Support study for an impact assessment for a possible revision of Regulation (EC) No 561/2006 on driving times, breaks and rest periods of road transport workers : final report : annexes.
Date: 2023-04-24
Institutions: Directorate-General for Mobility and Transport
Subjects: bus, carriage of passengers, carrier, driving period, humanisation of work, public consultation, regulation (EU), report, rest period, road safety, sample survey

Support study for an impact 
assessment for a possible 
revision of Regulation (EC) No 
561/2006 on driving times, 
breaks and rest periods of road 
transport workers 

Final Report 
Annexes 

Written by Oxford Research, TIS, Panteai and Tetra Tech 
February 2023 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Submitted in February 2023.  
No MOVE/C1/SER/2020-556/SI2.850002 implementing framework contract No MOVE/A3/2017-257 

EUROPEAN COMMISSION 
Directorate-General for Transport and Mobility 
Directorate C – Land 
Unit C.1 – Road Transport  
Contact: Katarzyna Kuske (Ms)   
E-mail: katarzyna.kuske@ec.europa.eu  

European Commission 
B-1049 Brussels

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Support study for an impact 
assessment for a possible 
revision of Regulation (EC) No 
561/2006 on driving times, 
breaks and rest periods of road 
transport workers 

Final Report 
Annexes 

Directorate-General for Transport and Mobility  
Driving times, breaks and rest periods of road transport workers 

 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

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Luxembourg: Publications Office of the European Union, 2023 

ISBN: 978-92-68-02172-9 
doi: 10.2832/109842 

© European Union, 2023 
Reproduction is authorised provided the source is acknowledged. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Contents 

Abbreviations and acronyms 

1.  Sector analysis 

1.1  Scope and methodology 
1.2  Key findings 

1.2.1  Market analysis 
1.2.2  Social Aspects 

2.  Stakeholder synopsis report 

2.1  Introduction and consultation strategy 
2.2  Consultation results 

2.2.1  Inception impact assessment 
2.2.2  Targeted interviews 
2.2.3  Public consultation 

3.  Feedback on the inception impact assessment 
3.1  Overview of the inception impact assessment 
3.2  Profile of respondents 
3.3  Business association feedback 
3.4  Company feedback 
3.5  Trade union feedback 
3.6  EU citizen feedback 
3.7  Public authority feedback 
3.8  Conclusion 

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4.  Analytical methods used to assess the baseline scenario 

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4.1  Methodological approach 
39 
4.2  Data collection phase 
4.3  Data used 
40 
4.4  Market share of occasional  transport  within  the passenger bus  and coach 
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sector 
4.5  Modelling approach adopted 
4.6  Future projections for total occasional bus and coach activity 
4.7  Projections of turnover and employment 

5.  Results of the targeted interviews 

5.1  Overview of the approach followed 

5.1.1  Approach to organising the interviews 

5.2  Overarching views and experiences of the current rules 
5.3  Potential changes to the rules 

5.3.1  Potential changes to the rules on breaks during a trip 
5.3.2  12-day rule 
5.3.3  Daily and weekly rest time rules 

5.4  Conclusions 

6.  Analysis of the public consultation results 

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Study on a possible revision of the break time and rest period rules for bus and coach drivers 

6.1  Overview of the public consultation 
6.2  Respondents’ profiles 

6.2.1  Bus and coach operators’ characteristics 
6.2.2  Bus drivers’ characteristics 

6.3  Feedback by EU citizens 
6.4  Overall views on existing rules 
6.4.1  Working conditions 
6.4.2  Road safety 
6.4.3  Quality of services 
6.4.4  Fair competition 
6.4.5  Compliance 
6.4.6  Need for change 

6.5  Potential changes 

6.5.1  Break changes 
6.5.2  Rest period changes 

6.6  Conclusion 

7.  Thematic case studies 

7.1  Case study 1- small bus operators 

7.1.1  Case study summary and conclusions 
7.1.2  Introduction 
7.1.3  Context 
7.1.4  Problems associated with existing legislation 
7.1.5  Expected impacts of the policy options on the market segment 

7.2  Case study 2 – large EU-wide bus and coach operators 

7.2.1  Case study summary and conclusions 
7.2.2  Introduction 
7.2.3  Context 
7.2.4  Problems associated with existing legislation 
7.2.5  Expected impacts of the policy options on the market segment 

7.3  Case study 3 – Medium-sized bus and coach operators 

7.3.1  Case study summary and conclusions 
7.3.2  Introduction 
7.3.3  Context 
7.3.4  Problems associated with existing legislation 
7.3.5  Expected impacts of the policy options on the market segment 

8.  Impacts on stakeholders of the preferred option 

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List of figures 

Figure 2.1: Feedback received by category of respondent .............................................. 24 
Figure 2.2: Country of origin of respondents .................................................................. 24 
Figure 2.3: Types of respondents ................................................................................... 27 
Figure 2.4: Organisations' size ....................................................................................... 28 
Figure 2.5: Overall, do you think that the existing rules on break times are appropriate, or 
should they be changed? ................................................................................................ 29 
Figure 2.6: Overall, do you think that the existing rules on rest periods are appropriate, or 
should they be changed? ................................................................................................ 29 
Figure 3.1: Feedback received by category of respondent .............................................. 33 
Figure 3.2: Country of origin of respondents .................................................................. 33 
Figure  4.1:  Statistical  tests  for  Spain.  Dependent  variable  occasional  national  transport 
(number of passengers) and independent variable Tourism (Expenditure and Investment, 
thousand euro) ............................................................................................................... 53 
Figure 4.2: Summary output for the regression for Spain ............................................... 54 
Figure 6.1: Types of respondents ................................................................................... 84 
Figure 6.2: Organisations' size ....................................................................................... 85 
Figure 6.3: Types of services provided ........................................................................... 86 
Figure 6.4: Percentage of seasonal services across bus operators ................................. 86 
Figure 6.5: Bus drivers' age groups ................................................................................ 87 
Figure 6.6: Share of bus drivers by average hourly wage in 2019 .................................. 88 
Figure 6.7: Frequency of short notice trips ..................................................................... 88 
Figure 6.8: "In your view, to what extent do the existing rules contribute to the following 
aspects?" ....................................................................................................................... 89 
Figure 6.9: “To what extent do you think that changes to make the rules more responsive 
to  the  needs  of  passengers/customers  could  lead  to  improvements  compared  to  the 
current situation?” ......................................................................................................... 90 
Figure 6.10: “To what extent do the existing rules contribute to good working conditions 
for drivers? Please consider the following aspects” ....................................................... 91 
Figure 6.11: “To what extent do you think the rules on rests and breaks contribute to ‘road 
safety’? Please consider the following aspects" ............................................................. 91 
Figure  6.12:  “To  what  extent  do  you  think  the  rules  on  rests  and  breaks  contribute  to 
'efficient and high-quality services'? Please consider the following aspects" ................. 92 
Figure 6.13: "Do you feel that the rules on breaks and rest periods interact with the multi-
manning rules in a way that allows efficient and high-quality services to be organised?"
 ....................................................................................................................................... 93 
Figure 6.14: “Do you think the driving, break and rest rules contribute to fair competition 
between domestic and international services?” ............................................................. 93 
Figure  6.15:  “To  what  extent  do  the  rules  pose  difficulties  with  compliance  / 
enforcement?”................................................................................................................ 94 
Figure 6.16: “Overall, do you consider that the existing rules are appropriate, or that they 
should be changed? Please consider separately for breaks and rest rules?” .................. 95 
Figure 6.17: “Overall, do you consider that the existing rules are appropriate, or that they 
should be changed? Please consider separately for breaks and rest rules: Breaks” (1) . 96 
Figure 6.18: “Overall, do you consider that the existing rules are appropriate, or that they 
should be changed? Please consider separately for breaks and rest rules: Rest times” (1)
 ....................................................................................................................................... 97 
Figure  6.19:  “Two  possible  changes  have  been  identified  to  make  the  organisation  of 
breaks during a trip more responsive to the needs of stakeholders. Please indicate whether 
you  think  either  of  these  changes  should  be  implemented  (NB:  maximum  one  of  these 
changes can be picked)” ................................................................................................ 98 
Figure 6.20: “Do you think that compensatory measures would be needed to prevent the 
deterioration of working conditions under your preferred (set of) change(s)?” ............. 99 
Figure  6.21:  "What  do  you  think  would  be  the  impact  of  the  proposed  change  (break 
change 1) compared to the current rules?" .................................................................. 100 
Figure  6.22:  "What  do  you  think  would  be  the  impact  of  the  proposed  change  (break 
change 2) compared to the current rules?" .................................................................. 100 
Figure  6.23:  “Compared  to  the  situation  with  the  current  rules,  we  would  like  you  to 
estimate  the  impact  that  the  proposed  change  (break  change  1)  would  have  on 
compliance, regulatory costs and business performance. Please select from the relevant 
responses” (1) ............................................................................................................. 101 
Figure  6.24:  “Compared  to  the  situation  with  the  current  rules,  we  would  like  you  to 
estimate  the  impact  that  the  proposed  change  (break  change  2)  would  have  on 

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Study on a possible revision of the break time and rest period rules for bus and coach drivers 

compliance, regulatory costs and business performance. Please select from the relevant 
responses” (1) ............................................................................................................. 102 
Figure 6.25: “Six possible changes have been identified to make the organisation of rests 
during a trip more flexible. Please indicate whether you think any of these changes should 
be  implemented  (NB:  multiple  possible  changes  can  be  picked)  and  explain  your 
preference.  If  you  do  not  favour  any  of  the  changes  listed,  you  can  propose  a  different 
idea, or state that the current rules should be maintained” ......................................... 103 
Figure 6.26: “What do you think would be the impact of the proposed (set of) change(s) 
compared to the current rules?” – Combination of rest period changes 1, 2, 3, 4, 5 and 6
 ..................................................................................................................................... 106 
Figure 6.27: “What do you think would be the impact of the proposed (set of) change(s) 
compared to the current rules?” – Combination of rest period changes 1, 2, 3, and 6 .. 107 
Figure  6.28:  “Compared  to  the  situation  with  the  current  rules,  we  would  like  you  to 
estimate the impact that the proposed change would have on compliance, regulatory costs 
and business performance. Please select from the relevant responses”  – Combination of 
rest period changes 1, 2, 3, 4, 5 and 6 ......................................................................... 108 
Figure  6.29:  “Compared  to  the  situation  with  the  current  rules,  we  would  like  you  to 
estimate the impact that the proposed change would have on compliance, regulatory costs 
and business performance. Please select from the relevant responses”  – Combination of 
rest period changes 1, 2, 3 and 6 ................................................................................. 108 
Figure  6.30:  “Compared  to  the  situation  with  the  current  rules,  we  would  like  you  to 
estimate the impact that the proposed change would have on compliance, regulatory costs 
and business performance. Please select from the relevant responses”  – Combination of 
rest period changes 1, 2, 3, 4, 5 and 6 ......................................................................... 109 
Figure  6.31:  “Compared  to  the  situation  with  the  current  rules,  we  would  like  you  to 
estimate  the  impact  that  the  proposed  change  (rest  period  change  2)  would  have  on 
compliance, regulatory costs and business performance. Please select from  the relevant 
responses” – Combination of rest period changes 1, 2, 3 and 6 ................................... 110 
Figure 7.1: Percentage of turnover in 2019 related to occasional bus and coach services 
(%) by size class .......................................................................................................... 114 
Figure 7.2: Social impacts of current rules, micro and small companies vs large companies
 ..................................................................................................................................... 119 
Figure 7.3: Agreement of small vs large companies towards rest time changes ........... 120 
Figure 7.4: Percentage of turnover in 2019 related to occasional bus and coach services 
(%) by size class .......................................................................................................... 124 
Figure 7.5: Percentage of services that are seasonal (%), by size class ...................... 125 
Figure 7.6: Responses to rest period policy option 3, by size class ............................... 128 
Figure 7.7: Agreement of small vs large companies towards rest time changes ........... 130 
Figure 7.8: Percentage of turnover in 2019 related to occasional bus and coach services 
(%) by size class .......................................................................................................... 134 
Figure 7.9: Dutch companies by company size, 2019 vs 2020 ...................................... 135 
Figure 7.10: "Do you think the driving, break and rest rules contribute to fair competition 
between domestic and international services? When providing responses, please consider 
your  answer  in  terms  of  the  following  aspect,  namely  the  “12-day  derogation”  (Article 
8(6a)  of  Regulation  561/2006),  which  applies  only  to  transport  crossing  international 
borders  as  part  of  a  single  trip,  meaning  occasional  services  taking  place  within  one 
country cannot use the derogation” – Medium-sized companies .................................. 137 
Figure 7.11: Preferences of medium-sized companies across rest period changes ....... 139 

List of tables 

Table 1.1: Types of bus and coach services ...................................................................... 7 
Table 1.2: Total purchases of goods and services – million euros..................................... 8 
Table 1.3: Modal split of passenger transport on land (2019) .......................................... 9 
Table 1.4: Average Age of Buses by country (2020, years) ............................................ 10 
Table 1.5: Comparison between options to optimise driving times and rest periods in the 
bus and coach industry................................................................................................... 12 
Table 1.6: Number of drivers by company size ............................................................... 19 
Table 2.1: Breakdown of the targeted interviews ........................................................... 25 
Table 2.2: Respondents’ country of origin ...................................................................... 27 
Table 2.3: Views by stakeholder group of the proposed policy measures ....................... 29 
Table 4.1: Historical data available in the period between 2012-2019 ........................... 39 

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Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Table 4.2: Historical data available on bus and coach transport activity (total) in the period 
from 2013-2019, from the Statistical Pocketbook in Transport ...................................... 41 
Table  4.3:  Historical  data  available  on  the  number  of  overall  bus  and  coach  passengers 
(total) in the period from 2013-2019 ............................................................................. 42 
Table  4.4:  Historical  data  available  on  the  number  of  national  occasional  bus  and  coach 
passengers in the period from 2013-2019 ...................................................................... 43 
Table  4.5:  Historical  data  available  on  the  number  of  occasional  international  bus  and 
coach passengers in the period from 2013-2019 ............................................................ 44 
Table  4.6:  Historical  data  available  on  the  volume  of  national  occasional  bus  and  coach 
transport (pax-km) in the period from 2013-2019 ......................................................... 45 
Table 4.7: Historical data available on the volume of international occasional bus and coach 
transport (pax-km) in the period from 2013-2019 ......................................................... 46 
Table 4.8: Historical data available on the turnover of other passenger land transport n.e.c 
in the period from 2013-2019 ........................................................................................ 47 
Table  4.9:    Historical  data  available  on  the  number  of  persons  employed  for  other 
passenger land transport n.e.c in the period from 2013-2019 ........................................ 48 
Table 4.10: Share of national and international occasional bus and coach transport for the 
sample of nine countries in 2019 ................................................................................... 49 
Table  4.11:  Occasional  bus  and  coach  transport  activity  (Gpkm)  and  respective  market 
share in relation to the overall bus and coach market in 2019 in the EU-27 ................... 50 
Table 4.12: Occasional bus and coach passenger (thousand) and respective market share 
in relation to the overall bus and coach market in 2019 in the EU-27 ............................ 51 
Table 4.13: Main outputs of the regression analysis ....................................................... 55 
Table  4.14:  Projection  of  the  transport  activity  (in  Gpkm)  in  occasional  bus  and  coach 
sector in the EU-27 in 2019-2050 ................................................................................... 56 
Table 4.15: Growth rates of occasional bus and coach activity in 2019-2050 ................. 57 
Table 4.16: Projection of the number of passengers in occasional bus and coach transport 
for the EU-27 in 2019-2050 ............................................................................................ 58 
Table 4.17: Growth rates of occasional bus and coach passengers in 2019-2050 ........... 59 
Table 4.18: Evolution of the share of occasional bus and coach activity in relation to total 
bus and coach activity in 2019-2050 .............................................................................. 60 
Table 4.19: Evolution of the share of occasional bus and coach passengers in relation to 
total bus and coach passengers in 2019-2050 ................................................................ 61 
Table  4.20:  Estimation  of  number  of  employees  and  turnover  in  the  occasional  bus  and 
coach sector in 2019 ...................................................................................................... 64 
Table  4.21:  Evolution  of  turnover  in  occasional  bus  and  coach  transport  over  the  years 
(EUR million, expressed in 2021 prices) ......................................................................... 65 
Table 4.22: Estimation of the number of companies in the occasional bus and coach sector 
in 2019 ........................................................................................................................... 66 
Table 5.1: Breakdown of the targeted interviews ........................................................... 69 
Table 5.2: Summary of interviewed occasional coach service providers ......................... 70 
Table 5.3: Policy proposals and arguments .................................................................... 73 
Table 6.1: Respondents’ country of origin ...................................................................... 83 
Table 6.2: Stakeholders by category in favour of break change 1 vs break change 2 ..... 99 
Table 6.3: Views on rest period changes 1 to 6 by stakeholder group .......................... 104 
Table 6.4: Distribution of stakeholders' preferences across (set of) rest period change(s)
 ..................................................................................................................................... 105 
Table 7.1: Summary of impacts on the market segment compared to occasional bus and 
coach sector as a whole ............................................................................................... 121 
Table 7.2: Turnover by type of services by size class, 2020, the Netherlands .............. 124 
Table 7.3: Average performance per coach 2019 by size class ..................................... 126 
Table 7.4: Summary of impacts on the market segment compared to occasional bus and 
coach sector as a whole ............................................................................................... 131 
Table 7.5: Share of turnover by type of service, by company class (2021) ................... 133 
Table 7.6: Dutch occasional coach transport industry's performance, 2019 vs 2020 .... 135 
Table 7.7: Summary of impacts on the market segment compared to occasional bus and 
coach sector as a whole ............................................................................................... 139 

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Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Abbreviations and acronyms  

ACEA 

AETR 

European Automobile Manufacturers’ Association  
European Agreement Concerning the Work of Crews of Vehicles Engaged in International 
Road Transport 

CONFEBUS  Confederación Española de Transporte en Autobús 

CORTE 

Conassociation of Organisations in Road Transport Enforcement  

COVID-19  Coronavirus disease 2019 SARS-CoV-2 

CPC 

Certificate of professional competence  

DG MOVE 

Directorate General for Transport and Mobility  

ECR 

EPTO 

ETF 

ETSC 

EU 

Euro Contrôle Route  

European Passenger Transport Organisation 

European Transport Workers Association  

European Transport Safety Council  

European Union 

EU-OSHA 

European Agency for Safety and Health at Work 

EWCS 
FeSMC-
UGT 

European Working Conditions Survey  
Federación de Servicios, Movilidad y Consumo - Unión General de Trabajadores de 
España 

FSC-CCOO  Federación de Servicios a la Ciudadanía - Comisiones Obreras 

GVA 

IA  

ISSG 

IRU 

ITF 

OECD 

PRM 

Gross Value Added 

Impact assessment 

Inter-service steering group 

World Transport Organization 

International Transport Forum 

Organisation for Economic Co-operation and Development 

Persons with Reduced Mobility and other disabilities 

ROADPOL 

European Roads Policing Network  

SME 

SWOV 

TIS 

ToR 

TUI 

Small and medium-sized enterprises 

Institute for Road Safety Research 

Consultores em Transportes Inovação e Sistemas, S.A. 

Terms of Reference 

Touristik Union International 

UNECE 

United Nations Economic Commission for Europe 

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Study on a possible revision of the break time and rest period rules for bus and coach drivers 

1. Sector analysis  

1.1  Scope and methodology  

The desk research has a pivotal role in the study, supporting all strands of the analysis. 
This entails both evidence on the current situation that can feed into the problem definition 
and information that can be used to define assumptions for the forward-looking assessment 
of impacts. On the one hand, obtaining usable data on certain issues from existing sources 
has allowed us to explore and discover new topics relevant for the subject under review. 
On the other hand, it has also enabled us to avoid asking about these same issues via the 
consultation activities (which are more resource-intensive), and thereby organise the work 
more efficiently. In this way, the desk research has played an integral, horizontal role in 
the development of the study methodology and progress is demonstrated throughout the 
report.  

Before presenting the results of the analysis, we need to point out a key limitation, namely 
that  literature  sources  only  marginally  refer  to  the  particular  case  of  the  occasional 
transport  services  and  data  sources  (either  public  or  privately-owned)  with  detailed, 
comparable information on occasional bus and coach transport are very scarce. The lack 
of literature and data can be partly explained by the sub-sector’s limited size. It is also due 
to the highly fragmented nature of the  sector1, coupled with the lack of specific sectoral 
regulations,  both  of  which  reduce  the  need  for  national  authorities  to  collect  granular 
information. Nevertheless, it was important to take stock of the available information and 
identify  to  what  extent  it  was  representative  of  or  could  be  extrapolated  to  cover  the 
occasional  transport  sub-sector.  This  in  turn  helped  to  structure  the  evidence  and 
determine  which  aspects  could  rely  on  previously  existing  sources  and  which  aspects 
needed  to  rely  on  input  from  stakeholders.  Due  to  the  scarcity  of  data  specifically  on 
occasional transport, much – but not all – of the analysis covers the bus and coach sector 
more broadly.  

All  in  all,  this  section  focuses  on  the  relevant  key  findings  from  two  parts  of  the  desk 
research, namely analyses of (1) the market for occasional bus and coach services 
and an overview of the (2) social aspects of the sector.  

1.2  Key findings  

1.2.1 

Market analysis 

This section provides a summary of the market for bus and coach services in the EU and, 
when available, to the specific sub-sector of occasional transport2. It looks at the sector 
from several angles, namely the structure of the sector, employment, market size share 
by country and mode  of transport, fleet characteristics and recent impacts of COVID-19 
pandemic. In all cases, the information provides valuable context for the purpose of making 
extrapolations and inferences based on other sources.  

Structure of the bus and coach market in the EU 

Understanding  the  structure  of  the  market  is  important  because  it  provides  the  context 
surrounding the main actors and their interests. The main evidence gathered comes from 
the  Comprehensive  Study  on  Passenger  Transport  by  Coach  in  Europe  of  20163,  which 

1 Ricardo, Milieu and TRT on behalf of DG MOVE, 2016, Ex-post evaluation of social legislation in road 
transport and its enforcement, Final Report 
2 The sources examined mostly cover the EU27 and the UK. 
3 European Commission, 2016, Comprehensive Study on Passenger Transport by Coach in Europe - 
Comprehensive Study on Passenger Transport by Coach in Europe (europa.eu). 

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Study on a possible revision of the break time and rest period rules for bus and coach drivers 

provides information regarding the overall structure of the market in EU countries. Despite 
being  six  years  old,  it  is  still  a  relevant  source  of  information  with  regard  to  several 
parameters.  It  covers  all  bus  and  coach  services  except  for  urban  and  rural  regular 
services, but also points out that certain Member States use different definitions for bus 
and coach services, particularly between regular and occasional transport. The report also 
distinguishes  between  domestic  and  international  market  services,  describes  terminals4 
and  discusses  the  conditions  of  inclusive  access  for  Persons  with  Reduced  Mobility  and 
other disabilities (PRM).  

The study considers three categories of coach services, as presented in the following table, 
which reflects the provisions laid down in Regulation 1073/2009. 

Table 1.1: Types of bus and coach services 

Type 

Definition 

Typical examples 

Special 
regular 
services 

Regular 
services 

Occasional 
services 

to 

Services  which  provide  the  carriage  of 
passengers  at  specified  intervals  along 
specified  routes,  with  passenger  being 
picked  up  and  set  down  at  pre-
determined  stopping  points,  providing 
the  carriage  of  specific  passenger 
the  exclusion  of  other 
profiles 
passengers.  
All  other  services  which  provide  the 
carriage  of  passengers  at  specified 
intervals  along  specified  routes,  with 
passengers  being  picked  up  and  set 
down at pre-determined stopping points. 
All  other  services,  mainly  characterised 
by the carriage of groups of passengers 
by the customers’ own initiative or by the 
carrier itself. 

Regular / scheduled services not open to 
all passengers, such as: 
•  School  services  serving  only  those 

attending school; and 

•  Staff  services  serving  only  those 
working at designated a location. 

Regular,  scheduled  services  open  to  all 
passengers,  e.g. 
inter-city  services 
between Member States. 

Multi-day  visits  or  tours  requested  by  a 
customer or offered by a carrier. 
Excursions  or  day-trips  requested  by  a 
customer or offered by a carrier. 
Local  excursions  or  day-trips  offered  to 
those already on a multi-day visit or tour. 

Source: Adapted from European Commission, 2016, Comprehensive Study on Passenger Transport 
by Coach in Europe - Comprehensive Study on Passenger Transport by Coach in Europe (europa.eu) 

In terms of market size and share, according to the EU Statistical Pocketbook5, in 2019, 
the transport and  storage  services sector  represented around 624 billion in  Gross Value 
Added  (GVA),  which  accounts  for  5%  of  GVA  in  the  EU-27;  the  data  only  includes 
companies  whose  main  activity  is  business  transport-related,  while  private  transport 
operations are not included. 

Importantly,  Eurostat  database  does  not  contain  any  specific  information  on 
occasional  services  regarding  enterprises.  Rather,  the  closest  available  proxy  is 
“Other passenger transport”. However, this category also includes scheduled long-distance 
bus  services6.  The  table  below  presents  the  figures  in  detail,  showing  that  in  2018  the 
category  of  “Other  passenger  transport”  accounts  for  about  2.3%  of  “Transport  and 

4 A bus terminal, or terminus, is the point where a bus route starts or ends, where vehicles stop, 
turn or reverse, and wait before departing on their return journeys. It is also where passengers board 
and alight from vehicles. It also often provides a convenient point where services can be controlled 
from. Bus Stations and Terminals (ppiaf.org)  
5  European  Commission,  2021,  EU 
figures,  statistical  pocketbook  2022, 
https://op.europa.eu/en/publication-detail/-/publication/14d7e768-1b50-11ec-b4fe-01aa75ed71a1  
6  Eurostat,  2021,  Annual  detailed  enterprise  statistics  for  services  -  Eurostat  -  Data  Explorer 
(europa.eu) 

transport 

in 

7 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

storage”, or EUR 22 billion. This varied from the highest share (6.8%) in Croatia, to just 
0.6% in Latvia.  

Table 1.2: Total purchases of goods and services – million euros  

Transport and storage 

Other passenger land transport 

% of Other in terms of 
Transport and Storage 

2018 

2019 

GEO/TIME 
EU27 (from 
2020) 
BE 
BG 
CZ 
DK 
DE 
EE 
IE 
EL 
ES 
FR 
HR 
IT 
CY 
LV 
LT 
LU 
HU 
MT 
NL 
AT 
PL 
PT 
RO 
SI 
SK 
FI 
SE 
IS 
NO 
CH 
UK 

940 623 
31 658 
6 407 
19 383 
46 646 
228 018 
4 568 
12 746 
9 391 
73 986 
137 061 
3 241 
104 232 
2 322 
4 161 
8 002 
4 750 
14 077 
1 788 
61 893 
31 026 
47 206 
14 813 
15 021 
4 151 
7 262 
15 170 
31 621 
2 634 
30 937 
47 744 
128 565 

35 700 
6 675 
19 659 
46 890 
223 106 
4 219 
18 878 
9 736 
78 990 
141 921 
3 365 
105 582 
2 504 
4 154 
8 750 
4 727 
14 479 
2 186 
64 409 
30 790 
50 562 
15 769 
15 971 
4 278 
7 322 
15 641 
32 113 

31 338 
50 323 

2018 

22 041 
287 
149 
410 
303 
2 422 
98 

564 
2 351 
5 988 
221 
2 154 
19 
24 
57 
201 

1 164 
464 
519 
131 
137 
252 
299 
116 
283 

2019 

357 
157 
467 
36 
2 285 

2 391 
5 637 
208 
2 242 
21 
25 
71 
178 

49 

1 226 
501 
504 
129 
143 

299 

2018 

2.3% 
0.9% 
2.3% 
2.1% 
0.7% 
1.1% 
2.1% 

6.0% 
3.2% 
4.4% 
6.8% 
2.1% 
0.8% 
0.6% 
0.7% 
4.2% 

2.5% 
3.1% 
3.5% 
3.1% 
1.9% 
1.7% 
0.9% 
4.4% 
0.9% 

2019 

1.0% 
2.4% 
2.4% 
0.7% 
1.0% 

3.0% 
4.0% 
6.2% 
2.1% 
0.8% 
0.6% 
0.8% 
3.8% 

2.3% 

2.4% 
3.2% 
3.2% 
3.0% 
2.0% 

0.9% 

1 825 
Source: Adapted from Eurostat, 2021, Annual detailed enterprise statistics for services (NACE Rev. 
2 H-N and S95) 

1.4% 

Regarding the activity expressed in passenger-kilometres, there are some figures 
for  bus  and  coach  transport  (though  again  with  no  distinction  for  occasional). 
According to the EU Statistical Pocketbook, in 2019 bus and coach transport represented 
8.1% of total passenger kilometres in the EU-27, i.e. 487.5 Gpkm billion pkm. This makes 
bus and coach transport (importantly including intra-urban as well as other services) the 
second-most-used  mode  of  transport,  albeit  far  behind  passenger  cars,  which  represent 
81.3% (i.e. 4,325 billion pkm).  

In terms of trends in modal split, the share of buses and coaches was 10.4% in 1995 
(468  billion  pkm)  and  has  been  decreasing  over  the  years.  The  average  modal  split  for 
buses and coaches in the EU-27 in 2019 was only of 8.1%. When breaking down the modal 
split of passenger transport on land transport, the share for EU-27 is 9.1%. For the Member 
States,  Hungary  is  the  country  with  the  highest  percentage  of  bus  and  coach  trips 
(representing  19.5%),  followed  by  Cyprus  (18.5%)  and  Romania  (18.0%).  Shares  are 
much  lower  in  the  Netherlands,  Germany  and  France,  with  3.1%,  5.7%  and  6.2%, 
respectively. Since these figures refer to the bus and coach sector as a whole, it is difficult 
to ascertain their relationship to occasional transport.  

8 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Table 1.3: Modal split of passenger transport on land (2019) 

Country 

BE 

BG 

CZ 

DK  DE 

EE 

IE 

EL 

ES 

FR 

HR 

IT 

CY 

LV 

LT 

LU 

PKM in % 

10.2  15.1  14.8  9.1  5.7  17.5  14.8  15.8  8.1  6.2  13.1  11.4  18.5  11.9  8.4  12.5 

Country 

HU  MT 

NL 

AT 

PL 

PT 

RO 

SI 

SK 

FI 

SE 

IS 

NO 

CH  UK 

EU27 

PKM in % 

9.1 
Source: European Commission, Table 2.3.3. Statistical Pocketbook 2022 – EU Transport in Figures 

11.7 

11.2 

17.1 

11.8 

19.5 

18.0 

15.8 

3.1 

5.9 

5.1 

9.4 

7.1 

9.8 

7.1 

4.0 

Turning  to  the  data  that  is  available  on  occasional  bus  and  coach  transport,  this 
was  often  patchy,  hard  to  verify  or  inconsistent.  This  assumption  is  aligned  with  the 
preliminary desk research carried out, which screened a significant number of statistical 
agencies  (EUROSTAT,  UNECE,  ITF,  etc),  all  of  which  applied  different  taxonomies  of 
occasional coach services. Moreover, it is worth mentioning that some figures from these 
databases  do  not  exactly  correspond  to  those  found  in  the  national  databases  of  EU 
Member States, EEA-EFTA countries, Switzerland and the UK. 

However,  data  extracted  from  the  United  Nations  Economic  Commission  for  Europe 
(UNECE) databases has allowed us to find some generally  consistent data on passenger 
numbers and / or passenger kilometres for 15 Member States for the specific subsector of 
the occasional bus and coach transport7. This was then used to make the extrapolations 
about the evolution of the baseline scenario, which is discussed further in Annex 4.  

The national statistics agencies give additional clues on how big the occasional  transport 
sector is. In Spain8, occasional bus transport accounts for 22% of the overall revenue of 
bus and coaches in the country. The national statistics agencies allow us to infer that the 
market for bus and coach services is larger in typical tourism destinations such as Spain. 
For  instance,  occasional  transport  represents  4.3%9  of  the  total  number  of  passengers 
transported  by  public  transport  in  Spain  for  2019.  On  the  other  hand,  in  Portugal, 
occasional  domestic  services  of  bus  and  coaches  represented  2.8%10  of  national  road 
transport  (accounting  for  14.5  million  passengers)  in  2017  and  1.18%11  (in  2018)  of 
national transport in Germany. 

It is important to point out that the figures from the official agencies referred to above are 
defined differently and thus are difficult to compare. For instance, the share of Spain refers 
to the total number of passengers by public transport (including international passengers) 
while for Portugal it refers only to domestic services. As explained in the baseline section 
(see  Annex  4),  there  was  a  necessity  to  use  the  same  indicator  for  comparison.  This 
indicator was the number of passengers on occasional national transport and its share on 
the national transport. With this indicator we have estimated an average market share of 
national occasional bus and coach passenger transport in relation to the overall national 
bus and coach  sector  – the calculations and assumptions are  explained in  Section 4– of 
3.31% for the European Union. 

Furthermore, the data that the team was able  to collect  (and to present in the baseline 
section) regarding the number of passengers of the sector and sub-sector (expressed in 

7  Austria,  Croatia,  Czech  Republic,  Estonia,  Finland,  Germany,  Hungary,  Lithuania,  Netherlands, 
Poland, Portugal, Romania, Slovakia, Spain and Sweden (data from UNECE database, updated with 
information until 2019 and from Comprehensive Study on Passenger Transport by Coach in Europe 
(europa.eu, 2016)) 
8 CONFEBUS, 2019, El bus, una visión de presente y futuro: Liderando el cambio de rumbo para la 
movilidad sostenible de las personas. Memoria-ElAutobusEnEspana_2019.pdf (confebus.org) 
9 Notas de prensa de INE (Instituto Nacional de Estadística) - Notas de prensa de INE 
10 INE Statistics Portugal, 2017, Estatísticas dos Transportes e Comunicações, Portal do INE  
11  UNECE,  Bus  and  coach  statistics  by  Topic,  Type  of  activity,  Country  and  Year, 
https://w3.unece.org/PXWeb2015/pxweb/en/STAT/STAT__40-TRTRANS__02-
TRROAD/05_en_TRBUSCOACH_r.px/  

9 

 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

thousand-pax), has enable us to conclude that the share of international services of bus 
and coach is very low in the total market. For instance, according to our estimations, the 
EU average share of international occasional services out of the total bus and coach sector 
was of 1.6% in 2018. Therefore, there seems to be currently relatively few services that 
can  make  use  of  derogations  to  Regulation  561/2006,  such  as  the  12-day  derogation, 
which only applies to international services. 

The share  of international  occasional services  varies significantly across Member States, 
representing 0.29% of the total bus and coach services in Poland, where domestic tourism 
seems to prevail, a slightly higher share in Estonia (2.2%) and a bigger but not significant 
proportion in Hungary (5.1%), where the proportion of tourists engaged in multi-country 
tours seems to be higher. 

Fleet characterisation 

The number of buses and coaches and – especially – the characteristics of the fleet may 
have implications for the environment and road safety. It is thus important to understand 
how  these  aspects  have  evolved  in  recent  years.  These  aspects  vary  significantly  by 
Member State, reflecting such factors as the influence of the public sector on the bus and 
coach market in some countries and types of services most frequently provided. 

The best available evidence on fleet characteristics comes from the European Automobile 
Manufacturers’  Association  (ACEA),  which  provides  relevant  information  in  their  annual 
report12.  According  to  the  latest  report  from  2020,  around  684,285  buses  are  operating 
throughout  the  EU,  almost  half  of  which  are  in  Poland,  Italy  and  France.  The  two  latter 
Member  States  are  amongst  the  largest  occasional  passenger  markets,  whilst  Poland  is 
renowned for being a relevant bus manufacturer and exporter to foreign customers. 

The average age of buses on EU roads is 12.8 years, but there is considerable diversity: 
Greece has the oldest fleet (19.4 years) and Austria the newest (4.9 years). Diesel buses 
make  up  93.5%  of  the  EU  fleet,  with  only  1.4%  comprised  of  hybrid  electric  and  0.9% 
battery electric; nonetheless, there are countries with a significant share of electric buses, 
such as Netherlands and Luxembourg (12.4% and 6.6% respectively). Furthermore, the 
yearly  publication  of  the  Commission’s  Statistical  Pocketbook  presents  the  information 
regarding the stock of buses and coaches, which shows a decrease in the  EU of 1.6% in 
2020 when comparing with 2019 of registrations. 

Table 1.4: Average Age of Buses by country (2020, years) 

Country 

Avg age 

AT 

4.9 

BE 

BG 

HR 

CY 

CZ 

DK 

EE 

11.1 

13.5 

14.6 

10.5 

13.6 

FI 

12 

FR 

8.1 

DE 

8.4 

EL 

HU 

IE 

IT 

19.4 

12.6 

11.7 

14.3 

LV 

12 

Country 

Avg age 

LT 

14.4 

LU 

5.4 

MT 

NL 

9.3 

PL 

PT 

RO 

SK 

SI 

ES 

SE 

IS 

NO 

15.6 

14.7 

18.1 

11.3 

10.1 

11.4 

6.5 

14.2 

9 

CH 

7.9 

UK 

EU27 

11.4 

12.8 

Source: Data from ACEA, Vehicles in Use Europe 2022 

Impact of COVID-19  

The COVID-19 pandemic has a significant impact on the occasional transport market, which 
has seen demand plummet. The entire transport sector has faced great difficulties, which 
has had a direct impact on transport companies’ revenues, limiting mobility and tourism13. 

12 ACEA, 2022, ACEA-report-vehicles-in-use-europe-2022.pdf  

13  Panteia  and  Università  degli  Studi  Roma,  Research  for  TRAN  Committee: 
Relaunching transport and tourism in the EU after COVID-19, 2021, 

10 

 
 
 
 
 
 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

In this respect, the International Road Transport Union (IRU) estimated a revenue loss of 
up to 82% in the European bus and coach sector for tourism in 2020 14. The International 
Labour  Organisation15,  based  on  IRU  research  and  reports,  predicts  that  long-distance 
international coach services fell by 100 per cent while national long-distance have declined 
by 90 per cent immediately after the outbreak of the pandemic. Although there are scarce 
desk research sources regarding the recovery of the sector following the initial impact of 
COVID-19, it became evident that during the pandemic the services of occasional coaches 
was  residual  or  even  null.  As  seen  in  the  dedicated  case-studies,  this  trend  eventually 
impacted  more  severely  SMEs  and  individual  drivers  who  have  less  liquidity  and  fewer 
opportunities to allocate manpower and their  assets to other  services (e.g. urban public 
transport) and that as result might been forced to close or open bankruptcy.  

1.2.2 

Social Aspects  

This part of the desk research aims at providing an overview of the social aspects related 
to  bus  and  coach  sector.  Social  rules  for  road  transport  have  been  set  up  in  Regulation 
(EC)  No  561/2006  to  secure  a  reasonable  and  healthy  working  environment  for 
professional drivers and to contribute to the efforts of continuously improving road safety 
conditions  by  requiring  professional  drivers  to  take  adequate  rests  and  breaks.  Such 
conditions are equally relevant for increasing the profession's attractiveness and ultimately 
for providing a high-quality service to passengers and ensuring fair competition conditions 
for road transport operators. 

Once again, it is important to note that, although several  sources have been consulted, 
they  usually  refer  to  the  sector  itself  and  do  not  specify  on  occasional  bus  and  coach 
services. Consequently, interviews with stakeholders and the public consultation were very 
important to complement the information regarding the sub-sector. This subsection starts 
with  an  overview  of  aspects  regarding  working  conditions,  followed  by  road  safety, 
infringements and employment conditions.  

Working Conditions  

ETF (the European Transport Workers’ Association) has consistently emphasised16 that the 
work environment in road transport is often poor. Moreover, the Association claims that, 
as new business models and platforms arise (such as, ´lean platforms´ in the transport 
sector  like  Uber,  and  coaches’  platforms  like  Flixbus17),  working  conditions  are  often 
downgraded – with labour conditions more insecure, payments less predictable and with 
more demand.  

A pilot study for the International Road Transport Union (IRU) on social rules18 examined 
the current EU regulatory framework on driving times and rest periods in the passenger 
road transport sector and its impact both on the sector’s business activities and on drivers’ 

in  sight 

IRU,  2019,  No  end 

to  pandemic-induced  passenger 

https://www.europarl.europa.eu/thinktank/en/document.html?reference=IPOL_STU(202
1)690884  
14 
https://www.iru.org/resources/newsroom/no-end-sight-pandemic-induced-passenger-transport-
crisis  
15 International Labour Organisation, 2020, ILO sectoral Brief, COVID-19 and road transport 
16  ETF  Report,  2018,  Driven  to  distraction?  Long-distance  coach  and  bus  drivers  in  the  EU, 
https://www.etf-europe.org/wp-content/uploads/2018/09/ETF-report-on-woking-conditions-of-bus-
and-coach-1.pdf. 
17 German company that owns a platform, provides administration and permission and does not own 
any bus or employees any drivers. 
18 TRT on behalf of IRU, 2015. A Pilot Study on Specific Driving and Rest Time Rules for Bus and 
Coach  Drivers  in  the  EU,  https://www.transportforetagen.se/globalassets/rapporter/buss/pilot-
study-on-specific-driving-and-rest-time-rules-for-bus-and-coach-drivers-in-the-
eu?ts=8d98cb9e34dc900  

transport  crisis, 

11 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

working  conditions.  To  understand  the  adequacy  of  the  application  of  the  current  EU 
legislation in the overall passenger sector, the study undertook a survey in 2015 on road 
passenger  transport  companies  and  drivers  operating  in  seven  EU  Member  States 
(Belgium,  Czechia,  Germany,  Italy,  Lithuania,  Romania,  and  Sweden)  and  the  United 
Kingdom. Respondents were asked to express their views on two possible options (option 
A  –  “do-nothing  scenario”  vs.  option  B  –”  changes  on  the  requirements  laid  down  in 
Regulation (EC) No 561/2006” for five thematic items), as presented on the following table.  

Despite  the  results  presented  below,  it  is  important  to  mention  that  the  sample  of 
respondents  (in  terms  of  participants  by  country)  is  not  at  all  well  balanced  among 
countries, with Germany, Belgium and the United Kingdom accounting for more than two-
thirds of the responses in both groups of commercial transport operators and drivers. It is 
also worth pointing out that the survey was conducted on behalf of the International Road 
Transport Union (IRU), which represents transport operators and might therefore display 
a certain bias, even if unintentional. 

Table 1.5: Comparison between options to optimise driving times and rest periods 
in the bus and coach industry 

Item 

Option A  
(keeping the requirements as currently laid 
down in Reg. (EC) 561/2006) 

Option B  
(changing requirements as under the 
previous rules set in Reg. 3820/85/ECC) 

Operat
or 
appreci
ation 

Driver 
appreciati
on 

12% 

34% 

Description 

Increase to 16 
hours 

Operator 
appreciati
on 

Driver 
appreciati
on 

82% 

59% 

Description 

15 hours  
(24 hours – 9 hours 
daily rest) 

Daily 
duty 
time 
(and 
daily 
rest) 

Weekly 
rest 

45 consecutive hours 
(or more) 

9% 

36% 

12-day 
deroga
tion 

Two combined  regular 
rest  periods  (i.e.,  90 
hours)  or  one  regular 
weekly rest (min. 45h)  

13% 

38% 

The journey must be a 
single trip and must be 
spent  in  one  Member 
State (or in a different 
country 
from  where 
the journey started) at 
least  24  consecutive 
hours  

12 

79% 

60% 

78% 

62% 

45 hours 
(regular weekly 
rest) and at 
least 24 hours 
taken as 
compensation 
during a 13-
week reference 
period (if not 
taken during 
the same week)  

rest 
Weekly 
could 
be 
postponed  until 
the  end  of  the 
driving 
12th 
and 
period 
added 
the 
second  week’s 
rest 
weekly 
period; 

to 

No  single  trip 
limitation 
and 
no  extra  weekly 
rest  required  - 
to 
extended 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

national 
occasional 
passenger 
transport 
international 
services  at  EU 
level 

and 

45 min. break 
as a whole or 3 
periods of at 
least 15 min. 
each 
(after 4.5h of 
cumulative 
driving) 

Single-manned 
for  at 
vehicle 
least  the 
first 
and (preferably) 
the last 4.5 hour 
driving period of 
the journey 

77% 

68% 

81% 

64% 

Breaks 

45 min. break or at 
least 15min. followed 
by 30min. 
(after a driving period 
of 4.5h) 

16% 

37% 

12% 

39% 

Multi-
mannin
g 

any 

A second driver in the 
vehicle  is  needed  for 
each  period  of  driving 
between 
two 
consecutive  daily  rest 
periods (or between a 
daily rest period and a 
weekly  rest  period). 
For  the  first  hour  of 
multi-manning, 
the 
presence  of  another 
driver  or  drivers  is 
the 
optional 
remainder 
the 
period is compulsory. 

but 
of 

Source: Adapted from TRT, 2015, A Study on Specific Driving and Rest Time Rules for Bus and 
Coach Drivers in the EU (transportforetagen.se) 

The results of the survey revealed that a great majority of respondents (more prominently 
transport companies, but  also most drivers) consider the current body of  social  rules to 
be: 

•  extremely relevant for road safety; 

•  adequate for guaranteeing healthy working conditions; 

• 

inadequate  to  meet  the  specificities  and  needs  of  the  road  passenger  transport 
segment, negatively affecting their business activity by increasing operational costs 
and lowering the quality of customer services,  thus endorsing IRU’s proposals of 
amendments to Regulation 561/2006.  

