their channels. 

With these tools, MDMS would be unleashed to play their role as modal shift and transparency enablers, convenient booking, and comparison services, allowing travellers to search, plan and purchase all transport offers, including cross-border ones. Combined with a set of enhanced passenger rights (to be proposed concurrently), the MDMS would thus have the potential to radically improve how European citizens can travel, in a policy shift akin to the abolition of mobile roaming charges.  

Current thinking  

Unfortunately, the Commission’s strong vision and solid policy tools have since been abandoned, as was evident in DG MOVE’s 19 June 2023 presentation of the current policy options for the Regulation. The options under consideration now aim to do the following:  

Policy Option 1: A purely voluntary framework reliant on industry cooperation.  

GBTA’s Concern: Based on the past years and even decades of empty promises by large incumbent operators to openly distribute their tickets, this option would achieve very little. 

 
Policy Option 2: Focused only on enabling a “re-linking” model. Customers would thus be helped by the Regulation to search multiple tickets but would be redirected to book connecting tickets on multiple operators’ websites.  

GBTA’s Concern: The policy tools under this option don’t go far enough to change the status quo in ticketing and booking, as “re-linking” is already possible in many cases. It will have no impact on business travel as booking through relinking is simply not an option for business travellers. By ignoring ticketing, booking, and purchasing, and making standardisation irrelevant, this policy option openly disregards the vision set out by the Commission’s leadership in 2021. In addition, the approach under this policy option would limit the application of passenger rights in case of disruptions, as an integrated booking of tickets with related safeguards would not be enabled.  

Policy Option 3: Focused on enabling re-linking and re-selling, but only for operators with a 50+% market share within a given Member State and only regarding domestic tickets. 

GBTA’s Concerns: While the framework and the obligations are conceptually sound, many relevant tickets for travellers would not be covered with notably cross-border travel not being covered at all. It is difficult to imagine why a Regulation focused on enabling smart and green travel across Europe should only focus on domestic routes, disregarding the subsidiarity issues that would be raised.  

All current policy options are flawed and would fail to achieve the objectives of the MDMS Regulation. They would do nothing to facilitate lower transport emission through modal shift, ease the booking of tickets across Europe or enable fair competition in transport.  

Solution  

GBTA is advocating for the original preferred policy approach as presented on 28 February 2023: enable the re-linking and reselling of all cross-border tickets and tickets of significant transport operators (such a definition including all modes of transport) on MDMS platforms, based on FRAND terms. This would be combined with an obligation on MDMS to rank offers in a neutral fashion and equally respect FRAND when they are of a significant size. GBTA strongly believes that this approach is needed to give the MDMS Regulation a significant impact in line with the ambitions of the Sustainable and Smart Mobility Strategy. Users’ needs should be put at the heart of the Regulation by ensuring that relevant rail and air tickets can be conveniently booked via MDMS.