Train and station operators are required by their operating licences to establish and comply with an Accessible Travel Policy (ATP) which must be approved by us.
An ATP sets out, amongst other things, the arrangements and assistance that an operator will provide to protect the interests of disabled people using its services and to facilitate such use.
Our guidance forms the basis of ORR's review and approval of operators ATP.
Here we provide information aimed at train and station operators about complying with these requirements. Operators should also refer to our regulatory statement.
Approval of ATPs for new franchises or new operators
Newly licensed operators or those with new franchise awards must establish and comply with an ATP. The licence condition sets out the steps required.
In our Assisted Travel consultation from November 2017, we took the view that it is not proportionate to ask licence holders to submit their DPPP (now ATP) policies for annual review and approval where only routine changes have been made.
Licence holders are now only required to submit their ATP for approval where a material change has been made. Changes are classed as material where they constitute a substantive change to the policy itself and impact on the assistance provided to passengers. Licence holders are still required to confirm to us that they have conducted an annual review, and that there has been no material change (if this is the case).
As per the licence condition, we can require licence holders to submit their ATP for review where evidence emerges that they are not being implemented appropriately or where we consider a material change has been made without approval.
To allow us to monitor train and station operators’ compliance with the accessibility licence condition, we have carried out a number of consumer research projects looking in depth at accessibility and assistance. The research allows us to build up a strong evidence base to help us prioritise and target regulatory interventions that may be necessary to improve the experience for passengers with disabilities.
In July 2022, we published the findings from three research projects:
- A survey of passengers who have booked assistance. This research investigates the extent to which Passenger Assist is meeting users’ needs and overall expectations and how well individual operators are meeting their Passenger Assist obligations. This research has been running since 2017, with findings published annually.
- A review of the accessibility of train operators’ websites. The review is in three parts: Web Content Accessibility Guidelines (WCAG) compliance, performance against Accessible Travel Policy (ATP) requirements and user testing of the websites by panel members who have a variety of accessibility needs.
- A review of Accessible Travel Policy implementation, with a focus on unbooked assistance and Help points.
Previous consumer research has included:
- A survey of passengers who have booked assistance. The findings helped to provide insight into passengers’ experiences of the booking process, assistance provision, changing trains, and the knowledge and helpfulness of staff they interact with. It also provided a measure of satisfaction with the overall experience.
- A mystery shop of ‘turn up and go’ (unbooked assistance) checked compliance, at an industry level, with the obligation to assist passengers who travel without booking ahead.
- A survey to measure levels of passengers with disabilities’ awareness of the current Passenger Assist and turn-up-and-go services. This was also used to investigate any potential barriers to travel for passengers who do not use these services and investigate ways in which information about them could best be presented and disseminated.
- A review of train and station operators’ websites to assess the provision and promotion of online assistance information from an accessibility perspective. This provided us with a snapshot of how accessible these websites are to passengers with particular disabilities or impairments.
Once we have given our approval to an ATP, we will publish a decision letter. The letter will summarise any issues that were raised during the approval process, note areas of good practice or highlight areas where we feel a licence holder should particularly seek to improve its practices.
We are also responsible for monitoring licence holders’ compliance with their approved policies. In order to carry out this monitoring, we ask licence holders to submit data which we refer to as ‘core data indicators’. These core data indicators collect a wide range of information. Specifically linked to accessibility, we collect core data indicators regarding:
- The volume of complaints about accessibility received by licence holders;
- Data about the number of journeys for which a Disabled Persons Railcard was used;
- The volume of assisted journeys provided by licence holders; and
- Information about the disability awareness training provided to staff by licence holders.
We will also:
- hold regular meetings with Transport Focus and London TravelWatch to discuss their views and research;
- review additional market research relevant to ensuring disabled people can travel confidently on the railways; and
- on occasion we may require additional information from operators, where possible we intend to rely on the information operators' already produce to monitor and evaluate complaints and their procedures.
A newly licensed operator, or newly awarded franchise, may have limited experience or data on which to develop its ATP. For this reason, we would expect an operators of a newly approved ATP to review its effectiveness in providing assistance within a suitable period, to allow for changes in light of experience.