The main conclusions of the pilot study for IRU were relevant to assess the validity of the 
measures  under  review  in  the  current  assignment.  The  study  combined  a  consultation 
exercise involving transport operators and drivers with an assessment of the fatigue and 
risk index (using an index designed by the UK Health and Safety Executive19) for the two 
scenarios. The results seem to indicate that the removal of the exceptions for the 12-
day derogation and the weekly rest periods could result, in all option scenarios 
tested, in lower average fatigue levels. The levels of fatigue do not seem to be affected 
with regard to the proposed options on break rules. These results suggest that a higher 

19 The fatigue and risk index consists of a biomathematical model whose interpretation can be found 
here: https://www.hse.gov.uk/research/rrhtm/rr446.htm   

13 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

flexibility  in  arranging  driving  and  resting  patterns  that  would  result  from  the  proposed 
IRU’s  amendment  might  allow  increased  operational  efficiency  of  the  industry  without 
damaging social conditions: 

•  On breaks, drivers would favour a return to the previous normative  setting with 
the possibility of introducing a higher fractioning of the break periods (e.g. dividing 
the break period in up to three breaks of 15 minutes each). In their view (shared 
by companies), this would allow a better management of the service with benefits 
for the customers as breaks would be organised in such a way as to be more tailored 
to passengers’ needs.  

•  On  daily  rest  and  maximum  daily  duty  time,  companies  underline  the  risk  of 
exceeding permitted duty hours due to unforeseen delays or the negative impacts 
in terms of costs. 

•  On  the  12-day  derogation,  most  companies  are  in  favour  of  a  revision  of  the  current 
requirements on the 12-day derogation rule,  which  should also entail the abolition of the single trip 
limitation,  along  with  its  extension  to  national  occasional  passenger  transport.  Most  drivers  also 
advocate a new regulatory setting for the 12-day derogation due to the perceived understanding that 
this change would improve the quality of services provided to customers.  

This study also sheds light on other parameters that are relevant for describing the working 
conditions of occasional transport. In terms of employment status, 91% of drivers declared 
being employed in a private company (73% full-time and 18% part-time) while 9% being 
owner  drivers.  Another  interesting  though  not  surprising  result  is  related  with  the 
representativity  by  gender  in  this  sample  of  road  transport,  for  which  male  drivers  are 
completely predominant (97% of respondents). 

The TRT study20 has also focused on the differences between freight and passenger 
road  transport,  the  latter  being  characterised  by  its  high  seasonality,  different 
length of trips and high standards for the service (breaks, route planning, stopovers, 
etc.).  Another  relevant  difference  is  the  amount  of  time  spent  driving,  with  road 
passengers’  drivers  driving  less  time  continuously  than  road  freight  drivers. 
Nevertheless, there are also similar issues between  freight and passenger transport that 
need to be addressed when debating working conditions, namely drivers’ fatigue. Indeed, 
fatigue is considered endemic to driving, because it is affected by the performance of 
monotonous tasks. 

According to the TRT study and the ETF report21, while there are many ways of defining 
driver fatigue, both studies agree that it is a state caused by prolonged exertion, being a 
condition  that  manifests  itself  physiologically,  cognitively  and  emotionally.  Fatigue  can 
have  many  effects  on  drivers,  namely  loss  of  attention,  decreased  reaction  time,  poor 
speed tracking and steering control. Although the list of symptoms of driver fatigue may 
be longer, it is widely understood that fatigue poses a serious problem for road safety.   

The  ETF  report  shows  that  the  main  contributors  to  fatigue  are  related  to  working  time 
(totalling more than 40 hours per week), irregular working schedules (with rotating and 
night shifts), as well as consequently irregular and interrupted sleep patterns. Moreover, 
drivers often work in harsh and uncomfortable environmental conditions (e.g. exposure to 
heat/ cold weather conditions, noise, poor road conditions, high-density traffic), which also 
contribute to fatigue.  

20 TRT on behalf of IRU,  2015. A Pilot Study on Specific Driving and Rest Time Rules for Bus and 
Coach  Drivers  in  the  EU,  https://www.transportforetagen.se/globalassets/rapporter/buss/pilot-
study-on-specific-driving-and-rest-time-rules-for-bus-and-coach-drivers-in-the-
eu?ts=8d98cb9e34dc900. 
21 ETF, Driver Fatigue in European Road Transport, 2021 - Report.pdf (etf-europe.org) 

14 

 
 
 
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One research carried out in Norway points out that fatigue is reduced among passenger 
drivers who work in more stimulating environments22. Indeed, driving a coach is not 
as lonely as truck driving. This trait has been found to have a profound effect on fatigue, 
which is affected by the performance of monotonous tasks, less prominent in the passenger 
sub-sector. 

The  European  Agency  for  Safety  and  Health  at  Work  (EU-OSHA)  also  highlights  the 
importance of ensuring adequate working conditions to guarantee a skilled and motivated 
workforce.  According  to  a  report23  published  by  the  Agency,  special  issues  that  have  a 
negative impact on the working conditions of freight transport drivers include many aspects 
that  are  also  applicable  to  drivers  transporting  passengers  for  occasional  services.  For 
instance, prolonged sitting and exposure to vibration was identified as a major trigger for 
fatigue.  In  addition,  the  report  also  included  case  studies  from  the  passenger  transport 
sector  which  suggest  that  flexible  resting  times  helps  to  keep  schedules  on  time. 
This result will, in turn, lead to lower levels of stress on drivers.  

Thus, stress significantly affects the performance of the drivers. According to the ex-post 
evaluation  on  the  social  legislation  in  road  transport24  there  are  several  factors  that 
contribute  to  stress,  such  as  “performance-based  payments”  (which  contribute  to  non-
compliance  with  the  rules,  and  consequently  increases  fatigue  and  stress),  long  periods 
away from home and time pressure. The latter is an aspect in which road social legislation 
on working time, driving times and rest periods might have a more direct impact due to 
the need to accommodate both the requirements from operators and passengers, besides 
the need to cope with uncertain driving conditions. 

Moreover, the last two studies (the EU-OSHA report and Ex-post evaluation) refer to the 
direct impact of bus and truck driving on drivers’ health. These drivers are more exposed 
to several dangerous and stressful situations, which make them more prone to accidents 
and  to  suffering  serious  injuries  when  compared  to  occasional  coach  drivers,  who  often 
have  to  cater  to  customers’  needs,  thus  providing  more  comfortable  and  customised 
journeys.  Together  with  long  and  often  unsocial  working  hours  (outside  the  traditional 
9am-5pm schedule, for instance night or weekend shifts), besides driving alone and with 
no social interaction, with little opportunity to exercise and relying on convenience food, 
road drivers are also more likely to develop unhealthy lifestyles which may lead to severe 
health conditions (e.g. obesity, cardiovascular disease, depression) than occasional coach 
drivers. 

Road safety 

The EU has been devoting significant attention to road safety and experienced enormous 
progress in that regard, particularly in the past two decades. Regulation (EC) No 561/2006 
is a cornerstone of these efforts. 

According to the European Road Safety Observatory25, the number of fatalities involving 
bus/coach accidents has been experiencing a downward trend in most EU countries. In the 
EU27,  in  2010  there  were  788  fatalities  involving  crashes  of  buses  and  coaches,  which 
represents 2.7% of total road deaths in EU, while in 2018, there were 585 fatalities which 
represents  a  share  of  2.5%  of  road  deaths.  By  analysing  the  fatalities  per  million 

– 

sea 

and 

transport 

22 Norwegian Centre for Transport Research, 2014, An assessment of studies of human fatigue in 
land 
II, 
https://www.toi.no/getfile.php?mmfileid=39679  
23 EU-OSHA, 2011, Managing risks to drivers in road transport  – European Agency for Safety and 
Health at Work, https://osha.europa.eu/en/publications/managing-risks-drivers-road-transport  
24  European  Commission,  2016,  Ex-post  evaluation  of  social  legislation  in  road  transport  and  its 
enforcement - Publications Office of the EU 
25 
facts_figures_buses_and_hgv_final_20210323.pdf 

Observatory, 

Transport 

European 

Figures, 

Fatigue 

Report 

Safety 

2020, 

Facts 

Road 

and 

in 

15 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

inhabitants  resulting  from  crashes  of  bus  and  coach,  we  can  see  the  highest  rate  in 
Bulgaria, with 5.1 deaths per million inhabitants – one of the reasons why this country was 
selected  as  part  of  the  sample  of  countries  subject  for  in-depth  analysis  in  this  study  – 
followed  by  Romania  and  Hungary,  both  with  3.4.  In  comparison,  in  the  Netherlands, 
Germany, Sweden and France, the fatalities per million inhabitants are less than 1. When 
one looks to the annual number of bus and coach fatalities of passengers travelling inside 
the  bus  and  coaches,  we  can  also  see  a  downward  trend:  in  2010  there  has  been  115 
fatalities while in 2019 the number has fallen to 84 fatalities26, as identified in the latest 
report from the same EU road safety Observatory. 

One of the main factors pointed as a cause of road accidents is fatigue, in particular the 
impacts of drivers’ sleep deprivation. In fact, according to the same ETF report and also 
the  TRT  study,  most  drivers  (66%  of  bus  and  coach  drivers  and  60%  of  truck  drivers) 
regularly  feel  tired  while  driving  and  around  a  quarter  to  almost  a  third  of  professional 
drivers admit having fallen asleep while driving, at least once in the previous twelve months 
(24% of the bus and coach drivers and 30% of truck drivers). However, the studies carried 
out by ETF and TRT point out that the extent of this problem seems to be underestimated 
as most accident reports and databases are poor and limited, considering fatigue only in 
crashes  where  driver  has  fallen  asleep,  while  there  is  evidence  that  other  fatigue  signs 
(e.g., drivers’ inattention or doing mistakes) are a contributory factor of road crashes.  

A  more  unexpected  factor  related  to  road  safety  is  mentioned  on  the  EU-OSHA  report: 
violence  to  passenger  transport  drivers,  including  violence  from  schoolchildren.  These 
situations  can  lead  to  several  consequences,  from  drivers’  stress,  staff  injuries,  vehicle 
damages and even road accidents. Yet, various case studies demonstrate that it is possible 
to deal with this issue  by presenting measures that involve  children,  allowing to control 
risks and improve safety for these drivers. Although the study does not necessarily report 
on this group, intoxicated passengers may often pose a threat to drivers’ well-being while 
on the wheel, which is usually experienced by workers in the occasional transport sector 
when transporting customers to specific parties and events. 

Another study on road safety from SWOV27 compares the safety of buses in traffic with the 
safety  of  other  transport  modes  (passenger  car,  train  and  airplane)  in  seven  European 
countries in terms of risk factors (i.e. number of causalities per distance travelled by vehicle 
occupants).  The  results  showed  that  buses  appear  to  be  safer  than  cars  but  more 
dangerous than train and airplane. It is important to mention that the comparison of safety 
between these modes was made in terms of “occupant risk” (deaths “inside the vehicle”), 
which may not illustrate the factual fatality risk, especially for trains - in which more than 
85%  of the  reported rails deaths  were  excluded (as it was not clear  whether they  were 
inside  or  outside  the  train),  as  pointed  out  by  SWOV.  Therefore,  if  considering  the  risk 
“outside the vehicle” (with coaches being involved), buses appear to be more dangerous 
than cars. In terms of ratio of the risk outside/inside the bus per country, Denmark and 
the  Netherlands  are  the  countries  with  the  highest  ratios,  thus  a  lower  number  of 
causalities “inside the bus” than “outside the bus”. 

Infringements  

Article 17 of Regulation (EC) No 561/2006 requires the EC to publish, on the basis of the 
information communicated by each Member State, a biannual report giving an account of 
the level of checks at the roadside and at the premises of transport undertakings. While 
the  levels  of  infringement  cannot  be  disaggregated  for  occasional  transport,  the 

26 European Road Safety Observatory, Annual statistical report on road safety in EU 2020 - Annual 
statistical report on road safety in the EU, 2020 (europa.eu) 
27  Institute for Road Safety Research - SWOV, 2019, Coaches and road safety in Europe 

16 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

implementation report in 2017-201828 of EU Social rules in road transport (which includes 
Regulation  (EC)  No  561/2006,  also  known  as  the  Driving  Time  Regulation;  Directive 
2002/15/EC, known as the Road Transport Working Time Directive; Directive 2006/22/EC, 
known  as  the  Enforcement  Directive;  and  Regulation  (EU)  No  165/2014,  known  as  the 
Tachograph Regulation) states that the  total number of offences  (but not disaggregated 
per occasional bus and coach sector) were of around 3.41 million, representing a slightly 
lower number than the one presented in the report for the 2015-2016 period, which was 
of  3.46  million;  however,  a  more  detailed  overview  of  the  ratio  of  offences  per  type  of 
passenger  transport  activity  shows  a  contrasting  upward  trend,  with  3.55  offences  per 
million PKM being observed in 2015-2016 and 3.61 in the subsequent period.  

Regarding  the  type  of  infringements,  rest  period  infringements  represented  23%,  and 
break  time  infringements  represented  17%  (a  decrease  from  21%  in  the  latest  report), 
while driving recording time accounted for 27%, driving time for 14%, recording equipment 
12% and lack/availability of records for other work 6%.  

With  regard  to  working  time  records,  the  ETF  study  on  driver  fatigue  shows  that  some 
coach drivers are often assigned to carry out extra activities (such as loading/unloading 
goods or luggage, selling drinks and snacks), and being instructed by their employers to 
register that time spent as break time, rather having appropriate breaks. 

According  to  another  ETF  report29,  road  transport  enforcement  agencies  are  under-
resourced, and  often have to deal with complex technical and social  aspects, as well as 
with arising new business models. This pressing issue was under the spotlight in a debate 
organised by IRU on the enforcement of Mobiliy Package 1 rules in September 2022. 

EuroContrôle Route, quoted in the above-mentioned report from ETF, reveals that, across 
Europe, there has been a 75 per cent reduction in the capacity (personnel and resources) 
of  European  road  traffic  enforcement  agencies  following  the  financial  crisis  of  2008. 
Nevertheless, the EU implementation reports still identify extensive violation in relation to 
drivers’  hours  during  inspections.  All  in  all,  as  previously  mentioned  in  the  section  on 
working conditions, the ex-post evaluation of social legislation from EU highlights that some 
illicit employment practices have adverse effects on drivers, and which may contribute to 
increased infringement levels. 

The ex-post evaluation also sheds light on these matters by highlighting that, for instance, 
some  Member  States  have  eliminated  the  use  of  the  attestation  forms  to  attest  driver 
activities  (as  required  per  Article  17  of  Regulation  (EC)  No  561/2006  for  attesting 
unrecorded  activities,  or  other  proof,  for  proving  such  activities).  This  is  especially 
important  in  occasional  transport,  because  the  nature  of  the  services  means  that  the 
activities  of drivers are especially  difficult to record with tachographs. As highlighted by 
the CORTE working group, approaches vary widely, for instance with drivers being fined 
for not having the form in France while it is considered irrelevant in other countries. Aside 
from causing  compliance problems, this problem reduces the availability of detailed  and 
comparable data. 

The lack of a uniform application of enforcement methods across MS, leads to distortions 
in the way the rules are applied by different operators within the EU sector. It  was also 
found (and corroborated during the preliminary interviews) that  some coach drivers are 

28 Report from the Commission to the European Parliament and the Council on the implementation 
in  2017-2018  of  Regulation  (EC)  No  561/2006  on  the  harmonisation  of  certain  social  legislation 
relating to road transport and of Directive 2002/15/EC on the organisation of the working time of 
persons  performing  mobile  road  transport  activities,  SWD,  2021  EUR-Lex  -  52021DC0610  -  EN  - 
EUR-Lex (europa.eu)  
29  ETF  Report,  2018,  Driven  to  distraction?  Long-distance  coach  and  bus  drivers  in  the  EU, 
https://www.etf-europe.org/wp-content/uploads/2018/09/ETF-report-on-woking-conditions-of-bus-
and-coach-1.pdf   

17 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

often assigned to carry out extra activities and forced to register that time spent as break 
time. Hence, the problem of accumulated fatigue might not be laid down in the current set 
of rules for drivers breaks and rests but rather on the enforcement mechanisms to control 
violations and enforce the rules. It is thus important that rules on breaks, rests and driving 
periods  are  revised  in  a  way  that  would  encourage  good  compliance  among  drivers 
performing occasional passenger services. 

Employment and attractiveness to the sector 

According  to  the  EU  Statistical  Pocketbook30  the  transport  and  storage  service  sector 
employed 10.5 million people in 2019, of which 52% were working in land transport, while 
Eurostat  data  on  ´Other  passenger  land  transport´  (which  includes  occasional  bus  and 
coach services) shows that, in 2018, 527,193 people in the EU27 worked in the sector31.  

Some work has also been done to estimate employment in occasional bus and coach 
transport.  The  comprehensive  study32  was  able  to  make  some  estimates  based  on 
crossing  the  available  sectoral  figures  with  register  data  from  Eurostat.  The  authors 
estimated  that  this  sub-sector  employed  around  550,000  people  across  the  EU  in  2014 
(with a margin of error of approximately 10%), with a slow trend of decline over the period 
2008-2013. While the authors make some caveats, pointing out that the database included 
some  regular  services  that  can  distort  the  figures,  this  gives  an  order  of  magnitude  of 
employment in occasional bus and coach transport that that can serve as a base to be built 
on for the present study.  

Looking at the countries for which estimates were available (15 countries33), France, Spain 
and  Hungary  were  the  ones  with  the  highest  number  of  occasional  coach  drivers,  with 
94,300, 17,896 and 17,000 respectively. Within the sample, Ireland, Sweden and Cyprus 
have the least drivers, with 2,000, 900 and 250 drivers, respectively. Surprisingly, Italy is 
estimated  to  have  only  2,700  coach  drivers.  This  is  difficult  to  understand  given  the 
country’s tradition in tourism and represents a vivid example of the patchy data available. 
The  data  are  also  starting  to  show  some  effects  of  the  COVID-19  crisis:    in  the 
Netherlands34  the  coach  sector  employed  5,592  drivers  in  2019  and  3,859  in  2020,  a 
precipitous drop of over 30%.  

Recent data – from a survey carried out by the European Transport Workers Association 
(ETF)35  –  also  shed  some  light  on  the  size  of  undertakings  for  which  drivers  work.  The 
survey gathered 696 responses from international and long-distance bus and coach drivers 
(hence, assembling both regular and occasional transport) and provides an overview of the 
size  of the undertakings where these drivers  work.  The  results  showed that 14% of the 
sample  worked  for  micro-companies  (of  less  than  10  employees).  The  largest  share  of 
drivers works for small companies (10 to 50 employees), while a similar number works for 
a medium-size company employing between 51 to 100 drivers. Almost 22% of the sample 
works for a medium-to-large company (101-500) and a fraction of drivers work for larger 
companies with over 500 employees. The breakdown of data does not allow to show how 

30 European Commission, 2021, Statistical Pocketbook 2022 EU Transport in figures - EU transport 
in figures - Publications Office of the EU (europa.eu) 
31 As stated above the category of ´Other passenger land transport´ includes other passenger road 
transport (scheduled long-distance  bus services, charters, excursions, and  other occasional coach 
services), airport shuttles, operation of school buses and for employees and passenger transport by 
man – or animal-drawn vehicles. 
32 European Commission, 2016, Comprehensive Study on Passenger Transport by Coach in Europe - 
Comprehensive Study on Passenger Transport by Coach in Europe (europa.eu). 
33  Belgium,  Bulgaria,  Cyprus,  Czechia,  Greece,  Spain,  France,  Croatia,  Hungary,  Ireland,  Italy, 
Luxembourg, Malta, Sweden and Slovakia. 
34 Panteia and FSO, 2021, Kerncijfers 2020 van het Nederlandse touringcarvervoer. 
35  ETF  Report,  2018,  Driven  to  distraction?  Long-distance  coach  and  bus  drivers  in  the  EU, 
https://www.etf-europe.org/wp-content/uploads/2018/09/ETF-report-on-woking-conditions-of-bus-
and-coach-1.pdf. 

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Study on a possible revision of the break time and rest period rules for bus and coach drivers 

the exact share of drivers working in SMEs according to the EU definition (staff headcount 
of less than 250 workers), but the share of companies fitting in this category, according to 
our estimates, should not be lower than 85%. 

These results are important because literature sources and interviews confirm that larger 
companies  have  greater  adaptability  to  accommodate  the  constraints  that  the 
current  set  of  driving  times  and  rest  rules  pose,  as  they  have  the  resources to 
compensate prolonged rest times within their pool of drivers. On the other hand, 
small  companies  and  self-employed  drivers  might  benefit  from  greater  adaptability 
introduced by eventual new rules subject to evaluation under the present initiative.  

Table 1.6: Number of drivers by company size  

Company size 

Number of 
respondents 

<10 employees 

10-50 employees 

51-100 employees 

101-500 employees 

>500 employees 

Total 

98 

205 

200 

150 

43 

696 

% 

14.1 

29.5 

28.7 

21.6 

6.2 

100 

Source: ETF report on working conditions of bus and coach (2018) 

The survey from ETF was targeted to union members and their affiliates. Therefore, it is 
likely to underestimate the number of employees working in micro and small companies, 
as well as those who may run their own bus and are therefore self-employed, a category 
which might be frequent in the occasional coach sector, as pointed out in a report from 
EU-OSHA36.  For  the  category  of  self-employed  drivers,  whose  entrepreneurial 
advantages lie in being able to make their own service scheduling decisions and 
seize business opportunities in a highly seasonal market, the rules on rest periods 
may bring negative side-effects to drivers, as noted in the ex-post evaluation on social 
legislation in road transport and its enforcement. 

The  current  rules  on  driving  and  rest  periods  also  have  an  impact  for  enterprises,  who 
might need to hire more drivers and therefore struggle with the shortage of drivers in order 
to provide coach services, even in cases where the driving time is in fact very short. This 
will have an indirect impact on consumer costs, which will therefore increase. 

Some information is also available on the topic of attractiveness of the sector to young 
drivers. This seems important since an old workforce is more likely to suffer from fatigue 
and tiredness, and a third of all of the sector’s workers is currently over 50 years old. In 
general, there are several factors that make this sector unattractive,  such as unfriendly 
work  schedules  with  weekends  away  from  home,  inadequate  rest  and  low  salaries,  as 
pointed out in a study for DG MOVE about the  attractiveness of transport37. In addition, 
the road transport sector is still linked to a negative image of “lonely male truck drivers, 
with low education and skill levels, performing a physically demanding job” and seen as a 

36 EU-OSHA, 2011, Managing risks to drivers in road transport, 
https://osha.europa.eu/en/publications/managing-risks-drivers-road-transport/view 
37 European Commission, 2017, Study on a Pilot project: Making the EU transport sector attractive 
to 
future  generations,  https://panteia.com/uploads/2017/09/DG-MOVE_Study-Attractiveness-
Transport_-Final-Report.pdf   

19 

 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

temporary  job  rather  than  a  career.  Nevertheless,  the  survey  carried  out  for  the  study 
indicates that the views of young people on the attractiveness of the transport sector is 
overall positive but somewhat varies between the countries analysed (the most positive 
views  on  working  conditions  in  the  sector  are  from  newer  Members  States,  such  as 
Croatia).  

In terms of job expectations in the transport sector, the same survey shows that young 
people consider certain aspects as essential to decent working conditions, namely fair pay 
(appropriate compensation for the job), a good work-life balance (i.e. “working hours that 
fit family and spare time but also with clear regulations on overtime”) and fair conditions 
(labour  protection  and  rights).  Similarly,  there  are  also  diverging  views  among  Member 
States.  Young people from countries with  less  favourable labour  markets (e.g. Bulgaria, 
Italy, Spain) expressed low expectations for jobs in general, while young employees from 
other Member States tend to value the social status provided by their job.  

Regarding job preferences, young people were found to prefer flexible working hours rather 
than  fixed  working  periods.  Moreover,  international  mobility  appears  to  be  an  attractive 
job feature, with the prospect of traveling being mentioned by 80% of the young survey 
respondents. National transport is considered to be more stable in terms of working hours 
and more compatible with private life, when compared to cross-border road transport. 

From  a  gender  perspective,  the  above-mentioned  study  carried  out  for  DG  MOVE  in 
2017 highlights the over-representation of men, who account for more than three-quarters 
of the total workforce on the transport sector. Their heavy dominance in certain roles and 
some  practical  obstacles  for  women,  for  instance  the  lack  of  separate  gender-specific 
toilets, seems to be discouraging factors for women to choose the transport sector to work. 
However, when asked about preferences in working in transport in general, young women 
express  a  strong  preference  for  jobs  with  social  interaction  (71%  of  female  survey 
respondents), which can be regarded as a specific trait of the occasional coach sector. In 
terms  of  job  contract,  young  men  are  slightly  more  likely  to  be  willing  to  work  as  self-
employed  (60%  of  male  and  49%  of  female  respondents)  rather  than  as  a  permanent 
employee.  

Another  relevant  study  on  female  employment  in  transport38  provides  a  complementary 
overview of employment conditions from a gender point of view. According to the study, 
there are several barriers (e.g. parental leave legislation, wage gap, gender stereotypes 
and  discrimination,  work-life  balance  with  inflexible  working  times,  with  little  schedule 
control, atypical shifts, labour conditions – sexual harassment, safety, a-typical contractual 
relations like self-employment or third-party contracts -, and others) that contribute for a 
lower presence of women in the transport labour force (22%) - a share that is even lower 
when  considering  only  land  transport.  The  study  provides  several  measures  to  improve 
gender balance. Such as, focused recruitment, training and career development, gender 
awareness, work-life balance and health and safety measures. 

It is important to highlight that ´Mobility Package I´ (MP1) introduced new provisions that 
addressed the above concerns. The new provisions include the obligation of employers to 
organise the work of a driver in such a way that the driver is able to return home at least 
every four weeks; the obligation of employers to provide a suitable accommodation for a 
driver for a regular weekly rest; the possibility to take two reduced weekly rests (at least 
24  hours)  to  give  more  flexibility  for  international  drivers  and  to  encourage  them  to  go 
back home for their longer rest; or standards for the creation of safe and secure parking 
areas  in  the  EU  to  improve  resting  conditions  of  drivers,  whose  Commission  Delegated 

38  European  Commission,  2018,  Business  case  to  increase  female  employment  in  transport,  Final 
Report, 
https://op.europa.eu/pt/publication-detail/-/publication/6f833428-54f9-11e9-a8ed-
01aa75ed71a1  

20 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Regulation was published in April 2022. However, as noted in several places in this report, 
MP1 did not include specific rules for occasional passenger road transport sub-sector. 

In  addition  to  the  above,  it  is  also  worth  referring  that  most  variables  that  negatively 
impact on the attractiveness of the sector are not directly related with the break and rest 
time rules themselves. For instance, the sector is suffering from an incapacity of attracting 
young people also due to restrictions of age in force. To this respect, the IRU 39 has called 
for the governments to set the minimum licensing age to 18 years old in the bus and coach 
sector, which is usually 21 years old in most Member States (but can vary from country to 
country). 

A glance at the distinct stakeholder needs 

All  in  all,  it  was  possible  to  find  that  rest  and  break  periods  are  controversial  topics, 
particularly to what the specific impacts posed upon working conditions is concerned, with 
polarised opinions among stakeholders. This assumption was evident in some of the results 
published by ETF and IRU, for instance. 

In general, desk research has allowed to devise that there are three fundamental groups 
of stakeholders with a strong claim on the issues under review in the present study: 
drivers, transport companies (and their representatives) and public authorities (enforcers). 
These actors have different levels of influence and pursue  multiple contrasting interests, 
e.g. between self-employed, temporary or permanent drivers. It is worth highlighting the 
diversity  of  drivers,  with  preferences  and  experiences  differing  depending  on  Member 
State, the size of companies where they work and the contractual agreements they have.  

Companies also experience different impacts if they are small, medium-sized or large and 
if  they  have  the  ability  to  gain  access  to  public  funding  and/or  cost-covering  services 
framed  by  public  service  obligations,  such  as  regular  public  transport  services.  Among 
other things, this makes companies more or less resilient to counteract the impacts from 
the  coronavirus  crisis.  In  addition,  larger  companies  have  the  opportunity  to  optimise 
human resources (i.e. drivers) to specific routes and services, whenever demand for coach 
services decreases, which occurs regularly in this highly seasonal sector. Public authorities 
also have different preferences and  constraints depending  on size of the Member State, 
sectoral composition, administrative capacity, resources and policy priorities. 

39 IRU, 2020, Fight global youth unemployment by reducing the minimum age of professional drivers, 
https://www.iru.org/resources/newsroom/fight-global-youth-unemployment-reducing-minimum-
age-professional-drivers 

21 

 
 
 
 
 
 
 
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2. Stakeholder synopsis report 

2.1 

Introduction and consultation strategy 

This annex provides a summary of the stakeholder consultation carried out in the scope of 
the study to support an  impact assessment  on potential changes to the break time and 
rest  period  rules  for  drivers  in  occasional  transport  services.  It  notes  the  range  of 
stakeholders consulted, describes the main consultation activities and provides a succinct 
analysis of their views and the main issues they raised. The consultation strategy and the 
various activities were carried out in line with the requirements for consultation defined in 
Tool #52 of the Better Regulation Toolbox.  

The consultation activities served purposes of accountability and transparency, by involving 
key stakeholders in the study and giving all interested parties (including EU citizens) the 
opportunity  to  provide  their  views.  In  addition,  given  the  lack  of  secondary  data  on  the 
occasional bus and coach sub-sector, information provided by stakeholders has been the 
single  most  important  source  of  evidence  for  the  study.  This  fed  into  all  aspects  of  the 
study, most importantly the assessment of the existing problems, development of policy 
options  and  assessment  of  the  likely  impacts  of  the  policy  options.  Three  types  of 
consultation were carried out:  

•  Inception impact assessment: on 21 January 2021, the Commission published 

an inception impact assessment for the initiative. In line with the Better 
Regulation Guidelines, feedback was welcomed from all interested parties for 5 
weeks, until 18 February 2021. While this took place before the study was 
launched, it analysed and took into account the responses for the analysis.  

•  Targeted  interviews:  the  technical  nature  of  the  rules  and  niche  status  of 
occasional bus and coach transport, as well as the lack of documentary evidence, 
meant that in-depth interviews were a crucial source of information for the study. 
These aimed to reach as broad a range of stakeholders as possible, while bearing 
in  mind  the  proportionate  level  of  analysis  and  limited  resources  available.  This 
activity  covered  both  the  current  situation  and  potential  changes  to  the  rules.  It 
consisted  of  9  exploratory  interviews  with  stakeholders  at  the  European  and 
international  levels,  as  well  as  29  interviews  in  a  sample  of  five  Member  States 
(Bulgaria, Germany, the Netherlands, Spain and Sweden) that was agreed with the 
Commission based on criteria including geographical diversity and the importance 
of tourism (as a proxy for the importance of occasional bus and coach transport). 
In addition, about ten more interviews were conducted with stakeholders to feed 
into  the  three  thematic  case  studies,  and  to  elicit  additional  information  and 
clarifications during the latter stages of the work.  

•  Public consultation: this gave citizens an opportunity to provide feedback on the 
initiative  with  several  general  questions,  while  filtering  by  respondent  group  was 
used to get more detailed input from key stakeholders, pertaining both the current 
situation  and  potential  changes  to  the  rules.  To  maximise  responses  from  key 
stakeholders,  the  public  consultation  was  promoted  among  representative 
organisations  as  well  as  on  the  Commission’s  consultations  website.  The  public 
consultation was open between 23 November 2021 and 18 February 2022.  

Across the different consultation activities, input was sought from the following types of 
stakeholders, which were mapped early in the study:  

•  Business associations: employer organisations and operator representatives at EU 

and national levels;  

•  Bus  and  coach  operators:  individual  bus  and  coach  companies  that  organise 

occasional passenger services, including both SMEs and larger groups;  
•  Trade unions: representatives of employed drivers at EU and national levels; 

22 

 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

•  Drivers: employed and self-employed individuals who work on occasional passenger 

services;  

•  Authorities: including organisations at EU and national levels with both policy and 
enforcement responsibilities for working conditions in general and the specific rules 
under review;  

•  Experts:  the  study  was  also  open  to  input  from  other  experts,  on  topics  such  as 

fatigue and road safety; 

•  EU citizens: any interested citizens were also invited to provide input via the public 

consultation.  

In  conjunction  with  desk  research,  the  stakeholder  consultation  activities  provided 
sufficient evidence to support the findings presented in the main report. However, three 
important limitations should also be borne in mind:  

•  Proportionality and limited scope: given the minor nature of the initiative and 
small size of the sub-sector, and the fact that a wide range of consultation activities 
were conducted as part of a broader impact assessment in 2017 (SWD(2017 186 
final),  the  resources  allocated  to  the  present  study  were  relatively  limited.  This 
meant  that  it  was  only  possible  to  select  five  Member  States  for  the  targeted 
interviews. Since the public consultation had targeted elements, these were used 
to gather input from stakeholders from across the EU and thereby corroborate and 
complement  the  more  detailed  information  from  the  targeted  interviews.  While 
consistency between the two sources, as well as with previous research and studies, 
speaks  to  the  validity  of  the  findings,  the  study  cannot  be  said  to  have  obtained 
representative data on stakeholders’ views or experiences.  

•  Difficulty reaching certain groups in the targeted interviews: due to factors 
such  as  survey  fatigue  from  other  recent  research,  an  unfamiliarity  with  policy 
development and consultation, and limited knowledge of occasional services, it was 
difficult to gather feedback from certain target groups. In particular, drivers were 
extremely difficult to reach for the targeted interviews, despite extensive outreach 
activities. The information provided directly by drivers was thus cross-checked with 
that provided by trade unions, as their representatives. Similarly, since customer 
representatives  at  EU  and  national  levels  also  declined  to  participate,  input  on 
certain  topics  (e.g.  service  quality)  was  gathered  largely  from  operators  and 
business  associations,  who  are  responsible  for  organising  services  according  to 
customer needs. This approach was in line with other recent research in this field, 
which faced similar challenges to engage with certain types of stakeholders.  

•  Uncertain  validity  of  input  from  drivers  to  the  public  consultation:  a 
considerable number of respondents to the public consultation identified as drivers 
(of which 34 self-employed, 21 employed and 2 not stating either way). However, 
these  replies,  particularly  from  employed  drivers,  were  much  more  critical  of  the 
current rules – and more open to changes – than the interview findings with drivers. 
Since the study team was able to verify the profile of interviewees and not public 
consultation  respondents,  it  has  placed  more  trust  in  the  former  throughout  the 
report, and interpreted the latter very cautiously.  

•  Limited provision of quantitative data: an important rationale for the initiative 
is that the current rules impose  excessive  costs on the occasional sub-sector. To 
assess these, stakeholders taking part in both the targeted interviews and public 
consultation were asked detailed questions on cost structures and how these would 
be expected to change under the different policy measures that were assessed, as 
well as related questions on business performance. However, while a great effort 
was  made  to  devise  clear  questions,  very  few  stakeholders  were  able  to  provide 
quantitative insight. This is likely related to the indirect and limited nature of the 
rules and the proposed changes, within the wider operational context of occasional 
transport. Documentary sources with quantitative data were also lacking. For these 
reasons, while the study relies as much as possible on the little quantitative data 
that was obtained, many findings consist of qualitative assessments.  

23 

 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

2.2  Consultation results 

The  rest  of  this  synopsis  report  summarises  the  results  of  the  three  main  consultation 
activities. Due to the breadth of the topics covered and amount of  information obtained, 
more  detail  is  provided  in  the  dedicated  annexes  for  the  inception  impact  assessment 
(Annex  3),  the  targeted  interviews  (Annex  5)  and  the  public  consultation  (Annex  6).  In 
addition, it should be noted that the consultation activities covered technical aspects of the 
current rules and policy measures that would involve changes to the break times and rest 
periods for drivers in the occasional transport sub-sector. The existing rules are presented 
in chapter 2 of the main report, while the policy measures under review are presented in 
chapter 6. 

2.2.1 

Inception impact assessment  

Between  21  January  2021  and  18  February  2021,  the  Commission  gathered  feedbacks 
from  a  total  of  87  different  stakeholders.  The  figure  below  shows  the  distribution  of 
responses across categories. 

Figure 2.1: Feedback received by category of respondent 

1, 1%

1, 1%

4, 5%

9, 10%

11, 13%

40, 46%

21, 24%

EU citizen

Trade union

Business association

Company/Business organisation

Other

Non-EU citizen

In terms of country coverage, a plurality of respondents were from Germany (37), followed 
by respondents from Italy (15) and Belgium (13). 

Figure 2.2: Country of origin of respondents40 

37

15

13

DE

IT

BE

NL

AT

FI

FR

NO

SE

5

2

2

2

2

2

Other

7

0%

10%

20%

30%

40%

50%

The  consultation  suggests  that  the  revision  of  Regulation  (EC)  No  561/2006  is  a 
highly  polarising  issue.  Respondents  to  the  initiative  seem  to  be  split  into  two  major 
groups: on one side, trade unions and stakeholders responding as EU citizens expressed 
resistance  to  any  changes  to  the  current  provisions  on  breaks  and  rest  arrangements, 
which were reported as seen as harmful to occasional bus drivers’ wellbeing and dangerous 

40 “Other” includes respondents from: CZ, DK, ES, SK, RO, UK and an international organisation.  

24 

 
 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

in terms of road safety; on the other side, businesses and business associations were in 
favour  of  introducing  specific  solutions  for  the  sub-sector,  which  they  felt  would  help  it 
respond  better  to  the  needs  of  coach  and  bus  drivers,  to  improve  the  experience  of 
passengers, and to increase profit margins. The only public authority who participated in 
the  initiative  stood  somehow  in  the  middle:  while  recognising  the  need  to  increase  the 
flexibility  of  legislation,  it  shared  some  of  the  concerns  expressed  by  trade  unions  and 
citizens. 

More specifically, trade unions and EU citizens (with only few exceptions) put the emphasis 
of  their  argument  on  the  potential  risks  that  the  implementation  of  derogations  to  the 
general rules set out in Regulation (EC) 561/2006 might entail. For instance, more flexible 
working hours are perceived as dangerous for the health and safety of drivers, which in 
turn  poses  a  threat  on  road  safety.  These  factors  are  altogether  contributing  to  the 
unattractiveness of the bus driver profession (which is already facing a significant labour 
shortage). EU citizens also criticise a lack of understanding of the role of professional bus 
drivers  by  the  Commission.  According  to  them,  allowing  for  the  extension  of  working 
hours/days means neglecting the diversified role of  occasional bus drivers, who oversee 
other activities beyond driving (e.g. assisting passengers).  

Business  associations  and  companies  argued  that  more  flexible  rules  are  necessary  to 
differentiate  between  two  inherently  different  types  of  transport:  freight  transport  and 
occasional passenger transport. If freight transport activities are schedulable in compliance 
with  Regulation  (EC)  561/2006  on  driving  times,  breaks  and  rest  periods,  the  needs  of 
bus/coach drivers and passengers cannot always comply with it (especially the occasional 
service). The lack of flexibility in working hours for bus and coach drivers – which currently 
follow the same standards for truck drivers in terms of daily driving times and breaks/rest 
– entails the need to hire more drivers and bear higher costs. This leads to reduced financial 
health  in  the  sector  as  well  as  investments,  and  a  slower  recovery  from  the  Covid-19 
pandemic.  Furthermore,  the  rigidity  of  the  Regulation  constitutes  was  reported  by 
businesses  and  business  associations  to  be  a  source  of  great  stress  for  the  drivers 
themselves, which adds up to the daily fatigue. This was attributed to the fact that drivers 
and operators can both face penalties for non-compliance with the rules.  

2.2.2 

Targeted interviews  

The targeted interviews took place in two steps, namely exploratory interviews at the EU 
level, which served to gather initial input and identify relevant stakeholders, and a second 
step consistent mainly of the interviews in the sample of five Member States agreed with 
the Commission. The interviews were carried out between June 2021 and January 2022, 
using detailed topic guides that were agreed with the Commission services. The breakdown 
of interviewees is summarised in the table below. Note that this does not include around 
10 interviews conducted later in the study for the purpose of the thematic case studies, 
and  to  provide  clarification  and  additional  insight  on  specific  issues  were  data  was  still 
required.  

Table 2.1: Breakdown of the targeted interviews  

Business 
associatio
n 

Bus & 
coach 
operator 

Trade 
union 

Authorities 

Drivers 

Experts 
and others 

Total 

EU/int’l 

Bulgaria  

Germany  

Netherlan
ds 

5 

2 

1 

1 

- 

2 

2 

1 

1 

- 

- 

1 

2 

- 

1 

1 

N/A 

2 

- 

1 

1 

- 

- 

- 

9 

6 

4 

5 

25 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Spain 

Sweden 

Total 

1 

2 

12 

1 

1 

7 

2 

1 

5 

- 

2 

6 

1 

2 

6 

- 

1 

2 

5 

9 

38 

In  terms  of  key  findings  and  conclusions,  views  were  quite  polarised,  with  all  trade 
unions  and  authorities,  and  most  drivers  favouring  the  current  rules  or  only  very  small 
changes,  while  all  operators  and  business  associations  supported  most  of  the  proposed 
changes. Nonetheless, more room for consensus emerged in some areas than others: 

•  On  the  current  rules,  all  trade  unions  and  national  authorities,  as  well  as  most 
drivers,  considered  these  appropriate  in  their  current  form,  and  emphasised  the 
need  for  better  compliance  and  enforcement.  For  this  reason,  none  of  the  trade 
unions  or  authorities  supported  any  of  the  proposed  changes.  In  contrast,  all 
operators and business associations considered the current rules to be obstruct their 
ability  to  schedule  services  efficiently  and  to  a  high  standard,  especially  at  peak 
seasons when driver shortages are acute.  

•  On potential changes to break times, all operators and their representatives would 
support either of the proposed changes. Most interviewed drivers were more open 
to the first proposed change, which would allow breaks to be spit into one longer 
and one shorter period, i.e. one break of 15 minutes and one of 30 minutes, without 
specifying which should be taken first.  

•  Allowing  for  the  12-day  rule  to  be  used  for  domestic  services  faces  much  less 
opposition  from  drivers  than  the  other  possible  amendments  to  it,  namely  the 
removal  of  the  single-service  condition  or  compensatory  rest  after  its  use 
amendments  to  the  12-day  derogation.  While  it  was  unclear  whether  the 
interviewed drivers would actively support the measure to extend the 12-day rule 
to domestic services, it seemed that they agreed that domestic and international 
services  should  face  the  same  rules,  which  this  measure  would  ensure.  Some 
drivers also mentioned that the 12-day rule would allow them to take more weekly 
rest  periods  at  home  rather  than  on  the  road,  which  was  seen  as  positive.  All 
operators  and  business  associations  supported  extending  the  12-day  rule  to 
domestic trips, as they would benefit from increased flexibility and avoid the need 
to staff certain trips (i.e. those lasting more than the six days when a weekly rest 
is  currently  required)  with  two  drivers.  They  also  supported  the  removal  of  the 
single-service  condition,  as  this  would  open  the  12-day  rule  up  to  a  greater 
proportion of services. However, on the measure to remove compensatory rest after 
using  the  12-day  rule,  a  few  operators  expressed  reservations,  because  they 
thought that the extra rest was needed to ensure good working conditions.  

•  On other changes to rest-time rules, the only potential consensus was on measures 
related to daily rests, which would increase the length of the duty cycle in certain 
circumstances  and  thereby  allow  services  to  cope  with  unexpected  changes  or 
demands.  While  the  interviewed  drivers  did  not  actively  support  such  measures, 
they did not oppose them either, which operators and business associations were 
strongly in favour.  

2.2.3 

Public consultation  

The public consultation was launched on 23 November 2021 and ended on 18 February 2022. The consultation 
was  promoted  primarily  among  key  stakeholders  (i.e.,  business  associations,  bus  and  coach  operators, 
drivers, national authorities and trade unions, as well as non-governmental organisations 
(NGOs)) in the EU-27, EEA-EFTA countries, Switzerland and the UK. This made it possible to 
gather feedback from a wider set of stakeholders than would have been possible using only targeted methods. 
In addition, the public consultation was also open to ‘ordinary’ citizens, both from the EU and third countries, for 

26 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

transparency purposes and because citizens consume bus and coach services directly and could potentially have 
views on how they are organised.  

The  different  respondent  groups  are  reflected  in  the  set  of  questions  asked,  which  contained  both  relatively 
general questions aimed at all interested parties, and more detailed questions that were only asked to ‘specialist’ 
respondents who have a good knowledge of the topic. In total, the consultation consisted of 44 questions (not 
including initial profiling questions pre-defined for all public consultations of the European Commission). 

Respondent profiles  

The  consultation  received  170  contributions,  which  broke  down  by  stakeholder  group 
according to the figure below. Participation from drivers, a particularly sought-after group, 
is worth discussing in more detail. Because the main profile question is fixed for all public 
consultations,  it  was  not  possible  to  include  a  choice  for  ‘drivers’.  Instead,  drivers  were 
asked to select ‘other’ (which was done by 24 of 33 ‘other’ respondents), and to confirm 
their status as a driver in a follow-up question, as well as to indicate whether they were 
employed  or  self-employed.  Some  drivers  misunderstood,  indicating  themselves  to  be 
drivers despite not describing themselves as ‘other’ in the first profile question. Overall, 
among the respondents  in the different groups  there were 57 drivers, of which 34 were 
self-employed and 21 were employed, while 2 did not answered.  

Figure 2.3: Types of respondents 

Company/business organisation
Other
Business association
Trade union
EU citizen
Public authority

33, 19.4%

18, 10.6%

14, 8.2%

12, 7.1%

10, 5.9%

83, 48.8%

0%

10%

20%

30%

40%

50%

60%

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 170 respondents 

In  terms  of  country  of  origin,  this  is  summarised  in  the  table  below.  Nearly  half  of 
respondents came from Germany, with pronounced numbers also from Austria, Italy, Belgium 
and  Czechia.  A  large  majority  of  countries  (i.e.,  fifteen  out  of  twenty-four)  had  their  respective  respondents’ 
share around or below 1%. Among third country residents, responses were submitted from the United Kingdom, 
Norway and Switzerland. 

Table 2.2: Respondents’ country of origin 

Country of 
origin 

No of 
responses 

% of 
responses 

Country of 
origin 

No of 
responses 

% of 
responses 

Germany 

Austria 

Italy 

Belgium 

United 
Kingdom 

Czechia 

France 

Spain 

77 

17 

16 

11 

8 

8 

6 

4 

45.3% 

10.0% 

9.4% 

6.5% 

4.7% 

4.7% 

3.6% 

2.4% 

Slovenia 

Romania 

Latvia 

Hungary 

Slovakia 

Ireland 

Estonia 

Switzerland 

2 

2 

1 

1 

1 

1 

1 

1 

27 

1.2% 

1.2% 

0.6% 

0.6% 

0.6% 

0.6% 

0.6% 

0.6% 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Sweden 

Luxembourg 

Netherlands 

Greece 

3 

2 

2 

2 

Source: Public consultation  

1.8% 

1.2% 

1.2% 

1.2% 

Bulgaria 

Norway 

Finland 

Poland 

1 

1 

1 

1 

0.6% 

0.6% 

0.6% 

0.6% 

Out  of the 83 companies that  participated in the public consultation, nearly 75% (62) had between 1 and 49 
employees (i.e., were either micro or small companies), whilst medium and large businesses accounted together 
for 25.3% (21) of all businesses that took part, as reported in the figure below. 

Figure 2.4: Organisations' size 

Micro (1 to 9 employees)
Small (10 to 49 employees)
Medium (50 to 249 employees)
Large (250 or more)

25, 30.1%

37, 44.6%

4, 4.8%

17, 20.5%

Source: Public consultation; Base: 83 respondents 

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

50%

It must also be noted that some of the responses were of a campaigning nature, whereby 
several clusters of responses were received that were nearly identical in terms of both the 
closed  and  open  questions.  These  entailed  three  clusters  of  identified  as  business 
associations  and  companies  (i.e.  from  Austria  and  Germany  (24  respondents),  Italy  (5 
responses), and Belgium, Sweden and the UK (4 responses) and 9 responses identified as 
trade  unions  (i.e.  from  Belgium,  Norway,  Romania  and  Slovenia).  While  the  number  of 
campaign responses was fairly small, it was meaningful in light of the overall number of 
responses (170), which made it necessary to take action to avoid skewing the results. For 
this purpose, each cluster of coordinated replies was counted only once in the quantitative 
analysis of the public consultation responses.  

Importantly, the analysis was also done in a way that avoided risks of under-reporting on 
the views of certain groups. This involved disaggregating the findings by stakeholder group 
throughout the analysis, and pointing out their similarities and differences.   

The next paragraphs present a brief overview of key findings from the public consultation, 
in terms of views on the current rules and potential changes to the rules on break times 
and rest periods. As explained above, the views of respondents identifying themselves as 
drivers  (particularly  employed  drivers)  should  be  interpreted  cautiously,  due  to  their 
inconsistency with the findings from the targeted interviews, which are considered more 
trustworthy.  

Summary of views on the current rules  

Respondents’ views of the current rules are best encapsulated in replies to a question on 
whether  the  rules  should  be  retained  or  changed.  These  are  summarised  below,  first  in 
terms of the rules on break times, then on rest periods. As shown, nearly all stakeholders 
considered  at  least  minor  changes  necessary.  Open  text  replies  suggested  that,  for 
companies, associations and drivers, this was mainly because they considered the current 
rules to be insufficiently adapted to the needs of the occasional sub-sector. The contrast 
between drivers taking part in the targeted interviews and drivers responding to the public 
consultation  was  interesting,  in  that  the  latter  were  more  likely  to  consider  changes 
needed. That said, since neither consultation activity involved a representative sample of 
drivers (or any other stakeholder group), the results should not be over-interpreted. As for 
trade  unions  and  authorities,  they  were  more  likely  than  others  to  support  keeping  the 

28 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

current rules in place, while open-text replies focused on enforcement measures and / or 
making the rules stricter.  

Figure  2.5:  Overall,  do  you  think  that  the  existing  rules  on  break  times  are  appropriate,  or  should  they  be 
changed? 

Business associations (n=12)
Employed drivers (n=14)
Companies (n=78)
Self-employed drivers (n=32)
Public authorities (n=10)
Trade unions (n=6)

2

1

20

13
4

2

13

10

51

16

4

6

7
3

0%

10%

20%

30%

40%

50%

60%

70%

80%

90% 100%

The rules need major changes

The rules need minor refinements

The rules should be retained

Source: Public consultation  

Figure  2.6:  Overall,  do  you  think  that  the  existing  rules  on  rest  periods  are  appropriate,  or  should  they  be 
changed? 

Companies (n=76)
Self-employed (n=31)
Employed drivers (n=16)
Business associations (n=12)
Trade unions (n=6)
Public authorities (n=10)

18

3

10

4
2

3

54

19

12
6

4
2
1

2

1

3

7

0%

10%

20%

30%

40%

50%

60%

70%

80%

90% 100%

The rules need major changes

The rules need minor refinements

The rules should be retained

Source: Public consultation  

Summary of views on potential changes to the rules  

Respondents were also asked for their views regarding eight policy measures that would 
entail changes to the current rules (see chapter 6 of the main report for more detail on the 
measures  considered).  The  views  on  each  measure  are  presented  in  the  table  below, 
broken  down  by  stakeholder  group.  As  shown,  most  groups  supported  most  of  the 
measures  being  proposed,  with  only  a  few  exceptions.  Namely,  trade  unions  and 
authorities  opposed  all  of  the  proposed  changes,  while  a  few  of  the  other  measures 
received only middling support. As with the views on the current rules, the findings were 
consistent with the interviews concerning business associations, companies, trade unions 
and authorities. But drivers taking part in the public consultation voiced much more support 
for  changes.  Again,  it  is  difficult  to  interpret  the  findings,  since  samples  were  not 
representative, and the number of drivers answering these questions was limited (ranging 
from 10 to 16 employed drivers and 20 to 27 self-employed drivers).  

Table 2.3: Views by stakeholder group of the proposed policy measures 
Legend: each cell is presented as: “Number supporting (% supporting) / number opposing (% opposing) 
Cells shaded green have more than 2/3 supporting, cells shaded amber have between 1/3 and 2/3 supporting, 
cells shaded red have more than 2/3 opposing 

PM 1: Allow drivers to split their 
break of minimum 45 minutes 
into 30+15 or 15+15+15 minutes 

Business 
associations  
9 (82%) / 2 
(18%) 

Companies 

38 (81%) / 9 
(19%) 

Self-
employed 
16 (80%) / 
4 (20%) 

Employed 
drivers  
15 (100%) / 
0 (0%) 

Trade 
unions 
1 (17%) / 5 
(83%) 

Public 
authorities 
2 (20%) / 8 
(80%) 

29 

 
 
 
 
  
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

PM 2: Breaks can be split in a 
fully open manner their break of 
minimum 45 minutes over the 
period of 4h30 driving time 
PM 3: Allow drivers on trips 
lasting 8 days and longer to 
postpone the start of the daily 
rest period by 1 h in certain 
conditions 
PM 4: Allow drivers on trips 
lasting 8 days and longer to 
postpone the start of the daily 
rest period by 2 h in certain 
conditions 
PM 5: Extension of the 12-day 
rule to domestic transport 
operations 
PM 6: Removal of the single-
service condition when using the 
12-day rule 
PM 7: Remove the compensatory 
rest after use of the 12-day rule 
PM 8: Flexible distribution of 
weekly rests over a 10-week 
reference period 

5 (45%) / 6 
(55%) 

30 (55%) / 25 
(45%) 

16 (70%) / 
7 (30%) 

10 (100%) / 
0 (0%) 

0 (0%) / 6 
(100%) 

1 (10%) / 9 
(90%) 

7 (70%) / 3 
(30%) 

37 (67%) / 18 
(33%) 

16 (67%) / 
8 (33%) 

15 (94%) / 
1 (6%) 

0 (0%) / 6 
(100%) 

4 (40%) / 6 
(60%) 

5 (45%) / 6 
(55%) 

32 (62%) / 20 
(38%) 

11 (52%) / 
10 (48%) 

13 (81%) / 
3 (19%) 

0 (0%) / 6 
(100%) 

2 (20%) / 8 
(80%) 

10 (91%) / 1 
(9%) 

55 (96%) / 2 
(4%) 

25 (93%) / 
2 (7%) 

15 (94%) / 
1 (6%) 

1 (17%) / 5 
(83%) 

3 (30%) / 7 
(70%) 

7 (78%) / 2 
(22%) 

45 (85%) / 8 
(15%) 

18 (78%) / 
5 (22%) 

14 (93%) / 
1 (7%) 

0 (0%) / 6 
(100%) 

3 (30%) / 7 
(70%) 

9 (82%) / 2 
(18%) 

7 (64%) / 4 
(36%) 

47 (82%) / 10 
(18%) 

42 (79%) / 11 
(21%) 

22 (81%) / 
5 (19%) 

17 (81%) / 
4 (19%) 

16 (100%) / 
0 (0%) 

15 (94%) / 
1 (6%) 

0 (0%) / 6 
(100%) 

0 (0%) / 6 
(100%) 

0 (0%) / 10 
(100%) 

0 (0%) / 10 
(100%) 

30 

 
 
 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

3. Feedback on the inception impact assessment 

Between 21 January 2021 and 18 February 2021, the European Commission launched an 
initiative to gather feedback on the existing rules, problems faced and possible solutions 
to them, in the form  of an inception impact assessment  aimed at initiating a process  of 
revision of the European legislation on the matter41.  

3.1  Overview of the inception impact assessment  

This section briefly outlines the problems, options and expected impacts presented in the 
inception  impact  assessment,  because  this  forms  the  backdrop  for  the  feedback  that 
stakeholders  provided  on  at  that  stage  of  the  policy  development  process.  With  this  in 
mind, the ensuing text should not be seen as study findings. Rather, the purpose of this 
section is to describe what stakeholders reacted to when giving their feedback.  

The  inception  impact  explains  that,  under  the  current  legislation  (Regulation  (EC) 
561/2006), professional drivers involved in the occasional carriage of passengers by bus 
and coach are subject to the same rules on the organisation of working and driving times, 
breaks and rest periods as truck drivers involved in the carriage of goods. This has raised 
issues of appropriateness, which were already addressed by the ex-post evaluation of the 
social legislation in road transport42 in preparation of the European Commission’s Mobility 
Package43. The analysis found evidence that the existing rules are not well suited to the 
needs of the occasional road passenger transport sector, which reduces their effectiveness 
through the following problems: 

•  High regulatory costs for operators, especially for smaller companies; 

•  Difficulties with legal compliance; 

•  Unequal  rules  for  drivers  and  operators  in  domestic  and  international  carriage  of 

passengers; 

• 

Increased stress and fatigue of drivers having difficulties with meeting passengers’ 
needs while complying with the rules; 

•  Consequent road safety issues. 

Finally,  the  evaluation  revealed  that  the  underlying  problem  was  that  the  EU  legislation 
fails  to  take  into  account  the  operational  specificities  of  the  occasional  road  passenger 
transport  sector.  Indeed,  the  coach  tourism  sector  is  characterised  by  high  seasonality, 
flexible  schedules,  and  provision  of  passenger  services.  In  addition  to  the  identified 
regulatory  problems,  new  problems  have  emerged  linked  to  the  outbreak  of  COVID-19 
pandemic. The bus and coach sector was severely hit by the pandemic in light of the travel 
restrictions. It is estimated that the losses of the sector in Europe would reach more than 
80% of their annual revenue in 2020. 

The  revision  of  the  legislation  promoted  by  the  European  Commission  aims  to  help  the 
sector to serve passengers efficiently and to contribute to making the European mobility 
system  more  efficient,  safer,  resilient  and  greener,  while  maintaining  an  adequate 
protection for drivers. To meet these objectives, the inception impact assessment identified 
the following preliminary policy options: 

41 Available at: Bus and coach drivers – EU rules on driving and rest times (europa.eu)  
42 Available at: LexUriServ.do (europa.eu)  
43  The  European  Commission's  Mobility  Package  is  a  collection  of  three  initiatives  concerning  the 
governance of commercial road transport in the European Union. 

31 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

1) No change to the current rules; 

2) Weekly rest arrangements – to allow for a restricted postponement of weekly rest period 
for  bus  and  coach  drivers  involved  in  international  and  domestic  occasional  carriage  of 
passengers; 

3) Breaks and daily rest arrangements – to allow for flexible distribution of breaks in daily 
driving times and arrangements of taking daily rest for bus and coach drivers involved in 
international and domestic tours; 

4) Breaks, daily  rest and weekly rest arrangements  - to allow for  flexible distribution  of 
breaks in daily driving times and adjustable arrangements of taking daily and weekly rest 
periods for bus and coach drivers involved in international and domestic occasional carriage 
of passengers. 

From an economic perspective, policy options 2, 3 and 4 would ensure the possibility for 
drivers to arrange their work schedule more flexibly, according to their needs as well as 
the needs of their passengers. Domestic and international tour operators would follow the 
same rules and would be able to schedule drivers’ shifts based on service demand level. 
Operators would be able to reduce their operational costs related to the need of ensuring 
additional drivers or renting local coaches for local short shuttle operations. However, these 
benefits  could  be  outweighed  by  a  potential  increase  in  accumulated  fatigue  of  drivers 
leading to road safety risks. 

In terms of social impacts, drivers would benefit from clearer and more specific rules that 
in turn would likely improve working conditions by helping drivers to cope with passengers’ 
and own needs as well  as with traffic circumstances. They  would help to avoid  stressful 
and risky situations (including risks for health and safety) and lead to improvement of job 
satisfaction as well as clients’ satisfaction. As the overall working conditions would improve, 
the profession could become more attractive to jobseekers. 

The  environmental  added  value  would  stem  from  a  more  efficient  organisation  of 
transport  operations.  This  would  be  driven  by  the  reduction  of  extra  journeys  of 
substitute/replacement drivers and/or additional vehicles. Furthermore, in the long-term 
an overall increase of the transport of passengers by bus and coach would lead to lower 
level  of CO2 emissions, as it has a relatively low level of CO2  emissions per passenger-
kilometres compared to the use of private cars. 

Lastly,  a  revision  of  the  EU  regulation  could  bring  about  impacts  on  both  fundamental 
rights  and  the  administrative  burden.  For  what  concerns  the  former,  the  initiative  is 
expected to have a positive impact on fundamental rights, especially in terms of improved 
working conditions of the transport workers in the bus and coach sector. For what concerns 
the latter, clearer and well-adapted rules would increase the level of compliance and would 
render controls of compliance easier and more efficient, which would subsequently lead to 
reducing administrative burdens of Member States linked with control activities 

3.2  Profile of respondents  

Between  21  January  2021  and  18  February  2021,  the  Commission  gathered  feedbacks 
from  a  total  of  87  different  stakeholders.  The  figure  below  shows  the  distribution  of 
responses across categories. 

32 

 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Figure 3.1: Feedback received by category of respondent 

1, 1%

1, 1%

4, 5%

9, 10%

EU citizen

Trade union

11, 13%

40, 46%

Business association

Company/Business organisation

21, 24%

Other

Non-EU citizen

Public authority

In terms of country coverage, a plurality of respondents were from Germany (37), followed 
by respondents from Italy (15) and Belgium (13). 

Figure 3.2: Country of origin of respondents44 

37

15

13

DE

IT

BE

NL

AT

FI

FR

NO

SE

5

2

2

2

2

2

Other

7

0%

10%

20%

30%

40%

50%

3.3  Business association feedback 

All business associations45 reacting to the Inception Impact Assessment were consistent in 
their  view  that  Regulation  (EC)  561/2006  (and  the  amendments  introduced  in  2020) 46 
failed to take into account some of the fundamental differences between the two types of 
transport  considered.  As  highlighted,  truck  and  bus  operations  are  diverse:  the 
considerable  heterogeneity  in  the  two  industries  stems  from  operational  characteristics 
ranging from fleet and employer sizes to work schedules and on-the job activities. If freight 
transport activities are schedulable in compliance with Regulation (EC) 561/2006 on driving 

44  “Other” includes respondents from: CZ, DK,  ES,  SK,  RO, UK and an international organization. 
“EU” includes respondents from Europe-wide organizations (e.g., EU Trade Unions and associations). 
45 The term “Business associations” includes both national associations/associations of bus and coach 
operators and tour operators. 
46 Regulation (EU) 1054/2020. 

33 

 
 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

times,  breaks  and  rest  periods,  the  needs  of  bus/coach  drivers  and  passengers  cannot 
always comply with it (especially the occasional service). Whereas freight transport entails 
the delivery of goods from a starting to an arrival point in the fastest possible way (dividing 
the route into roughly equal segments), occasional bus and coach drivers sometimes cover 
the largest part of the planned route during the first and the last day of the journey (i.e., 
on days of departure and arrival). 

Greater flexibility – while respecting the safety of drivers, passengers and road users – is 
deemed as essential for the occasional bus and coach industry, since it plays a pivotal role 
within the tourism industry. The perceived negative consequences of the current legislation 
are mostly connected with the harmful impact on the costs and profit margin in the sector. 
The lack of flexibility in working hours for bus and coach drivers – which currently follow 
the same standards for truck drivers in terms of daily driving times and breaks/rests47 – 
entails the need to hire more drivers and bear more costs. This leads to reduced financial 
health  in  the  sector  as  well  as  investments,  and  a  slower  recovery  from  the  COVID-19 
pandemic. 

Overall,  the  main  issue  discussed  by  business  associations  is  their  concern  that  an 
inappropriate  Regulation  might  have  a  negative  impact  not  only  on  drivers’  safety  and 
stress levels (for example, if drivers are forced to rush to avoid exceeding the maximum 
driving time) but also on customers’ needs. According to the business associations, more 
flexible rules would help the sector to deliver a more tailored service as the drivers’ breaks 
can be synchronised with scheduled tour breaks. 

Some of the changes proposed by the business associations to make the Regulation more 
flexible include: the possibility for drivers to take three breaks of 15 minutes, each after 
every driving period of four and a half hours (rather than one uninterrupted break of 45 
minutes or a break of 15 minutes followed by a break of 30 minutes)48,49; the introduction 
of  the  12-day  derogation  foreseen  for  international  journeys  also  at  the  national  level 
(international coach tour drivers can drive up to 12 days before they need to take a weekly 
rest period), which they envisage would alleviate the need for multiple drivers for longer 
domestic trips50; the possibility to be on duty for up to 18 hours in a day (instead of 15 
hours)– provided that the daily rest time is not reduced – which would reportedly prevent 
drivers from rushing to reach their destination at the end of a trip; the possibility for drivers 

47 The main EU rules on driving, breaks and rest periods set out by Regulation 561/2006 are that 
workers must not drive more than: 9 hours in a day (this can be extended to 10 hours twice a week); 
56 hours in a week; 90 hours in any two consecutive weeks. The main EU rules on breaks and rests 
are that drivers must take: at least 11 hours rest every day (this can be reduced to 9 hours rest 
three times between any two weekly rest periods); a continuative rest period of 45 hours every week 
(this can be reduced to 24 hours every other week); a break or breaks totaling at least 45 minutes 
after  no  more  than  4  hours  30  minutes  of  driving;  a  weekly  rest  after  six  consecutive  24  hours 
periods of working, starting from the end of the last weekly rest period taken. 
48  At  the  present  time,  after  a  driving  period  of  four  and  a  half  hours  a  driver  shall  take  an 
uninterrupted break of not less than 45 minutes. This break may be replaced by a break of at least 
15 minutes followed by a break of at least 30 minutes.  
49 As underlined by one business association, the possibility of taking more short breaks fits better 
the driving schedule of smaller groups of passengers (e.g., 10-15) who do not need long stops. 
50  Lastly  the  unequal  rules  for  drivers  and  operators  in  domestic  and  international  carriage  of 
passengers (the 12-day derogation) was seen by associations to distort competition, as international 
operators have more flexible rest-regulation when performing the same work. 

34 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

to take two consecutive reduced weekly rest periods51, which would be compensated during 
the following week52. 

3.4  Company feedback 

All  companies53  providing  their  feedback  to  the  inception  impact  assessment  considered 
that  –  while  drivers’  safety  remains  their  biggest  priority  –  the  perceived  rigidity  of  the 
Regulation constitutes a source of great stress for the drivers themselves, which companies 
in turn felt could increase daily fatigue. It was pointed out that drivers and operators face 
penalties for non-compliance with the rules on breaks and rest times. An example given 
was  that  safe  driving  may  sometimes  lead  to  breaking  the  limit  of  the  maximum  daily 
working hours. Similar rules were seen, in some ways, to encourage drivers to try to reach 
their destination point as fast as possible, regardless of safety concerns. The consequence 
of this could reportedly be reduced traffic safety and health among drivers, which in turn 
results in a socio-economic burden on the health sector, as well as reduced attractiveness 
of the sector to new labour. 

3.5  Trade union feedback 

All  trade  unions  that  participated  in  the  inception  impact  assessment’s  consultation 
opposed a liberalisation of the current social legislation of road transport – a change which 
is considered to bring about negative impacts on the safety of workers, passengers, and 
other road users and thus to counteract the objective of the legislation itself. What trade 
unions and workers fear the most is the implementation of derogations to the general rules 
set out in Regulation (EC) 561/2006 on daily/weekly breaks and rest arrangements, and 
its consequences on bus and coach drivers’ health and safety. Particularly, trade unions 
reported  that  of  concerns  to  professional  drivers  is  the  manipulation  of  rules  that  place 
additional  demands  and  stresses  on  the  driver,  which  in  turn  affects  driver  safety,  the 
safety  of  other  road  users  and  the  long-term  viability  of  undertakings.  Therefore,  any 
change to the rules should have protections in place to ensure that  they cannot serve a 
purpose not expected under the spirit of the Regulation. 

Such potential derogations mixed with what has been labelled by ETF as unfriendly work 
schedules, restricted social life during working periods, poor levels of pay are – according 
to  EU  citizens  and  trade  unions  –  contributing  to  the  unattractiveness  of  the  bus  driver 
profession.  This  in  turn  puts  at  risk  the  sustainability  of  a  sector  that  is  already  facing 
labour shortages (and an increasingly old workforce). As reported by one respondent, to 
support this claim, the  2020 IRU driver  shortage  survey argued that  commercial freight 
driver shortage on the continent to rise from 23% in 2019 to 36% in 2020; the survey also 
highlighted driver shortages in bus and coach transport54. Therefore, (unintended) future 
impacts need to be reflected on, and changes to the Regulation (EC) 561/2006 should be 
made in the spirit of good working conditions for drivers, fair business conditions for road 
transport undertakings and safer roads for all users. 

In the majority of trade unions’ opinion, to support the sector in its recovery (also in light 
of the  COVID-19 pandemic’s impact on tourism) and to make the bus and coach  sector 
more  resilient  and  attractive,  the  root  causes  of  the  above-described  issues  need  to  be 

51  According to  regulation  561/2006  (Art.  4),  weekly  rest  period  means  the  weekly  period  during 
which a driver may freely dispose of his time; regular weekly rest period means any period of rest 
of at least 45h; reduced weekly  rest  period means any period of rest of less than 45 hours (to a 
minimum of 24 hours). 
52 According to regulation 561/2006 (Art. 6), “In any two consecutive weeks a driver shall take at 
least two regular weekly rest periods or one regular weekly rest and one reduced weekly rest period 
of at least 24 hours”. 
53 “Companies” bus and coach operators in addition to tour operators. 
54 Available at: Reducing labour shortages by improving skills matching | IRU  

35 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

addressed  first.  Namely,  the  bus  and  coach  sector  needs  to  meet  the  expectations  of 
today’s workforce in terms of quality of work and life as well as in terms of pay. 

3.6  EU citizen feedback 

According to the feedbacks received, there seems to be a deep harmony of views between 
trade  unions  and  EU  citizens  (this  could  however  be  related  to  the  fact  that  some  EU 
citizens have identified themselves as – or seem to speak on behalf of  – bus and coach 
drivers). In fact, a large majority of the EU citizens who provided feedback to the Inception 
Impact Assessment has expressed their concerns towards the preliminarily identified policy 
options  (and  potential  legislative  amendments).  In  line  with  trade  unions,  they  seem  to 
fear  a  deterioration  of  working  conditions,  driven  by  a  worsening  of  occupational  health 
and safety, which, in turn, might lead to negative impacts  on road safety and the more 
general attractiveness of jobs in the sector. 

Overall,  what  they  call  into  question  is  rooted  into  the  understanding  of  the  role  of 
professional bus drivers provided by the Commission and by the road transport industry 
as a whole. More specifically, “professional bus driver” is argued to be a term that is very 
loosely used to describe a worker who carries out a multitude of complex tasks in a very 
broad spectrum of working conditions and environments. While many are of the mind that 
the  main  activity  is  driving,  in  fact,  the  least  stressful  aspect  of  the  job  is  driving  itself 
(which in some cases can constitute only a small share of the total daily working time). To 
support this statement, one of the respondents quoted a recent survey55 by the European 
Transport  Workers  Association  (ETF)  which  argues  that  a  large  portion  of  the  chronic 
fatigue reported by professional bus drivers is to be linked to the many activities they can 
be responsible for (besides driving): selling tickets (also a feature of urban and inter-urban 
road  transport),  cleaning  the  coach,  selling  drinks/snacks,  baggage  handling,  pick-
up/drop-off at the hotel, assisting passengers, etc. Furthermore, the ETF study argues that 
such  “secondary”  tasks  limit  daily  rest  periods  and  breaks.  Drivers’  tiredness  is  strictly 
connected with higher risks of road accidents which, in turn, undermine the achievement 
of “Vision Zero”, the ambitious goal of the European Commission to reduce road deaths to 
almost zero by 2050. 

Distancing  himself  from  the  opinion  of  most  EU  citizens,  a  respondent  in  this  category 
claimed  that  having  the  same  regulation  for  freight  and  passenger  transport  is  simply 
unfeasible, as bus drivers have different duties such as taking care of customers and their 
needs. Although people safety should always be the first concern of legislators, the rigidity 
of the Regulation is such that it is perceived as a source of great stress for the drivers. 

3.7  Public authority feedback 

Similar concerns are expressed by the only public authority who provided feedback on the 
initiative.  However,  it  recognised  the  need  to  increase  the  flexibility  of  legislation 
particularly for drivers in occasional transport of passengers by bus or coach. Indeed, the 
EU Regulation applies to both freight and passengers transport, providing similar guidelines 
in  terms  of  organisation  of  working  and  driving  times,  and  breaks  and  rest  periods. 
Nonetheless, the bus and coach sector, which plays a vital role for the tourism industry, is 
dependent  on  holiday  schedules  and  is  organised  very  differently  from  freight  transport 
activities and from other passenger services. 

3.8  Conclusion 

The inception impact assessment for an initiative on the EU rules on driving time, breaks 
and  rest  periods  received  a  total  of  79  submissions.  Nearly  half  of  them  came  from  EU 

55  Available  at:  ETF:  European  Transport  Workers'  Association  |  ETF  survey  on  driver  fatigue  in 
European road transport - ETF: European Transport Workers' Association (etf-europe.org)  

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Study on a possible revision of the break time and rest period rules for bus and coach drivers 

citizens  (46%),  followed  by  trade  unions  (25%),  Business  associations  (13%)  and 
Companies (10%), with the remaining 6% comprised of public authorities, non-EU citizens 
and respondents ticking ‘other’. 

The  consultation  suggests  that  the  revision  of  Regulation  (EC)  No  561/2006  is  a 
highly  polarising  issue.  Respondents  to  the  initiative  seem  to  be  split  into  two  major 
groups: on one side, trade unions and stakeholders responding as EU citizens expressed 
resistance  to  any  changes  to  the  current  provisions  on  breaks  and  rest  arrangements, 
which were reported as seen as harmful to occasional bus drivers’ wellbeing and dangerous 
in terms of road safety; on the other side, businesses and business associations  were in 
favour  of  introducing  specific  solutions  for  the  sub-sector,  which  they  felt  would  help  it 
respond  better  to  the  needs  of  coach  and  bus  drivers,  to  improve  the  experience  of 
passengers, and to increase profit margins. The only public authority who participated in 
the  initiative  stood  somehow  in  the  middle:  while  recognising  the  need  to  increase  the 
flexibility  of  legislation,  it  shared  some  of  the  concerns  expressed  by  trade  unions  and 
citizens. 

More specifically, trade unions and EU citizens (with only few exceptions) put the emphasis 
of  their  argument  on  the  potential  risks  that  the  implementation  of  derogations  to  the 
general rules set out in Regulation (EC) 561/2006 might entail. For instance, more flexible 
working hours are perceived as dangerous for the health and safety of drivers, which in 
turn  poses  a  threat  on  road  safety.  These  factors  are  altogether  contributing  to  the 
unattractiveness of the bus driver profession (which is already facing a significant labour 
shortage). EU citizens also criticise a lack of understanding of the role of professional bus 
drivers  by  the  Commission.  According  to  them,  allowing  for  the  extension  of  working 
hours/days means neglecting the diversified role of  occasional bus drivers, who oversee 
other activities beyond driving (e.g. assisting passengers).  

Business  associations  and  companies  argued  that  more  flexible  rules  are  necessary  to 
differentiate  between  two  inherently  different  types  of  transport:  freight  transport  and 
occasional passenger transport. If freight transport activities are schedulable in compliance 
with  Regulation  (EC)  561/2006  on  driving  times,  breaks  and  rest  periods,  the  needs  of 
bus/coach drivers and passengers cannot always comply with it (especially the occasional 
service). The lack of flexibility in working hours for bus and coach drivers – which currently 
follow the same standards for truck drivers in terms of daily driving times and breaks/rests 
– entails the need to hire more drivers and bear higher costs. This leads to reduced financial 
health  in  the  sector  as  well  as  investments,  and  a  slower  recovery  from  the  Covid-19 
pandemic.  Furthermore,  the  rigidity  of  the  Regulation  constitutes  was  reported  by 
businesses  and  business  associations  to  be  a  source  of  great  stress  for  the  drivers 
themselves, which adds up to the daily fatigue. This was attributed to the fact that drivers 
and operators can both face penalties for non-compliance with the rules.  

37 

 
 
 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

4. Analytical methods used to assess the baseline 

scenario 

This  annex  presents  the  methodology  for  and  results  of  the  analysis  of  the  baseline 
scenario. The baseline scenario consisted of a stepwise approach to model the data from 
the occasional bus and coach sector until 2050. This has been a challenging exercise, due 
to the lack of granular data for the occasional transport of bus and coach passengers, which 
is  a  very  small  sub-sector  of  the  transport  market  (as  highlighted  in  the  proposal  and 
inception reports, as well as previous studies). Despite the lack of granular data, the team 
developed  a  methodological  approach  for  extrapolating  data  on  the  sub-sector  for  all 
countries in the EU-27. This annex presents the methodological approach that was adopted 
and the main results. 

4.1  Methodological approach  

•  Step 1: since there are no readily available projections on the occasional transport 
sector,  we  first  had  to  obtain  projections  for  the  closest  possible  proxy.  The 
projections for the bus  and coach sector  from  the PRIMES-TREMOVE  model have 
been used for this purpose56. These projections build on the EU Reference scenario 
2020 but also reflect the “Fit for 55” package proposed by the European Commission 
in July 2021.  

•  Step  2:  we  then  built  a  separate  model57  aimed  at  ‘translating’  the  PRIMES-
TREMOVE  projections  into  occasional  transport,  using  the  information  at  our 
disposal.  In  practice,  this  meant  identifying  and  assessing  the  relationship  (i.e. 
correlation) between a key ‘dependent variable’ which is related to the occasional 
sector and for which data has been available – in this case numbers of passengers 
–  and  a  relevant  number  of  independent  variables.  If  a  strong  correlation  (i.e.  a 
high goodness of fit) is obtained, the behaviour of the independent variables can be 
correlated to the dependent variable. This assessment was important to establish 
the behaviour of the dependent variable. The potential correlations, which took into 
account the independent variable GDP and tourism activity, as pointed out below, 
then served as the basis to estimate projections for the number of passengers in 
the sub-sector until 2050, which in turn allowed us to estimate the market share of 
the occasional transport within the overall bus and coach market.  

•  Step 3 involved extrapolating, based  on real  data from 9 countries considering a 
base year of 2019, data on transport activity (in terms of pax-km and thousands of 
passengers) for the remaining 18 countries of the EU-27. First, based on the data 
available, we  estimated the share  of national occasional bus and coach transport 
and international occasional bus and coach transport in terms of total bus and coach 
activity in 2019. In order to establish a correlation between the countries with data 
available  in  2019  and  those  with  missing  data  in  the  same  year,  some  relevant 
parameters  were  considered  to  determine  similarities  between  the  use  of  land 
transport  and  the  effect  it  has  on  occasional  bus  and  coach  transport,  namely  i) 
GDP per capita (with data from PRIMES-TREMOVE); ii) motorisation rate (Eurostat 
per 1,000 inhabitants); iii) rail passengers per inhabitants (Eurostat). Taking into 

56  The  PRIMES-TREMOVE  model  developed  by  E3Modelling  projects,  on  a  five-year  basis,  the 
evolution  of  demand  for  passengers  and  freight  transport  by  transport  mode  and  vehicle 
types/fuel/technologies. The model includes all Member States of the EU and is also able to provide 
detailed outlooks for some other countries (PRIMES-TREMOVE – E3 Modelling). 
57 This is a multi-variate regression model, which, as the name implies, is a technique that measures 
the  relationship  between  multiple  independent  variables  to  explain  and  estimate  a  particular 
dependent  variable.  It  is  a  tool  widely  used  for  forecasting  parameters  over  time,  establishing 
descriptive and causal inferences. 

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Study on a possible revision of the break time and rest period rules for bus and coach drivers 

account the base year of 2019, projections until 2050 for all EU-27 countries were 
determined using the results from the model developed in Step 2. 

•  Step 4 involved using the correlations established on the market share of occasional 
transport  to  make  projections  for  a  variety  of  relevant  indicators  (employment 
levels,  turnover  and  the  number  of  occasional  bus  and  coach  companies).  These 
projections  are  carried  out  taking  into  account  the  behaviour  of  the  independent 
variables over time and the evolution of the market share over the years. It was 
not  possible  to  make  such  projections  for  the  fleet  size  in  the  sub-sector,  as  we 
considered that such variable cannot be estimated as a proportion to market share, 
given  that  the  occasional  sub-sector’s  fleet  is  typically  characterised  by  a  mix  of 
vehicles that operate in regular and occasional services.  

•  Step 5 involved a qualitative assessment of other variables, which cannot be derived 
quantitatively  due  to  lack  of  data  or  because  of  their  qualitative  nature.  This  is 
especially the case for parameters such as levels of fatigue, etc. This assessment is 
carried out based on the results from the stakeholder consultation and expressed 
using numbers where relevant and possible (e.g. operating costs). 

4.2  Data collection phase  

In order to assess the baseline scenario of the occasional bus and coach sector, several indicators (quantitative 
and qualitative) were pre-defined. Although extensive research was done to gather quantitative evidence, scarce 
and patchy data was only found in some countries. This  research was done on official national and European 
studies, reports, surveys and from national databases.  

It is important to note that as the data available per country varies, the analyses presented 
in  the  following  section  involve  different  combinations  of  countries.  The  following  table 
shows which historical variables are available in each Member State. Estimated data are 
based on existing data from other years. 

Table 4.1: Historical data available in the period between 2012-201958 

Total number 
of 
passengers in 
bus and 
coach 
transport 

Number of 
passengers in 
national59 
bus and 
coach 
transport 

Number of 
passengers in 
international 
bus and coach 
transport 

Total number 
of passengers 
in occasional 
bus and coach 
transport 

Number of 
passengers in 
national 
occasional 
bus and coach 
transport 

Number of 
passengers in 
international 
occasional bus 
and coach 
transport 

Belgium 

Available 

Estimated 

Estimated 

Estimated 

Estimated 

Estimated 

Czechia 

Available 

Available 

Available 

Available 

Available 

Available 

Estonia 

Available 

Available 

Available 

Estimated 

Available 

Estimated 

Germany 

Available 

Available 

Available 

Estimated 

Available 

Estimated 

Hungary 

Available 

Available 

Available 

Available 

Available 

Available 

Lithuania 

Available 

Available 

Available 

Estimated 

Available 

Estimated 

Netherlands 

Estimated 60 

Estimated 

Estimated 

58 Data retrieved from Eurostat 
59 National transport is related to passenger services within a certain country 
60 Estimated based on the reports on Key Figures of Dutch Coach Transport in 2018, 2019 and 2020 
(Kerncijfers van het Nederlandse touringcarvervoer, Panteia) 

39 

 
 
 
 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Poland 

Available 

Available 

Available 

Available 

Available 

Available 

Portugal 

Available 

Available 

Available 

Available 

Available 

Available 

Romania 

Available 

Available 

Available 

Available 

Available 

Available 

Spain 

Estimated 

Available 

Estimated 

Estimated61 

Available 

Estimated 

Source: Authors’ own compilation 

4.3  Data used 

The following tables show the data that the team was able to collect. The data was retrieved from 
multiples sources, namely from UNECE, national databases and some national/social representatives 
reports.  

61 Estimated based on reports from CONFEBUS 

40 

 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Table  4.2:  Historical  data  available  on  bus  and  coach  transport  activity  (total)  in  the  period  from  2013-2019,  from  the 
Statistical Pocketbook in Transport 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

Country 

Total bus and coach (billion pkm) 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

8.8 
15.8 
10.3 
1.3 
15.7 
60.5 
6.5 
2.4 
21.0 
53.8 
7.5 
55.7 
3.5 
17.1 
8.1 
101.8 
2.8 
1.0 
2.3 
0.5 
4.6 
37.8 
6.0 
17.1 
9.7 
3.3 
5.3 

9.0 
15.4 
11.5 
1.3 
17.1 
62.2 
6.6 
2.4 
21.0 
39.5 
7.5 
57.2 
3.6 
17.6 
8.4 
102.8 
3.0 
1.0 
2.3 
0.5 
4.5 
39.2 
5.7 
18.3 
9.7 
3.4 
5.4 

9.1 
14.4 
12.5 
1.4 
16.3 
65.1 
6.9 
3.1 
21.1 
46.4 
7.5 
58.0 
3.4 
17.8 
8.5 
102.5 
2.7 
1.1 
2.2 
0.5 
4.9 
37.6 
6.6 
24.9 
9.8 
3.6 
5.4 

9.4 
13.6 
12.2 
1.5 
17.3 
64.4 
7.1 
2.9 
20.9 
47.8 
8.3 
59.3 
3.8 
17.8 
9.0 
102.3 
2.6 
1.1 
2.2 
0.5 
5.0 
36.8 
7.6 
25.6 
9.9 
3.6 
5.9 

9.7 
13.4 
10.6 
1.5 
18.3 
62.5 
7.3 
2.8 
20.5 
30.5 
8.2 
59.5 
4.2 
18.3 
9.8 
102.7 
2.7 
1.1 
2.1 
0.6 
4.6 
36.1 
7.4 
25.0 
10.0 
3.7 
5.9 

10.3 
13.5 
9.9 
1.6 
18.1 
62.5 
7.1 
2.8 
20.5 
32.2 
8.0 
60.0 
3.8 
18.9 
10.5 
103.0 
2.8 
1.2 
2.2 
0.6 
5.5 
34.5 
7.9 
26.7 
10.0 
3.8 
6.2 

10.4 
13.7 
10.8 
1.6 
18.0 
61.3 
6.9 
3.1 
20.3 
33.3 
7.9 
59.2 
4.0 
18.8 
10.7 
104.3 
2.9 
1.2 
2.2 
0.6 
5.5 
36.2 
7.9 
26.7 
10.1 
3.8 
6.2 

Source: Data from the EU transport in figures - Statistical pocketbook 2022 

41 

 
 
 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Table 4.3: Historical data available on the number of overall bus and coach passengers (total) in the period from 2013-2019 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

Country 

Total bus and coach (thousand passengers) 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

179,909 
21,060 
426,763 
N/A 
1,127,390 
5,587,793 
N/A 
176,440 
N/A 
N/A 
352,736 
N/A 
248,536 
1,632,681 
192,535 
3,832 
298,173 
N/A 
147,222 
N/A 
N/A 
4,080,846 
546,383 
274,393 
N/A 
N/A 
N/A 

180,068 
18,851 
425,603 
N/A 
1,125,375 
5,592,743 
N/A 
175,669 
N/A 
N/A 
349,416 
N/A 
250,396 
1,651,105 
197,390 
N/A 
321,451 
N/A 
146,115 
N/A 
N/A 
4,142,660 
476,348 
282,019 
N/A 
N/A 
N/A 

179,465 
18,562 
442,244 
N/A 
1,131,020 
5,574,012 
N/A 
179,120 
N/A 
N/A 
347,612 
N/A 
250,964 
1,630,622 
200,994 
N/A 
300,567 
N/A 
144,375 
N/A 
282,600,000 
4,088,929 
515,092 
1,488,456 
N/A 
N/A 
N/A 

Source: Data from Eurostat 
Note: Highlighted cells indicate extrapolated/estimated data 

179,839 
16,565 
447,621 
N/A 
1,127,563 
5,585,616 
N/A 
171,414 
N/A 
N/A 
348,336 
N/A 
252,132 
1,596,913 
205,571 
N/A 
291,505 
N/A 
141,390 
N/A 
282,600,000 
4,156,665 
513,389 
1,374,841 
N/A 
N/A 
N/A 

42 

178,538 
14,248 
445,332 
N/A 
1,130,333 
5,545,214 
N/A 
158,075 
N/A 
N/A 
345,816 
N/A 
249,382 
1,590,255 
217,605 
3,833 
292,243 
N/A 
138,467 
N/A 
282,600,000 
4,117,974 
514,832 
1,401,316 
N/A 
N/A 
N/A 

178,586 
14,924 
422,532 
N/A 
1,200,079 
5,546,700 
N/A 
150,202 
N/A 
N/A 
345,909 
N/A 
238,117 
1,631,028 
226,745 
3,831 
288,684 
N/A 
135,605 
53,467 
282,600,000 
4,110,605 
543,144 
1,432,919 
N/A 
N/A 
N/A 

178,586 
149,239 
446,185 
155,838 
1,237,924 
5,546,700 
6,939,848 
161,800 
2,098,990 
1,351,895 
345,909 
3,401,187 
231,878 
1,587,929 
227,698 
3,760,000 
290,106 
76,083 
132,802 
57,409 
410,709 
4,192,345 
565,911 
1,317,893 
345,909 
168,238 
398,855 

 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Table 4.4: Historical data available on the number of national occasional bus and coach passengers in the period from 2013-
2019 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

Country 

Occasional national bus and coach transport (passengers) 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

140,366 
21,060 
N/A 
N/A 
N/A 
63,537 
N/A 
3,195 
N/A 
156,328 
17,532 
N/A 
5,773 
76,170 
N/A 
N/A 
4,175 
N/A 
N/A 
N/A 
37,137 
17,727 
9,055 
13,315 
N/A 
N/A 
N/A 

N/A 
18,851 
N/A 
N/A 
38,375 
65,958 
N/A 
4,466 
N/A 
162,916 
16,577 
N/A 
4,846 
74,658 
N/A 
N/A 
4,273 
N/A 
N/A 
N/A 
33,891 
18,045 
10,249 
13,736 
N/A 
N/A 
N/A 

N/A 
18,562 
N/A 
N/A 
42,218 
70,702 
N/A 
4,137 
N/A 
170,896 
16,725 
N/A 
N/A 
75,644 
N/A 
N/A 
4,988 
N/A 
N/A 
N/A 
34,238 
15,094 
12,235 
11,092 
N/A 
N/A 
N/A 

Source: Data from Eurostat 

N/A 
14,248 
N/A 
N/A 
31,712 
68,770 
N/A 
3,547 
N/A 
192,189 
N/A 
N/A 
N/A 
80,298 
N/A 
N/A 
5,778 
N/A 
N/A 
N/A 
33,973 
15,453 
14,501 
16,200 
N/A 
N/A 
N/A 

N/A 
14,924 
N/A 
N/A 
33,628 
65,020 
N/A 
3,340 
N/A 
205,809 
N/A 
N/A 
N/A 
83,112 
N/A 
N/A 
6,499 
N/A 
N/A 
N/A 
35,584 
11,916 
11,520 
25,867 
N/A 
N/A 
N/A 

N/A 
14,924 
N/A 
N/A 
37,784 
N/A 
N/A 
4,830 
N/A 
205,809 
N/A 
N/A 
N/A 
85,363 
N/A 
N/A 
7,340 
N/A 
N/A 
N/A 
35,714 
10,285 
9,881 
30,913 
N/A 
N/A 
N/A 

N/A 
16,565 
N/A 
N/A 
28,830 
69,911 
N/A 
2,465 
N/A 
179,791 
N/A 
N/A 
N/A 
75,493 
N/A 
N/A 
5,349 
N/A 
N/A 
N/A 
33,478 
16,336 
10,691 
13,197 
N/A 
N/A 
N/A 

43 

 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Table 4.5: Historical data available on the number of occasional international bus and coach passengers in the period from 
2013-2019 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

Country 

Occasional international bus and coach transport (passengers) 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
560 
N/A 
N/A 
N/A 
N/A 
703 
1,659 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
998 
288 
955 
N/A 
N/A 
N/A 

N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
557 
N/A 
N/A 
N/A 
N/A 
773 
2,223 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
943 
400 
870 
N/A 
N/A 
N/A 

N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
408 
N/A 
N/A 
N/A 
N/A 
N/A 
2,361 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
1,482 
292 
855 
N/A 
N/A 
N/A 

Source: Data from Eurostat 

N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
491 
N/A 
N/A 
N/A 
N/A 
N/A 
4,015 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
939 
553 
841 
N/A 
N/A 
N/A 

N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
557 
N/A 
N/A 
N/A 
N/A 
N/A 
4,093 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
1,411 
471 
951 
N/A 
N/A 
N/A 

N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
515 
N/A 
N/A 
N/A 
N/A 
N/A 
3,049 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
1,033 
457 
638 
N/A 
N/A 
N/A 

N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
323 
N/A 
N/A 
N/A 
N/A 
N/A 
2,481 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
985 
412 
369 
N/A 
N/A 
N/A 

44 

 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Table 4.6: Historical data available on the volume of national occasional bus and coach transport (pax-km) in the period from 
2013-2019 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

Country 

Occasional national bus and coach transport (million pax-km) 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

7,903 
2,312 
N/A 
N/A 
N/A 
13,066 
N/A 
315 
N/A 
N/A 
1,231 
N/A 
535 
3,202 
N/A 
N/A 
197 
N/A 
N/A 
N/A 
4,077 
1,981 
796 
932 
N/A 
N/A 
N/A 

N/A 
2,181 
N/A 
N/A 
3,800 
12,620 
N/A 
270 
N/A 
N/A 
1,114 
N/A 
612 
3,233 
N/A 
N/A 
223 
N/A 
N/A 
N/A 
3,921 
2,061 
950 
935 
N/A 
N/A 
N/A 

N/A 
2,251 
N/A 
N/A 
3,717 
13,185 
N/A 
454 
N/A 
N/A 
1,107 
N/A 
700 
3,511 
N/A 
N/A 
245 
N/A 
N/A 
N/A 
3,921 
1,625 
1,086 
831 
N/A 
N/A 
N/A 

Source: Data from Eurostat 
Note: Highlighted cells indicate extrapolated/estimated data 

N/A 
1,940 
N/A 
N/A 
4,318 
12,022 
N/A 
306 
N/A 
N/A 
998 
N/A 
916 
4,374 
N/A 
N/A 
274 
N/A 
N/A 
N/A 
N/A 
1,539 
1,598 
1,250 
N/A 
N/A 
N/A 

N/A 
2,096 
N/A 
N/A 
3,648 
12,597 
N/A 
397 
N/A 
N/A 
1,051 
N/A 
801 
3,926 
N/A 
N/A 
228 
N/A 
N/A 
N/A 
N/A 
1,740 
1,184 
1,021 
N/A 
N/A 
N/A 

45 

N/A 
1,859 
N/A 
N/A 
4,083 
11,557 
N/A 
275 
N/A 
N/A 
947 
N/A 
1,048 
4,805 
N/A 
N/A 
285 
N/A 
N/A 
N/A 
N/A 
1,499 
1,575 
1,206 
N/A 
N/A 
N/A 

N/A 
2,124 
329 
N/A 
4,158 
11,349 
N/A 
359 
N/A 
6,500 
899 
N/A 
1,073 
5,229 
N/A 
N/A 
348 
N/A 
N/A 
N/A 
N/A 
2,937 
1,357 
1,636 
N/A 
N/A 
N/A 

 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Table 4.7: Historical data available on the volume of international occasional bus and coach transport (pax-km) in the period 
from 2013-2019 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

Country 

Occasional international bus and coach transport (million pax-km) 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

N/A 
1,780 
N/A 
N/A 
N/A 
N/A 
N/A 
312 
N/A 
N/A 
N/A 
N/A 
188 
805 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
1,438 
295 
1,445 
N/A 
N/A 
N/A 

N/A 
1,679 
N/A 
N/A 
N/A 
N/A 
N/A 
192 
N/A 
N/A 
N/A 
N/A 
193 
1,117 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
1,526 
315 
871 
N/A 
N/A 
N/A 

N/A 
1,733 
N/A 
N/A 
N/A 
N/A 
N/A 
172 
N/A 
N/A 
N/A 
N/A 
N/A 
1,288 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
3,030 
281 
978 
N/A 
N/A 
N/A 

Source: Data from Eurostat 

N/A 
965 
N/A 
N/A 
N/A 
N/A 
N/A 
230 
N/A 
N/A 
N/A 
N/A 
N/A 
1,412 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
1,696 
525 
591 
N/A 
N/A 
N/A 

N/A 
1,614 
N/A 
N/A 
N/A 
N/A 
N/A 
147 
N/A 
N/A 
N/A 
N/A 
N/A 
1,296 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
1,583 
744 
427 
N/A 
N/A 
N/A 

46 

N/A 
1,043 
N/A 
N/A 
N/A 
N/A 
N/A 
208 
N/A 
N/A 
N/A 
N/A 
N/A 
1,566 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
1,578 
645 
961 
N/A 
N/A 
N/A 

N/A 
1,098 
N/A 
N/A 
1,432 
5,169 
N/A 
280 
N/A 
N/A 
N/A 
N/A 
N/A 
1,476 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
N/A 
1,794 
563 
973 
N/A 
N/A 
N/A 

 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Table 4.8: Historical data available on the turnover of other passenger land transport n.e.c in the period from 2013-2019 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

Country 

Annual detailed enterprise statistics for services - Other passenger land transport n.e.c. 
Turnover or gross premiums written - million euro 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

2,023 
716 
210 
32 
N/A 
4,250 
523 
108 
515 
3,777 
N/A 
7,565 
242 
503 
689 
3,579 
39 
222 
32 
N/A 
N/A 
1,295 
581 
553 
519 
179 
121 

2,055 
644 
212 
30 
N/A 
4,422 
611 
131 
794 
3,949 
N/A 
7,019 
258 
578 
754 
3,718 
42 
217 
32 
N/A 
N/A 
1,409 
578 
607 
517 
180 
138 

2,161 
697 
208 
31 
306 
4,649 
576 
125 
756 
4,153 
N/A 
7,150 
276 
790 
828 
3,752 
45 
227 
30 
N/A 
2,018 
1,325 
585 
575 
509 
183 
138 

Source: Data from Eurostat 
Note: Highlighted cells indicate extrapolated/estimated data 

2,308 
663 
215 
39 
386 
4,966 
608 
132 
715 
4,126 
N/A 
13,274 
320 
995 
975 
3,559 
69 
264 
37 
N/A 
2,345 
1,285 
631 
613 
475 
193 
206 

2,366 
710 
210 
34 
335 
5,090 
587 
124 
644 
3,958 
N/A 
7,052 
294 
863 
1,000 
3,767 
54 
259 
30 
N/A 
2,304 
1,281 
599 
592 
507 
180 
160 

47 

2,268 
551 
217 
37 
518 
4,879 
644 
129 
761 
4,341 
513 
13,900 
336 
1,336 
958 
3,748 
91 
307 
35 
N/A 
2,723 
1,599 
714 
746 
531 
218 
212 

2,188 
658 
234 
39 
585 
4,707 
673 
139 
809 
4,449 
536 
13,445 
344 
1,508 
924 
3,964 
106 
266 
37 
73 
2,365 
1,680 
759 
787 
605 
222 
214 

 
 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Table 4.9:  Historical data available on the number of persons employed for other passenger land transport n.e.c in the period 
from 2013-2019 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

Country 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

16,051 
7,073 
10,233 
559 
N/A 
73,046 
5,787 
2,143 
8,916 
49,859 
N/A 
102,038 
6,109 
15,198 
6,519 
42,531 
1,529 
2,986 
1,405 
N/A 
25,803 
37,473 
10,668 
20,758 
5,075 
3,070 
3,784 

Annual detailed enterprise statistics for services - Other passenger land transport n.e.c. 
Number of persons employed 
16,288 
7,351 
9,936 
744 
7,464 
75,719 
6,078 
2,269 
11,374 
56,745 
N/A 
119,931 
7,078 
31,794 
7,971 
42,370 
3,166 
3,527 
1,596 
N/A 
24,604 
34,227 
11,344 
22,420 
4,962 
3,268 
6,829 

15,883 
6,418 
9,586 
774 
9,063 
73,838 
6,463 
2,308 
12,711 
57,720 
6,283 
117,771 
7,027 
38,606 
8,476 
41,161 
4,541 
3,815 
1,569 
N/A 
24,790 
35,390 
11,603 
24,164 
5,401 
3,479 
7,330 

16,626 
6,855 
10,254 
701 
6,687 
77,288 
5,583 
2,238 
13,111 
53,651 
N/A 
87,050 
7,106 
28,485 
7,322 
43,796 
1,953 
3,361 
1,478 
N/A 
24,827 
35,001 
11,006 
22,549 
5,191 
3,212 
6,107 

16,112 
7,208 
10,043 
659 
5,961 
74,903 
5,969 
2,475 
13,513 
51,192 
N/A 
N/A 
6,876 
25,392 
6,996 
42,995 
1,501 
3,176 
1,400 
849 
24,059 
36,391 
10,708 
21,424 
5,402 
3,191 
5,806 

16,120 
6,566 
10,173 
579 
N/A 
74,938 
6,499 
2,493 
15,286 
50,062 
N/A 
94,887 
6,443 
16,685 
6,692 
42,855 
1,472 
3,030 
1,492 
N/A 
24,657 
38,254 
10,864 
20,961 
5,308 
3,113 
5,410 

16,524 
7,129 
9,510 
826 
9,486 
76,814 
6,287 
2,354 
13,277 
56,579 
6,112 
121,629 
7,656 
40,407 
8,245 
41,561 
6,121 
3,982 
1,600 
1,101 
25,230 
34,894 
12,120 
24,588 
6,624 
3,551 
6,822 

Source: Data from Eurostat 
Note: Highlighted cells indicate extrapolated/estimated data 

48 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

4.4  Market share of occasional transport within the passenger 

bus and coach sector 

The  data  collection  phase  served  specially  to  highlight  the  lack  of  data  regarding 
international occasional bus and coach services. Nevertheless, where data were available, 
international  occasional  services  were  proven  to  be  considerably  less  significant  when 
compared to national transport. Data on the overall sector was also important to estimate 
the market share of occasional bus and coach transport.   

The starting point is the table below, which shows transport activity of occasional bus and 
coach transport for a sample of countries for the latest available year (usually 2019).  

Table  4.10:  Share  of  national  and  international  occasional  bus  and  coach 
transport for the sample of nine countries in 2019 

Million Passenger-km in the occasional bus and coach services and share in terms of total 
occasional bus and coach transport in 2019 

National 
Occasional 

% of total 
occasional 

Occasional 
International 

% of total 
occasional 

Total 
Occasional 

Belgium 

Czechia 

Estonia 

Germany 

Hungary 

Lithuania 

Poland 

Portugal 

Romania 

Average 

2,124 

4,158 

359 

11,284 

5,229 

348 

2,937 

1,357 

1,636 

Sources: Data from Eurostat 

66% 

74% 

56% 

68% 

78% 

54% 

62% 

71% 

66% 

1,098 

1,432 

280 

5,236 

1,476 

299 

1,794 

563 

973 

34% 

26% 

44% 

32% 

22% 

46% 

38% 

29% 

34% 

3,222 

5,590 

639 

16,520 

6,705 

647 

4,731 

1,920 

2,609 

66% 

34% 

As mentioned, the 2019 figures show a larger share of national occasional services of bus 
and coach transport activity in terms of occasional bus and coach transport activity across 
the  sample  of  countries  analysed.  Lithuania  showed  the  highest  share  of  international 
occasional  services  in  the  sample,  with  46%.  In  turn,  the  lowest  share  of  international 
occasional bus and coach services was experienced in Czechia, accounting for 26%. 

With  this  in  mind,  in  order  to  establish  a  correlation  between  these  countries  with  data 
available  for  2019  and  those  with  missing  data  for  the  same  year,  we  considered  the 
following parameters:  

i) 

ii) 

GDP per capita (with data from PRIMES-TREMOVE);  

Motorisation rate (Eurostat per 1,000 inhabitants);  

iii) 

Rail passengers per inhabitants (Eurostat).  

This correlation was established as a way to determine similarities between the use of land 
transport  and  the  effect  it  has  on  occasional  bus  and  coach  transport,  also  taking  into 
account  the  effect  of  economic  indicators  (i.e.  GDP  per  capita).  These  correlations  were 
then used to estimate the share of occasional transport in terms of overall road transport 
in 2019, with the latter available from PRIMES-TREMOVE’s data. 

49 

 
 
 
 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Table  4.11: Occasional bus and coach transport  activity (Gpkm)  and  respective 
market share in relation to the overall bus and coach market in 2019 in the EU-
27 

Market share of 
occasional bus and 
coach transport activity 
vs overall bus and coach 
passenger sector 
25.7% 

22.4% 

12.0% 

34.4% 

20.5% 

25.4% 

24.8% 

20.3% 

19.8% 

16.6% 

27.8% 

24.9% 

41.3% 

37.6% 

35.9% 

30.1% 

9.5% 

23.6% 

39.6% 

20.5% 

31.5% 

12.6% 

29.2% 

14.1% 

25.2% 

21.8% 

27.3% 

AT 

BE 

BG 

CZ 

CY 

DE 

DK 

EE 

ES 

EL 

FI 

FR 

HR 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

Occasional Bus and Coach Transport 
Activity (Gpkm) in 2019 

2.65 

3.22 

1.50 

5.59 

0.29 

16.52 

1.70 

0.64 

9.20 

3.51 

2.09 

14.35 

1.39 

6.70 

3.06 

30.85 

0.21 

0.65 

0.43 

0.11 

1.54 

4.73 

1.92 

2.47 

2.48 

0.78 

1.47 

EU-27 

24.7% 

120.05 

Source: Authors’ own compilation, based on extrapolations62 and real data 

Transport activity in the occasional bus and coach sector represented approximately 25% 
of the overall bus and coach activity in the EU-27 in 2019. The highest volume of occasional 
bus  and  coach  transport  was  observed  in  Italy  (30.85  Gpkm),  while  the  lowest  was  in 
Latvia (0.21 Gpkm), respectively representing 30.1% and 9.5% in relation to overall road 
transport activity in these countries. 
A similar exercise was carried out to estimate the number of passengers for occasional bus 
and coach transport in all countries in the EU-27. The number of passengers of occasional 
bus and coach transport is represented in the table below. 

62  Data  on  total  bus  and  coaches  was  extrapolated  considering  figures  from  the  2022  Statistical 
Pocketbook in Transport and data from PRIMES-TREMOVE 

50 

 
 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Table  4.12:  Occasional  bus  and  coach  passenger  (thousand)  and  respective 
market share in relation to the overall bus and coach market in 2019 in the EU-
27 

Market share of 
occasional bus and 
coach transport 
passengers vs overall 
road passenger sector 
2.5% 

2.4% 

3.6% 

5.9% 

4.4% 

2.3% 

2.2% 

5.2% 

3.8% 

4.1% 

4.2% 

2.2% 

10.3% 

10.5% 

2.5% 

4.8% 

0.6% 

4.8% 

3.0% 

4.7% 

8.8% 

0.5% 

3.9% 

4.2% 

2.1% 

5.2% 

3.8% 

AT 

BE 

BG 

CZ 

CY 

DE 

DK 

EE 

ES 

EL 

FI 

FR 

HR 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

Occasional Bus and Coach Transport 
passenger (passengers) 

4,521 

3,511 

15,857 

72,472 

6,851 

130,040 

152,322 

8,428 

51,682 

86,900 

14,655 

73,304 

23,949 

166,279 

5,604 

180,268 

735 

13,871 

2,317 

2,723 

36,231 

22,438 

21,883 

54,704 

7,331 

8,794 

15,130 

EU-27 

3.31% 

1,182,801 

Source: Authors’ own compilation, based on extrapolations and available data 

The number of passengers in the sub-sector represented on average 3.3% of total bus and 
coach transport in the EU-27 in 2019. The highest share was observed in Hungary (10.5%), 
while Poland had the lowest share (0.5%). It is important to note that in countries with 
high touristic activity, such as Italy, Portugal and Spain, the share of occasional bus and 
coach passengers represented between 3.8% and 5% of the total share of road passenger 
transport. 

For  the  following  sections,  the  team  adopted  a  mixed  approach  to  compute  the  future  trends  of  the  sector, 
initially applying a multivariate linear regression model, and computing trends aiming to project the values of the 
main indicators to the future. The following points are focused on the modelling at the different stages. 

51 

 
 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

4.5  Modelling approach adopted 

a.  Description of the modelling tool used: Regression analysis 

The following equation describes the model used. 

Where 𝑦 is the result for the dependent variable, 𝑎 and 𝑏 are the coefficients of the independent variables (𝑥1 
and 𝑥2), and 𝜀 is the intercept of the regression. 

𝑦 = 𝑎 ∙ 𝑥1 + 𝑏 ∙ 𝑥2 + ⋯ + 𝜀 

The model used to make the prediction of the outcome of the dependent variable was the Multivariate Linear 
Regression Model63. This statistical technique uses explanatory variables to predict the outcome of a response 
variable.  The  goal  is  to  model  the  linear  regression  between  the  independent  (explanatory)  variables  and 
dependent (response) variables. For this purpose, the team considered the level of interception (equal to 0) and 
the correlation coefficients, namely if the value and the signal appropriately described the dependent variable 
in  each  country.  Figure  4.1  illustrates  the  example  for  Spain  (dependent  variable:  occasional  services; 
independent  variables:  GDP  and  tourism).  This  shows  a  strong  R2,  as  well  as  reliable  correlation  coefficients. 
Regression  analyses  is  a  tool  often  used  in  transport  modelling  (in  various  transport  modes)  for  estimating 
transport demand and its determinants 64,65,66. 

b.  Description of the Dependent and Independent Variables 

The  modelling  approach  was adopted  to  compute  potential  correlations  between  the data  collected  and  the 
independent variable. 

At  this  stage,  the  dependent  variable,  i.e.  the  parameter  being  predicted,  was  considered  the  number  of 
passengers  in  the  occasional bus  and  coach sector.  This  variable  was  tested  both  in  terms  of  the  number  of 
passengers  and  passenger-kilometres.  In  addition,  services  were  distinguished  between  national  and 
international transport.  

The definition of the  independent  variables  – i.e. those variables that will not change due to the dependent 
variable and are used to explain the latter – was based on certain conditions. Firstly, only variables with a broad 
impact in the transport sector, and more specifically in the bus and coach market, were considered. In addition, 
only data available in European reports or official databases were taken into account.  

In this regard, the independent variables defined were: 

•  Gross Domestic Product (in millions of Euros),  
• 

Tourism activity (in terms of expenditure and investment, and accounted in thousands of Euros),  

Data on tourism was calculated based on projections from the World Tourism Organization67 and trends for the 
European Regions, as well as on the unemployment rate from the latest Ageing Report68. The GDP projections 
draw on the latest Ageing Report69.  

of 

Bureau 

statistics, 

transportation 

63 Multiple Linear Regression (MLR) Definition (https://www.investopedia.com/terms/m/mlr.asp) 
64 Ortuzar, Juan de Dios; Willumsen, Luis G. Modelling Transport (2011) – Fourth edition. p. cm 
65 
https://www.bts.gov/archive/subject_areas/national_household_travel_survey/methodology/regre
ssion_estimation 
66 Fitting a multiple regression line to travel demand forecasting: The case of the prefecture of Xanthi, 
Northern Greece, Mathematical and Computer Modelling, Volume 42, Issues 7–8, 2005, Pages 817-
836, ISSN 0895-7177, 
https://doi.org/10.1016/j.mcm.2005.09.010. 
67 European Union Tourism Trends (e-unwto.org) 
68 The 2021 Ageing Report: Economic and Budgetary Projections for the EU Member States (2019-
2070) | European Commission (europa.eu) 
69 The 2021 Ageing Report: Economic and Budgetary Projections for the EU Member States (2019-
2070) | European Commission (europa.eu) 

available 

at: 

52 

 
 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

c.  Statistical Tests 

The team carried out several statistical tests, aiming at understanding the correlations between the dependent 
variable and the independent variables. To assess the statistical  significance, the team considered a p-value70 
lower than 0.10. This has the objective of testing the probability of the hypothesis test (null hypothesis), i.e. no 
correlation between the independent and the dependent variable. In this regard, a p-value lower than 0.10 is 
indicative of a low evidence that the null hypothesis is true, thus of a good fit. 

In addition, the team considered regressions that returned a R2 above 0.9571. This statistical measure shows how 
well the data fit the regression model; a higher R2 means a higher fit of the data into the regression model.  

The behaviour of the curves (regarding the predicted and normal values), as shown in the figure below, show a 
high goodness-of-fit of the data in the model.  

Figure 4.1: Statistical tests for Spain. Dependent variable occasional national transport (number of passengers) 
and independent variable Tourism (Expenditure and Investment, thousand euro) 

Source: Authors’ own compilation 

After the initial set of tests, some adjustments were carried out aiming at correcting  some outlier dependent 
variables, especially ensuring the harmonisation of different sources of data. Furthermore, considering the low 

70  The  p-value  is  the  probability  of  finding  the  observed,  or  more  extreme,  results  when  the  null 
hypothesis of a study question is true.   
71 The R-squared (R2) is a statistical measure that represents the proportion of the variance for a 
dependent variable that is explained by an independent variable or variables in a regression model. 

53 

Occasional national transport, Nº of pax (multiple official sources)Tourism (Expenditure and Investment), thousand euro (Eurostat)SignificanceCoefficients0.000.000.00054P-value0.000.00R²Lower 90,0%0.000.000.92503Upper 90,0%0.000.00050,000100,000150,000200,000250,00020092010201120122013201420152016201720182019YearsOccasional national transport, Nº of pax (multiple official sources)Predicted Value 
 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

share  of  international  bus  and  coach  services,  the  modelling  was  focused  on  national  passenger  services, 
assuming the same behaviour both for national and international shares. 

As previously mentioned, the team performed the tests for countries where data on the number of occasional 
passengers  of  bus  and  coach  transport  was  available,  namely  Belgium,  Czechia,  Estonia,  Germany,  Hungary, 
Lithuania, Poland, Portugal and Romania. For those countries with a strong correlation between variables, a high 
goodness  of  fit  was  found  for  one  or  two  independent  variables.  This  sample  ensured  a  reasonable 
geographical balance within Europe. 

d.  Main Outputs 

The analysis focused on the R2 (typically used to define the proportion of the variance for a dependent variable 
that  is  explained  by  an  independent  variable)  and  on  the  coefficients  between  the  dependent  and  the 
independent variables. Furthermore, additional corrections were applied:  

• 

For adjusting the base year of each regression (i.e., base year difference between the regression output 
and the historical value is set to zero, directly using the growth rate between two consecutive results of 
the regression to apply to each previous year); 

•  On the data (namely tourism forecasts72), aiming to reflect the impact of COVID-19 pandemic on the 
tourism figures (a “delay” in the forecasts was introduced, making the original forecast volumes for 2020 
being reached only around 2024). 

However, given the small dataset with real data available, some projections may be overestimated, especially in 
larger countries with higher GDP rates (such as Germany), or even underestimated (e.g. in smaller countries such 
as Estonia and Lithuania). We attempted to overcome these limitations by ensuring a higher goodness fit with 
independent variables that would also better reflect the reality of the sub-sector in the sample of countries with 
data available. 

Figure 4.2: Summary output for the regression for Spain 

Source: Authors’ own compilation 

72  At  the  time  of  the  analysis,  projections  from  the  World  Tourism  Organization  did  not  take  into 
account the effect of COVID-19. 

54 

SUMMARY OUTPUTRegression StatisticsMultiple R0.96178563R Square0.925031598Adjusted R Square0.910037917Standard Error5742.611247Observations7ANOVAdfSSMSFSignificance FRegression12034544299203454429961.694765240.00053712Residual5164887919.732977583.94Total62199432219CoefficientsStandard Errort StatP-valueLower 95%Upper 95%Lower 90,0%Upper 90,0%Intercept91172.2163610844.654828.4071109540.00039029363295.14365119049.289169319.7123113024.7204Tourism (Expenditure and Investment), thousand euro (Eurostat)0.0026561180.0003381617.8546015330.000537120.0017868480.0035253890.0019747080.003337529 
 
  
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Table 4.13: Main outputs of the regression analysis 

Main outputs of the regression analysis 

Independent 
Variable 1 

Independent 
Variable 2 

R square 

Coefficient 1 

Coefficient 2 

Tourism 

Tourism 

Belgium 

Czechia 

GDP 

GDP 

Germany 

Tourism 

Hungary 

Lithuania 

GDP 

GDP 

Poland 

GDP 
Source: Authors’ own compilation 

Tourism 

0.96935 

0.00501 

0.89672 

0.08689 

0.97354 

0.0051 

0.90385 

0.25193 

0.99485 

0.13814 

0.00168 

0.00105 

- 

- 

0.93031 

0.03028 

0.00001 

Correction 
Factor 

0.79825 

1.00392 

0.75302 

1.00417 

1.08747 

0.60512 

For each of the seven countries in the sample, good correlations were found for regressions 
for at least one variable in seven out of the nine countries, with two countries presenting 
a goodness of fit73 with both independent variables. For Hungary and Lithuania, a strong 
correlation was shown with the independent variable GDP, i.e. the dependent variable was 
clearly  explained  by  the  GDP,  as  it  is  common  in  most  transport  demand  analyses.  For 
Germany  and  Spain,  the  model  showed  a  strong  goodness  of  fit  for  the  independent 
variables  GDP  and  tourism,  which  shows  the  strong  impact  between  the  occasional  bus 
and coach sector on the GDP and tourism in these countries. In turn, Czechia, Belgium and 
Poland presented good correlations with both GDP and tourism. 

e.  Additional projections 

Besides the regression analysis explained in the previous sections, the team established a 
way to determine similarities between the use of land transport and the effect it has on 
occasional  bus  and  coach  transport  in  order  to  fill  in  the  gap  on  missing  data  for  the 
remaining  countries  of  the  EU-27.  As  previously  mentioned,  these  correlations  were 
established  by  comparing  GDP  per  capita,  motorisation  rate  and  rail  passengers  per 
inhabitants.  

These correlations were then used to estimate the share of occasional transport in terms 
of overall road transport in 2019. Taking into account the base year of 2019, projections 
until 2050 for all EU-27 countries were determined using the results from the regression 
analysis for the country with data available. For countries with missing data, we considered 
the extrapolations that had been previously determined. 

4.6  Future projections for total occasional bus and coach activity 

The following table shows the projections over time of the transport activity in occasional national bus and coach 
services, expressed in Gpkm. These projections were used to estimate the market share of the occasional bus 
and coach sub-sector. A detailed analysis is presented in chapter 7 of the main report. 

Using  the  figures  on  market  share  and  the  PRIMES-TREMOVE  projections  on  transport 
activity in Gpkm in the bus and coach sector as a whole, it has been possible to estimate 
the evolution of the transport activity in occasional bus and coach transport, expressed in 
Gpkm, in the baseline scenario. The projections are shown in the table below, covering the 
period until 2050 and considering the COVID-19 pandemic, which has severely impacted 

73 As explained above, a strong goodness of fit means that the independent variables and dependent 
variables can be correlated.  

55 

 
 
 
 
 
 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

the tourism sector and consequently is affecting the tourism-dependent occasional bus and 
coach sub-sector. 

Table 4.14: Projection of the transport activity (in Gpkm) in occasional bus and 
coach sector in the EU-27 in 2019-2050 

Evolution of the occasional bus and coach activity (Gpkm) over time 

2019 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

2.65 

3.22 

1.50 

5.59 

0.29 

0.53 

0.40 

0.15 

1.13 

0.01 

2.91 

3.22 

1.28 

4.30 

0.30 

3.37 

3.51 

1.50 

5.37 

0.38 

3.56 

3.66 

1.55 

5.90 

0.40 

3.51 

3.46 

1.50 

5.82 

0.38 

3.77 

3.56 

1.60 

6.24 

0.40 

4.13 

3.72 

1.65 

6.85 

0.42 

16.52 

3.29 

18.17 

21.00 

22.21 

21.91 

23.51 

25.80 

1.70 

0.64 

9.20 

3.51 

2.09 

0.34 

0.10 

0.58 

0.27 

0.42 

1.87 

0.54 

9.71 

3.61 

2.20 

2.16 

0.64 

2.29 

0.66 

2.26 

0.64 

2.42 

0.68 

2.66 

0.70 

11.07 

11.82 

11.89 

12.82 

13.69 

4.65 

2.54 

4.92 

2.68 

4.69 

2.65 

4.89 

2.84 

5.17 

3.12 

14.35 

2.86 

14.35 

16.59 

17.53 

17.30 

18.56 

20.37 

1.39 

6.70 

3.06 

0.13 

0.64 

0.61 

1.11 

5.36 

3.21 

1.34 

6.47 

3.71 

1.43 

6.89 

3.92 

1.39 

6.68 

3.87 

1.47 

7.07 

4.15 

1.56 

7.53 

4.56 

30.85 

1.63 

32.58 

37.14 

39.66 

39.91 

43.00 

45.92 

0.21 

0.65 

0.43 

0.11 

1.54 

4.73 

1.92 

2.47 

2.48 

0.78 

1.47 

0.02 

0.05 

0.02 

0.00 

0.31 

0.36 

0.08 

0.09 

0.49 

0.09 

0.29 

0.17 

0.53 

0.36 

0.11 

1.69 

4.02 

2.03 

2.10 

2.54 

0.66 

1.25 

0.21 

0.68 

0.41 

0.15 

1.95 

4.74 

2.31 

2.47 

2.94 

0.85 

1.44 

0.21 

0.72 

0.43 

0.15 

2.06 

4.87 

2.47 

2.55 

3.11 

0.90 

1.52 

0.21 

0.69 

0.43 

0.15 

2.04 

4.74 

2.48 

2.48 

3.07 

0.86 

1.50 

0.22 

0.72 

0.46 

0.15 

2.19 

5.04 

2.68 

2.63 

3.29 

0.90 

1.61 

0.23 

0.76 

0.50 

0.16 

2.40 

5.19 

2.86 

2.71 

3.61 

0.95 

1.77 

AT 

BE 

BG 

CZ 

CY 

DE 

DK 

EE 

ES 

EL 

FI 

FR 

HR 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

EU-27 

120.05 

14.91 

120.19 

139.61 

148.09 

146.52 

156.89 

168.99 

Source: Authors’ own compilation 

The COVID-19 pandemic took an unprecedented toll on the passenger transport sector and 
on tourism, with touristic-related activities reaching a standstill throughout most of 2020. 
The impact of the pandemic was also heavily felt on the tourism-dependent occasional bus 
and  coach  sector.  Projections  show  that  passenger  activity  fell  by  88%  in  the  EU-27  in 
2020 when compared to 2019. The highest percentage decrease was observed in countries 
such as Cyprus (-95%) and Malta (-96%), possibly due to their remote location and heavily 
tourist-dependant market.  

56 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

By 2025, the sub-sector is expected to recover to transport activity levels close to those in 
2019 for the EU-27. Nonetheless, the market is not expected to reach pre-pandemic levels 
in some countries by 2025. This is especially the case in countries in Eastern Europe (e.g. 
Bulgaria, Czechia, Hungary, Latvia and Lithuania), which are expected to reach on average 
80% of 2019 levels by this year.  

The following table presents an overview of the growth rates for national occasional bus 
and coach activity for the 2019-2050 period. 

Table 4.15: Growth rates of occasional bus and coach activity in 2019-2050 

Growth rates of occasional bus and coach activity (Gpkm) over time 

2019-
2020 

-80% 

2019-
2025 

2025-
2030 

2030-
2035 

2035-
2040 

2040-
2045 

AT 

BE 

BG 

CZ 

CY 

DE 

DK 

EE 

ES 

EL 

FI 

FR 

HR 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

10% 

16% 

-88% 

0% 

9% 

-90% 

-15% 

18% 

6% 

4% 

3% 

-80% 

-23% 

25% 

10% 

-95% 

1% 

29% 

-80% 

10% 

16% 

-80% 

10% 

16% 

-85% 

-15% 

18% 

-94% 

-92% 

-80% 

-80% 

6% 

3% 

5% 

0% 

14% 

29% 

16% 

16% 

-90% 

-20% 

21% 

-90% 

-20% 

21% 

-80% 

-95% 

5% 

6% 

16% 

14% 

-92% 

-18% 

18% 

-92% 

-18% 

29% 

-94% 

-18% 

16% 

-96% 

2% 

29% 

-80% 

10% 

16% 

-92% 

-15% 

18% 

-96% 

6% 

14% 

-96% 

-15% 

18% 

6% 

6% 

6% 

3% 

7% 

6% 

6% 

6% 

6% 

6% 

6% 

7% 

3% 

6% 

6% 

6% 

6% 

3% 

7% 

3% 

57 

-1% 

-5% 

-3% 

-1% 

-5% 

-1% 

-1% 

-3% 

1% 

-5% 

-1% 

-1% 

-3% 

-3% 

-1% 

1% 

-3% 

-5% 

-1% 

-5% 

-1% 

-3% 

1% 

-3% 

7% 

3% 

6% 

7% 

4% 

7% 

7% 

6% 

8% 

4% 

7% 

7% 

6% 

6% 

7% 

8% 

6% 

4% 

7% 

4% 

7% 

6% 

8% 

6% 

2045-
2050 

-80% 

-88% 

-90% 

-80% 

-95% 

-80% 

-80% 

-85% 

-94% 

-92% 

-80% 

-80% 

-90% 

-90% 

-80% 

-95% 

-92% 

-92% 

-94% 

-96% 

-80% 

-92% 

-96% 

-96% 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

SE 

SI 

SK 

-80% 

3% 

16% 

-89% 

-15% 

29% 

-80% 

-15% 

16% 

6% 

6% 

6% 

-1% 

-5% 

-1% 

7% 

4% 

7% 

-80% 

-89% 

-80% 

EU-27 

-88% 

0.12% 

16% 

6% 

-1% 

7% 

8% 

Source: Authors’ own compilation 

Regarding the evolution of the number of passengers in the sub-sector, a similar reduction level was observed 
(i.e. -86% in the EU-27 for the 2019-2020 period). The number of passengers carried in the sub-sector 
is expected to reach close to pre-pandemic levels by 2025 as a result of the strong recovery 
foreseen  for  the  tourism  sector.  Nonetheless,  the  share  of  the  number  of  passengers 
compared to the overall bus and coach sector is expected to remain relatively stable over 
the period between 2025-2050, with shares ranging between 2.4% -2.6% in the period. 
Moreover, this share is expected to be lower than the pre-pandemic share, which may be 
linked to the slower growth of the occasional bus and coach sub-sector when compared to 
other sub-sectors in the road passenger sector (i.e. scheduled urban, suburban and long-
distance services). This trend is illustrated in the table below. 

Table 4.16: Projection of the number of passengers in occasional bus and coach 
transport for the EU-27 in 2019-2050 

Evolution of the number of passengers in occasional bus and coach transport 

2019 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

AT 

BE 

4,521 

901 

4,973 

5,749 

6,078 

5,997 

6,435 

7,062 

3,511 

1,016 

3,511 

3,822 

3,989 

3,776 

3,882 

4,051 

BG 

15,857 

4,366 

13,479 

15,873 

16,340 

15,904 

16,890 

17,388 

CZ 

CY 

72,472 

25,449 

55,804 

69,674 

76,463 

75,440 

80,951 

88,839 

6,851 

1,624 

6,919 

8,920 

9,420 

8,996 

9,380 

9,906 

DE 

130,040 

25,913 

143,044  165,352  174,815  172,478  185,077  203,111 

DK 

152,322 

30,353 

167,554  193,684  204,769  202,031  216,789  237,913 

EE 

ES 

EL 

FI 

FR 

8,428 

1,286 

7,164 

8,436 

8,684 

8,452 

8,977 

9,241 

51,682 

3,255 

54,576 

62,217 

66,442 

66,855 

72,037 

76,929 

86,900 

6,737 

89,507 

115,394  121,862  116,373  121,342  128,144 

14,655 

2,920 

15,387 

17,787 

18,805 

18,554 

19,909 

21,849 

73,304 

14,607 

73,304 

84,736 

89,585 

88,387 

94,844 

104,085 

HR 

23,949 

1,714 

19,159 

23,121 

24,616 

23,868 

25,265 

26,899 

HU 

166,279 

15,870 

133,023  160,528  170,909  165,713  175,414  186,758 

IE 

IT 

LV 

5,604 

1,117 

5,884 

6,802 

7,191 

7,095 

7,613 

8,355 

180,268 

8,972 

190,363  217,015  231,752  233,194  251,270  268,333 

735 

56 

603 

710 

730 

711 

755 

777 

58 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

LT 

LU 

13,871 

1,141 

11,374 

14,664 

15,486 

14,789 

15,420 

16,284 

2,317 

132 

1,900 

2,196 

2,322 

2,291 

2,458 

2,698 

MT 

2,723 

224 

2,778 

3,581 

3,782 

3,611 

3,766 

3,977 

NL 

36,231 

7,220 

39,854 

46,069 

48,706 

48,055 

51,565 

56,590 

PL 

PT 

22,438 

1,712 

19,072 

22,459 

23,120 

22,503 

23,900 

24,603 

21,883 

1,054 

23,109 

26,344 

28,133 

28,308 

30,502 

32,574 

RO 

54,704 

2,086 

46,498 

54,756 

56,367 

54,863 

58,267 

59,982 

SE 

SI 

7,331 

1,461 

7,519 

8,692 

9,189 

9,066 

9,728 

10,676 

8,794 

963 

7,475 

9,637 

10,177 

9,719 

10,134 

10,702 

SK 

15,130 

3,015 

12,860 

14,866 

15,717 

15,506 

16,639 

18,260 

EU-27 

1,182,8
01 

165,16
4 

1,156,6
95 

1,363,0
82 
Source: Authors’ own compilation 

1,445,4
49 

1,422,5
34 

1,519,2
11 

1,635,9
88 

The table below presents the growth rates for the number of passengers in the occasional bus and coach sector 
in the EU-27 over the same period. 

 Table 4.17: Growth rates of occasional bus and coach passengers in 2019-2050 

Growth rates of occasional bus and coach passengers over time 

2019-
2025 

2025-
2030 

2030-
2035 

2035-
2040 

2040-
2045 

AT 

BE 

BG 

CZ 

CY 

DE 

DK 

EE 

ES 

EL 

FI 

FR 

HR 

HU 

IE 

2019-
2020 

-80% 

10% 

16% 

-71% 

0% 

9% 

-72% 

-15% 

18% 

6% 

4% 

3% 

-65% 

-23% 

25% 

10% 

-76% 

1% 

29% 

-80% 

10% 

16% 

-80% 

10% 

16% 

-85% 

-15% 

18% 

-94% 

-92% 

-80% 

-80% 

6% 

3% 

5% 

0% 

14% 

29% 

16% 

16% 

-93% 

-20% 

21% 

-90% 

-20% 

21% 

-80% 

5% 

16% 

6% 

6% 

6% 

3% 

7% 

6% 

6% 

6% 

6% 

6% 

6% 

59 

-1% 

-5% 

-3% 

-1% 

-5% 

-1% 

-1% 

-3% 

1% 

-5% 

-1% 

-1% 

-3% 

-3% 

-1% 

7% 

3% 

6% 

7% 

4% 

7% 

7% 

6% 

8% 

4% 

7% 

7% 

6% 

6% 

7% 

2045-
2050 

10% 

4% 

3% 

10% 

6% 

10% 

10% 

3% 

7% 

6% 

10% 

10% 

6% 

6% 

10% 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

-95% 

6% 

14% 

-92% 

-18% 

18% 

-92% 

-18% 

29% 

-94% 

-18% 

16% 

-92% 

2% 

29% 

-80% 

10% 

16% 

-92% 

-15% 

18% 

-95% 

6% 

14% 

-96% 

-15% 

18% 

-80% 

3% 

16% 

-89% 

-15% 

29% 

-80% 

-15% 

16% 

7% 

3% 

6% 

6% 

6% 

6% 

3% 

7% 

3% 

6% 

6% 

6% 

1% 

-3% 

-5% 

-1% 

-5% 

-1% 

-3% 

1% 

-3% 

-1% 

-5% 

-1% 

8% 

6% 

4% 

7% 

4% 

7% 

6% 

8% 

6% 

7% 

4% 

7% 

7% 

3% 

6% 

10% 

6% 

10% 

3% 

7% 

3% 

10% 

6% 

10% 

EU-27 

-86% 

-2% 

18% 

6% 

-2% 

7% 

8% 

Source: Authors’ own compilation 

Market share Projections  

As  previously  pointed  out,  occasional  bus  and  coach  passenger  activity  (in  pax-km) 
accounted for 25% of overall bus and coach activity in the EU-27 in 2019. In 2020, this 
share decreased to 3.1% as a result of the COVID-19 pandemic. The sub-sector is expected 
to reach 4.8% market share by 2025, experiencing a moderate increase until 2050. The 
table below presents the evolution of market share of occasional bus and coach activity (in 
pkm) over the 2019-2050 period.  

Table 4.18: Evolution of the share of occasional bus and coach activity in relation 
to total bus and coach activity in 2019-2050 

Share of occasional bus and coach activity in relation to total bus and coach activity (in 
terms of pkm) over time 

2019 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

AT 

BE 

BG 

CZ 

CY 

DE 

DK 

EE 

ES 

22.6% 

7.2% 

27.3% 

30.5% 

30.4% 

28.9% 

30.3% 

31.7% 

23.6% 

4.8% 

24.0% 

24.0% 

24.1% 

24.1% 

24.1% 

24.1% 

13.8% 

1.7% 

11.2% 

12.2% 

12.1% 

12.1% 

12.5% 

12.3% 

31.1% 

8.0% 

22.8% 

22.8% 

23.7% 

23.7% 

23.7% 

23.7% 

18.3% 

1.3% 

20.3% 

23.3% 

23.4% 

24.1% 

24.4% 

24.3% 

26.9% 

6.4% 

28.3% 

28.3% 

28.5% 

29.2% 

30.3% 

31.4% 

24.6% 

4.9% 

23.8% 

24.0% 

24.3% 

24.8% 

25.5% 

27.1% 

20.6% 

3.7% 

17.0% 

16.2% 

14.7% 

14.3% 

14.3% 

13.2% 

27.7% 

3.3% 

22.5% 

22.5% 

22.2% 

22.2% 

22.2% 

22.2% 

60 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

EL 

FI 

FR 

HR 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

17.2% 

1.7% 

17.2% 

19.3% 

19.0% 

17.4% 

16.7% 

17.3% 

26.5% 

6.0% 

26.9% 

26.9% 

26.6% 

26.8% 

28.2% 

30.3% 

24.1% 

10.5% 

28.0% 

28.8% 

29.7% 

31.1% 

32.4% 

34.5% 

34.6% 

4.6% 

28.4% 

29.9% 

30.3% 

30.7% 

30.5% 

29.9% 

35.7% 

4.7% 

29.8% 

29.8% 

30.0% 

30.0% 

30.0% 

30.0% 

28.7% 

11.9% 

32.7% 

32.4% 

31.4% 

29.9% 

30.3% 

30.8% 

30.0% 

2.9% 

35.2% 

36.2% 

37.0% 

38.0% 

39.7% 

41.6% 

9.7% 

0.9% 

8.0% 

8.2% 

8.0% 

7.8% 

7.9% 

7.9% 

22.3% 

2.3% 

18.5% 

19.7% 

21.6% 

24.0% 

27.5% 

31.4% 

35.5% 

3.8% 

31.9% 

28.6% 

26.9% 

27.8% 

28.6% 

29.7% 

19.8% 

1.1% 

19.1% 

19.7% 

19.4% 

19.0% 

19.4% 

20.1% 

29.1% 

8.2% 

35.3% 

36.3% 

34.2% 

33.8% 

34.0% 

34.6% 

13.1% 

1.4% 

11.1% 

11.1% 

10.8% 

10.8% 

10.8% 

10.8% 

24.2% 

2.1% 

27.6% 

27.1% 

28.6% 

31.0% 

32.8% 

34.0% 

13.2% 

0.9% 

11.4% 

11.3% 

11.4% 

11.8% 

12.5% 

12.3% 

24.6% 

5.3% 

24.9% 

25.0% 

25.1% 

25.6% 

26.0% 

27.6% 

20.7% 

3.2% 

16.7% 

16.3% 

16.3% 

15.1% 

14.8% 

14.8% 

23.7% 

6.5% 

20.4% 

19.9% 

19.8% 

19.8% 

19.8% 

19.9% 

EU-27 

25.0% 

4.8% 

25.4% 

25.8% 

26.0% 

26.3% 

27.0% 

27.8% 

Source: Authors’ own compilation 

In turn, the share of passengers from the occasional bus and coach sub-sector in terms of 
the number of passengers from the overall bus and coach sector represented 3.3% in 2019 
in the EU-27. As a result of the effects of the pandemic, this share plummeted to 0.7% in 
2020. Nonetheless, the sub-sector’s representativeness is expected to reach 3.2% in 2025, 
driven  by  the  partial  recovery  of  the  sector.  This  share  is  expected  to  remain  relatively 
stable over the years, to around 3.4% in 2030 and to slightly go up to 3.6% in 2050, as 
presented in the table below. 

Table  4.19:  Evolution  of  the  share  of  occasional  bus  and  coach  passengers  in 
relation to total bus and coach passengers in 2019-2050 

Share of occasional bus and coach passengers in relation to total bus and coach 
passengers over time 

2019 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

AT 

BE 

BG 

CZ 

2.5% 

0.8% 

3.1% 

3.4% 

3.4% 

3.2% 

3.4% 

3.6% 

2.4% 

1.1% 

2.4% 

2.4% 

2.4% 

2.4% 

2.4% 

2.4% 

3.6% 

1.2% 

2.9% 

3.1% 

3.1% 

3.1% 

3.2% 

3.2% 

5.9% 

2.6% 

4.3% 

4.3% 

4.5% 

4.5% 

4.5% 

4.5% 

61 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

CY 

DE 

DK 

EE 

ES 

EL 

FI 

FR 

4.4% 

1.7% 

4.9% 

5.6% 

5.6% 

5.8% 

5.9% 

5.8% 

2.3% 

0.6% 

2.5% 

2.5% 

2.5% 

2.5% 

2.6% 

2.7% 

2.2% 

0.4% 

2.1% 

2.1% 

2.2% 

2.2% 

2.3% 

2.4% 

5.2% 

0.9% 

4.3% 

4.1% 

3.7% 

3.6% 

3.6% 

3.3% 

3.8% 

0.5% 

3.1% 

3.1% 

3.1% 

3.1% 

3.1% 

3.1% 

4.1% 

0.4% 

4.1% 

4.6% 

4.6% 

4.2% 

4.0% 

4.2% 

4.2% 

1.0% 

4.3% 

4.3% 

4.3% 

4.3% 

4.5% 

4.8% 

2.2% 

0.9% 

2.5% 

2.6% 

2.7% 

2.8% 

2.9% 

3.1% 

HR 

10.3% 

1.0% 

8.5% 

8.9% 

9.0% 

9.1% 

9.1% 

8.9% 

HU 

10.5% 

1.4% 

8.7% 

8.7% 

8.8% 

8.8% 

8.8% 

8.8% 

IE 

IT 

LV 

LT 

LU 

2.5% 

1.0% 

2.8% 

2.8% 

2.7% 

2.6% 

2.6% 

2.6% 

4.8% 

0.4% 

5.6% 

5.8% 

5.9% 

6.1% 

6.4% 

6.7% 

0.6% 

0.0% 

0.5% 

0.5% 

0.5% 

0.4% 

0.5% 

0.4% 

4.8% 

0.5% 

4.0% 

4.2% 

4.6% 

5.2% 

5.9% 

6.7% 

3.0% 

0.3% 

2.7% 

2.5% 

2.3% 

2.4% 

2.5% 

2.5% 

MT 

4.7% 

0.6% 

4.6% 

4.7% 

4.6% 

4.6% 

4.6% 

4.8% 

NL 

PL 

PT 

8.8% 

2.5% 

10.7% 

11.0% 

10.3% 

10.2% 

10.3% 

10.5% 

0.5% 

0.1% 

0.5% 

0.5% 

0.4% 

0.4% 

0.4% 

0.4% 

3.9% 

0.4% 

4.4% 

4.3% 

4.6% 

5.0% 

5.2% 

5.4% 

RO 

4.2% 

0.3% 

3.6% 

3.6% 

3.6% 

3.7% 

3.9% 

3.9% 

SE 

SI 

SK 

2.1% 

0.5% 

2.1% 

2.2% 

2.2% 

2.2% 

2.2% 

2.4% 

5.2% 

0.8% 

4.2% 

4.1% 

4.1% 

3.8% 

3.7% 

3.7% 

3.8% 

1.0% 

3.3% 

3.2% 

3.2% 

3.2% 

3.2% 

3.2% 

EU-27 

3.31% 

0.71% 

3.28% 

3.37% 

3.40% 

3.42% 

3.50% 

3.61% 

Source: Authors’ own compilation 

62 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

4.7  Projections of turnover and employment 

Aiming to get a broader picture of the occasional bus and coach sub-sector, a linear trend 
estimation was carried out to estimate the number of employees and turnover in the sub-
sector.  Linear  trend  estimation  is  a  simple  statistical  technique  to  extrapolate  upon 
historical data, being typically used in traffic demand models to model traffic volumes from 
a  time  series  of  traffic  count  data74.  Linear  trend  models  have  been  widely  used  by 
American State departments of transportation for project level forecasting purposes75. 

The main source for this analysis was the data from Eurostat, regarding other passenger 
land  transport  n.e.c.76.  This  classification  includes  scheduled  long-distance  bus  services, 
charters,  excursions  and  other  occasional  coach  services,  as  well  as  airport  shuttles, 
operation of school buses and for employees and passenger transport by man – or animal-
drawn  vehicles.  The  methodology  adopted  aimed  to  estimate  the  share  of  occasional 
services within this Eurostat classification for the number of employees and turnover.  

The only countries with historical data available on the occasional bus and coach sub-sector 
for both variables were Spain77 and the Netherlands78. In turn, only CONFEBUS estimated 
the number of employees and turnover for the occasional sector in Spain in 201279 and 
201880. The team then attempted to establish the relationship between the Eurostat data 
and the historical data available. According to our calculations, the share of employees on 
occasional  services  within  other  passenger  land  transport  n.e.c.  is  of  65%  in  Spain  and 
33.8% in the Netherlands. A share of 22% was also found for turnover in the occasional 
sector in the year of 2018 for Spain.  

Regarding the number of occasional bus and coach companies, these were based on the 
available data obtained for the Netherlands, as presented in Table 7.6. With this, occasional 
bus  and  coach  companies  in  the  Netherlands  represent  24%  of  the  total  number  of 
companies for other passenger land transport n.e.c.  

Based  on  these  shares,  the  team  assumed  a  similar  share  of  occasional  bus  and  coach 
services for other land transport n.e.c.. This enabled to estimate the number of employees 
and  the  turnover,  as  well  as  the  number  of  companies  for  other  countries  taking  into 
account the correlations previously established.  

Considering the projections of the number of passengers in the occasional bus and coach 
sub-sector, the turnover was assumed to grow in line with the number of passengers until 
2050. By considering this growth rate, we were able to estimate the evolution of turnover 
until 2050. The number of companies in the occasional bus and coach sector is estimated at 
6,032 in 2019 and is projected to remain stable over time.  

74 Ortuzar, Juan de Dios; Willumsen, Luis G. Modelling Transport (2011) – Fourth edition. p. cm 
75 Available at: 
https://tfresource.org/topics/Trend_models_in_project_level_traffic_forecasting.html  
76  Eurostat,  2021,  Annual  detailed  enterprise  statistics  for  services  -  Eurostat  -  Data  Explorer 
(europa.eu) 
77 The data available for Spain included the number of employees and turnover for the occasional 
bus and coach sector in 2013 and 2018, according to CONFEBUS sources (CONFEBUS, El transporte 
en autocar, una solución sostenible para la movilidad de las personas, 2014; CONFEBUS, El bus, una 
visión  de  presente  y  futuro:  Liderando  el  cambio  de  rumbo  para  la  movilidad  sostenible  de  las 
personas, 2019) 
78 Estimated based on the reports on Key Figures of Dutch Coach Transport in 2018, 2019 and 2020 
(Kerncijfers van het Nederlandse touringcarvervoer, Panteia) 
79 CONFEBUS, El transporte en autocar, una solución sostenible para la movilidad de las personas, 
2014 
80  CONFEBUS,  El  bus,  una  visión  de  presente  y  futuro:  Liderando  el  cambio  de  rumbo  para  la 
movilidad sostenible de las personas, 2019 

63 

 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Extrapolating this share for the sample of countries considered in this study, the number 
of employees and the turnover for 2019 would be the following. 

Table  4.20:  Estimation  of  number  of  employees  and  turnover  in  the  occasional 
bus and coach sector in 2019 

Number of employees 

 Turnover (million euros, expressed in 
2021 prices) 

Countries 

Other passenger 
land transport 
n.e.c (Eurostat) 

Estimation of 
Employees for the 
Occasional sector  

Other passenger 
land transport 
n.e.c (Eurostat) 

Estimation of 
turnover for the 
Occasional sector 
(million euros) 

AT  

BE  

BG  

CZ  

CY  

DE  

DK  

EE  

EL  

ES  

FI  

FR  

HR  

HU  

IE  

IT  

LT  

LU  

LV  

MT  

NL  

PL  

PT  

RO  

SE  

SI  

SK  

16,524 

7,129 

9,510 

826 

9,486 

76,814 

6,287 

2,354 

13,277 

56,579 

6,112 

121,629 

7,656 

40,407 

8,245 

41,561 

6,121 

3,982 

1,600 

1,101 

25,230 

34,894 

12,120 

24,588 

6,624 

3,551 

6,822 

 5,592  

 2,852  

 3,804  

 3,889  

 541  

 25,996  

 2,515  

 1,169  

 4,493  

 37,050  

 2,017  

 41,162  

 3,445  

 14,143  

 2,790  

 10,390  

 541  

 2,142  

 1,394  

 385  

 8,831  

 10,468  

 4,000  

 7,376  

 2,186  

 1,172  

 2,251  

 2,279.4  

 682.3  

 243.3  

 39.3  

 624.3  

 4,871.7  

 688.8  

 144.6  

 803.1  

 4,567.9  

 548.7  

 13,794.9  

 353.1  

 1,639.9  

 941.6  

 4,033.4  

 112.2  

 275.4  

 38.1  

 73.6  

 2,458.8  

 1,832.2  

 765.3  

 838.6  

 625.5  

 225.7  

 223.9  

EU-27 

551,029 

202,595 

 43,725.8  

 332.1  

 92.4  

 49.8  

 105.2  

 10.0  

 657.3  

 87.0  

 21.7  

 153.1  

 1,004.9  

 133.8  

 1,711.0  

 83.9  

 247.1  

 133.4  

 556.4  

 1.2  

 15.4  

 48.3  

 20.1  

 312.1  

 56.4  

 144.8  

 140.2  

 76.3  

 47.5  

 34.2  

6,275 

Source: Authors’ own compilation based on Eurostat data on other passenger land transport n.e.c. 
Note: Highlighted cells indicate extrapolated data 

Considering  these  estimations,  the  country  with  highest  number  employees  in  the  sub-
sector in our sample is France, followed by Germany. On the other hand, Malta presents 
the lowest number of employees in the sub-sector. In terms of turnover, the sample follows 
the same trend of employees, with Germany and France showing the highest shares and 
Lithuania the lowest. 

The projected turnover in the sub-sector until 2050 is provided in the table below. 

64 

 
 
 
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Table 4.21: Evolution of turnover in occasional bus and coach transport over the 
years (EUR million, expressed in 2021 prices) 

Estimation of Turnover in the occasional bus and coach sector 

Countries  2019 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

AT 

BE 

BG 

CZ 

CY 

DE 

DK 

EE 

ES 

EL 

FI 

FR 

HR 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

332.1 

66.2 

365.3 

422.3 

446.5 

440.5 

472.7 

518.7 

92.4 

49.8 

26.7 

13.7 

105.2 

36.9 

10.0 

2.4 

92.4 

42.3 

81.0 

10.1 

100.6 

104.9 

49.8 

51.3 

99.3 

49.9 

102.1 

106.6 

53.0 

54.6 

101.1 

111.0 

109.5 

117.5 

128.9 

13.0 

13.7 

13.1 

13.6 

14.4 

657.3 

131.0 

723.0 

835.8 

883.6 

871.8 

935.5 

1,026.6 

87.0 

21.7 

153.1 

17.3 

3.3 

9.6 

95.7 

18.4 

110.6 

117.0 

115.4 

123.8 

135.9 

21.7 

22.3 

21.7 

23.1 

23.8 

161.7 

184.3 

196.8 

198.0 

213.4 

227.9 

1,004.9 

77.9 

1,035.1 

1,334.5 

1,409.3 

1,345.8 

1,403.2 

1,481.9 

133.8 

26.7 

140.5 

162.4 

171.7 

169.4 

181.7 

199.4 

1,711.0 

340.9 

1,711.0 

1,977.8 

2,091.0 

2,063.0 

2,213.7 

2,429.5 

83.9 

6.0 

67.2 

81.0 

86.3 

83.7 

88.6 

94.3 

247.1 

23.6 

197.6 

238.5 

253.9 

246.2 

260.6 

277.5 

133.4 

26.6 

140.0 

161.9 

171.1 

168.8 

181.2 

198.8 

556.4 

27.7 

587.6 

669.8 

715.3 

719.8 

775.6 

828.3 

1.2 

15.4 

48.3 

20.1 

0.1 

1.3 

2.7 

1.7 

1.0 

12.7 

39.6 

20.5 

1.2 

16.3 

45.8 

26.4 

1.2 

17.2 

48.4 

27.9 

1.2 

16.5 

47.7 

26.6 

1.2 

17.2 

51.2 

27.8 

1.3 

18.1 

56.2 

29.3 

312.1 

62.2 

343.3 

396.8 

419.5 

413.9 

444.1 

487.4 

56.4 

144.8 

140.2 

76.3 

47.5 

34.2 

4.3 

7.0 

5.3 

15.2 

5.2 

6.8 

48.0 

56.5 

58.1 

56.6 

60.1 

61.9 

152.9 

174.3 

186.1 

187.3 

201.8 

215.5 

119.2 

140.4 

144.5 

140.6 

149.4 

153.8 

78.2 

40.4 

29.1 

90.4 

52.1 

33.6 

95.6 

55.0 

35.5 

94.3 

52.5 

35.1 

101.2 

111.1 

54.8 

37.6 

57.8 

41.3 

EU27 

6,275 

948 

6,353 

7,499 

7,935 

7,788 

8,306 

8,981 

Source:  Authors’  own  compilation  based  on  historical  data  from  Eurostat  and  on  projections  on 
passenger activity  

These  estimations  clearly  highlight  the  impacts  of  COVID-19.  According  to  these 
projections,  the  turnover  in  the  sub-sector  is  expected  to  recover  to  the  levels  of  2019 
before 2025 in the majority of the countries, except for some countries in Eastern Europe. 
When comparing the values of 2019 and 2050, both variables are expected to increase in 
all countries. 

Besides  these  projections,  we  have  also  estimated  the  number  of  companies  in  the 
occasional  bus  and  coach  sector,  taking  into  account  the  figures  from  Eurostat  on  the 
number of enterprises for other passenger land transport n.e.c. in 2019.  

65 

 
 
 
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The number of companies in the occasional bus and coach sector is estimated at 6,032 in 
2019 and is projected to remain stable over time. The number of companies in the sub-
sector in the 2019 is presented in the table below. 

Table  4.22:  Estimation  of  the  number  of  companies  in  the  occasional  bus  and 
coach sector in 2019 

Number of 
companies in the 
occasional bus 
and coach sector 

2019 

AT 

BE 

BG 

CZ 

CY 

DE 

DK 

EE 

ES 

EL 

FI 

FR 

HR 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SE 

73 

610 

153 

61 

286 

237 

29 

55 

119 

480 

89 

319 

320 

691 

78 

454 

100 

32 

26 

45 

302 

180 

161 

577 

48 

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SI 

SK 

84 

425 

EU-27 

6,032 

Source: Authors’ own compilation based on projections carried out by the team 

67 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

5. Results of the targeted interviews  

This chapter focuses on the targeted interviews. It starts with an overview of the approach, 
followed by the findings, structured in terms of experiences of the current rules, followed 
by  views  on  potential  changes.  In  each  case,  any  general  findings  are  followed  by  an 
analysis of the feedback from the main groups of stakeholders. Since the dynamics vary 
on the two major areas of interest, namely breaks and rest times, these are also presented 
separately. The chapter then ends with some brief initial conclusions.  

5.1  Overview of the approach followed 

To gather detailed insight on experiences of the rules and views on potential changes, the 
study includes targeted interviews at (1) the EU and international levels and (2) in a sample 
of  five  Member  States.  These  aim  to  cover  a  diverse  selection  of  interests  in  terms  of 
drivers,  bus  and  coach  operators,  business  associations,  trade  unions,  government 
enforcement representatives and relevant academic experts.81 While around 48 interviews 
were initially foreseen for the targeted interviews, 38 were carried out. This was due to the 
difficulty to reach certain stakeholders despite extensive efforts. Additional interviews were 
also conducted in the frame of the thematic case studies. 

5.1.1 

Approach to organising the interviews 

This  interview  process  started  with  exploratory  interviews  at  the  EU  level,  for  which 
contacts  were  identified  with  the  help  of  DG  MOVE  and  the  study  team’s  own  network. 
These aimed both to deepen the team’s grasp of the issues at stake and to identify relevant 
contacts  in  the  fieldwork  Member  States.  The  latter  function  was  especially  important, 
because the fragmented nature of the sector made it difficult to find and get in touch with 
the most relevant interlocutors. For instance, drivers are sometimes grouped in different 
trade  unions  than  the  ones  that  organise  other  transport  workers,  and  not  all  coach 
operators are part of the same business association with a single Member State.  

The  approach  also  took  into  account  the  fact  that  stakeholders  became  progressively 
harder to reach as one proceeded through the value chain, with drivers being the toughest 
to get a hold of. For this reason, interviewees were asked to provide details for a contact 
at the next level closer to the ground. For instance, we would ask the international level 
road  transport  business  organisation  for  a  business  association  contact  in  a  particular 
Member  State,  who  would  then  direct  us  to  some  companies  willing  to  participate.  The 
same was done on the trade union side. In order to capture the diversity of views from 
drivers, we sought contact details both from trade union representatives and companies. 
However, trade unions have generally been more willing and able to provide contact details 
for drivers, a potential sampling bias that has been taken into account in the analysis.  

The interviews at EU and international levels started in June 2021, while the Member State 
interviews were launched in October 2021, with a view to obtaining good representation 
among all the different target groups. This took some time, in part because the specialised 
nature of the rules made it especially important not just to reach the right organisations, 
but  the  right  individuals  within  those  organisations.  In  a  similar  vein,  identifying  and 
arranging  interviews  with  drivers  was  difficult,  because  this  group  is  not  accustomed  to 
taking part in consultation exercises. This led to the sample presented in the table below, 
which does not count around 10 interviews conducted for the thematic case studies, and 

81 Since driver fatigue is more than a subjective matter, the sample included in particular an interview 
with  an  academic  expert  on  fatigue  whose  views  are  referred  to  where  relevant  as  part  of  the 
analysis.  

68 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

further  interactions  that  took  place  with  numerous  stakeholders  with  the  purpose  of 
clarification or to obtain additional information.  

At the EU level, there are several business associations related to the occasional transport 
sector, while a single trade union representative organisation covers the entire transport 
sector. A similar dynamic can be observed in the Member States.  This causes the number 
of  interviews  at  EU  level  to  tilt  towards  business  representatives,  a  fact  that  has  been 
weighed appropriately in the analysis.  

Table 5.1: Breakdown of the targeted interviews  

Business 
associatio
n 

Bus & 
coach 
operator 

Trade 
union 

Authorities 

Drivers 

Experts 
and others 

Total 

EU/int’l 

Bulgaria  

Germany  

Netherlan
ds 

Spain 

Sweden 

Total 

5 

2 

1 

1 

1 

2 

12 

- 

2 

2 

1 

1 

1 

7 

1 

- 

- 

1 

2 

1 

5 

2 

- 

1 

1 

- 

2 

6 

N/A 

2 

- 

1 

1 

2 

6 

1 

- 

- 

- 

- 

1 

2 

9 

6 

4 

5 

5 

9 

38 

The interviews have been conducted by following a detailed interview guide, which was 
tailored for each type of stakeholder. Importantly, the interview guide was adjusted after 
testing with a small number of stakeholders, mainly to improve the clarity and flow of the 
questions,  and  to  keep  the  length  manageable.  The  interview    guide  contained  three 
sections, on (1) respondent profiles, (2) views on the current rules, and how they affect 
working conditions, road safety, fair and even competition and the ability to deliver quality 
services  to  the  customer,  followed  by  detailed  questions  on  (3)  views  on  the  policy 
measures that could be implemented in the future, including follow up questions on which 
amendments would be most acceptable or desired, as well as for compensatory measures 
where relevant.  

5.2  Overarching views and experiences of the current rules 

The  rest  of  this  chapter  presents  the  findings  of  the  interviews.  This  starts  with 
stakeholders’ overarching views and experiences on the current rules, then examines more 
specific problems and the extent to which  stakeholders feel the potential policy changes 
would be solved in terms of break times, the 12-day derogation and rest times. The chapter 
finishes with some conclusions in terms of the potential for consensus around the different 
proposed changes.  

There  is  also  an  overarching  pattern  that  is  worth  bearing  in  mind  when  reading  the 
analysis.  Namely,  while  drivers  and  authorities  displayed  some  diversity  of  views,  the 
feedback from trade unions and operators and their representatives was highly polarised: 
trade unions were overall in favour of maintaining the rules, and if changes were proposed, 
they  were  to  make  the  rules  stricter,  for  example  by  removing  completely  the  12-day 
derogation  and  possibilities  for  reduced  daily  rests.  For  their  part,  employers  generally 
found the existing rules to be too rigid and ill-suited to the sector and supported the policy 
proposals under review, albeit to different degrees.  

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Bus and coach operators and their representatives 

All  employers  reported  that  the  current  rules  obstruct  their  ability  to  schedule  services 
efficiently,  particularly  in  the  high  season.  The  general  view  is  that  the  rules  are  better 
suited to sectors where distances to be covered are of primary concern, which is not always 
the case in the occasional sector. Instead, occasional services vary widely. For example, 
they may include longer trips as part of one-day excursions or on the first and last day of 
a multi-day trip, but while many working days involve only short and sporadic driving. They 
thought in general that the  rules did not need major  overhauling, but rather  wished for 
minor  adaptations  to  make  scheduling  easier  and  to  provide  customers  with  better 
experiences at lower costs.  

While  overall  views  were  consistent,  individual  interviewees  also  showed  a  variety  of 
specific  preoccupations  about  which  aspects  of  the  rules  were  the  most  problematic. 
Indeed, these often related to the characteristics of the market in specific Member States 
and the size of the company involved. To illustrate this, the main concerns with the current 
rules for the seven operators interviewed are summarised in the table below, along with 
an overview of their company profiles. 

Table 5.2: Summary of interviewed occasional coach service providers 

Country 

Size 

% of 
services 
occasional 

Company profile 

Main concern 

Bulgaria  

10-49 

70% 

Mainly international trips. 
Interviewed CEO is also a driver. 

The existing break rules are 
too rigid, which is hard to fit 
into specific trip itineraries.  

Bulgaria 

1-9 

100% 

Germany  

50-249 

50%  

Germany 

10-49 

100% 

Netherlands  

10-49 

100%  

Spain 

250+ 

20% 

Sweden 

250+ 

5% 

Does both domestic and 
international trips. Interviewed CEO 
is also driver.  

Difficulty to deal with 
unforeseen events while 
complying with the rules. 

Company split in two parts, one for 
occasional services and one for 
regular. Within occasional, the 
services provided are very diverse.  

Inability to use the 12-day 
derogation during long 
domestic services.  

Medium-sized operator that covers 
all of Europe.  

Overly rigid rules for the 12-
day derogation, particularly 
the single-service condition  

Provides a wide variety of 
occasional services both nationally 
and internationally 

Rest rules that make it 
difficult to satisfy demand 
during high season peaks 

Large company doing both regular 
and occasional services; 90% of the 
occasional services are provided 
during peak season in the summer. 

Inability to use the 12-day 
derogation during long 
domestic services.  

Very large company, primarily 
running scheduled services, but 
doing some occasional services 
during the summer peak season.  

Difficulties adjusting to 
different rules depending on 
the type of service, e.g. over 
or under the 50k threshold 

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Trade unions and drivers 

In contrast to operators, all trade unions and most drivers were favourable towards 
the current rules. Trade unions in particular were very concerned that the rules were not 
sufficiently  enforced  to  prevent  fatigue  and  ensure  good  working  conditions  and  were 
therefore  wary  of  any  changes  that  could  potentially  put  further  pressure  on  drivers. 
Indeed, rather than providing detail on why the current rules are appropriate, they focused 
on problems with compliance, which they considered to have two causes:  

•  Low risks for companies of getting caught for infringements, which was attributed 
to the complexity of monitoring compliance and limited resources for enforcement 
among authorities; 

•  Driver  shortages  that  encourage  operators  to  schedule  services  according  to  the 
upper limits of the rules, which causes difficulties to comply with the rules in case 
of even small unforeseen issues. 

All trade unions worried that any additional derogations or sector-specific changes would 
further complicate efforts to enforce the rules, thereby exacerbating the existing problems. 
Elaborating  further,  interviewees  including  drivers  explained  that  much  of  enforcement 
today is done by checking report cards. This was described as an administrative burden 
that does not provide real evidence of driver behaviour. For example, the card does not in 
and of itself prove that breaks were actually taken as reported. Most drivers also mentioned 
being  fined  significant  amounts  (EUR  1,300  in  one  example,  more  than  half  a  month’s 
salary) for filling in their attestation incorrectly, which contributed to stress.  

National authorities and authorities 

All interviewed authorities have also been in favour of maintaining the current rules. Their 
main concern, regardless of the Member State, was a drastic reduction in the number of 
staff  for  roadside  checks,  mainly  due  to  resource  constraints.  Indeed,  so  far  only  the 
authorities  in  Germany  remarked  that  they  sometimes  do  road  stop  checks  at  common 
coach rest stops to control compliance with the break time rules, while a representative of 
an international coordinator of traffic police departments confirmed most Member States 
lack the capacity for such action.  

Resource constraints have been exacerbated by the increased sophistication of tachograph 
fraud.  Such  fraud  was  described  as  rare  in  the  occasional  sector,  mainly  because 
tachographs  are  ill-suited  to  keeping  track  of  these  services  (e.g.  because  they  do  not 
measure whether drivers are doing other tasks during break times). But tachograph fraud 
is prevalent in the much larger freight transport sector, which has required an increase in 
specialised officers and equipment, thus sapping resources for enforcement in occasional 
services.  

Scientific opinion on fatigue 

Given  that  the  causes  and  effects  of  fatigue  have  also  been  studied  scientifically,  an 
academic expert was also interviewed. The expert was selected due to his involvement in 
a previous accident commission to study the effect of fatigue and the role it played in a 
Swedish bus crash. He has worked in several EU projects on fatigue in various transport 
subsectors, such as the maritime sector and freight transport sector, and has developed 
models for airline companies to measure fatigue among pilots. 

Purely from the perspective of fatigue and related risks (that is to say, regardless of other 
concerns about working conditions), he provided additional relevant input on the state of 

71 

 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

the  art.  According  to  research,82  there  are  three  elements  that  determine  the  level  of 
fatigue a person experiences, all three equally important. They are number of hours awake, 
number of hours of sleep, and time of day. This has several implications.  

•  Total driving time is not considered the main factor of fatigue when driving. Fatigue 
increases the longer a person is awake, but the act of driving has only marginal 
impacts on fatigue as such. The number of hours of sleep and hours awake 
are however incredibly important.  

•  Reducing numbers of available for daily sleeping hours is very dangerous. 
There is not an exact threshold when the danger starts, it is rather that schedules 
that reduce how much sleep a driver should be avoided.  

•  Working  at  night  is  a  high-risk  situation.  If  driving  with  two  drivers  it  is 
important  that  the  second  driver  uses  their  time  to  sleep  while  the  other  drives. 
Currently, some countries require the second driver to sit next to the first driver to 
“entertain” them during the drive. This is considered dangerous because it does not 
reduce the first driver’s fatigue, while preventing the second driver from sleeping.  

•  In  contrast,  weekly  rests  may  be  important  for  working  conditions,  but 
they do not affect fatigue as such. One day is necessary to have a break, but 
longer rest-periods of two or three days has shown not to have any real impact.  

5.3  Potential changes to the rules 

Unsurprisingly,  stakeholders’  views  on  the  current  rules  shaped  their  preferences  about 
what (if anything) should be changed. In this section, we focus on the policy options, first 
in terms of the measures to change rules on breaks, then the 12-day derogation and finally 
the  proposed  changes  to  the  daily  and  weekly  rest  periods.  Since  enthusiasm  for  the 
potential  changes  often  depended  on  perceptions  of  whether  and  to  what  extent  these 
would solve problems  with the existing rules, examples are provided in this regard. The 
findings  are  structured  in  terms  of  stakeholder  group,  namely  operators  and  their 
representatives, trade unions and authorities. Since the views of drivers varied, they 
are presented throughout the text where relevant.  

Before  presenting  the  findings  in  detail,  the  table  below  presents  an  overview  of  the 
proposed  policy  changes  and  typical  arguments  for  and  against  accepting  them. 
Unsurprisingly, the main arguments for a given path of changes should be accepted were 
provided by operators and their representatives, while trade unions were behind most of 
the arguments against the changes.  

82 The interviewed expert’s most relevant research can be accessed here:  
Åkerstedt, et al (2011) Chapter 11 - Sleep loss and accidents—Work hours, life style, and sleep 
pathology in Human Sleep and Cognition Part II: Clinical and Applied Research, Edited by Hans P.A. 
Van Dongen, Gerard A. Kerkhof. Available at: 
https://www.sciencedirect.com/science/article/abs/pii/B9780444538178000116?via%3Dihub  

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Table 5.3: Policy proposals and arguments 

Policy proposal  

Short description 

Typical arguments for 
accepting the proposal 

Typical arguments 
against the proposal 

Supporters:  

Supporters:  

Most businesses, 
business associations 
and self-employed 
drivers 

Most trade unions, 
employed drivers, 
enforcement authorities 

Break times 

Free distribution of 
breaks in chunks of 15 
minutes 

Completely flexible 
distribution of breaks 

Domestic use of the 12-
day rule 

Removal of the single 
service condition when 
using the 12-day rule 

During the first 4.5 hours 
of driving there is the 
possibility to have three 
15-minute breaks, one 
15-minute breaks and a 
30-minute break in any 
order, or finally one 
continuous 45-minute 
break.  

During the first 4.5 hours 
of driving, breaks can be 
freely distributed as long 
as they are in total 45 
minutes at least.  

The current rules 
sometimes force drivers 
to take breaks when 
they are not necessary, 
leading to frustrations 
within the touring 
groups.  

A break must be longer 
to give the driver enough 
time to recuperate, 
preferably taken at the 
peak of the driving time. 

Same as above, except 
this proposal gives more 
freedom to organise 
breaks, which makes it 
even easier to arrange 
around services.  

In addition to the above, 
the risks of abuse are 
perceived as high, with 
breaks likely to be used 
for other work tasks, 
such as picking up 
passengers. 

12-day rule 

For international travel, 
the operators have the 
option to make trips 
lasting up to 12-days 
without a weekly rest, 
on the condition that 
only one group is driven, 
and that extra rest is 
provided. This proposal 
would allow this for 
domestic travel.  

This would allow for a 
driver to drive more 
than one tour group 
while using the 12-day 
derogation. E.g., a driver 
could first drive one tour 
group for 6 days, and 
then pick up another 
tour group and do a 6-
day trip, within the other 
conditions of the 12-day 
rule. 

This would eliminate the 
unfair competition 
between companies 
providing similar services 
and open the derogation 
to domestic tourist trips 
in large countries, which 
are common. The 
derogation would also 
allow drivers to wait 
with a weekly rest until 
they are back with their 
families.  

Since the number of 
groups being driven is 
not related to safety, 
this would allow 
operators to book many 
more groups of tourists 
during the peak season.  

The derogation involves 
too many consecutive 
days of work and was 
only accepted on the 
condition that it would 
be exceptional. Indeed, 
some feel it should be 
removed entirely.  

Because itineraries 
during a single service 
typically do not involve 
long drives each day, 
allowing multiple groups 
could risk leading to 
abuse of the rules and 
unsafe driving. It would 
also broaden a 
derogation that was 
intended as exceptional.  

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Removal of extra 
compensatory rest after 
the 12-day rule  

One hour postponement 
of the daily resting 
period if driving time is 
less than 7 hours, i.e., 
16-hour duty cycle  

Two hours 
postponement of daily 
resting period if driving 
time is less than 5 hours, 
i.e., 17-hour duty cycle 

Flexible distribution of 
weekly rests over a 10-
week reference period 

To use the 12-day 
derogation, the driver 
needs to first have a rest 
of 45-hours before the 
start of the trip, and a 
rest afterwards of either 
69-hours or 90-hours. 

This would allow bus and 
coach operators to 
schedule more tourist 
groups during the peak 
season. Drivers are 
seasonal workers, and 
therefore often want to 
work as much as 
possible in the peak 
season.  

It is seen as unfair to not 
provide extra 
compensation for drivers 
working 12-days in a 
row, which this change 
would remove, 
potentially worsening 
working conditions. 

Rest times 

On the condition that 
the trip lasts more than 
8 days and the total daily 
driving time is less than 
7 hours, the driver can 
be on active duty for up 
to 16 hours, instead of 
the usual 15 hours.  

On the condition that 
the trip lasts more than 
8 days and the total 
driving time is less than 
5 hours, the driver can 
be in active duty for up 
to 17 hours, instead of 
the usual 15 hours. 

A regular weekly rest 
period is 45 hours, and a 
reduced rest period is 24 
hours. This would allow 
the rest periods to be 
distributed so that more 
24-hour rest periods 
could be taken in a row, 
which would then be 
compensated later.  

This would allow some 
driving in the morning, 
and some in the evening. 
If the duty cycle starts 
early, but the driver then 
has nothing to do during 
the day, it is illogical and 
impractical that they are 
not able to work an 
evening drive.  

The current rules already 
allow 15-hour workdays, 
which is longer than 
most occupations. 
Extending this would 
undermine working 
conditions and be 
dangerous, as it is tiring 
to be awake for such a 
long time.  

Similar to the above.  

Similar to the above.  

This would allow more 
intensive working during 
busy peak seasons, 
which could 
compensated once the 
season ends.  

The driver must often 
spend extra time 
preparing the coach 
between rides. This 
would mean that there 
would be almost no time 
off for relaxation and 
recuperation.  

5.3.1 

Potential changes to the rules on breaks during a trip 

Currently,  the  break  times  of  45  minutes  per  4.5h  of  driving  can  be  taken  as  one  long 
break of 45 minutes, or be split into a 15-minute break first and a 30-minute break second 
within a period of 4.5h of driving time. If a driver takes an initial 30-minute break, only 15 
minutes  would  be  counted,  and  they  would  still  need  to  take  30  minute  of  break  time 
during the period. Two potential changes to the rules are being tested. The first of these 
is to allow the break to be split into any chunks of at least 15 minutes, meaning that any 
of the following would be allowed: 

•  One 45-minute break 

•  A first break of 15 minutes, and a second break of 30 minutes 

•  A first break of 30 minutes, and a second break of 15 minutes 

•  Three separate breaks of 15 minutes each  

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The second proposal is to allow free distribution of the 45 minutes across the first 4.5 hours 
of driving time, meaning any division from a single break of 45 minutes to 45 breaks of 
one minute each would in principle be allowed. 

Bus and coach operators and their representatives 

All business associations and individual operators interviewed found the current rules on 
break  times  too  rigid  for  providing  customers  with  a  seamless  and  efficient  experience. 
This  is  because,  unlike  long-distance  transport,  occasional  transport  does  not  typically 
maximise  kilometres  travelled  in  a  certain  time,  but  rather  involves  frequent,  irregular 
stops, e.g. to allow customers to visit certain sites during a tour. This generates ‘natural’ 
break moments which may or may not fit in the framework of the rules. For instance, if a 
group is driving to various locations around a city as part of their tour, they might already 
stop in several places, where there would be breaks, but not long enough to avoid another 
break of 30 minutes within the 4.5 hours of driving time.  

According to most  operators interviewed, the  need to schedule additional breaks strikes 
customers as arbitrary and annoying, undermining their satisfaction with the service. If for 
some  reason  the  group  would  stop  for  45  minutes  the  first  time,  often  due  to  a  client 
request, the same customers find it strange that the driver would have to legally take at 
least 30 minutes of break shortly thereafter. Being able to split the breaks into chunks of 
15 minutes would make for smoother journeys and less disruption, as would the possibility 
of free allocation of break time. The companies mention that this is not necessarily a matter 
of increasing revenue, as their bottom line is not really affected by this issue, but rather 
that it can be frustrating for both drivers and passengers to stop for (seemingly) arbitrary 
and unnecessary breaks. Essentially, any possibility to make the scheduling duties easier 
would be widely appreciated, meaning that either of the two proposed changes would be 
supported.  

Trade unions 

Every trade union interviewed, as well as drivers, thought that the current rules on break 
time should remain, but that additional measures to enforce the rules should be taken. The 
main issue for trade unions and drivers is the possibility that drivers would not get at least 
one lengthy break if they could be divided into several shorter breaks. Indeed, 15-minute 
breaks were not seen as enough time for the driver to enjoy the break and get 
some rest. Moreover, due to the nature of working with passengers, as opposed to goods, 
several  minutes  are  inevitably  spent  every  break  (even  if  not  formally  allowed)  on 
unloading  the  coach,  lifting  baggage,  and  answering  questions  that  the  passengers  had 
saved  until  the  break  time.  One  trade  union  mentioned  the  systematic  abuse  of  break 
times, and felt that splitting the 45-minute break into three chunks of 15 minutes would 
be used for instance to stop and pick up passengers in different locations at the start of a 
trip or make sightseeing stops in which the driver would act as a tour guide, making the 
situation even worse and compromising road safety and working conditions. 

Relatedly,  trade  unions  also  felt  that  shorter,  more  variable  breaks  would  be  even 
more difficult to enforce. Breaks are already difficult for enforcement agencies to verify, 
and the drivers report that the 15-minute break is expected to take 15 minutes. If tasks 
before and after a break take 10 minutes, then the time not driving would in practice need 
to be 25 minutes. The  half-hour break after 4.5 hours allows the driver a bit  of time to 
recuperate,  be  alert  enough  to  continue  working.  This  justifies  the  15  +  30  minutes 
arrangement  specifically,  since it allows the longer break before the  next period  of long 
driving. As they experience that many 15-minute breaks are spent with performing non-
driving tasks, the longer break needs to be positioned in such a way that the driver can 
eat something and have some coffee ahead of taking on the next section of the journey. 
In  principle,  it  could  be  accepted  that  the  first  break  would  be  longer,  but  it  is  of  more 
value to the driver if the second break is 30 minutes.  

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National authorities and enforcement agencies 

As  mentioned,  even  the  current  rules  are  reportedly  hard  to  enforce.  All  interviewed 
authorities felt that allowing shorter breaks, as either proposed change would do, would 
exacerbate  the  problem.  One  national  enforcement  agency  referred  to  the  past  policy 
where it was possible to break up the breaks into three periods of 15 minutes, and that 
non-compliance in general was higher during this time.  

To give more detail, 15 minutes of break time on the tachograph is sufficient to prove that 
a break has been taken but does not show what this break has been spent on. This makes 
enforcement  in  practice  very  difficult  to  do.  Since  this  is  less  of  an  issue  in  regularly 
scheduled bus services and among truck drivers, there would have to be special rest-stop 
police to ensure that the breaks are not spent working for this relatively small number of 
vehicles. An expert within the German police who works internationally with training police 
officers on the driving and rest time regulation echoes this sentiment, that having several 
shorter breaks  would lead to the driver not having any  real breaks. One break must be 
longer.  

5.3.2 

12-day rule 

The 12-day rule is in its current form only available as part of international trips, with at 
least 24 hours outside of the starting country, and with one group of passengers only. At 
the start of the journey the group needs to be listed, which can be shown to authorities to 
verify compliance with this specific derogation from the normal rest-time rules. The rule 
can also only be applied if the driver precedes the service with a rest of at least 45 hours, 
and  follows  it  with  an  extended  rest  of  69  or  90  hours.  Three  possible  changes  to  the 
derogation are being explored, namely:  

•  To allow the 12-day rule to be used domestically  

•  To remove the single-service condition for use of the 12-day rule 

•  To remove the extra compensatory rest after using the 12-day rule.  

Bus and coach operators and their representatives 

Domestic use of the 12-day rule 

All businesses – especially in larger Member States where long domestic trips are possible 
–  view  the  possibility  of  using  the  12-day  derogation  nationally  as  a  very  helpful 
possibility. They explained that many long tours can take place within a single Member 
State.  The  current  rules  thus  come  across  as  arbitrary,  and  give  companies  in 
neighbouring, (in particular) smaller countries a competitive advantage.  

One Swedish operator provided an example of the kind of problem that changing the rule 
would solve: a Danish company going on a ski trip to the Swedish mountains may use the 
derogation, while a Swedish company may not. The specific use-case in such an instance 
would be to take a group to a hotel by a ski-slope, and during the day do  shorter trips 
between  the  hotel  and  the  slopes.  If  the  trip  would  be  between  a  Saturday  and  the 
succeeding  Sunday,  8  days,  then  a  service  starting  in  Denmark  could  carry  out  the  trip 
with one driver by using the derogation; a service starting nearby, in southern Sweden, 
could not. Instead, the Swedish group would have to get to the slopes by themselves one 
day, or that a second driver would have to be transported to the resort to transport them. 
Additionally, the driver would have to spend a weekly resting period away from their home 
and continue to do 4 days of work as he would arrive home. With the 12-day derogation, 
the driver would forego the possibility of having a weekly rest, but instead have 
a longer rest afterwards, at home with their family.  

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Indeed,  most  drivers,  both  the  employed  and  self-employed,  also  echoed  the 
sentiment  that,  given  access  to  the  12-day  rule,  and  the  trade-off  of  compensating  a 
longer  service  with  more  time  at  home,  would  be  considered  an  improvement  to  their 
working conditions. That said, there was some concern about the maximum length of 12 
days, which drivers considered fatiguing and materially different from driving for 7 days in 
a row. Rather, they would intend to use the rule in order to be able to schedule trips of 7-
8 days, a trip-length more often sought by customers.  

Removal of single service condition and extra rest after use of the 12-day rule 

Most  operators  and  their  representatives  were  also  enthusiastic  about  the  other  two 
proposed changes, to remove the single-service condition and the extra rest after using 
the  12-day  rule.  They  explained  that,  especially  if  implemented  in  conjunction  with  an 
extension of the derogation to domestic trips,  the changes would both help them to 
schedule more trips during high season, when driver shortages are often acute. 
Operators from smaller companies felt that they faced bigger challenges to schedule 
drivers without recourse to the 12-day derogation, because of their limited pool of drivers. 
In contrast, larger companies were considered better able to allocate resources according 
to scheduling needs and the availability of individual drivers. 

Elaborating further, it was highlighted that the 12-day rule would often not be used 
the  maximum,  but  rather  would  facilitate  the  scheduling  of  trips  of  7-8  days, 
which, as mentioned above, are fairly common in the sector, e.g. for trips starting on a 
Saturday and returning the following weekend. Customers reportedly react negatively to 
the significant price increase between six- and seven-day trips, which stems from the need 
under the current rules to take on an additional driver.   

Operators went on to provide examples of how the changes would improve their service 
offering.  One  explained  that  removing  the  single  service  condition  would  allow  a 
driver to take a 7-day trip with a first group, come back, and then drive another 
group for several days, exceeding the current limits but not fully using the 12 days. They 
considered  the  current  rule  to  be  arbitrary,  since  the  group  of  passengers  does  not 
materially affect the nature of the job.  

Another example concerned the need for extra rest after using the 12-day rule. A typical 
tour offered by the interviewee’s company takes a group of tourists for 10 days starting on 
a Saturday and ending on the following Tuesday. The rule now requires the driver to have 
three days of rest after the derogation is used, and two days before. Since five days of rest 
would be required before using the derogation again, a driver would  be prevented from 
carrying out consecutive services, even though they would be cleared to take a normal 6-
day  trip  after  three  days  of  rest.  The  long  rest  times  are  particularly  a  hindrance 
interviewed  business 
during  the  high  season,  when,  according  to  the 
associations,  companies  and  drivers  would  want  to  schedule  as  many  trips  as 
possible, to earn enough to cover for the loss of income during the low season. Indeed, 
this was emphasised by all companies as well as some of the drivers, both employed and 
self-employed.  It  should  be  repeated  that  many  of  the  interviewed  respondents 
differentiate between a 7-day trip and a 12-day trip, which both are subject to the extra 
restrictions  under  the  12-day  derogation,  but  have  significantly  different  effects  on  the 
fatigue level of drivers.  

All of that said, while operators generally appreciated changes that would increase their 
autonomy,  some  did  express  reservations,  especially  about  the  removal  of  the 
double rest period and the single service condition. These reservations came from 
businesses and business associations in larger countries, where the most useful change to 
the 12-day rule would be the one permitting domestic use. These companies felt that the 
12-day rule is used in  quite exceptional  cases, and that having an extended  rest period 
afterwards was a fair compromise for the additional work. If the double rest after using the 

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derogation would be removed, they said that they would still be inclined to give the driver 
extra days off afterwards. Given this, and the expected likelihood that trade unions would 
oppose  the  changes,  some  operators  (albeit  a  minority)  were  more  in  favour  of  minor 
tweaks to the general rest-time rules, which would allow them to react better to bookings 
at short notice and periods of peak demand.  

Trade unions  

All trade unions are in general opposed to any changes to the rules and feel that they have 
previously accepted liberalisations that have made it easier to schedule occasional services. 
According to one trade unionist, the 12-day derogation is a good example of this. In the 
original negotiations for allowing the 12-day derogation, the issue was not of Danish and 
Swedish companies carrying out services within Scandinavia, but rather trips that involve 
driving across Europe, where it would take several days to get to the location. The unions 
accepted the derogation during the negotiations, but the proposal to extend the derogation 
to be used nationally or more often is an example of a slippery slope that explains the 
opposition to allowing the derogation to be used for domestic trips. 

There was even stronger resistance to the other two proposed changes to the 12-
day  derogation,  that  is,  the  removal  of  the  single  service  condition  and  extended  rest 
period.  The  point  that  the  unions  made  frequently  is  that  the  rules  set  the  minimum 
conditions  of  work,  that  the  idea  is  not  for  companies  to  schedule  at  these  limits 
consistently,  and  that  using  the  derogation  should  be  exception,  with  strictly  limited 
conditions  for  use.  In  this  context,  the  extra-long  rest  after  using  the  derogation  is 
appropriate, while removing it would be both dangerous and unfair. Trade unions saw a 
risk  that  extending  the  scope  of  the  derogation,  or  making  it  easier  to  fit  within  tight 
schedules, would make it the de facto norm.  

One  driver  echoed  this  view,  feeling  that  the  most  important  condition  for  the  12-day 
derogation,  is  the  single  service  condition.  This  driver  explained  that,  under  the  current 
rules, his total working hours actually go down when using the derogation, because trips 
are usually arranged so as to avoid making customers spend many days in a row sitting in 
a coach for hours. It was feared that removing the single-service condition would truly lead 
to 12 consecutive days of extensive driving.  

National and enforcement authorities 

Compared to others, the authorities were relatively neutral about using the 12-day 
derogation  nationally  and  did  not  express  a  strong  preference.  It  was  merely 
pointed out that this would be unlikely to create additional problems from an enforcement 
perspective.  

However, all authorities were very sceptical of the other proposed changes to the 
derogation. A particular concern was that, if deviating from the single service condition 
would be possible for the occasional services, it would be hard to argue why this derogation 
should not be available for use in regular passenger or heavy goods sectors. This would in 
turn lead to a drastic increase in bus and truck drivers who would work 12-days in a row 
(potentially with just a day of rest between shifts if the extended rest was to be removed 
as well). The justification would be the seasonality of occasional services, but, due to their 
major concerns about spill-over into other sectors, authorities did not generally find this 
sufficiently convincing to support the change.   

5.3.3 

Daily and weekly rest time rules 

With regard to daily rest, the current rules stipulate drivers should have 11 hours of rest 
per  day,  which  can  be  reduced  to  nine  hours  3  times  during  a  two-week  period.  This  is 
usually done in order to be able to schedule some driving in the morning, and then some 

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in the evening, rather than continuous driving. There are two potential changes proposed, 
one that extends the duty cycle to 16h when actual driving is less than seven hours, and 
the other to extend the duty cycle to 17h when actual driving is less than five hours. In 
both  cases,  the  rest  would  be  postponed  to  the  morning  hours,  thereby  not  impacting 
number of hours available for resting and sleeping. The proposal would also only apply to 
trips that last eight days or more. 

As regards to the weekly rest period, there are two types of resting periods, the regular 
2-day (min 45h) rest and a reduced weekly rest of min 24h. Under the current rules, it is 
not possible to have several reduced weekly resting periods one after the other. Practically 
for  drivers,  this  means  that  the  working  week  alternates  between  5  and  6  days.  The 
proposal would allow the flexible distribution of these weekly rests over a reference period 
of 10 weeks, in order to allow companies to schedule more 6-day working weeks during 
peak seasons and more 4-5-day weeks when demand is lower.  

As shown below, the issue of daily rest is found the most polarisation among the 
different  stakeholder  groups,  with  operators  and  their  representatives  supporting 
changes that trade unions, drivers and (for the most part) authorities opposed.  

Bus and coach operators and their representatives 

Most  coach  service  providers  reported  encountering  frequent  issues  with  the  duty 
cycle,  due  to  the  nature  of  the  occasional  sector.  If  some  unforeseen  delay  has 
happened, companies often need to send another driver to quickly cover a last stretch of 
driving, which is very impractical, or face the risk of infringement. Though this could not 
be corroborated by drivers, operators felt this would be a cause for stress for drivers, who 
can be caught in the situation where they are close enough to feel pressure to finish the 
journey despite this not being compliant with the rules. With this in mind, most operators 
felt that the proposed changes would provide slack in the scheduling, thus reducing stress 
and facilitating compliance, as well as making it easier to schedule late-night events. They 
saw the proposed reductions in overall driving time as a fair compromise.  

That said, several operators criticised the limitation of applying the extension only 
to trips of more than eight days. The problems encountered were considered rare on 
such trips anyway, which tended to reduce the envisaged benefits of the changes.  

Trade unions 

The  opposition  to  increasing  the  duty  cycle  is  again  universal  among  the  trade 
unions, as well as drivers. The main argument is that there is an undue focus on the 
driving time as a factor for fatigue, when the reality for drivers in this sector is that they 
have many  other duties besides driving. The union argument is that it is already longer 
working days and working weeks than most other jobs, while wages are still low, and that 
these poor working conditions are a reason for the shortage of drivers.  

Increasing  the  duty  cycle  to  either  16  or  17  hours  would  reportedly  lead  to 
dangerous situations. It would mean requiring drivers to stay awake for a long time and 
to drive late into the night. As the expert on fatigue explained, driving time matters less 
for the level of fatigue than the hours one has been awake, and whether driving occurs at 
night.  The  unions  maintain  that  this  would  lead  to  more  accidents,  and  they  are  in  fact 
critical of the possibility of 15-hour workdays already.  

Continuing  the  topic  of  fatigue,  as  it  currently  is,  the  driver  can  get  9  hours  of  rest  if  a 
reduced  weekly  rest  is  scheduled.  These  hours  are  counted  from  the  moment  the  shift 
ends, and deal with a range of personal tasks (e.g. take a shower, clean the coach, get a 
meal)  before  going  to  sleep.  In  the  morning,  the  driver  then  must  do  all  the  safety 
inspections and necessary preparations before the trip the next day. Therefore, it is not 

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unusual,  according  to  several  of  respondents,  that  drivers  only  get  about  4-6 
hours of sleep when they have the reduced daily rest period. Being able to postpone 
the rest to the morning would still give only a 9 hour rest period, which would reportedly 
not be enough hours of rest to recuperate from a 16- or 17-hour workday.  

The  limit  on  how  much  driving  time  a  driver  can  do  during  the  duty  cycle  ignores  an 
important impact of the occupation, which is that drivers often have to do a lot of work 
outside of driving, such as cleaning the coach or acting as a tour guide. The current limit 
within the 15-hour duty cycle is 9 hours of driving, but when counting the non-driving, the 
driver can be working the entire 15-hour duty cycle. Extending this to either 16 or 17 hours 
would potentially extend the already long working day.  

National and enforcement authorities  

Authorities  expressed  varied  opinions  on  the  policy  proposals.  On  daily  rests,  most 
authorities  interviewed  tended  to  support  the  changes  if  they  could  be 
implemented as a tool only for exceptional circumstances. This would give drivers 
the possibility of finishing a drive without risking non-compliance and a fine. This could be 
acceptable not as a scheduling tool, but rather to be able to react to unforeseen situations 
which has led to long delays. A driver should not be fined for having been held up in traffic, 
for instance. The issue is to balance the adaptability to unforeseen events without exposing 
passengers and drivers to danger on the road. This position was widely held by authorities, 
who also felt it would not be a difficult policy to enforce, while repeatedly highlighting the 
importance of any changes being for exceptional use.  

As  for  making  weekly  rests  more  flexible,  authorities  pointed  due  existing  resource 
constraints, and the likely difficulty in getting operators to report on and enforcing 
the  ten-week  reference  period.  It  was  explained  that  this  would  require  extensive 
training and guidance, as well as additional staff, to implement this effectively and avoid 
abuse.  

5.4  Conclusions  

The  trade  unions,  drivers  and  national  authorities  tended  to  favour  keeping  the  current 
rules – especially on rest times – while operators and their representatives supported most 
of the proposed changes. Moreover, the topic of compensatory measures was not especially 
fruitful: operators and their representatives would consider increased pay for extra shifts, 
or  extra  time  off  in  low  season,  but  generally  considered  that  the  changes  would  not 
materially worsen working conditions, and therefore did not need to be compensated. With 
a similar logic, trade unions did not want to answer the questions about “compensatory” 
measures,  as  that  would  imply  that  they  would  accept  the  rule  changes  with  such 
measures.  

Nonetheless,  looking  at  the  details  of  the  different  proposed  changes  shows  that  the 
possibilities for reaching consensus are greater in some areas than in others: 

•  Starting with the proposal of splitting breaks differently than today, we see 
that there is more room for a policy amendment where you can split the breaks into 
one  longer  and  one  shorter  period,  i.e.  one  break  of  15  minutes  and  one  of  30 
minutes,  without  specifying  which  should  be  taken  first.  This  would  be  only 
marginally better for scheduling reasons but would avoid the feared situation where 
a half hour break is forced after a longer break has already been taken. There is a 
point to having a longer break at the peak of fatigue, and the 15 minutes first and 
then  30  minutes  break  model  would  likely  remain  in  practice  when  scheduling  a 
longer trip. However, for some trips, this setup would be preferable to both driver 
and company.  

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•  Allowing  for  the  12-day  derogation  to  be  used  nationally  faces  less 
opposition than the other amendments to the 12-day derogation. Under the 
same  conditions  as  is  applied  internationally,  this  policy  would  potentially  be 
possible to reach a consensus around. Especially when the clients want to have a 
7-8-day  trip,  it  would  be  preferable  to  use  the  12-day  rule,  as  the  driver  would 
otherwise  have  to  take  their  weekly  rest  period  away  from  their  home.  Some 
compensating rest after using the 12-day rule was considered necessary by drivers 
and trade unions, making the option to remove it unpopular. That drivers would be 
able  to  drive  multiple  different  groups  of  passengers  during  the  12-days  (i.e. 
removing the single-service condition) is however not a policy option that seemed 
acceptable  to  drivers  and  unions  in  its  current  formulation,  because  of  the 
meaningful  differences  between  dealing  with  a  single  group  and  multiple  groups 
during a certain length of time.  

•  Finally, on changes to rest-time rules, the only potential opening for changing 
daily rests to increase the length of the duty  cycle  concerned doing this for truly 
exceptional circumstances (such as a traffic accident causing significant delays or 
forced slow driving due to icy roads). Since working days  – and periods awake – 
were already considered long by trade unions and drivers, the regular working day 
should  not  be  increased  to  16  or  17  hours.  As  for  making  reduced  weekly  rests 
more flexible, there were fears that short rests would become the norm, while the 
authorities  foresaw  significant  challenges  and  costs  for  enforcement  that  could 
result  in  widespread  non-compliance.  Indeed,  authorities  expressed  a  general 
concern that reducing rest periods in occasional transport could be a slippery slope 
and lead to similar calls in other sectors, which they would not favour.  

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6. Analysis of the public consultation results 

6.1  Overview of the public consultation 

As  required  in  the  Better  Regulation  guidelines,  a  public  consultation  was  carried  out  to 
inform  the  impact  assessment  and  to  complement  the  targeted  interviews  and  other 
sources of evidence.83. The consultation was launched on 23 November 2021 and ended 
on 18 February 2022. The consultation was promoted primarily among  key stakeholders 
(i.e.,  business  associations,  bus  and  coach  operators,  drivers,  national  authorities  and 
trade unions, as well as non-governmental organisations (NGOs)) in the EU-27, EEA-EFTA 
countries, Switzerland and the UK. This made it possible to gather feedback from a wider 
set  of  stakeholders  than  would  have  been  possible  using  only  targeted  methods.  In 
addition, the public consultation was also open to ‘ordinary’ citizens, both from the EU and 
third countries, for transparency purposes and because citizens consume bus and coach 
services directly and could potentially have views on how they are organised.  

The different respondent groups are reflected in the set of questions asked, which contain 
both  relatively  general  questions  aimed  at  all  interested  parties,  and  more  detailed 
questions that were only asked to ‘specialist’ respondents who have a good knowledge  – 
as well as economic and political interest – of the topic. In total, the consultation consisted 
of  44  questions  (not  including  initial  profiling  questions  pre-defined  for  all  public 
consultations of the European Commission). 

This  report  provides  an  overview  of  the  170  contributions  received.  In  the  ensuing 
paragraphs,  the  analysis  of  the  questions  from  the  public  consultation  will  describe  the 
respondents’  profile,  and  will  then  focus  on  the  respondents’  views  of  the  EU  rules  for 
occasional  transport  of  passengers  by  bus  and  coach  as  a  whole  and  potential  future 
changes. 

The  analysis  of  the  feedback  received  had  to  deal  with  several  specific  issues,  most 
importantly: 

•  Respondents  who  identified  themselves  as  bus  drivers  (34  self-employed,  21 
employed and 2 not stating either way) were particularly critical of the current rules, 
while they were largely in favour of changes. However, bus drivers interviewed were 
not criticising current rules to the same extent. Thus, since the study team was able 
to verify the profile of interviewees and not public consultation respondents, it has 
placed  more  trust  in  the  former  throughout  the  report  and  interpreted  the  latter 
very cautiously. 

•  The  number  of  replies  for  certain  specialised  questions  was  too  low  to  allow  for 
meaningful results (e.g., certain questions on the detailed of enforcement, for public 
authorities). 

•  Respondents were asked to indicate their preferred option(s) among a set of eight 
policy measures as well as five fully-fledged policy option packages. However, since 
the composition of the fully-fledged options was later changed, the answers to these 
questions were not analysed and presented.  

•  Some of the responses were of a campaigning nature, whereby several clusters of 
responses were received that were nearly identical in terms of both the closed and 
open questions. These entailed three clusters of identified as business associations 
and  companies  (i.e.  from  Austria  and  Germany  (24  respondents),  Italy  (5 
responses),  and  Belgium,  Sweden  and  the  UK  (4  responses)  and  9  responses 

83 European Commission: Better Regulation Guidelines, Chapter II: Stakeholder Consultation. 

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identified as trade unions (i.e. from Belgium, Norway, Romania and Slovenia). While 
the number of campaign responses was fairly small, it was meaningful in light of 
the overall number of responses (170), which made it necessary to take action to 
avoid skewing the results. For this purpose, each cluster of coordinated replies was 
counted only once in the quantitative analysis of the public consultation responses. 
The analysis was also done in a way that avoided risks of under-reporting on the 
views of certain groups. This involved disaggregating the findings by stakeholder 
group throughout the analysis, and pointing out their similarities and differences.  

6.2  Respondents’ profiles 

The  initial  section  of  the  consultation  asked  respondents  for  information  about  key 
characteristics  such  as  their  country  of  origin  and  organisation  or  role  (e.g.,  industry 
stakeholders, public administrations, or citizens), as well as contextual information on their 
knowledge and views on existing rules about driving and rest time rules in the occasional 
bus and coach transport sector. 

Table 6.1 shows that nearly half responses came from Germany (77, 45.3%). They were 
followed  by  respondents  from  Austria  (17,  10%),  Italy  (17,  9.4%),  Belgium  (11,  6.5%) 
and Czechia (8, 4.7%). A large majority of countries (i.e., fifteen out of twenty-four) had 
their respective respondents’ share around or below 1%. Among third country residents, 
responses were submitted from the United Kingdom (8, 4.7%), Norway and Switzerland 
(both 1, 0.6%). 

Table 6.1: Respondents’ country of origin 

Country of 
origin 

No of 
responses 

% of 
responses 

Country of 
origin 

No of 
responses 

% of 
responses 

Germany 

Austria 

Italy 

Belgium 

United 
Kingdom 

Czechia 

France 

Spain 

Sweden 

Luxembourg 

Netherlands 

Greece 

77 

17 

16 

11 

8 

8 

6 

4 

3 

2 

2 

2 

45.29% 

10.00% 

9.41% 

6.47% 

4.71% 

4.71% 

3.53% 

2.35% 

1.76% 

1.18% 

1.18% 

1.18% 

Slovenia 

Romania 

Latvia 

Hungary 

Slovakia 

Ireland 

Estonia 

Switzerland 

Bulgaria 

Norway 

Finland 

Poland 

2 

2 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1.18% 

1.18% 

0.59% 

0.59% 

0.59% 

0.59% 

0.59% 

0.59% 

0.59% 

0.59% 

0.59% 

0.59% 

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 170 respondents 

Among  those  respondents  who  contributed  to  the  consultation  as  “Other”  types  of 
respondents (33, 19.4%), the largest share affirmed to be a professional bus driver (24, 
72.7%).  

Figure 6.1, nearly half of responses (83, 48.8%) were submitted by companies/business 
organisations. Business associations accounted respectively for 10.6% of all respondents 
(18), while 8.2% of respondents (14) were trade unions. Only 12 EU citizens (7.1%), and 
10 public authorities (5.9%) participated to the consultation. 

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Among  those  respondents  who  contributed  to  the  consultation  as  “Other”  types  of 
respondents (33, 19.4%), the largest share affirmed to be a professional bus driver (24, 
72.7%).  

Figure 6.1: Types of respondents 

Company/business organisation

83, 48.8%

Other

33, 19.4%

Business association

18, 10.6%

Trade union

14, 8.2%

EU citizen

12, 7.1%

Public authority

10, 5.9%

0%

10%

20%

30%

40%

50%

60%

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 170 respondents 

However, bus drivers did not only provide their contribution to the public consultation as 
“Other” types of respondents. Although explicitly requested to select the option “Other” in 
case they identified themselves as bus drivers, many were the respondents who did not 
follow this specific questionnaire’s guideline. As a matter of fact, out of a total of 57 bus 
drivers  who  contributed  to  the  public  consultation,  only  27  did  so  as  “Other”  types  of 
respondents.  Twenty-three  of  them  instead  contributed  to  it  as  companies/business 
organisations,  five  as  “EU  citizens”,  one  as  “Trade  union”,  and  one  as  “Business 
association". 

Apart  from  this,  34  out  of  57  bus  drivers  (59.7%)  reported  to  be  freelance  workers  or 
owner of their own business rather than being working for an employer; 21 were instead 
contracted employees (36.8%) and 2 bus drivers did not provide an answer.  

Out of the 83 companies that participated in the public consultation, nearly 75% (62) had 
between 1 and 49 employees (i.e., were either micro or small companies), whilst medium 
and large businesses accounted together for 25.3% (21) of all businesses that took part, 
as reported in Figure 6.2. 

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Figure 6.2: Organisations' size 

Micro (1 to 9 employees)

25, 30.1%

Small (10 to 49 employees)

37, 44.6%

Medium (50 to 249 employees)

17, 20.5%

Large (250 or more)

4, 4.8%

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

50%

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 83 respondents 

59 companies also provided information on the type(s) of services provided. About 56% of 
them reported being involved only in bus and coach services; on the other side, 40.6% of 
respondents reported providing both bus and coach, and tourism services. The remaining 
portion of companies (3.4%) was involved in both aforementioned services and, on top of 
that, in the provision of other goods/services. 

6.2.1 

Bus and coach operators’ characteristics 

In  order  to  contextualise  their  responses  to  questions  on  the  rules  and  preferences  for 
potential  future  changes,  bus  and  coach  operators  were  asked  to  provide  more  details 
about the nature of their activities. About 61% (56) of them declared to offer a diversified 
range of services which included: multi-day trips, single day excursion, and ad-hoc services 
(e.g., airport shuttles). 

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Figure 6.3: Types of services provided 

Combination of multi-day trips, single-day excursions,
and ad hoc services (e.g. airport shuttles)

56, 60.9%

Combination of multi-day trips and single-day excursions

18, 19.6%

Combination of multi-day trips, single day excursions, ad
hoc services (e.g., airport shuttles), and others

12, 13.0%

Combination of multi-day trips, single day excursions,
and others

2, 2.2%

Other

1, 1.1%

Combination of single day excursions and ad hoc services
(e.g., airport shuttles)

1, 1.1%

Multi-day trips

1, 1.1%

0%

10%

20%

30%

40%

50%

60%

70%

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 92 respondents 

Bus  and  coach  operators  were  also  asked  to  provide  details  on  the  length  of  the  peak 
season  for  their  respective  businesses.  Out  of  88  respondents,  71  (80.7%)  said  that 
typically  the  season  when  travel  is  most  active,  and  rates  are  highest  lasts  for  3-to-6 
months, while only 8 respondents (9%) agreed that it does not last longer than 3 months. 
Furthermore, as illustrated in Figure 6.4, 95% of respondents (83) indicated that seasonal 
services take between 50 and 100% of the total amount of services provided. 

Figure 6.4: Percentage of seasonal services across bus operators 

48, 54.1%

35, 40.9%

75-100%

50-75%

25-50%

4, 4.1%

0-25%

1, 0.8%

0%

10%

20%

30%

40%

50%

60%

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 88 respondents 

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Furthermore,  according  to  32  out  of  71  bus  operators  (45.1%),  in  2019  the  turnover 
generated by occasional transport was more than 75% of total yearly sales. According to 
28.2% of the respondents, instead, the occasional transport sales’ share was between 75% 
and 50% of the total turnover. 

6.2.2 

Bus drivers’ characteristics 

Overall,  the  average  age  of  bus  drivers  who  participated  in  the  public  consultation  was 
47.2, while the median age was 53. More in detail, about two thirds of drivers were older 
than  50,  with  almost  one  of  every  five  drivers  being  above  the  age  of  60.  In  contrast, 
drivers between 40 and 50 made up about 16% while less than 20% were under 40. 

Figure 6.5: Bus drivers' age groups 

Source: Public consultation – Driving and rest time for bus and coach drivers 
Note: ≥ 60: 9 respondents; ≥ 50; ≤ 59: 24 respondents;  ≥ 40; ≤ 49: 8 respondents;  ≥ 30; ≤ 39: 
6 respondents; ≥ 20; ≤ 29: 4 respondents  
Base: 51 respondents 

Bus drivers were then asked to indicate the percentage of working days spent on coach 
services in 2019. 87.1% of respondents reported that occasional transport constituted at 
least  50%  of  the  services  provided  during  the  year,  while  28.2%  indicated  that  it 
represented the only service provided.  

The figure below shows the distribution of average hourly wages across respondents. As 
can be noticed, in 2019 the largest majority of bus drivers (78%) earned between €10-
19/hour, with a subgroup of 55% of respondents earning between €15-19/hour. 

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Figure 6.6: Share of bus drivers by average hourly wage in 2019 

Source: Public consultation – Driving and rest time for bus and coach drivers 
Note: >€30/hour: 1 respondent; €25-29/hour: 4 respondents; €20-24/hour: 2 respondents; €15-
19/hour: 22 respondents; €10-14/hour: 9 respondents; <€10/hour: 2 respondents. 
Base: 41 respondents 

Given the peculiarities of the occasional bus and coach sector (e.g., the provision of tailored 
services  to  meet  the  needs  of  customers),  bus  drivers  were  also  asked  to  provide  an 
estimate  of  how  often  they  have  been  requested  to  work  on  a  short  notice.  Out  of  51 
respondents, 33.3% (17) reported to have done so not often (i.e., less often than once a 
month),  while  25.5%  (13)  and  23.5%  (12)  of  respondents  reported  to  have  worked  on 
short  notice  respectively  several  times  a  month  and  around  once  a  month  (see  Figure 
6.7). 

Figure 6.7: Frequency of short notice trips 

Less often

17, 33.3%

Several times a month

13, 25.5%

Around once a month

12, 23.5%

Several times a week or more

5, 9.8%

Never

4, 7.8%

0%

5%

10%

15%

20%

25%

30%

35%

40%

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 51 respondents 

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6.3  Feedback by EU citizens 

Since  the  number  of  questions  targeting  only  EU  citizens  was  limited  compared  to  the 
number  of  questions  targeting  other  groups  of  stakeholders,  this  paragraph  aims  at 
presenting EU citizens’ views on those questions requesting solely their input.  

EU citizens were asked for their views on the impact of the current rules regarding good 
working  conditions  for  drivers;  driver  and  passenger  safety;  and  quality  of  services 
offered.84 Results are presented in the figure below and show that most respondents found 
the existing legislation to have contributed positively to drivers and passengers’ safety and 
good working  conditions. Although  respondents were less positive about the impacts on 
the quality of services offered, with about two thirds answering that the rules contributed 
‘to a little extent’.  

Figure 6.8: "In your view, to what extent do the existing rules contribute to the 
following aspects?" 

Ensuring driver and passenger safety

2

5

3

Good working conditions for drivers

1

5

4

 The quality of services offered, in line with customer
needs

2

8

2

2

2

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

To a great extent

To some extent

To a little extent

Not at all

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 12 respondents 

In  order  to  figure  out  the  likely  impacts  compared  to  the  current  situation  of  several 
possible changes to the existing rules, EU citizens were also asked if – in their opinion - 
changes to make the rules more responsive to the needs of passengers/customers could 
lead to improvements compared to the current situation. Figure 6.9 shows that overall, 
changes in that direction are perceived as positive by the majority of those replying as EU 
citizens. If changes are to take place, the most significant positive impacts are believed to 
be experienced in the realm of working conditions for bus drivers, drivers and passengers’ 
safety, and quality of services. 

84 Citizens were also asked to elaborate on any additional aspects, but only one reply was provided.  

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Figure 6.9: “To  what extent do you think  that changes to make the rules more 
responsive  to  the  needs  of  passengers/customers  could  lead  to  improvements 
compared to the current situation?” 

Working conditions

5

Drivers and passengers safety

4

Quality of services

3

Overall impact

Price competitiveness between operators of domestic
and international services

4

4

4

5

6

3

1

1

1

2

3

1

2

2

2

2

2

2

Improve a lot

Improve a little

Stay the same

Get a little worse

Get a lot worse

Don't know

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 12 respondents 

When  asked  to  provide  further  comments,  some  respondents  said  that  improving  the 
responsiveness of the service to customers’ needs can be a good driver for change only if 
the rules become more flexible and hence (in their view) allow bus driver to operate with 
less stress. To these respondents, the future rules must be more responsive of the needs 
of  people  and  grant  exceptions  in  cases  of  delays  not  attributable  to  the  driver.  It  is 
essential to drive without the stress of a mandatory timetable (with respect to break and 
rest times) to be respected. 

It was also noted that users should be made aware of and informed about the legislation 
that the driver must comply with. Very often it is the passengers who do not understand 
that the driver cannot satisfy every desire of the user. 

6.4  Overall views on existing rules 

The  next  part  of  the  consultation  focused  on  experiences  of  the  existing  rules,  both  to 
ascertain whether changes were considered necessary, and to establish a baseline against 
which  future  changes  could  be  compared  (see  section  6.5).  When  deemed  appropriate 
(i.e., when replies do not differ much by stakeholders’ group), both the views on current 
rules and future changes have been analysed by category of respondent (e.g., bus drivers, 
companies, etc.).  

6.4.1 

Working conditions 

More specialised stakeholders (i.e., all respondents but EU citizens) were asked for more 
detailed  feedback  on  the  impact  of  the  rules  regarding  each  key  aspect.  On  working 
conditions,  respondents  were  asked  to  consider  different  perspectives:  working 
patterns/schedules;  work-life  balance;  work  intensity;  wage  levels;  job  security; 
attractiveness  of  the  sector  (especially  for  new  drivers  and  women);  additional  aspects. 
Results are presented in Figure 6.10.   

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Figure  6.10:  “To  what  extent  do  the  existing  rules  contribute  to  good  working 
conditions for drivers? Please consider the following aspects” 

Work intensity

12

Work-life balance

15

66

63

Working patterns / scheduling

28

Job security

39

Wage levels

14

48

Attractiveness of the sector for women

3

35

Attractiveness of the sector for new drivers

6

24

32

7

1

28

37

11

3

5

3

21

27

23

22

6

6

34

14

28

8

47

28

33

53

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

To a great extent

To some extent

To a little extent

Not at all

Don't know

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 120 respondents 

In terms of working conditions, the most important contributions of the rules were seen in 
the areas of work intensity and work-life balance, where a total of 66% respondents 
(78)  thought  that  current  legislation  contributed  to  either  some  or  a  great  extent. 
Respondents  also  seemed  to  see  the  benefits  of  the  rules  in  the  areas  of  working 
patterns/scheduling  and  job  security.  On  the  other  side,  57%  of  respondents  (67) 
believed  that  current  rules  did  little  or  nothing  to  improve  the  attractiveness  of  the 
sector for woman and 69% (81) of respondents thought the same also for new drivers 
in general. 

6.4.2 

Road safety 

Respondents  were  then  asked  to  assess  the  role  of  the  existing  rules  in  ensuring  road 
safety, in terms of the effects on several aspects, such as the stress and fatigue for drivers 
and the level of compliance. Results are presented below. 

Figure 6.11: “To what extent do you think the rules on rests and breaks contribute 
to ‘road safety’? Please consider the following aspects" 

Facilitating high levels of compliance

38

51

15

13

3

Minimising stress and fatigue for drivers

27

61

23

11

0%

10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

To a great extent

To some extent

To a little extent

Not at all

Don't know

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 122 respondents 

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In terms of road safety, current rules were overall seen as important. For instance, 
75% of respondents (89) said that they were beneficial in terms of levels of compliance 
(e.g., they were overall easy to comply with) – of which 32% (38) said they contributed 
to the objective to a great extent. Most respondents (88, 72%) also concurred on the fact 
that current rules helped the reduction of drivers’ stress and fatigue. 

6.4.3 

Quality of services 

With respect to the interplay between current legislation and the level of quality of services 
provided,  respondents  were  asked  to  assess  rules  according  to  five  different  aspects: 
organisation  of  efficient  bus  and  coach  operations;  provision  of  high-quality  services; 
responding  to  client  demands  in  terms  of  volume  of  services;  coping  with  unexpected 
situations  (e.g.,  traffic,  bad  weather);  dealing  with  trips  organized  at  night.  Results  are 
depicted in Figure 6.12. 

Figure 6.12: “To what extent do you think the rules on rests and breaks contribute 
to 'efficient and high-quality services'? Please consider the following aspects" 

Dealing with trips organised at night

17

Organisation of efficient bus and coach operations

21

68

66

Providing high-quality services

23

27

72

Coping with unexpected situations (e.g. traffic, bad
weather)

19

20

Responding to client demand in terms of volume of
services

9

27

61

68

26

23

5

36

19

19

40

30

14

To a great extent

To some extent

To a little extent

Not at all

Don't know

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 148 respondents 

According to respondents the most important contribution of rules on occasional passenger 
transport  were  seen  in  terms  of  the  way  night  trips  are  dealt  with  and  efficient 
organization of bus operations. Sixty-one percent of respondents (87) have witnessed 
some  or  great  impacts  for  each  of  the  two  aspects.  On  the  other  side,  no  or  little 
contribution of current rules were seen in terms of quality of services provided (64% of 
respondents  saw  no  or  little  impact),  coping  with  unexpected  situations  (73%  of 
respondents  claimed  to  have  witnessed  no  or  little  impact)  and  responding  to  client 
demand in terms of volume of services (66% of respondents claimed to have witnessed 
no or little impact). 

Figure  6.13  shows  the  respondents’  views  on  the  relation  between  current  social  rules 
and multi-manning rules and whether their interplay contributes to the provision of high-
quality services. About half of respondents (60, 49%) seemed to believe that the interplay 
promotes  to  some  extent  the  organisation  of  high-quality  services,  while  a  fourth  of 
respondents (31, 25%) believed it only contributes to quality to a little extent. 

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Figure 6.13: "Do you feel that the rules on breaks and rest periods interact with 
the multi-manning rules in a way that allows efficient and high-quality services 
to be organised?" 

60, 49%

31, 25%

16, 13%

60%

50%

40%

30%

20%

10%

0%

13, 11%

3, 2%

To a great extent To some extent To a little extent

Not at all

Don't know

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 123 respondents 

6.4.4 

Fair competition 

Since the 12-day derogation can only be used for international trips, the public consultation 
explored the role of the existing rules to perceptions of fair competition between domestic 
and  international  services.  Nearly  half  of  respondents  (50,  44%)  did  not  feel  that  the 
current  rules  contributed  to  fair  competition  at  all,  while  most  of  the  others  gave  non-
committal answers. In other words, those with an opinion considered the existing rules not 
to  contribute  to  a  level  playing  field  between  domestic  and  international  services  (see 
Figure 6.14). 

Figure  6.14:  “Do  you  think  the  driving,  break  and  rest  rules  contribute  to  fair 
competition between domestic and international services?” 

50%

40%

30%

20%

10%

0%

21, 19%

22, 19%

20, 18%

50, 44%

0, 0%

To a great extent To some extent To a little extent

Not at all

Don't know

Source: Public consultation – Driving and rest time for bus and coach drivers 
Note:  When  providing  their  answers,  respondents  were  asked  to  please  consider  the  “12-day 
derogation”  (Article  8(6a)  of  Regulation  561/2006),  which  applies  only  to  transport  crossing 
international borders as part of a single  trip,  meaning  occasional services  taking place  within one 
country cannot use the derogation. Base: 113 respondents 

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6.4.5 

Compliance 

Since  reduced-quality  services  and  difficulties  with  compliance  are  often  closely  related, 
bus and coach operators, business associations and trade unions were also invited 
to provide their views on the extent to which current rules facilitate compliance for a sector 
where – due to the varied nature of services – difficulties to comply with rules are evident. 
As shown in Figure 6.15, more than half of respondents (67) thought that current rules 
pose a problem for compliance either to a large or some extent. 

Figure  6.15:  “To  what  extent  do  the  rules  pose  difficulties  with  compliance  / 
enforcement?” 

46, 37%

36, 29%

31, 25%

40%

35%

30%

25%

20%

15%

10%

5%

0%

8, 6%

4, 3%

To a great extent To some extent To a little extent

Not at all

Don't know

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 125 respondents 

Most of respondents who provided additional comments specified that the difficulties with 
compliance arise from the lack of flexibility of current norms which are said to be “unfit” 
for the business pattern of coach tourism. Therefore, compliance and enforcement of the 
existing  rules  continue  to  pose  difficulties  to  both  operators  and  to  the  enforcement 
agencies across the EU. Furthermore, respondents also claimed that reduced operational 
flexibility, ultimately negatively affects the business viability of coach tourism operator. 

6.4.6 

Need for change 

The section on the current situation concluded by collecting views on the extent to which 
stakeholders (i.e. all but EU citizens) were in favour of changing the rules. Not surprisingly 
given the issues described above, most respondents found necessary some kind of change 
in current rules. More specifically, more than 60% of respondents (87 for break rules and 
86  for  rest  time  rules)  believed  that  some  minor  refinements  were  needed  for  rules 
concerning both breaks and rest times, while only a few thought that rules should be kept 
as they are (Figure 6.16). 

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Figure 6.16: “Overall, do you consider that the existing rules are appropriate, or 
that  they  should  be  changed?  Please  consider  separately  for  breaks  and  rest 
rules?” 

Breaks

30

Rest times

30

87

86

22

20

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

The rules should be retained

The rules need minor refinements

The rules need major changes

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 139 respondents 

In  terms  of  break  rules,  it  is  worth  noticing  that  the  big  majority  of  every  group  of 
respondents  except  public  authorities  and  trade  unions  was  in  favour  of  some  sort  of 
changes: 17% of business associations (2) have expressed in favour of major changes, 
while the remaining 83% (10) was leaning towards less substantial modification; 93% of 
companies (71) was supporting either major or minor legislative mutation. 

A  significant  propensity  towards  a  change  in  current  break  rules  could  also  be  noticed 
among self-employed and employed bus drivers. However, self-employed respondents 
were more in favour of major changes than employed ones (41% or 13 vs 7% or 1).  

The  strongest  opposition  to  any  form  of  change  in  break  rules  came  from  public 
authorities and trade unions. However, whereas a minority of public authorities showed 
also a certain propensity towards change (40% or 4 were in favour of minor changes), a 
third of trade unions argued to be in favour of major changes (Figure 6.17).  

Trade  unions’  stance  is  particularly  surprising.  Although  they  have  expressed  strong 
negative  opinions  towards  the  proposal  of  a  more  flexible  social  legislation  for  bus  and 
coach drivers, the figure below seems to suggest that a significant share of them is actually 
not against a change in that direction. However, the question under assessment did not 
specify to  respondents  which kind of change it is to be pursued.  Therefore, it should be 
safe to assume that trade unions’ disposition to change displays their intention to make 
rules – to a certain extent – stricter.  

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Figure 6.17: “Overall, do you consider that the existing rules are appropriate, or 
that  they  should  be  changed?  Please  consider  separately  for  breaks  and  rest 
rules: Breaks” (1) 

Business associations

2

Employed

1

Companies

20

Self-employed

Public authorities

13

4

Trade unions

2

13

10

51

16

6

4

7

3

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

The rules need major changes

The rules need minor refinements

The rules should be retained

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: Number of companies = 78; number of business associations = 12; number of trade unions = 
6; number of public authorities = 10; number of self-employed drivers = 32; number of employed 
drivers: 14 

Similarly, in terms of changes to rest time rules, the largest opposition came from public 
authorities (70% or 7 opposed to any type of change) and trade unions (50% or 3). On 
the  other  side,  companies  and  business  associations  were  still  the  two  groups  of 
respondents showing the most propensity towards change (with an average share of 94% 
of  respondents  who  reported  being  in  favour  of  some  sort  of  changes).  Business 
associations, though, had a larger proportion of respondents in favour of major changes to 
current rest time rules (33% or 4 vs 24% or 18 of companies).  

Regardless of their level of opposition towards rest time changes, trade unions displayed 
again  a  significant  share  of  respondents  who  supported  the  proposal  of  major  changes 
(30%, 2). The same argument made for trade unions for Figure 6.17 applies here. 

In general, self-employed and employed bus drivers endorsed the idea of changing rest 
time rules too. The share  of  self-employed  respondents in favour  of  major changes was 
however significantly larger than the share of employed bus drivers (32% or 10 vs 19% or 
3) (see Figure 6.18). 

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Figure 6.18: “Overall, do you consider that the existing rules are appropriate, or 
that  they  should  be  changed?  Please  consider  separately  for  breaks  and  rest 
rules: Rest times” (1) 

Companies

18

Self-employed

Employed

3

Business associations

Trade unions

Public authorities

10

4

2

3

54

19

12

6

4

2

1

2

1

3

7

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

The rules need major changes

The rules need minor refinements

The rules should be retained

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: Number of companies = 76; number of business associations = 12; number of trade unions = 
6; number of public authorities = 10; number of self-employed drivers = 31; number of employed 
drivers: 16 

6.5  Potential changes 

In addition to general aspects, the public consultation collected the views of respondents 
on a number of potential changes that could address the main problems identified with the 
current rules on break times and rest periods for the occasional bus and coach sector (as 
per Regulation 561/2006). More specifically, this section of the public consultation asked 
respondents to identify a (set of) preferred change(s) and then to assess their impact on 
a number of socio-economic indicators such as “working conditions” for bus drivers, “bus 
driver and passengers’ safety”, and “ability to organise efficient services” for customers. 
In case respondents did not support any of the proposed break and/or rest period changes, 
they  were  asked  to  indicate  the  option  they  considered  the  most  tolerable.  This  has 
provided a larger base of respondents when preferences were analysed.   

This section is divided into two main subsections: subsection 6.5.1 on Break changes and 
subsection 6.5.2 on Rest period changes. Whereas in the first subsection respondents were 
asked to pick one of the two break changes proposed, in the second subsection respondents 
could select a set of most favourite changes (i.e., a set of measures). In turn, the analysis 
of likely impacts of selected rest period changes focused on the most favoured combination 
of changes. 

6.5.1 

Break changes 

Preferred change 

All  respondents  but  EU  citizens  were  presented  with  two  possible  changes  to  make  the 
organisation  of  breaks  during  a  trip  more  responsive  to  the  needs  of  stakeholders. 
Break change 1 entails that occasional bus and coach drivers are allowed to split their 
break of minimum 45 minutes into 30 + 15 minutes85 or 15 + 15 + 15 minutes; break 

85 Note that under the current rules splitting the break into 15 + 30 minutes is already allowed. 

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change 2, instead, allows occasional bus and coach drivers to arrange and split in a fully 
open  manner  their  break  of  minimum  45  minutes  over  the  period  of  4h30  driving  time. 
Results are showed below. 

Figure 6.19: “Two possible changes have been identified to make the organisation 
of  breaks  during  a  trip  more  responsive  to  the  needs  of  stakeholders.  Please 
indicate whether you think either of these changes should be implemented (NB: 
maximum one of these changes can be picked)” 

Break change 1

103

29

Break change 2

63

80

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Yes

No

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 143 respondents 

Break change 1 was also deemed the most  satisfactory option by those 26  respondents 
who believed that neither of the proposed changes should be implemented. 

Furthermore, among them, fourteen respondents were in favour of retaining the current 
rules, whereas the remaining twelve proposed different changes. When the latter group of 
respondents was given the chance to explain what kind of changes they would like to see 
implemented, nine of them proposed the elimination ex novo of the split of breaks and its 
replacement with the so called “effective break”86. 

When  examining  the  responses  of  different  stakeholders’  groups  (Table  6.2),  it  can  be 
noticed that break change 1 is a much more polarising proposal compared to break change 
2. Indeed, break change 1 meets the favours of 82% and 81% of business associations 
and companies while it faces the opposition of a large share of public authorities and 
trade unions. On the other side, break change 2 still meets the opposition of trade unions 
and public authorities; however, also a slight majority of business associations is against 
it. 

When  it  comes  to  bus  drivers  (38  respondents  in  total),  both  employed  and  self-
employed seem to favour both changes (with a slight preference towards break change 
1). Whereas the majority of both groups welcomed the two proposals, they did not do so 
equally. The share of respondents in favour of break change 1 was 80% for self-employed 

86 Some respondents from trade unions proposed the replacement of the concepts of “break” and 
“rest  period”  with  the  more  comprehensive  term  of  “effective  break”.  The  argument  behind  this 
proposition, according to this group of respondents, lies on the fact the flexibilization of driving and 
rest patterns is believed to be used by the industry to extend the amount of consecutive working 
hours to better fit the business needs and would consequently worsen drivers’ working conditions. 
In turn, the introduction within the current legislation of a reference to the “effective break” would 
ensure that drivers can benefit of a full 45-minute break in between two slots of driving times of 4,5 
hours each - without being engaged in other activities qualifying as work. 

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and 100% for employed; the share of respondents in favour of break change 2 was around 
70% for self-employed and again 100% for employed. 

Table 6.2: Stakeholders by category in favour of break change 1 vs break change 
2 

Business 
associatio
ns 

Companie
s 

Self-
employed 
drivers 

Employe
d drivers  

Trade 
unions 

Public 
authorities 

1
e
g
n
a
h
c

2
e
g
n
a
h
c

k
a
e
r
B

k
a
e
r
B

Yes  9 (82%) 

38 (81%) 

16 (80%)  

15 
(100%) 

1 (17%) 

2 (20%)  

No 

2 (18%) 

9 (19%) 

4 (20%) 

0 (0%) 

5 (83%) 

8 (80%) 

Yes  5 (45%)  

30 (55%) 

16 (70%) 

10 
(100%) 

0 (0%)  

1 (10%) 

No 

6 (55%) 

25 (45%) 

7 (30%) 

0 (0%) 

& (100%)  9 (90%) 

Source: Public consultation – Driving and rest time for bus and coach drivers 

Compensatory measures 

Then,  the  public  consultation  participants  were  invited  to  provide  their  opinion  on  the 
following question: “Do you think that compensatory measures would be needed to prevent 
deterioration of working conditions under your preferred (set of) change(s)?”. Respondents 
were  essentially  asked  whether  any  given  change  should  be  accompanied  by  additional 
measures  aiming  to  ensuring  that  drivers  are  able  to  take  sufficient  breaks  and  avoid 
fatigue. According to Figure 6.20, overall 26% (29) of the 112 respondents considered 
the integration of compensatory measures as necessary in view of the improvement of the 
working conditions (regardless of the change preferred). 

Figure  6.20:  “Do  you  think  that  compensatory  measures  would  be  needed  to 
prevent  the  deterioration  of  working  conditions  under  your  preferred  (set  of) 
change(s)?” 

12, 11%

29, 26%

83, 74%

Yes

No

Don't know

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 112 respondents 

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Likely impacts of preferred change 

Respondents  were  asked  to  give  their  views  on  the  expected  impacts  of  their  preferred 
break  measure  on  different  indicators.  The  two  figures  below  show  respectively:  1)  the 
answers of respondents who are in favour of implementing break change 1 (Figure 6.21); 
2) the answers of respondents who are in favour of implementing break change 2 (Figure 
6.22). 

Figure  6.21:  "What  do  you  think  would  be  the  impact  of  the  proposed  change 
(break change 1) compared to the current rules?" 

Ability to organise services efficiently and in line with
customer needs

62

8

2

Overall impact compared to the current rules

47

20

4

2

Working conditions

39

19

12

Driver and passenger safety

14

22

35

Improve a lot

Improve a little

Stay the same

Get a little worse

Get a lot worse

Don't know

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 73 respondents 

Figure  6.22:  "What  do  you  think  would  be  the  impact  of  the  proposed  change 
(break change 2) compared to the current rules?" 

Ability to organise services efficiently and in line with
customer needs

47

6

2

Overall impact compared to the current rules

Working conditions

31

32

15

7

2

14

7

Driver and passenger safety

19

12

22

2

Improve a lot

Improve a little

Stay the same

Get a little worse

Get a lot worse

Don't know

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 57 respondents 

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The two figures above showed that supporters of each break change expected important 
improvements, mainly in terms of  service delivery, working conditions, and overall 
impacts. More specifically, both groups of respondents recognised that each break change 
would primarily impact the flexibility of bus drivers and bus operators to organise services 
that are in line with customer needs. Furthermore, as far as break change 1 is concerned, 
54% of respondents (49) consider that bus drivers’ working conditions would improve a 
lot, while 26% of respondents (19) agreed that they would improve but to a smaller extent. 
On  the  other  hand,  break  change  2  would  significantly  improve  working  conditions 
according to 57% of respondents (32). 

Then bus and coach operators as well as bus and coach drivers – who opted for break 
change 1 – were asked to estimate the impact of the proposed change on the overall level 
of  legal  compliance,  the  compliance  costs  related  to  administrative/financial  costs,  the 
costs required to train bus drivers in accordance with new rules and the volume of services 
provided. 

According to the majority of respondents, the largest positive impacts of break change 1 
are to be expected on volumes of services provided and level of compliance (about 60% 
of respondents expect both of them to improve). However, break change 1 is expected to 
bring  no  major  positive  effect  on  compliance  costs  and  training  costs,  as  a  respective 
majority of 55% (23) and 77% (30) of respondents foresees either no changes or minor 
drawbacks (see Figure 6.23).  

Figure 6.23: “Compared to the situation with the current rules, we would like you 
to estimate the impact that the proposed change (break change 1) would have 
on  compliance,  regulatory  costs  and  business  performance.  Please  select  from 
the relevant responses” (1) 

Volume of services provided

7

17

12

3

Level of compliance

10

Compliance costs related to administrative/financial
costs

1

9

14

16

10

2

5

7

1

8

Costs required to train drivers about the new rules

1

5

27

3

3

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Increase a lot (>+10%)

Increase a little (+3% to +10%)

Stay the same (+ / - 2%)

Deacrease a little (-3% to -10%) Decrease a lot (>-10%)

Don't know

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 42 respondents 

Bus operators and bus drivers were separately asked to assess one different impact each. 
Thus, 69% of bus operators largely agreed that break change 1 would imply no change for 
what concerns the number of bus drivers employed in the sector. All the bus drivers shared 
the same views with regards to the yearly turnover of their companies. 

Similarly to the views expressed on break change 1, the majority of respondents expected 
the largest positive impacts of break change 2 to be on  general levels of compliance 
and compliance to costs. Again, the impact  on  training costs seems to be negligible 

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(less than 50% of respondents could identify potential impacts), while a consistent share 
of 60% of respondents sees either no changes or even a little decrease in terms of volume 
of services provided (see Figure 6.24). 

Figure 6.24: “Compared to the situation with the current rules, we would like you 
to estimate the impact that the proposed change (break change 2) would have 
on  compliance,  regulatory  costs  and  business  performance.  Please  select  from 
the relevant responses” (1) 

Level of compliance

15

24

7

5

Volume of services provided

5

26

17

3

Compliance costs related to administrative/financial
costs

Costs required to train drivers about the new rules

1

1

16

18

8

8

10

31

3

1 3

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Increase a lot (>+10%)

Increase a little (+3% to +10%)

Stay the same (+ / - 2%)

Deacrease a little (-3% to -10%) Decrease a lot (>-10%)

Don't know

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 51 respondents 

Again, bus operators and bus drivers were separately asked to assess one different impact 
each.  Thus,  63%  of  bus  operators  largely  agreed  that  break  change  2  would  imply  no 
change  for  what  concerns  the  number  of  bus  drivers  employed  in  the  sector.  Most  bus 
drivers  (67%)  shared  the  same  views  with  regards  to  the  yearly  turnover  of  their 
companies. 

National public authorities were then given a specific question related to their role as 
enforcement bodies. This consultation revealed that public authorities expect break change 
1 (which they did not explicitly favour but found as the most acceptable) to bring no change 
to or even significantly increase the amount of time/staff needed to enforce rules. Fines 
for non-compliance and expenditure on legal actions are similarly expected to either remain 
the same or increase a little. The general level of compliance is instead likely to stay the 
same or decrease a little. 

6.5.2 

Rest period changes 

Six possible changes have been identified to make the organisation of rests during a trip 
more flexible. They are the following: 

•  Rest period change 1. Allow bus and coach drivers in domestic occasional carriage 
of passengers to use the “12-day derogation”. The current rules only foresee this 
derogation for bus and coach drivers in international passenger services. 

•  Rest period change 2. Allow bus and coach drivers to deviate from a single service 
condition  (“single  trip”)  in  domestic  and  international  occasional  carriage  of 
passengers 

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•  Rest  period  change  3.  Remove  the  obligation  of  taking  two  regular  weekly  rest 
periods after using the “12-day derogation”. The removal of this obligation would 
envisage the introduction of compensatory measures for drivers ensuring adequate 
rest. 

•  Rest period change 4. Allow bus and coach drivers on trips lasting 8 days and longer 
to postpone the start of the daily rest period by 1 h, provided that the total daily 
driving time on that day does not exceed 7 hours. 

•  Rest period change 5. Allow bus and coach drivers on trips lasting 8 days and longer 
to postpone the start of the daily rest period by 2 h, provided that the total daily 
driving time that day does not exceed 5 hours. 

•  Rest period change 6. Allow bus and coach drivers on trips lasting 8 days and longer 
to distribute their weekly rest periods in such a way that the average weekly rest is 
at least 45h over the period of 10 consecutive weeks, where the minimum duration 
of weekly rest every week cannot be less than 24h. 

Preferred change 

Public consultation participants (all but EU citizens) were firstly asked to indicate whether 
they thought any of these changes should be implemented. Results are presented below. 

Figure 6.25: “Six possible changes have been identified to make the organisation 
of rests during a trip more flexible. Please indicate whether you think any of these 
changes should be implemented (NB: multiple possible changes can be picked) 
and explain your preference. If you do not favour any of the changes listed, you 
can propose a different idea, or state that the current rules should be maintained” 

Rest period change 1

Rest period change 2

Rest period change 3

Rest period change 6

Rest period change 4

Rest period change 5

77

79

75

69

56

95

20

29

36

35

42

50

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Yes

No

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 115 respondents 

Figure  6.25  shows  that  all  proposed  rest  changes  are  generally  welcomed  by  most 
respondents, with rest period change 1 being by far the most wanted. 

Twenty-one respondents indicated that none of the proposed rest period changes should 
be  implemented.  Nine  of  them  (42.9%)  deemed  to  retain  the  current  rules  as  the  best 
available option. Twelve of them (57.1%) instead proposed different changes. Ten of the 
twelve  respondents  who  proposed  different  changes  used  the  comment  box  at  their 

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disposal to write about the need to “keep the current regulation as it is, except for split 
rest  time,  which  should  be  eliminated  from  the  current  rules”.  The  remaining  two 
respondents,  instead,  explicitly  demanded  the  abolition  of  the  12-day  derogation  “for  a 
small, pseudo-privileged group of drivers with a category D driving license and thus the 
return to the 6-day week, as stipulated by Regulation (EC) No 561/2006 of the European 
Parliament and Council”. 

When examining the responses of different stakeholders’ groups, what becomes evident is 
a  general  opposition  towards  any  of  the  changes  proposed  by  public  authorities  and 
(especially)  trade  unions.  The  table  below  show  the  variation  of  preferences  across 
stakeholders’ groups for rest period changes 1 to 6. 

Table 6.3: Views on rest period changes 1 to 6 by stakeholder group 

Business 
associatio
ns 

Companie
s 

Self-
employed 
drivers 

Employe
d drivers  

Trade 
unions 

Public 
authorities 

Yes  10 (91%) 

55 (96%)  

25 (93%)  

15 (94%)   1 (17%)  

3 (30%)  

No 

1 (9%) 

 2 (4%) 

2 (7%) 

1 (6%) 

5 (83%) 

7 (70%) 

Yes  7 (78%)  

45 (85%)  

18 (78%)  

14 (93%)   0 (0%)  

3 (30%)  

No 

2 (22%) 

8 (15%) 

5 (22%) 

1 (7%) 

6 (100%)  7 (70%) 

Yes  9 (82%)  

47 (82%)  

22 (81%)  

16 
(100%)  

0 (0%)  

0 (0%)  

No 

2 (18%) 

10 (18%) 

5 (19%) 

0 (0%) 

6 (100%)  10 (100%) 

Yes  7 (70%)  

37 (67%)    16 (67%)  

15 (94%)   0 (0%)   

4 (40%) 

No 

3 (30%) 

18 (33%) 

8 (33%) 

1 (6%) 

6 (100%)  6 (60%) 

Yes  5 (45%)  

32 (62%)  

11 (52%) 

13 (81%)    0 (0%)  

2 (20%)  

No 

6 (55%) 

20 (38%) 

10 (48%) 

3 (19%) 

6 (100%)  8 (80%) 

Yes  7 (64%)  

42 (79%)  

17 (81%)  

15 (94%)   0 (0%)  

0 (0%)  

No 

4 (36%) 

11 (21%) 

4 (19%) 

1 (6%) 

6 (100%)  10 (100%) 

g
n
a
h
c

t
s
e
R

1
e

2
e

g
n
a
h
c

3
e
g
n
a
h
c

t
s
e
R

t
s
e
R

g
n
a
h
c

t
s
e
R

4
e

g
n
a
h
c

t
s
e
R

5
e

g
n
a
h
c

t
s
e
R

6
e

Source: Public consultation – Driving and rest time for bus and coach drivers 

Respondents were then once again asked – for the remaining parts of this questionnaire – 
to answer in terms of their preferred (set of) change(s). In case they thought the existing 
rules should be retained, answers should have been given in terms of the proposed (set 
of) change(s) considered the most acceptable.  

Compensatory measures 

Asked whether they think that compensatory measures would be needed to prevent the 
deterioration  of working conditions under their preferred (set  of) change(s),  views were 
mixed – as for each proposed rest period change around 50% of respondents did not see 
the  need  of  introducing  compensatory  measures.  Overall,  between  38%-45%  of 
respondents were of opposite views, and the remaining 7-10% did not take a position on 
the matter. 

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Likely impacts of preferred (set of) change(s) 

Respondents were then requested to assess the likely impacts of their preferred rest period 
change(s) on different indicators as well as the overall impact. Respondents were invited 
to compile a package  comprised of  one  or more measures  on  rest times, to answer the 
impact questions in terms of their preferred (set of) change(s).  

Given the amount of potential combination of  rest period  changes that each respondent 
could choose from (i.e., a total of 63 packages), the analysis of responses has focused on 
the  most  popular  combinations.  This  exercise  revealed  that  62  out  of  a  total  of  157 
respondents (39.5%) were favouring the implementation of  all six changes proposed. 
The second largest group of respondents – 13 respondents – opted for the combination of 
rest  period  changes  1,  2,  3  and  6.  The  table  below  shows  the  distribution  of 
stakeholders’ preferences across the six proposed changes (only options and combination 
of options that received at least one preference have been included). 

Table  6.4:  Distribution  of  stakeholders'  preferences  across  (set  of)  rest  period 
change(s) 

Preferred (set of) change(s) 
Rest change 1, 2, 3, 4, 5 and 6 
Rest change 1, 2, 3 and 6 
Rest change 1 
Rest change 1 and 3 
Rest change 1, 3 and 5 
Rest change 1, 2, 3, 4 and 6 
Rest change 6 
Rest change 1, 2 and 6 
Rest change 1, 3 and 4 
Rest change 1, 3, 4 and 6 
Rest change 1, 2, 3, 4 and 5 
Rest change 1 and 4 
Rest change 2 and 4 
Rest change 1, 2, 3 and 4 
Rest change 1, 2, 4 and 5 
Rest change 1, 2, 3, 5 and 6 
Rest change 1, 2, 4, 5 and 6 
Rest change 1, 3, 4, 5 and 6 
Rest change 2 
Rest change 4 and 5 
Rest change 1, 2 and 3 
Rest change 1, 3 and 6 
Rest change 1, 2, 5 and 6 
Rest change 1, 3, 4 and 5 
Rest change 1, 4, 5 and 6 
Rest change 2, 4, 5 and 6 
Rest change 3, 4, 5 and 6 
TOT 

N of respondents 
62 
13 
7 
5 
5 
5 
3 
3 
3 
3 
3 
2 
2 
2 
2 
2 
2 
2 
1 
1 
1 
1 
1 
1 
1 
1 
1 
157 

Share 
39.5% 
8.3% 
4.5% 
3.2% 
3.2% 
3.2% 
1.9% 
1.9% 
1.9% 
1.9% 
1.9% 
1.3% 
1.3% 
1.3% 
1.3% 
1.3% 
1.3% 
1.3% 
0.6% 
0.6% 
0.6% 
0.6% 
0.6% 
0.6% 
0.6% 
0.6% 
0.6% 
100% 

Before digging into the deemed likely impacts of the three most popular set of changes, it 
is useful to look at the characterisation of the three different groups of respondents. Most 
respondents favouring  all the proposed changes  were  companies (64.5%), followed by 
bus  drivers  (25.8%)  and  business  associations  (9.7%).  Among  bus  drivers,  11 
(73.3%) were employed whereas 5 (26.6%) self-employed. Respondents who picked rest 
changes 1, 2, 3 and 6 were again for the most part companies (61.5%) and bus drivers 

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(30.8%), while the remaining preferences came from business associations (7.7%). In 
this case, among the bus drivers, three were self-employed and one employed bus drivers.  

Importantly,  the  overwhelming  majority  of  trade  unions  did  not  support  any  of  the 
individual  changes  proposed.  On  the  contrary,  a  solid  majority  of  bus  drivers  (both 
employed  and  self-employed),  companies  and  business associations  supported  each 
individual  rest  period  change  (with  the  exception  of  rest  period  change  5,  where  “only” 
50% of business associations looked at it positively).  

The  figures  below  show  the  views  of  respondents  on  the  potential  impacts  of  the  two 
preferred combinations of rest period changes on: drivers’ working conditions; driver and 
passenger  safety;  the  ability  to  organise  services  efficiently  and  in  line  with  customer 
needs;  the  level  of  fair  competition  between  operators  of  domestic  and  international 
services; and the overall impact compared to the current rules. 

Figure  6.26:  “What  do  you  think  would  be  the  impact  of  the  proposed  (set  of) 
change(s) compared to the current rules?” – Combination of rest period changes 
1, 2, 3, 4, 5 and 6 

Ability to organise services efficiently and in line with
customer needs

57

4

1

Overall impact

Working conditions

15

Fair competition between operators of domestic and
international services

49

48

8

3

1

42

3

2

7

6

1

Driver and passenger safety

6

7

48

1

Improve a lot

Improve a little

Stay the same

Get a little worse

Get a lot worse

Don't know

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 62 respondents 

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Figure  6.27:  “What  do  you  think  would  be  the  impact  of  the  proposed  (set  of) 
change(s) compared to the current rules?” – Combination of rest period changes 
1, 2, 3, and 6 

Ability to organise services efficiently and in line with
customer needs

12

Working conditions

2

11

Overall impact

Driver and passenger safety

4

Fair competition between operators of domestic and
international services

10

9

8

1

1

1

2

3

Improve a lot

Improve a little

Stay the same

Get a little worse

Get a lot worse

Don't know

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 13 respondents 

As showed in Figure 6.26, the  combination  of  all rest period changes is  expected to 
bring overall significant positive impacts compared to current rules. For instance, nearly or 
even  more  than  90%  of  respondents  believed  that  organisation  of  services,  working 
conditions and the fair  competition between operators are all going to improve with the 
implementation  of  all  six  changes  proposed.  In  the  case  of  the  organisation  of  efficient 
services  and  the  overall  impacts,  respectively  92%  (57)  and  80%  (49)  of  respondents 
expected large improvements – while working conditions are rather expected to improve 
moderately.  Drivers  and  passengers’  safety,  instead,  should  more  or  less  remain 
unchanged as stated by 77% of respondents (48). 

According to a consistent majority of respondents favouring rest period changes 1, 2, 3 
and 6 (Figure 6.27), the implementation of this set of changes is likely to considerably 
improve all relevant aspects of current rules (respondents considering this set of changes 
as bringing improvements ranged from a minimum of 75% to a maximum of 100%). 

Then bus and coach operators and bus and coach drivers were asked to estimate the 
impact of the proposed change on a different set of indicators, namely: the overall level of 
legal compliance, the compliance costs related to administrative/financial costs, the costs 
required  to  train  bus  drivers  in  accordance  with  new  rules  and  the  volume  of  services 
provided. Results are provided in the figures below and are once again grouped according 
to the preferred change selected by respondents. 

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Figure 6.28: “Compared to the situation with the current rules, we would like you 
to  estimate  the  impact  that  the  proposed  change  would  have  on  compliance, 
regulatory  costs  and  business  performance.  Please  select  from  the  relevant 
responses” – Combination of rest period changes 1, 2, 3, 4, 5 and 6 

Volume of services provided

4

16

5

Level of compliance

8

4

13

Costs required to train drivers about the new rules

1

7

16

Compliance costs related to administrative/financial
costs

2

4

15

4

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Increase a lot >+10%

Increase a little +3% to +10% Stay the same + / - 2%

Decrease a little -3% to -10% Decrease a lot >-10%

Don't know

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 25 respondents 

Figure 6.29: “Compared to the situation with the current rules, we would like you 
to  estimate  the  impact  that  the  proposed  change  would  have  on  compliance, 
regulatory  costs  and  business  performance.  Please  select  from  the  relevant 
responses” – Combination of rest period changes 1, 2, 3 and 6 

Level of compliance

Volume of services provided

2

2

Costs required to train drivers about the new rules

1

8

1

5

8

4

2

Compliance costs related to administrative/financial
costs

7

3

1

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Increase a lot >+10%

Increase a little +3% to +10% Stay the same + / - 2%

Decrease a little -3% to -10% Decrease a lot >-10%

Don't know

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 11 respondents 

Companies  and  bus  drivers  who  opted  for  the  implementation  of  all  six  rest  period 
changes seemed to agree that most benefits will impact the level of compliance (91% of 
respondents thought that it would increase to different degrees) and volume of services 
provided (80% of them could see the amount of trips increasing in the future – although 
to  different  extents).  For  the  three  remaining  areas  under  analysis  (i.e.,  level  of 

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compliance, costs to train bus drivers, and compliance costs), a majority of respondents 
ranging from 52% (13) to 67% (16) were of the opinion that rest period changes would 
not produce any major effects. 

For what concerns companies and bus drivers who picked the combination of changes 1, 
2, 3 and 6, a large majority of them thought that they would first and foremost increase 
the level of legal compliance. 62% of respondents (7) could also see how these changes 
could  benefit  the  volume  of  service  provided.  However,  also  in  this  case  a  significant 
majority of respondents were inclined to think that the costs of training bus drivers about 
the new rules and the compliance costs in general would stay the same.   

Bus operators and bus drivers (only self-employed ones) were separately asked to assess 
one different impact each. More in detail, the questionnaire aimed to gather views of bus 
operators on the magnitude of impacts of the six proposed changes on the amount of bus 
drivers employed in the sector. On the other side, self-employed bus drivers were asked 
to express their views on the likely impacts on the yearly turnover. Results are presented 
below. 

Figure 6.30: “Compared to the situation with the current rules, we would like you 
to  estimate  the  impact  that  the  proposed  change  would  have  on  compliance, 
regulatory  costs  and  business  performance.  Please  select  from  the  relevant 
responses” – Combination of rest period changes 1, 2, 3, 4, 5 and 6 

Yearly turnover of your company

4

13

8

Number of drivers employed

2

9

14

0%

10%

20%

30%

40%

50%

60%

70%

80%

90% 100%

Increase a lot >+10%

Increase a little +3% to +10% Stay the same + / - 2%

Decrease a little -3% to -10% Decrease a lot >-10%

Don't know

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 25 respondents 

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Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Figure 6.31: “Compared to the situation with the current rules, we would like you 
to estimate the  impact that the  proposed  change  (rest period  change  2)  would 
have  on  compliance,  regulatory  costs  and  business  performance.  Please  select 
from the relevant responses” – Combination of rest period changes 1, 2, 3 and 6 

Yearly turnover of your company

1

7

2

Number of drivers employed

1

3

6

1

1

0%

10%

20%

30%

40%

50%

60%

70%

80%

90% 100%

Increase a lot >+10%

Increase a little +3% to +10% Stay the same + / - 2%

Decrease a little -3% to -10% Decrease a lot >-10%

Don't know

Source: Public consultation – Driving and rest time for bus and coach drivers 
Base: 11 respondents 

According  to  the  results  above,  bus  operators  who  are  inclined  to  see  all  the  proposed 
changes implemented did not think that they would have a strong impact on the number 
of  drivers  employed  in  the  sector.  Most  of  these  respondents  (56%,  14)  have  indeed 
reported that – in view of these changes – the employment in the sector would stay roughly 
the same. On the contrary, bus operators believed that the combination of changes 1, 2, 
3 and 6 would have a positive impact on the number of drivers employed in the sector. 
Most  respondents  (64%,  7)  believed  that  in  this  scenario  the  employment  in  the  sector 
would increase to different extents. 

National public authorities were then confronted with a specific question related to their 
role as enforcement bodies. Although only three public authorities provided their response 
to the question, they expected the amount of time and staff needed to enforce new rules 
to either stay the same or increase. On the contrary, the level of compliance is believed to 
either stay the same or decrease. There seemed to be a wider agreement on the fact that 
the average number of yearly fines for non-compliance will slightly increase (2 out of three 
public authorities shared this view). 

It should be noted that all three public authorities did not favour any of the changes listed 
(i.e., rest period change 1, 2, 3, 4, 5, or 6) but found rest period change 1 as the most 
acceptable.  

6.6  Conclusion 

To conclude, respondents were invited to express their views on current social rules in the 
passenger transport sector and on what changes they believed are needed to improve the 
provision of services in a post-COVID scenario, with an eye on working conditions and road 
safety. 

The majority of respondents deemed current rules as beneficial in terms of work intensity 
and work-life balance. Similarly, current rules help keeping the levels of stress and fatigue 
for drivers under control ensuring thus road safety and rules compliance.  

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Current rules are however too rigid to cope with unexpected situations, deal with clients 
demands during trips and to overall provide high quality services. Current rules are also 
believed to not contribute to fair competition at all, since the 12-day derogation can only 
be used for international trips. 

Consequently,  a  large  share  of  respondents  –  with  very  different  degrees  across 
stakeholders’ groups – were in favour of some sort of changes in terms of break and rest 
time rules. 

Respondents  were  then  presented  with  two  possible  changes  identified  to  make  the 
organisation  of  breaks  during  a  trip  more  responsive  to  the  needs  of  customers.  Break 
change 1 entails that occasional bus and coach drivers are allowed to split their break of 
minimum 45 minutes into 30 + 15 minutes87 or 15 + 15 + 15 minutes; break change 2, 
instead, allows occasional bus and coach drivers to arrange and split in a fully open manner 
their  break  of  minimum  45  minutes  over  the  period  of  4h30  driving  time.  Results  are 
showed below. Undoubtedly, break change 1 was the most favoured potential change, as 
it still requires bus drivers to mandatorily take a sufficient break rather than shaping their 
breaks schedules completely on customers’ needs. 

According  to  a  majority  of  respondents,  break  change  1  would  allow  to  organise  better 
services  in  line  with  customer  needs  but  would  also  improve  working  conditions  for  bus 
drivers. Break change 1 would also facilitate compliance with administrative and financial 
costs to a certain extent. However, it would not increase the overall volume of services. 

Moreover, six possible rest time changes were proposed to respondents. Rest period change 1 (which allow bus 
and  coach  drivers  in  domestic  occasional  carriage  of  passengers  to  use  the  “12-day 
derogation”.  The  current  rules  only  foresee  this  derogation  for  bus  and  coach  drivers  in 
international  passenger  services)  was  the  most  preferred  single  measures,  although  all  proposed 
changes were favoured by a majority of respondents.  Respondents  were  then  invited  to  compile  a 
package comprised of one or more measures on rest times, to answer the impact questions 
in terms of their preferred (set of) change(s). This exercise revealed that 62 out of a total 
of  157  respondents  (39.5%)  were  favouring  the  implementation  of  all  six  changes 
proposed.  Overall,  the  combination  of  all  rest  period  changes  is  expected  to  bring 
significant positive impacts compared to current rules. For instance, nearly or even more 
than 90%  of  respondents believed that  organisation of services, working conditions and 
the fair competition between operators are all going to improve with the implementation 
of all six changes proposed. The package of six changes was also expected to benefit the 
both the overall level of compliance and the volume of services provided. 

87 Note that under the current rules splitting the break into 15 + 30 minutes is already allowed. 

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7. Thematic case studies  

7.1  Case study 1- small bus operators  

7.1.1 

Case study summary and conclusions 

The objective of this case study is to provide a high-level characterisation of the specific 
needs of occasional bus and coach transport operators in Member States highly dependent 
on tourism. The concrete focus has relied on a well-known touristic destination – Portugal 
– which is therefore particularly vulnerable to fluctuant seasonality and may be regarded 
as a small market88, further affected by its peripherical location.  

For this purpose, the study team has carried out two targeted interviews, both representing 
essentially the viewpoint of operators on the suitability of the driving rules for the bus and 
coach ecosystem. Considering the lack of detailed information about the specific case of 
small-size companies, the testimonials are complemented by data collected in the frame 
of  the  public  consultation  (PC).  The  key  takeaways  from  this  case  study  can  be  found 
below:  

•  Market size: there is no detailed information that could help to shape the profile of 
small companies in Portugal. Nonetheless, it is  important to note that  more than 
2/3  of  the  responses  from  the  public  consultation  (PC)  (108  out  of  158)  were 
provided by micro or small companies. 

•  Key features and trends: according to the interviewees, the majority of the coach 
services  in  Portugal  are  domestic.  The  main  international  routes  are  performed 
within  the  corridor  Portugal-Spain-France-Switzerland.  However,  international 
services represent a residual share (which can be confirmed by the data presented 
in the main report of this study).  

•  COVID-19  impacts:  both  interviewees  and  PC  findings  confirm  that  smaller 
companies are much more dependent on occasional services than medium or large-
size companies, the latter being characterised for running different types of services 
simultaneously. Even if the Portuguese government has put aside some measures 
to reallocate coach services to minimise the economic impact of the pandemic on 
coach  companies,  this  trait  makes  them  more  vulnerable  to  the  impacts  of  the 
pandemics than large-size companies.  

•  Working conditions and economic aspects: according to the small and micro-sized 
companies that participated in the PC, the current rules contribute for a good life-
balance  for  workers.  The  same  data  source  also  confirms  that  the  current  rules 
favour small and micro companies, as they are easy to comply with and facilitate 
an  efficient  organisation  of  coach  operations  and  consequently  a  good  service 
provision.  However,  there  seems  to  be  no  agreement  on  this  point,  as  the 
interviewees consider that small-size employers have more difficulties to manage 
human  resources  and  replace  drivers  who  have  drove  the  maximum  number  of 
hours.  

•  Problems  related  to  the  rules  on  break  times:  according  to  the  PC,  small  and 
medium  size  companies  are  happier  with  the  current  set  of  rules.  They  are  also 
paradoxically  more  in  favour  of  targeted  small  changes.  One  of  such  chances 
concerns break time rules as there is strong agreement in favour of introducing a 

88 According to the market characterisation carried out as part of the desk research, the occasional 
domestic services of bus and coaches in Portugal represented only 2.8% of the overall number of 
national road transport passengers in 2017. 

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measure that allows drivers to split their break of minimum 45 minutes into 30 + 
15 or 15 + 15 + 15 minutes (representatives from larger companies tend also to 
agree with this measure, although to a lesser extent). 

•  Problems  related  to  the  rules  on  rest  periods:  according  to  the  PC,  only  a  small 
fraction of small companies’ representatives (4%, 2 out of 46) agree that current 
rest time rules  should  be  kept as they are on Regulation (EC) No 561/2006. The 
rigidity of the rules is perceived to have a negative impact on productivity and on 
service quality. In general, small and micro companies tend to agree with all  the 
changes suggested in the present initiative. Nonetheless, the measure that gathers 
more consensus among small companies (and that is also perceived as positive by 
larger companies) is definitely the 12-day derogation89.  

7.1.2 

Introduction 

This case study is inserted in the impact assessment for a possible revision of the occasional 
bus and coach drivers’ regulation. As this sub-sector has specific characteristics with great 
dependency on tourism, it makes sense to assess if there is a need for a change that meets 
the needs of small companies and self-employed drivers. Indeed, while all desk research 
sources  consulted  in  the  frame  of  this  study  confirm  that  the  regulatory  framework 
introduced by Regulation (EC) No 561/2006 have had a positive effect on road safety and 
working conditions of the drivers, small companies and self-employed drivers working in 
highly seasonable environments may be particularly disadvantaged by the rigidity of some 
rules, particularly those related with rest periods.  

The geographical scope of this case study is Portugal, an EU Member State that is situated 
in the periphery of the continent and has great tourism activity. In 2019, travel and tourism 
accounted for 16.5%  of total  economy90. The targeted country was  selected  for being  a 
highly touristic country with the purpose of being able to collect and analyse sufficiently on 
the experiences of companies in this market segment, particularly those that are small or 
that are comprised by self-employed drivers. 

For  this  purpose,  the  study  team  has  carried  out  two  targeted  interviews.  The  first 
interviewee was the  secretary-general of the  national association of  passengers on road 
transport. Due to the lack of information from the specific market of the coach sector in 
Portugal, she has recommended that the team could organise a second interview, which 
was held with a representative from the legal department of the Portuguese bus and coach 
companies’  association  who  would  be  in  a  better  position  to  inform  about  the  impact  of 
Regulation (EC) No 561/2006 in small companies based in Portugal.   

The main aim of the interviews was to get insight on the specific needs and pitfalls raised 
by  small-size  operators  and  to  get  feedback  on  the  expected  impacts  of  the  possible 
revisions  that  are  under  review.    These  two  institutions  were  earmarked  to  provide 
elements  for  discussion  as  they  have  several  associates  that  operate  in  the  occasional 
transport  sector  and  could  help  to  identify  small  size  companies  which  could  be  further 
consulted. However, it is important to note that none of the interviews were able to provide 
an  up-to-date  characterisation  of  the  sub-sector  and  showed  very  few  knowledge  about 
the reality of small companies that could help to shape a full picture of these.  

89  Stakeholders  interviewed  call  for  measures  that  are  more  ambitious  than  the  policy  measures 
proposed and consider, for instance, that the possibility to postpone the start of the daily rest period 
by  1h  provided  that  drivers  do  not  drive  more  than  7  hours  should  be  applicable  to  all  services, 
regardless of the number of days. They have advocated that these measures would be particularly 
relevant for small companies, since less human resources would then be needed. 
90 TRAVEL & TOURISM: GLOBAL ECONOMIC IMPACT & TRENDS 2020, World Travel & Tourism Council 
| Global Economic Impact Trends 2020.pdf (wttc.org) 

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Indeed, the interviewees shared with the team a comprehensive study with a full diagnose 
of the public transport sector, including the occasional sector in Portugal, and setting out 
strategies for the competitiveness of the sector. This document, however, was published 
in 2002 and was therefore of little use for providing a rigorous evidence base to inform our 
Impact Assessment. 

To overcome this barrier  related  with the lack  of in-depth information that is specific to 
this target group, the case study also draws on other evidence sources, notably the PC91. 
The  integration  of  these  complementary  methods  allows  to  enhance  our  understanding 
about the specific legal elements that are relevant for small-size coach companies. 

7.1.3 

Context 

According to the data collected in the main report and derived from the PRIMES-TREMOVE, 
the  sector  of  occasional  bus  and  coach  transport  has  a  residual  market  share  when 
comparing to other type of bus and coach services, such as regular services, accounting 
only  to  3.31%  of  the  overall  number  of  passengers.  These  figures  are  slightly  higher  in 
touristic  countries  such  as  in  Portugal,  where  the  market  share  of  occasional  coach 
transport  services  accounts  to  3.9%  of  the  overall  national  sector  in  2019.  In  terms  of 
activity flow, the sub-sector of coach services is mainly characterised for being extremely 
seasonal and dependent on the tourism activity.  

As  the  focus  of  this  case  study  lies  on  small-size  companies,  it  is  important  to  draw 
attention to data collected by the European Transport Workers Association (ETF), showing 
that 44% of drivers in Europe work for a micro or small company (i.e. with less than 51 
employees). These figures represent only ETF affiliates and may therefore be not taking 
fully into account self-employed drivers, whose number might be underestimated in the 
sample. The PC has instead highlighted  how significant occasional services are for small 
(and micro) companies in terms of turnover (see figure below). 

Figure 7.1: Percentage of turnover in 2019 related to occasional bus and coach 
services (%) by size class 

83%

60%

48%

31%

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

Large (250 or more)

Medium (50 to 249
employees)

Small (10 to 49
employees)

Micro (1 to 9 employees)

Source: public consultation, October 2021 – February 2022.  
Base: 83 respondents 

91 The public consultation has received information from small-size companies although none come 
from Portugal. 

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The PC has collected information  from 108  representatives of  micro or  small  companies 
and gathered only 50 responses from medium and large-size companies. However, it was 
not  possible  to  confirm  the  market  breakdown  per  company  size  during  the  targeted 
interviews.  Nonetheless,  interviewees  have  confirmed  that  the  main  services  that  this 
sector  provides  in  Portugal  correspond  to  one-day  trips,  excursions  to  events  (such  as 
festivals  or  sport  games),  as  well  as  tourist  trips  to  cultural  places  and  monuments.  In 
terms of market share, they have mentioned that most of the activity refers to domestic 
trips, while the share of international services can be regarded as marginal. They have also 
outlined that coach buses in Portugal offer, on average, 50 seated places. 

According to the testimonial of the interviewees, since tourism and leisure is  one  of the 
fundamental  activities  that  trigger  occasional  coach  services,  bus  operations  mainly 
compete with individual transport and airplane, as the rail network in Portugal is not very 
suited to provide a convenient response to tourists needs.  

It was also acknowledged by the interviewees that the COVID-19 pandemic had a great 
impact on this sub-sector, as “it stopped completely and it still recovering”. This finding is 
consistent  with  the  report  from  DG  REGIO  which  shows  a  sharp  decline  of  tourism  in 
Portugal due to the COVID-19 outbreak in a country that has reached top positions in the 
world’s travel and tourism market92 in recent years. 

Although  the  impact  of  COVID-19  on  smaller  companies  could  not  be  fleshed  out  more 
significantly, it is important to show how the sector has responded to the crisis in peripheral 
countries highly dependent on tourism. To this respect, the interviewees have noted that 
the  Portuguese  Government  called  on  the  Portuguese  bus  market  to  urgently  make 
available necessary equipment, rolling stock and vehicles that could reinforce key regularly 
scheduled  public  transport  services  as  the  restrictions  on  vehicle  capacity  due  to  social 
distancing measures has required additional manpower and vehicles. This solution allowed 
to  minimise  the  number  of  companies  that  entered  bankruptcy  and  the  number  of 
subsidised  companies  and  drivers,  whilst  guaranteeing  an  economic  and  financial 
equilibrium  for  small  companies  that  protect  the  public  interest  and  the  drivers 
themselves93. 

“There  are  300  touristic  buses  in  the  Metropolitan  Area  of  Lisbon  that  could  be  used  to 
reinforce the urban train, subway and urban buses, whilst in the Metropolitan Area of Porto 
there are 150 to 200 buses which have completely stopped after the COVID-19 outbreak 
and can also be reallocated to regular services. This will allow to bring about 400 drivers, 
which  are  at  home  in  lay-off  and  receiving  only  2/3  of  their  wage  back  to  operations. 
(President of the national association of passengers on road transport) 

Arguably,  it  is  possible  to  assume  that  these  measures  have  had  a  stronger  impact  on 
smaller companies, as the PC confirms that 71% of services provided by micro and small 
companies are dependent on occasional services that were forced to stop with COVID-19, 
a  much  higher  share  than  the  one  featured  by  medium  and  large  companies,  for  which 
only 41% of services are dependent on occasional services. This statistic clearly shows that 
smaller companies are much more vulnerable as they do not have other business revenues 
to rely on in case of any disruptive event, such as the one introduced by the pandemics94.  

2021, 

92 European Commission, the impact of the COVID-19 outbreak on the tourism and travel sectors in 
Portugal, 
https://www.portugal2020.pt/wp-content/uploads/ccosta_for_ec.covid-
The 
19.report_txt.final_.pdf  
93 Observador, Covid-19. Ministro do Ambiente reitera segurança no uso dos transportes públicos, 
2020, 
https://observador.pt/2020/11/04/covid-19-ministro-do-ambiente-reitera-seguranca-no-
uso-dos-transportes-publicos/  
94 This business uncertainty may lead to a deterioration of the working conditions of drivers. This can 
be confirmed by the fact that, according to the results of the PC, all drivers working for medium and 

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7.1.4 

Problems associated with existing legislation 

This case study identifies several problems related to the current legislation. First of all, 
interviewees have reported that current rules steamed from Regulation (EC) No 561/2006 
are in general too rigid, negatively affecting small or large companies alike. In their opinion, 
small-size  employers  may  need  to  struggle  a  little  bit  more  with  human  resource 
management and staff allocation as they might not have another driver to replace the one 
who  has  drove  the  maximum  number  of  hours.  If  a  second  driver  is  not  available,  the 
immediate consequence might be a change of the tour services plan, a situation that should 
be prevented according to the stakeholders interviewed in the frame of this case study as 
it leads to a poor customer-service experience.  

“The  client  does  not  understand  these  rest  periods.  And  we  must  bear  in  mind  that 
occasional services are very unpredictable because they are depended on the activities of 
the tourists and the duration of the events. Hence, often the solution from the companies 
and drivers to cope with the rigid rules of occasional is not to comply at all” (Secretary-
general of the national association of passengers on road transport) 

One of the problems raised by the stakeholders with whom the team directly engaged in 
Portugal concerns compliance, which is rendered more difficult as a result of the level of 
inadequacy  to  the  service  needs  and  may  be  impacting  particularly  smaller  companies. 
There is however no detailed information about how often coach companies are fined as a 
result of infringements to the rest rules.  

According  to  the  stakeholders  consulted  during  the  interviews,  there  are  in  fact  high 
penalties in Portugal for non-compliance and road-side inspections are very regular (even 
if  less  frequent  among  the  occasional  transport  sub-sector).  In  fact,  case  study 
interviewees highlighted that penalties are higher in Portugal than in Spain or France. Also, 
there was an understanding that there is a lack of common and shared knowledge from 
the part of authorities with regard to specifications of the legislation, namely with regard 
to  the  12-day  derogation.  As  such,  it  was  argued  that  control  officers  from  different 
Member States do not often apply the enforcement mechanisms uniformly95.  

It was also mentioned by the interviewees that smaller bus and coach companies are more 
prone  to  find  difficulties  in  compliance.  This  is  due  to  the  fact  that,  according  to  the 
interviewees and their working experience, smaller companies tend to dedicate to single 
services,  whilst  larger  companies  have  the  ability  to  run  different  types  of  services 
simultaneously,  allocating  drivers  to  these  different  services,  a  feature  that  has  been 
corroborated by the results from the PC we have made mention to above. 

“Sometimes drivers of large bus companies perform different types of services (regular, 
specialised regular or occasional services) in the same shift and this makes very hard to 
comply  with  the  tachograph.  The  same  does  not  happen  in  smaller  companies  because 
they do not have so many permanent and regular services in their portfolio” (Secretary-
general of the national association of passengers on road transport) 

When  referring  to  the  practical  differences  related  with  the  application  of  the  12-day 
derogation, the stakeholders consulted in the interviews have made a point saying that it 

large companies have a permanent contractual  relationship with the  company, whilst we can  find 
nearly 10% of drivers employed for small and micro coach companies with a temporary contract. 
95 It was said that the different enforcement of compliance is also felt in terms of paying, 
for instance in Spain when a fine is issued it has to be paid in the spot while in Portugal 
there  is  a  deadline  and  there  is  a  possibility  for  revoking  it.  This  underlying  problem  is 
triggering several EU research projects in the context of the new Horizon Europe projects 
such  as  CORTE  2:  https://www.iru.org/news-resources/newsroom/iru-eager-start-work-
most-important-eu-project-enforcement-mobility-package-1.  

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is  not  well  justified  the  reason  why  a  driver  can  extend  the  period  of  working  days  by 
simply crossing a border. This was felt particularly unviable for coach companies based in 
small countries such as Portugal.  

Another  interconnected  problem  raised  by  the  interviewees  concerns  the  single  service 
condition.  Their  opinion  is  that  this  restriction  should  be  removed  to  raise  the 
competitiveness of the coach industry and to increase the modal share of the sub-sector 
against its main competitors (private vehicle and airplanes). 

“For  instance,  if  there  is  a  one-way  service  from  Portugal  to  France  or  Switzerland,  the 
driver is not able to bring another service back, while if it was the same service, he would 
be  allowed  to  drive  them  back  because  that  would  be  considered  a  single  service.  This 
limitation  impends  multimodal  synergies  (in  that  scenario,  passengers  could  stay  for  a 
period in the final destination and return back later to Portugal by airplane while the bus 
driver  would  bring  another  group  that  was  performing  the  opposite  journey)  (Legal 
representative of the Portuguese bus and coach companies’ association) 

7.1.5 

Expected impacts of the policy options on the market segment 

In terms of expected impacts of the policy options for small coach companies operating in 
peripheral  countries,  one  can  conclude  that  less  rigid  rules  concerning  the  rest  periods 
would have a positive impact on the competitiveness of the companies. This is particularly 
important as the sector faces a downward market trend96, which was exacerbated by the 
pandemics. 

Although it was not directly mentioned during  the interviews, a vibrant and  competitive 
market might also represent more working opportunities for drivers, benefiting in particular 
self-employed  drivers  and  small  companies  that  have  a  more  familiar  management 
background  and  may  be  less  resilient  to  external  shocks  such  as  the  ones  brought  by 
COVID-19.   

In general, the stakeholders interviewed call for further exemptions beyond the policy 
measures  proposed.  They  think  that  derogations  such  as  the  ones  that  allow  drivers  to 
postpone the start of the daily rest period by 1h provided that they do not drive more than 
7 hours should be applicable to all services, regardless of the number of days. In short, 
they advocate that this possibility could be applicable to one-day tours, for instance, since 
the same driver could finish a tour himself without the need to employ a second driver. 
This would be particularly relevant for small companies, they have said, since less human 
resources would then be needed.  

The  stakeholders  consulted  argued  that  12-day  derogation  would  be  important  for  the 
coach sector in Portugal, particularly the one composed by smaller companies, to become 
more competitive in long-distance journeys (against the private vehicle and airplane which 
are  the  most  common  options  for  holidays  in  Portugal)  and  to  allow  a  better  human 
resources management. This measure could be introduced in tandem with the removal of 
the  single  service  condition,  as  it  is  foreseen  in  the  PO  related  with  the  restricted 
postponement of weekly rest periods. Even if this measure could have a profound effect 
among companies which have a smaller pool of drivers available, it is important to make 
a caveat to indicate that this argument was not completely justified. Indeed, even if the 
merit  of  the  measure  is  clear  for  regularly  scheduled  and  long-distance  bus  services,  it 
remained uncertain how this removal could beneficiate occasional touristic tours as they 

96 The methodological note produced by the study team as part of  the interim report showed that 
the overall number of occasional bus and coach passengers in Portugal has been steadily decreasing 
since 2017 (14,501 passengers in 2017, 12,073 passengers in 2018 and 10,352 passengers in 2019, 
only 4.5% of which involved in international services). The data source for these figures was United 
Nations Economic Commission for Europe. 

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tend to transport the same group of people and finalise in the same city where the journey 
has started. 

In terms of break times, one of the stakeholders supported the complete flexibilization of 
break periods over the period of 4h30 driving time highlighting the need to transfer part 
of  the  onus  of  managing  the  driver  working  times  to  the  driver  himself.  The  reasoning 
behind is the fact that only the driver knows and understands if it is feeling tired or fit to 
drive.  Once  again,  this  argument  is  not  directly  influencing  smaller  companies  or  those 
located  in  more  peripheral  countries  that  are  highly  dependent  on  tourism.  It  rather 
corresponds to an overarching statement that seems to affect all bus and coach companies 
alike97. 

The public consultation provides more detailed information on the singularity of small-
size companies. According to the figure below, current rules contribute in general to a good 
working  environment  for  drivers  who  currently  are  employed  in  the  sector.  It  does  not 
however  cater  for  attractive  working  conditions  for  new  drivers,  especially  women.  The 
main takeaway at this respect is that the current rules contribute for a good life-balance 
particularly among drivers that work in small or micro-sized companies. 

97 Another global suggestion that has been  made by one of the interviewees concerns a 
suggestion to differentiate the rules between day trips and night trips. Although no relevant 
differences among small bus and coach companies could be devised, it was argued that 
when  a  driver  makes  a  trip  during  the  night, he  may  feel  more  exhausted  and  that  the 
legislation in place should have this into account. In practical terms, this suggestion might 
be  materialised  by  restricting  the  applicability  of  some  policy  measures  in  certain 
conditions.  For  instance,  allowing  drivers  involved  in  services  lasting  at  least  8  days  to 
postpone the start of the daily rest period by 1h provided that they do not drive more than 
7 hours and additionally limiting this option to services that are mainly performed during 
day-time periods. 

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Figure 7.2: Social impacts of current rules, micro and small companies vs large 
companies  

Working patterns

Work-life balance

Work intensity

Wage levels

Job security

Attractiveness for new drivers

Attractiveness for women

Minimising stress and fatigue for drivers

3, 66%

43, 69%

1, 32%

26, 42%

1, 30%

13, 21%

2, 57%
35, 57%

2, 55%
36, 56%

2, 60%

42, 68%

2, 56%

42, 72%

2, 52%
31, 50%

0%

10%

20%

30%

40%

50%

60%

70%

80%

Large (250 or more employees) (n=4)

Micro and Small (0-49 employees) (n=62)

Source: public consultation, October 2021 – February 2022.  
Base: 66 respondents 

On  economic  aspects,  there  are  contrasting  views  in  this  area  between  small  and  large 
companies, with the smaller undertakings perceiving the current rules as very favourable 
for providing high-quality services, responding to client demands, coping with unexpected 
situations  –  for  instance  those  related  with  unforeseen  traffic  disturbance  –  and  dealing 
with trips organised at night, whereas all these features have been negatively appreciated 
by representatives of larger companies. However, there is consensus among all companies, 
regardless of their size, in confirming that current rules do not promote a fair competition 
between domestic and international services. 

Although small coach companies are in general happier with the current rules, assessing 
their impact as globally very positive for economic wellbeing and particularly to the social 
working  conditions  of  the  sector,  they  are  also  more  prone  to  the  introduction  of 
targeted changes to the break and rest time rules. Indeed, smaller companies tend to 
be  more  favourable  to  the  introduction  of  new  rules  on  breaks  and  rest  periods  when 
compared to larger companies. 

When analysing the new policy options more in detail, it becomes evident that there is a 
need to introduce new break time rules, adopting the measure that allows drivers to split 
their break of minimum 45 minutes into 30 + 15 or 15 + 15 + 15 minutes. More flexible 
break time rules do not gather enough traction neither among small nor large companies. 

As for rest time rules, all options are perceived positively by small companies (see figure 
below).  However,  the  only  measure  that  is  regarded  as  positively  influencing  the  sector 
regardless  of  the  company  size  is  the  12-day  derogation,  even  if  stakeholders  do  not 

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provide quantitative information about the perceived impact of these legislative changes. 
As  a  result,  specific  quantitative  details  that  could  help  the  team  to  inform  about  the 
magnitude of introducing these changes is missing and therefore could not be identified in 
table 2 presented further below. 

Figure 7.3: Agreement of small vs large companies towards rest time changes 

Rest period change 1. Allow bus and coach drivers in 
domestic occasional carriage of passengers to use the 
“12-day derogation”. 

4, 100%

58, 94%

Rest period change 2. Allow bus and coach drivers to
deviate from a single service condition

Rest period change 3. Remove the obligation of taking 
two regular weekly rest periods after using the “12-day 
derogation”. 

Rest period change 4. Allow bus and coach drivers on
trips lasting 8 days and longer to postpone the start of
the daily rest period by 1 h, provided that the total daily
driving time on that day does not exceed 7 hours.

Rest period change 5. Allow bus and coach drivers on
trips lasting 8 days and longer to postpone the start of
the daily rest period by 2 h, provided that the total daily
driving time that day does not exceed 5 hours.

1, 25%

Rest period change 6. On trips lasting 8 days and longer
to distribute their weekly rest periods in such a way that
the average weekly rest is at least 45h over the period of
10 consecutive weeks (with a minimum weekly rest
remaining 24h)

2, 50%

2, 50%

47, 76%

54, 87%

2, 50%

43, 69%

41, 66%

3, 75%

44, 71%

Large (250 or more employees) (n=4)

Micro and Small companies (0-49 employees) (n=64)

0%

20%

40%

60%

80%

100%

120%

Source: public consultation, October 2021 – February 2022.  
Base: 66 respondents 

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Table 7.1: Summary of impacts on the market segment compared to occasional 
bus and coach sector as a whole 

Economic impacts 

Social impacts 

Environmental impacts 

Break times 

breaks 

The option that allows for 
regular 
of 
15+15+15  is  perceived  to 
contribute  positively  for 
managing 
customer 
demands  and  unexpected 
driving situations 

No relevant social impacts 
linked  to  break  time  rules 
were found that impact on 
small coach companies 

No relevant social impacts linked to break 
time  rules  were  found  that  impact  on 
small coach companies 

Rest periods 

the 

relevant 

derogation 

The  extension  of  the  12-
is 
day 
particularly 
in 
countries such as Portugal, 
where 
share  of 
domestic  services  is  high. 
However, it would lead to 
few  impacts  per  se  if  it  is 
not  backed  up  by  the 
single trip and the removal 
of the obligation of taking 
two  regular  weekly  rest 
periods  after  using  the 
“12-day rule” 

in 

countries  with 

Although  of  marginal  impact  as  these 
services are a niche product, the removal 
of the single service condition in particular 
could  favour  the  selection  of  coach 
services for international or long-distance 
journeys 
poor 
international  rail  connections  such  as 
Portugal.  A  group  could  be  driven  to 
Switzerland  and  return  by  plane  (or  the 
other way around), instead of relying on 
plane  in  both  directions.  This  option  is 
more environmental-friendly than relying 
on private vehicles or planes 

Advocators  of  the  12-day 
rule extension to domestic 
services argued that there 
is  little  evidence  that  the 
in 
risks  entailed 
long 
services 
domestic 
(working 
environment, 
safety) are higher than the 
ones 
in 
international journeys 

involved 

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7.2  Case study 2 – large EU-wide bus and coach operators  

7.2.1 

Case study summary and conclusions 

This  case  study  looks  at  large  operators  in  the  occasional  passenger  services  market, 
meaning  companies  with  more  than  250  employees.  There  are  relatively  few  such 
companies, and therefore the scope is to include evidence from any company large enough 
in the EU.  

There are a few points in this case study about the larger companies operating occasional 
services.  The  main  takeaway  is  that  very  few  large  companies  operate  primarily 
occasional services, and most large companies who do any occasional services still get 
a  majority  of  their  revenue  from  operating  regularly  scheduled  services,  such  as  public 
transport  services.  According  to  both  available  data  and  interview  sources,  larger 
companies do seem to have relatively easy time coping with the driving and rest time rules, 
as they have more people to fill in for drivers who need to take their long rest breaks after 
an international trip under the 12-day derogation rules.  

The implications of these findings are that any benefits to companies due to potential 
changes  of  the  rules  is  going  to  be  muted  for  large  operators.  Companies  who 
mostly  conduct  regularly  scheduled  services  are  more  likely  to  be  concerned  about  any 
unintended spill over effects into the regularly scheduled services, which are supposed to 
be  exempt  from  the  EU  regulation  on  driving  and  rest  time  rules  and  would  make  the 
regularly scheduled services more difficult to organise.  

While data specific to the occasional services of large companies is sparse, mainly due to 
the  small  number  of  companies  involved,  the  available  information  indicates  that  large 
companies are less motivated to demand rule change. Logically, if large companies gain a 
competitive advantage due to their ability to cope with the current rules, there also would 
exist a financial incentive to leave the rules in place. To summarise, when considering the 
impact  on  large  companies  of  changing  or  keeping  the  driving  and  rest  time  rules,  the 
following points should be kept in mind:  

•  Large transport operators are primarily involved in regular services and is therefore 
less dependent on being as efficient as possible in the occasional transport sector. 

•  Large  companies  are  primarily  involved  in  providing  regular  services  and  are 
therefore more concerned with problems of coordinating between the separate sets 
of regulation (the 561/2006 and national regulation).  There is already some spill 
over, making drivers on public transport bus lines over 50km work under separate 
sets of regulation from their colleagues driving shorter bus lines. 

•  Larger transport companies with a relatively high degree of occasional services have 
an easier time utilising their coaches, leading to less downtime per coach and better 
financial performance.  

7.2.2 

Introduction 

This  case  study  assessed  the  current  situation  and  impacts  of  future  changes  for  large 
occasional passenger transport companies, meaning businesses with over 250 employees, 
operating internationally in the EU. As detailed below, these companies are quite rare. Due 
to this, the participation of such companies in the data collection was fairly limited: only 
two of the interviews conducted for the targeted consultation were large companies, both 
of which primarily operated in regular services. Five of the respondents to the open public 
consultation were also large companies, and these were also primarily involved in providing 
regular passenger services.   

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Therefore, two secondary interviews were conducted, one with a large company involved 
in primarily occasional transport services, as well as a shorter scoping interview with the 
main trade association for the coach transport sector on European level.  

7.2.3 

Context 

An initial distinction that is necessary to make is between two types of large companies 
involved in the passenger transport sector. The most common one is the large undertaking 
that primarily conducts regularly scheduled services (for instance public transport services 
or  scheduled  international  travel  buses),  but  that  also  conducts  a  certain  amount  of 
occasional services. The other type of larger operator would be a company that primarily 
organises  coach  tours.  This  second  type  of  company  is  very  rare;  among  all  the  coach 
companies  in  Europe  who  are  members  of  the  main  business  association,  only  two 
companies  who  primarily  provide  occasional  transport  services  have  more  than  250 
employees.  Indeed,  of  the  two  large  companies  interviewed  for  the  study,  one  was  a 
Swedish company that conducted about 95% regular services, and the other was a Spanish 
company  for  which  about  80%  of  business  was  for  regular  services.  The  issues  with 
estimating market share and activity in terms of passengers/km for instance, is therefore 
exacerbated for the large companies, as they are to a greater degree also involved in the 
regular services.  

An important point to note is that different rules apply to the types of services conducted 
by  large  companies.  According  to  article  3a  of  the  561/2006  Regulation  on  Driving  and 
Rest Time rules, any regularly scheduled service carrying passengers is exempt from the 
rules, provided that the route does not exceed 50 km. A concern for larger companies is 
therefore how to handle any routes that are more than 50 km, as it leads to different rules 
for the same employees, depending on which route they are taking.  

The best available data to look at the occasional transport sector and comparing by size is 
a dataset over the Dutch coach sector. In the table below the companies have been divided 
into  groups  of  “large”  and  “small/medium”.  Due  to  the  lack  of  numbers  on  drivers,  the 
predictor for company size is instead based on the number of coaches that the company 
uses. The large companies are defined as companies with more than 70 coaches, and the 
small/medium  ones  have  fewer  than  70.  This  definition  allows  us  to  compare  relatively 
large companies to smaller ones. It is not necessarily the case that these companies have 
more  than  250  employees  (as  the  definition  of  large  company  states),  but  it  gives  an 
indication of differences among smaller and larger companies.  

Below is an overview of table of which types of services provide the main source of income 
for the two size classes of companies. As the targeted interviews (see annex 3 above) 
also  showed,  the  larger  companies  rely  to  larger  extent  on  providing  public 
transport  services  compared  to  the  smaller  companies.  Additionally,  large 
companies earn a more important share of their overall revenue from shuttle and 
international scheduled services. Similar evidence is found in the public consultation 
carried  out  for  the  impact  assessment,  where  larger  companies  stated  that  they  earn  a 
lower  percentage  of  their  total  revenue  from  providing  occasional  services,  as  seen  in 
Figure 7.4. 

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Table 7.2: Turnover by type of services by size class, 2020, the Netherlands 

Turnover by type of services by size class, 2019 
Average turnover from regular services (school/company 
transport) 

Public scheduled services 

Day trips* 

Multi-day trips* 

Shuttle and international scheduled services* 

Total 

Small/medium 

Large 

29% 

11% 

45% 

11% 

4% 

11% 

49% 

19% 

9% 

13% 

100% 

100% 

Source:  Kerncijfers  2019  van  het  Nederlandse  touringcarvervoer  (Panteia,  2021),  authors  own 
calculations.  
* Occasional transport service  

Figure 7.4: Percentage of turnover in 2019 related to  occasional bus and coach 
services (%) by size class 

83%

60%

48%

31%

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

Large (250 or more)

Medium (50 to 249
employees)

Small (10 to 49
employees)

Micro (1 to 9 employees)

Source: public consultation, October 2021 – February 2022.  
Base: 83 respondents 

Looking into the data gathered from the public consultation, we see a continuation of this 
same pattern. In Figure 7.5, we see that size does not affect how much of the company 
services  are  dependent  on  seasonality.  We  see  that  micro  companies  are  slightly  more 
sensitive to seasonality (68% of services depend on season) while large companies state 
that 60% of services are seasonal, which is comparable to both small and medium sized 
businesses. 

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Figure 7.5: Percentage of services that are seasonal (%), by size class 

60%

58%

60%

68%

80%

70%

60%

50%

40%

30%

20%

10%

0%

Large (250 or more) Medium (50 to 249

employees)

Small (10 to 49
employees)

Micro (1 to 9
employees)

Source: public consultation, October 2021 – February 2022.  
Base: 83 respondents 

This  seasonality  could  be  attributed  to  a  company  being  more  or  less  dependent  on 
occasional services, since a peak-season would be the time where the most tourists are 
present, and occasional services being understood as a form of touristic service. However, 
according to the data gathered, despite all sizes of companies stating that a slight majority 
of services are seasonal, they depend to a varying degree on occasional services. In this 
data  it  is  also  evident  that  large  companies  depend  to  a  lesser  extent  on  occasional 
services,  and  in  fact,  the  larger  the  company  the  lesser  the  dependency  on  occasional 
services. This would imply that companies providing regular services are about as sensitive 
to seasonality as those providing mainly occasional services.  

7.2.4 

Problems associated with existing legislation 

The problems associated with existing legislation is similar to the problems faced by smaller 
companies in the sector, albeit the effect seems muted due to the characteristics of this 
market segment. As explained above, this comes from the fact that most larger companies 
depend  on  providing  regularly  scheduled  services  for  a  larger  part  of  their  income,  and 
thus have a smaller percentage of their business affected by the 561/2006 regulation on 
driving  and  rest  time  rules.  In  general,  public  transport  routes  are  shorter  than  50km, 
which exempts drivers on that bus route from the 561/2006 regulation. For public transport 
routes  over  50km,  the  driver  must  drive  according  to  the  561/2006  regulation,  where 
between national regulation and the EU regulation can vary. Some examples of how the 
rules can differ include: 

•  Different  use  of  a  tachograph.  Tachographs  are  required  under  the  561/2006 
regulation, but the use of tachographs can be different in the national regulation.  

•  Different type of break time. Public transport drivers take a break when they have 

finished driving their route, and passengers are not   

However,  according  to  interview  sources  and  the  available  data,  it  seems  that  large 
companies have an advantage over smaller companies also when it comes to scheduling 
and coping with the rest time rules.  

Looking at pre-pandemic performances per coach between smaller and larger companies 
in the Netherlands, we see a pattern of larger companies getting more mileage out of each 

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coach than smaller ones tend to. Larger companies do not only have more coaches, but 
they also have better performance per each coach as well - more passengers per coach, 
more deployment days per coach, and greater number of kilometres both domestically and 
abroad. This finding is backed up in interviews, where both larger and smaller companies 
stated that larger companies had an easier time to employ enough drivers to keep 
coaches in motion.  

Table 7.3: Average performance per coach 2019 by size class 

Average performance per coach 2019 by size class 

Small/medium 

Large 

Passenger occupancy on average per coach  

Number of deployment days per coach 

Number of operating hours per coach  

Number of kilometres per coach  

- 
- 

of which kilometres in the Netherlands 

of which kilometres abroad 

Number of kilometres per day of deployment 

Number of kilometres per operating hour 

36 

71 

486 

17 011 

14 521 

2 490 

246 

31 

43 

91 

689 

26 933 

17 414 

5 551 

295 

32 

Source:  Kerncijfers  2019  van  het  Nederlandse  touringcarvervoer  (Panteia,  2021),  authors’  own 
calculations  

The labour shortages that are affecting the entire transport sector can also hit a smaller 
company harder compared to a larger one; if a few buses are unable to move due to lack 
of drivers, a greater percentage of the fixed capital is unused for a company with fewer 
coaches and drivers.  

Because  larger  companies  as  a  rule  only  conduct  a  smaller  percentage  of  their  overall 
activities in the occasional transport sector, their views on the driving and rest time rules 
tend  to  be  very  different  from  the  smaller,  primarily  occasional  service  provides.  One 
company  which  only  does  5%  occasional  services  (and  the  remaining  95%  in  public 
transport) stated that their primary concern was about possible spill over effects into their 
regular services. For instance, during railroad maintenance or a train accident it is common 
that the temporarily unavailable line is replaced by a bus for a specific period of time. The 
company in question usually would provide buses to make up for the train route, and this 
activity is counted as an occasional transport service. The company would argue that the 
nature of this service is regularly scheduled for a limited time and should be regulated the 
same way as their other public transport services, but this is not the case. This route would 
be covered by the 561/2006 regulation on driving and rest time rules, provided that the 
distance is longer than 50 km, and can have strange impacts on when a driver needs to 
take a break and how much of that break is actually counted as a break, for instance.  

Similar issues can arise on regularly scheduled traffic that traffics routes that are longer 
than 50km. These are more common in rural areas, where routes can often be longer and 
bus stops are spaced out with greater distance. Driving one route over 50km requires the 
driver to conform to the EU legislation during the entire day, which has implications for the 
use of tachographs on any other routes that the driver is trafficking during the day.   

In summary, the evidence points to the conclusion that large companies face relatively 
fewer issues with the current legislation when compared to smaller competitors. 
This has to do with the ability to deploy more drivers to work within the framework of the 
rules, causing fewer issues with compliance.  

This is not to say that larger companies can experience the rules as troublesome in similar 
ways, but only that their financial performance would be impacted less significantly from 
changing  the  rules.  Precise  financial  impacts  are  difficult  to  predict  for  any  part  of  the 

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market, but most of the evidence suggests that the financial impact on larger companies 
would be lower than for smaller companies, as elaborated on in the next section.  

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7.2.5 

Expected impacts of the policy options on the market segment 

Due to the nature of larger companies, which often rely to a greater extent on providing 
regularly  scheduled  services,  the  economic  impacts  for  large  companies  would  be 
more  limited  compared  to  the  impact  on  smaller  companies.  Break  times  are 
expected to make scheduling somewhat easier for companies, but not necessarily affect 
the total revenue much. Therefore, any changes to break times is expected to have similar 
impacts  on  larger  companies  compared  to  any  smaller  companies,  which  is  to  say  that 
across the entire sector, economic impacts due to changes in the break time rules 
would be marginal.  

While certain changes to the 12-day derogation or the rest period rules are expected 
to  have  economic  benefits  for  smaller  companies,  it  is  expected  that  larger  companies 
would likely see impacts of a similar nature, but less prominent. One of the issues is that 
the  rest  periods  create  downtime  for  each  coach,  which  is,  according  to  data  from  the 
Netherlands, less of an issue for the larger companies compared to the smaller ones. In an 
interview with a large company in Spain, the respondent was positive towards all changes 
to the rules98 except for the removal of the obligation to have two weekly rest periods after 
a  trip  under  the  12-day  derogation.  All  other  companies  were  in  favour  of  this  change, 
which indicates that they have an easier time coping with this rule as a result of having 
more employees and more coaches. This pattern can be further seen in the results of the 
public consultation, where most companies were in favour of this rule change, but where 
two of the four large companies were not. Because there are very few large companies in 
the  sector,  the  data  reliability  is  fine  enough  to  draw  conclusions,  but  the  sum  of  the 
evidence  provided  from  interviews,  the  public  consultation  and  the  data  from  the 
Netherlands points in the same direction, which is that larger companies have an easier 
time coping with the current rest time rules.  

Figure 7.6: Responses to rest period policy option 3, by size class 

Micro (1 to 9 employees)

Small (10 to 49 employees)

Medium (50 to 249 employees)

20

14

34

4

3

2

Large (250 or more)

2

2

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Yes

No

Source: public consultation, October 2021 – February 2022.  
Base: 83 respondents.  

98 The proposed policy options were flexible distribution of breaks, extension of 12-day derogation 
to apply nationally, removal of single service condition for the 12-day rule, removal of the condition 
to have two weekly rest periods after the 12-day derogation, and extension of the duty cycle. 

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Overall, large companies were more sceptical about rule changes overall compared 
to  their  smaller  counterparts,  shown  in  Figure  7.7,  which  again  indicates  that  they  are 
under less pressure from the current legislation. The larger companies consistently are less 
in  favour  of  changing  the  rules,  with  the  notable  exception  of  extending  the  12-day 
derogation nationally, which all responding large companies agreed with, despite some of 
them  having  reservations  about  the  other  policy  options.  The  increased  flexibility  in 
arranging  weekly  rest  periods  was  also  favoured  by  a  majority.  However,  the  possible 
conclusions that can be drawn from this fact should not be overstated. Firstly, while the 
coverage of micro, small and medium-sized  companies is adequate, there are few large 
companies  in  the  sample,  partly  due  to  the  lack  of  large  companies  in  the  occasional 
transport  services  sector.  Secondly,  the  lower  enthusiasm  for  rule  changes  for  large 
companies can be the result of either of two important factors. The first possible factor is 
that they, as a rule, earn most of their revenue in the regular services, and therefore have 
less of a financial motivation to demand rule changes. The second possibility is that they 
already  cope  with  the  rules  better  than  their  smaller  industry  partners.  Beyond  the  fact 
that this could mean that they simply have less of an incentive to change the rules, it could 
also  point  to  the  fact  that  they  have  a  competitive  advantage  over  smaller  companies, 
since they are able to absorb more clients, and have higher turnover per coach, compared 
again to their smaller competitors. The data is not substantial enough to prove which factor 
is the most important one in this respect, but it is the best data that is available for such 
analyses.  

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Figure 7.7: Agreement of small vs large companies towards rest time changes 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Rest period change 1. Allow bus and coach drivers in 
domestic occasional carriage of passengers to use the 
“12-day derogation”. 

Rest period change 2. Allow bus and coach drivers to
deviate from a single service condition

Rest period change 3. Remove the obligation of taking 
two regular weekly rest periods after using the “12-day 
derogation”. 

Rest period change 4. Allow bus and coach drivers on
trips lasting 8 days and longer to postpone the start of
the daily rest period by 1 h, provided that the total daily
driving time on that day does not exceed 7 hours.

4, 100%

75, 95%

2, 50%

2, 50%

63, 80%

68, 86%

2, 50%

55, 70%

Rest period change 5. Allow bus and coach drivers on
trips lasting 8 days and longer to postpone the start of
the daily rest period by 2 h, provided that the total daily
driving time that day does not exceed 5 hours.

1, 25%

Rest period change 6. On trips lasting 8 days and longer
to distribute their weekly rest periods in such a way that
the average weekly rest is at least 45h over the period of
10 consecutive weeks (with a minimum weekly rest
remaining 24h)

55, 70%

3, 75%

60, 76%

Large (250 or more) (n=4)

Micro, Small and Medium companies (0-249 employees) (n=79)

Source: public consultation, October 2021 – February 2022.  
Base: 83 respondents 

Looking to social impacts, any impacts of either worsened or improved working conditions 
would affect drivers in large companies similarly to those employed in smaller companies. 
However, it seems at least possible that larger companies have an easier time scheduling 
and  working  within  the  framework  of  the  regulation  to  keep  coaches  moving,  which 
indicates that there is less pressure on an employee in large company to shorten rest times 
or skip breaks. This pressure is argued by industry representatives to cause stress and can 
endanger  both  driver  and  passengers,  as  well  as  risking  fines  for  both  drivers  and 
companies.  

In  terms  of  the  preferred  policy  options  for  the  future,  there  unfortunately  is  not 
enough evidence to point to clear conclusions on which options would be preferred by the 
large  operators.  According  to  the  public  consultation,  the  expansion  of  the  12-day 
derogation for use nationally was the only one that had unanimous support and was also 

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supported  by  the  interviewed  organisations.  This  would  enable  organisations  to  offer  a 
wider range of services and is expected to have positive impacts on the financial situation 
for any size operator. For the other policy options, the evidence is too thin to make clear 
statements on which policy options would be preferred.  

The table below presents a summary of the expected impacts, with a focus on comparing 
large operators to providers of occasional services as a whole. 

Table 7.4: Summary of impacts on the market segment compared to occasional 
bus and coach sector as a whole 

Economic impacts 

Social impacts 

Environmental impacts 

Break times 

Rest periods 

Similar impacts to the rest 
of the occasional bus and 
coach sector. The 
economic impacts of 
changed break times is 
estimated to be marginal, 
which is the case for large 
companies as well. 

More limited impacts than 
for the smaller companies 
in the sector. Domestic 
use of the 12-day 
derogation would be 
economically beneficial to 
large companies as well, 
but have a less important 
increase of overall 
revenue, as they are often 
quite involved in regular 
services. 

Similar impact as for the 
rest of the sector.  

Similar impact as for the 
rest of the sector.  

Similar impact as for the 
rest of the sector.  

Similar impact as for the 
rest of the sector.  

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7.3  Case study 3 – Medium-sized bus and coach operators 

7.3.1 

Case study summary and conclusions 

The subject of this case study is medium-sized bus operators providing occasional transport 
services in north-western Europe, with a focus on Germany and the Netherlands.  

Medium-sized companies in the sector still constitute a minority compared to the amount 
of micro and small enterprises established in the market. Nonetheless, occasional transport 
constitutes  an  important  share  of  the  overall  turnover  of  medium-sized  companies. 
Although  they  perform  a  wide  variety  of  services,  occasional  transport  makes  up  for  at 
least 50% of their yearly turnover. 

Due  to  their  reliance  on  occasional  services  –  hence  on  tourism,  COVID-19  has  had  a 
significant impact on medium-sized bus operators, which, in the Netherlands, went from 
representing  a  share  of  8%  of  the  market  to  only  4%.  Similar  trends  can  be  noticed  in 
Germany. 

Overall, medium-sized bus operators in north-western Europe, including Germany and the 
Netherlands, are mainly faced with challenges that related to the 12-day derogation and 
the organisation of breaks during the trip. The main criticism levelled against the 12-day 
derogation by medium-sized bus operators is that relatively few companies can make use 
of it as it only applies to international services. Furthermore, in its current formulation, the 
12-day derogation has a negative impact  on the number of trips a driver can carry out, 
indirectly benefiting companies with a larger pool of drivers. For what concerns the rules 
on  breaks,  medium-sized  operators  seemed  to  agree  that  a  change  is  needed  in  the 
direction of more flexibility since, under current circumstances, bus drivers find it hard to 
provide services that are in line with customer needs.  

Whereas none of the proposed fully fledged policy options seem completely satisfactory to 
stakeholders  from  the  countries  under  analysis,  there  are  a  couple  of  measures  that 
medium-sized bus operators would particularly favour: 1) the possibility to split the break 
of  minimum  45  minutes  into  30  +  15  or  15  +  15  +  15  minutes,  as  it  would  improve 
significantly the ability to organise services efficiently and in line with customer needs; 2) 
the possibility for bus drivers engaged in domestic services to postpone their weekly rest 
period for up to 12 consecutive periods of 24h, following a regular weekly rest, as it would 
guarantee  a  level  playing  field  between  actors  in  the  sector  (especially  between  bus 
operators providing either international or domestic transport services) regardless of their 
size. 

7.3.2 

Introduction 

This  case  study  focuses  on  medium-sized  operators  based  in  north-western  EU  Member 
States (such as Germany and the Netherlands) that – among others – provide occasional 
services. The aim is to shed light on how this specific market segment is affected by the 
current legislation on driving times, breaks and rest periods of occasional road transport 
workers (as well as by the COVID-19 pandemic). Medium-sized bus operators might, for 
instance,  have  more  difficulties  than  large  companies  to  provide  a  continuous  service 
during peak season (i.e., May-September in most  cases) in light of current rules, which 
requires bus drivers to operate in between a set of mandatory rest periods. Also, medium-
sized companies could have more difficulties than large companies to access public funding 
or cost-covering services framed by public services obligations. In  turn, size could affect 
companies’ resilience in the face of the impacts of the COVID crisis. 

The make-up of the occasional bus and coach market adds relevance to this case study. 
In  fact,  according  to  a  recent  survey  from  the  European  Transport  Workers  Association 

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(ETF)99,  the  largest  share  of  drivers  in  the  sector  works  for  small  companies  (10  to  50 
employees),  while  a  similar  number  works  for  a  medium-sized  company  employing 
between 51 to 100 drivers (28.7%) 

Being the most relevant source of comprehensive data on the structure and activities of 
the market segment, this case study mainly draws on sectorial statistics coming from the 
Dutch  umbrella  organisation  for  professional  passenger  transport  “KNV”  (Koninklijk 
Nederlands Vervoer – Royal Dutch Transport). However, the case study only relies on the 
Federal  Statistical  Office  of  Germany100,  and  the  significant  insights  that  were  collected 
through interviews in the Member States under analysis in this case study (i.e., Germany 
and  the  Netherlands).  Additional  relevant  feedback  has  been  collected  from  the  public 
consultation. 

Interviewees  from  the  above-mentioned  countries  are  bus  operators  providing  the 
following range of services: multi day trips, single day excursions, ad hoc services (both 
domestic and international). 

7.3.3 

Context 

The best way to infer the general characteristics of the market segment under review is by 
looking  at  the  comprehensive  2020  national  database  on  the  Dutch  bus  and  coach 
passenger transport sector (KNV statistiek van het Nederlandse touringcarondernemingen) 
as well as at the outcome of the public consultation launched between October 2021 and 
February 2022. Due to the lacking data on drivers employed by the businesses in the sector 
at  company  level  within  the  national  Dutch  database,  the  best  way  to  categorise  small, 
medium and large companies is by looking at the fleet size of companies. The fleet size is 
in turn a good proxy for the number of employees/bus drivers in each business. This case 
study  will  consider  medium-sized  companies  those  companies  that,  within  the  Dutch 
national database, have declared a number of coaches comprised between 30 and 69101.  

The table below shows the main source of income for middle-sized companies. 

Table 7.5: Share of turnover by type of service, by company class (2021) 

Type of service 

Small companies 

Medium companies 

Average turnover from regular services 
(school/company transport) 
Average turnover public scheduled 
services 

Average turnover day trips* 

Average turnover multi-day trips* 
Average turnover shuttle and 
international scheduled services* 

Total 

32% 

28% 

27% 
8% 
5% 

14% 

19% 

48% 

11% 

9% 

Large 
companies 

11% 

49% 

19% 
9% 
13% 

100% 

100% 

100% 

*Occasional transport service 
Source: KNV statistiek van touringcarondernemingen 

The Dutch data tell us that occasional transport services constitute a much larger share of 
turnover for medium-sized enterprises (68%) than for the rest of company classes. This, 

99  ETF  Report,  2018,  Driven  to  distraction?  Long-distance  coach  and  bus  drivers  in  the  EU, 
https://www.etf-europe.org/wp-content/uploads/2018/09/ETF-report-on-woking-conditions-of-bus-
and-coach-1.pdf.  
100 Homepage - German Federal Statistical Office (destatis.de) 
101 According to IRU’s officials, the number of employees in bus companies is approximately 1.7 times 
higher than the number of coaches. Therefore, this case study will look at those companies with a 
number of staff comprised between 51 and ca. 100 employees. 

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however,  does  not  mirror  the  outcome  of  the  public  consultation  launched  between 
November 2021 and February 2022. As showed in Figure 1.1,  medium-sized  companies 
were the second smallest group after large companies in terms of turnover generated by 
occasional services. The differences between the two datasets could derive from the fact 
that  the  first  one  is  strictly  connected  with  the  specificity  of  transport  provision  in  the 
Netherlands.  

Nonetheless, it could be concluded that occasional transport services are a significant 
source of income for medium-sized companies, which generally range between half 
and two thirds of their total yearly turnover.  

Figure 7.8: Percentage of turnover in 2019 related to occasional bus and coach 
services (%) by size class 

83%

60%

48%

31%

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

Large (250 or more)

Medium (50 to 249
employees)

Small (10 to 49
employees)

Micro (1 to 9 employees)

Source: Public consultation, October 2021 – February 2022.  
Base: 83 respondents 

Dutch data and the public consultation’s findings, instead, seem to agree on the fact that 
medium-sized bus operators are mainly involved in domestic trips, however there is 
still a significant share of these companies involved in international operations. 

According to key figures of occasional coach transport in the Netherlands102, both in 2019 
and 2020 the overwhelming majority of companies belonged to the category of micro and 
small  enterprises.  Medium-sized  companies  represented  a  remaining  share  of  4-
8%. Largely due to the COVID-19 pandemic and its  impacts on tourism, between 2019 
and 2020 the number of medium-sized bus operators decreased by 44% (Figure 7.9). 

102  Available  at:  Kerncijfers  van  het  touringcarvervoer  van  Nederlandse  touringcarondernemingen 
2020.pdf (panteia.nl)  

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Figure 7.9: Dutch companies by company size, 2019 vs 2020 

Source: Kerncijfers 2020 van het Nederlandse touringcarvervoer (Panteia, 2021) 

The year 2020 was (unsurprisingly) exceptionally bad for the occasional coach sector; as 
a  result  of  the  COVID-19  pandemic  restrictions,  Dutch  coach  companies  generated  only 
3.7  billion  passenger/kilometres  (-63%  compared  to  2019),  of  which  3.3  within  the 
Netherlands (-56%) and 0.4 abroad (-84%). This was, naturally, accompanied by of a drop 
in numbers of companies and employees in the sector. The table below shows a comparison 
of data of the industry between 2019 and 2020.  

Table  7.6:  Dutch  occasional  coach  transport  industry's  performance,  2019  vs 
2020 

2019 

2020 

Difference 
(%) 

Number of companies 

302 

Passenger/kilometres 
(billion) 

9.9 

260 

3.7 

-14% 

-63% 

Number of coaches 

3,827 

3,544 

-7% 

Driven  kilometres  by 
coach 

70,519 

28,792 

-59% 

Number of drivers 

5,592 

3,859 

-31% 

Source: Kerncijfers 2020 van het Nederlandse touringcarvervoer (Panteia, 2021) 

The sectorial trend in Germany is similar. The number of passengers carried by occasional 
road services in the country decreased by 77% between 2019 and 2020103. National data 
on occasional long-distance transport by bus confirm the overall challenges faced by the 
sector within the same timeframe. Whereas in 2019 the distance covered by coaches was 
of ca. 543 million kilometres (of which 45% covered beyond Germany’s national borders), 
in  2020  it  dropped  to  ca.  101  million  kilometres  (of  which  30%  abroad)104.  Similarly, 
between 2019 and 2020 the number of available seats/kilometres dropped by 82% - likely 
due to both the reduced activity in the sector and the necessity to keep a safe distance 
between passengers. Then, still according to national statistics, the number of companies 
in the occasional road transport sector decreased by 13%105. In a recent publication, the 

103 Passenger transport - German Federal Statistical Office (destatis.de)  
104 Federal Statistical Office Germany - GENESIS-Online: Result 46181-0002 (destatis.de)  
105 Statistisches Bundesamt Deutschland - GENESIS-Online: Ergebnis 46181-0010 (destatis.de)  

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Federal Association of German Bus Operators (BDO)106 estimated that, in 2021, a smaller 
but still significant share of large (55%), medium (59%) and small-sized (59%) companies 
in  the  occasional  transport  sector  will  have  faced  a  similar  unfavourable  financial 
situation107.  Similarly,  dissatisfaction  in  terms  of  sales  development  was  expected  to 
increase  with  decreasing  company  size:  61%  and  59%  of  small  and  medium  sized 
companies assessed the sales development as less favourable compared to the previous 
year, versus 57% of large companies108.  

7.3.4 

Problems associated with existing legislation 

Most of the evidence on issues faced by the medium-sized market segment came from the 
targeted interviews and public consultation. Whereas there is a general agreement among 
stakeholders that current rules (which cover all road transport services) do not take into 
account the specificities of the occasional sub-sector, operators from companies with less 
than 250 employees felt that they faced bigger challenges. These related to various aspects 
of the rules, as explained in the next paragraphs. 

According to medium-sized bus  operators involved in  our rounds  of  consultation, one of 
the main challenges they face currently relates to the 12-day derogation provision109. 
More  specifically,  bus  operators  seemed  to  agree  that  there  are  relatively  few 
companies  that  can  make  use  of  it  as  it  only  applies  to  international  services. 
According to current rules, bus drivers in domestic trips need to take a weekly rest period 
(45h) after six days of driving. Once again, this hampers the organisation of services able 
to meet  customers’  expectations in terms of quality. In  fact, whereas a larger company 
would be able to send another driver in order to ensure the continuity of service provision, 
medium-sized  companies  –  especially  during  peak  season  –  often  lack  this  possibility. 
Additionally, as clearly stated by medium-sized operators in the public consultation, this 
distorts the competitiveness advantages of international transport service providers over 
national transport service providers. 

Another  issue  mentioned  by  medium-sized  bus  operators,  still  related  to  the  12-day 
derogation,  was  that  for  companies  operating  (mostly)  internationally  (and  thus  having 
access to the derogation) the rule can only be applied if the driver precedes the service 
with  a  rest  of  at  least  45  hours  and  follows  it  with  an  extended  rest  of  69  or  90  hours. 
Especially during peak  season, this has a  negative  impact on the  number  of trips a 
driver can carry out in a given period (thus on his productivity). In turn, trip planning is 
reportedly  hampered  by  the  lack  of  continuity  in  bus  drivers’  workflow.  Furthermore, 
compared to large size companies, medium-sized ones are less able to allocate resources 
according to scheduling needs because of their limited pool of drivers. 

Medium-sized  bus  operators  therefore  face  a  competitiveness  issue:  under  the  current 
rules, a larger pool of drivers increases the possibility to offer a higher number of services 

106  BDO  (Der  Bundesverband  Deutscher  Omnibusunternehmen)  is  the  leading  association  of  the 
German  bus industry  and represents  the  interests of  private  and  medium-sized  companies  in  the 
field of local public transport, bus tourism and long-distance buses. 
107  Konjunkturumfrage  2021/2022.  Available  at:  broschüre-konjunktur2022-web_lay-05.indd 
(bdo.org)  
108 Ibid. 
109 Article 8 of Regulation (EC) 561/2006 reads that within each period of 24h after the end of the 
previous daily rest period or weekly rest period, a driver shall have taken a new daily rest period. 
Furthermore,  in  any  two  consecutive  weeks  a  driver  shall  take  at  least  two  regular  weekly  rest 
periods; or one  regular weekly rest period and one  reduced weekly rest period of at least 24h. A 
weekly rest period shall start no later than at the end of six-24h periods from the end of the previous 
weekly rest period. However, by way of derogation, a driver engaged in a single occasional service 
of international carriage of passengers may postpone the weekly rest period for up to 12 consecutives 
24h periods following a previous regular weekly rest period. 

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Study on a possible revision of the break time and rest period rules for bus and coach drivers 

and  in  turn  to  better  orient  their  services  towards  customers’  needs.  This  was  also 
confirmed by the public consultation, as shown in the figure below. 

Figure  7.10:  "Do  you  think  the  driving,  break  and  rest  rules  contribute  to  fair 
competition  between  domestic  and  international  services?  When  providing 
responses, please consider your answer in terms of the following aspect, namely 
the “12-day derogation”  (Article 8(6a) of Regulation 561/2006), which applies 
only to transport crossing international borders as part of a single trip, meaning 
occasional services taking place within one country cannot use the derogation” – 
Medium-sized companies 

Source: Public consultation, October 2021 – February 2022.  
Base: 16 respondents 

Another  minor  issue  identified  by  stakeholders  –  which  also  emerged  in  the  public 
consultation  –  related  to  the  organisation  of  breaks  during  the  trip.  Medium-sized 
operators seemed to agree that a change is needed in the direction of more flexibility since, 
under current circumstances, bus drivers find it hard to provide services that are in line 
with customer needs. Furthermore, bus drivers’ working conditions would benefit too from 
an enhanced flexibility of break rules. Indeed, while truck drivers drive continuous hours 
in less urban environments, coach drivers have additional stress deriving from the need to 
accommodate  both  the  requirements  of  their  employers  and  passengers  who  demand 
customised journeys, besides the need to cope with uncertain driving conditions. 

7.3.5 

Expected impacts of the policy options on the market segment 

In terms of potential impacts of the policy options on the market segment under review, it 
must be noted that the nature of the impacts themselves would be similar across market 
segments. However, since the scale of the problems is bigger for medium-sized companies 
than for larger ones, the expected impacts would also be relatively more important.  

Nonetheless,  stakeholders  were  asked  throughout  the  public  consultation  to  assess  and 
evaluate the likely impacts of the single policy options’ measures. It follows that, in terms 
of  proposed  break  changes,  respondents  giving  their  contribution  as  medium-sized 
companies  seemed  to  favour  more  the  possibility  to  split  the  break  of  minimum  45 
minutes into 30 + 15 or 15 + 15 + 15 minutes (i.e., Policy Measure 1). This outcome 
was also mirrored in most of the interviews carried out with medium size companies, as 
they  supported  the  break  split  for  it  would  improve  significantly  the  ability  to 
organise  services efficiently  and  in  line  with customer  needs. According to them, 

137 

 
 
 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

this  break  change  would  also  benefit  drivers  working  conditions.  On  the  other  side, 
medium-sized  companies  seem  to  favour  less  a  change  that  would  allow  bus  drivers  to 
arrange and split their break in a fully open manner over the period of 4h30 driving time, 
as “no one would really benefit from a 5-minute break”110. 

Finally, from the perspective of medium-sized operators, this measure would also be able 
to  address  a  decisive  question  in  the  occasional  transport  of  passengers,  namely  that 
passengers’ wishes are taken into consideration. This would help restore the credibility of 
a sector which has suffered more than others from the COVID-19 movement restrictions. 
Furthermore, they would help strengthen small and medium operators’ business model by 
increasing their competitiveness and overcoming the compelling issue of labour shortage. 

In terms of rest period changes, medium-sized operators looked mostly favourably at the 
possibilityfor bus drivers engaged in domestic services to postpone their weekly 
rest period for up to 12 consecutive periods of 24h, following a regular weekly rest 
(i.e., Policy Measure 5). According to interviewees, this measure would in fact guarantee 
a  level  playing  field  between  actors  in  the  sector  (especially  between  bus  operators 
providing either international or domestic transport services) regardless of their size – i.e., 
regardless  of  the  pool  of  bus  drivers  at  their  disposal.  To  a  larger  extent,  this  measure 
would have positive effects on those companies operating in larger Member States (e.g., 
Germany) where long domestic trips are not the exception. Measures 6 and 7 would also 
ensure  a  desirable  level  of  flexibility  to  bus  operators.  For  instance,  the  removal  of  the 
single-service  condition  would  allow  bus  operators  to  schedule  more  trips  and  help 
companies with a limited pool of drivers (small and medium bus operators) to allocate their 
resources more efficiently. Similarly, the derogation to the extra compensatory rest after 
using  the  12-day  rule  would  allow  drivers  to  carry  out  consecutive  services  hence  the 
company to schedule more trips during high season. 

The  use  of  the  12-day  derogation  at  national  level  was  also  the  most  supported  single 
measure  by  medium-sized  companies  in  terms  of  rest  period  changes.  Although  a 
significant  majority  of  respondents  favoured  each  change  proposed,  the  entire  set  of 
respondents was in favour of this (see Figure 7.11) 

110 Reporting directly one stakeholder’s opinion. 

138 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Figure 7.11: Preferences of medium-sized companies across rest period changes 

Rest period change 1. Allow bus and coach drivers in 
domestic occasional carriage of passengers to use the 
“12-day derogation”. 

0, 0%

Rest period change 2. Allow bus and coach drivers to 
deviate from a single service condition (“single trip”) in 
domestic and international occasional carriage of 
passengers.

1, 6%

17, 100%

16, 94%

Rest period change 3. Remove the obligation of taking 
two regular weekly rest periods after using the “12-day 
derogation”. 

3, 18%

14, 82%

Rest period change 4. Allow bus and coach drivers on
trips lasting 8 days and longer to postpone the start of
the daily rest period by 1 h, provided that the total daily
driving time on that day does not exceed 7 hours.

5, 29%

12, 71%

Rest period change 5. Allow bus and coach drivers on
trips lasting 8 days and longer to postpone the start of
the daily rest period by 2 h, provided that the total daily
driving time that day does not exceed 5 hours.

3, 18%

Rest period change 6. Allow bus and coach drivers on
trips lasting 8 days and longer to distribute their weekly
rest periods in such a way that the average weekly rest
is at least 45h over the period of 10 consecutive weeks,
where the minimum duration of w

1, 6%

14, 82%

16, 94%

0%

20%

40%

60%

80%

100%

120%

No

Yes

Source: Public consultation, October 2021 – February 2022.  
Base: 17 respondents 

Table 7.7: Summary of impacts on the market segment compared to occasional 
bus and coach sector as a whole 

Economic impacts 

Social impacts 

Environmental impacts 

Break times 

Larger positive impacts due to 
the more flexible breaks would 
help strengthen medium 
operators’ business model by 
increasing their competitiveness 
and overcoming the compelling 
issue of labour shortage 

Similar impacts as for 
the rest of the sector 

Similar impacts as for the 
rest of the sector 

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Study on a possible revision of the break time and rest period rules for bus and coach drivers 

Rest periods 

Larger positive impact as they 
would guarantee a level playing 
field between actors in the sector 
regardless of their size. Rest 
period changes would have 
positive effects especially on 
those medium-sized companies 
operating in larger Member 
States (e.g., Germany) where 
long domestic trips are not the 
exception 

Similar impacts as for 
the rest of the sector 

Similar impacts as for the 
rest of the sector 

140 

 
 
 
Study on a possible revision of the break time and rest period rules for bus and coach drivers 

8. Impacts on stakeholders of the preferred 

option 

Summary of the preferred policy implementation  

The  preferred  option  (policy  option  1)  entails  adjustments  to  the  break  times  and  rest 
period rules that would apply only to drivers in the occasional transport of passengers by 
bus and coach. While these rules would differ from the ones that are currently applicable, 
they would not involve changes to the nature of the rules. More specifically, drivers would 
still be subject to requirements in terms of the amount of break time for every 4.5 hours 
of driving, a maximum length of the duty cycle before a daily rest period must be taken, 
and the timing and length of weekly rest periods. The amount of total driving time per day 
would  remain  unchanged,  as  would  the  arrangements  for  operators  and  drivers  to 
demonstrate compliance with the rules. For this reason, the implementation modalities for 
the preferred option would be essentially the same as for the current rules. As such, no 
changes to administrative burdens are foreseen, except for one-off implementation costs 
for operators, drivers and enforcement authorities to familiarise themselves with the new 
rules.  

Summary  of  costs  and  benefits  for  consumers,  market  actors  and  public 
authorities  

The  preferred  option  would  have  implications  for  four  types  of  actors  involved  in  the 
production and use of occasional transport services by bus and coach, namely consumers, 
occasional  bus  and  coach  operators,  drivers  and  public  authorities.  These  are  briefly 
outlined below, followed by summaries in table format.  

•  Consumers: since it is envisaged that the rules would make it easier for operators 
to arrange services in a high-quality and efficient way, consumers are expected to 
experience benefits in the form of a better and / or cheaper service offering. 

•  Occasional bus and coach operators: policy option 1 entails minor adjustments to 
the  rules,  that  require  bus  and  coach  operators  in  the  sector  to  familiarise 
themselves  with  the  changes.  These  entail  one-off  adjustment  costs  for  bus  and 
coach  operators  in  2025  (when  the  new  rules  are  expected  to  be  in  force).  The 
workload  required  to  familiarise  with  the  new  rules  is  estimated  at  4  hours  per 
company. The average cost per hour at EU level is estimated at EUR 24.9 in 2021 
prices  and  it  is  assumed  to  remain  constant  over  time.  The  total  number  of 
occasional bus and coach companies in 2025 is estimated at 6,032. Thus, the one-
off adjustment costs for transport operators in the occasional bus and coach sector 
in 2025 are  estimated  at EUR 0.6 million relative to the baseline. This should be 
regarded  as  an  upper-bound  estimate,  as  it  is  likely  that  any  familiarisation  with 
the new rules would take place in the context of the regular activities performed by 
the bus and coach operators. 

• 

In addition, the rules for operators would be less restrictive than is currently the 
case,  meaning  that  they  would  face  reduced  operational  costs  and  an  improved 
regulatory  environment  for  arranging  occasional  bus  and  coach  services.  The 
savings are estimated at between EUR 106.4 to 141.9 million for the occasional bus 
and coach sub-sector as a whole. It is assumed that this will have a greater effect 
in the first two years of implementation of the measures, then gradually taper off 
over time. These savings would be expected to have knock-on effects in terms of 
increased service volumes and revenues. The preferred option is also expected to 
facilitate  compliance,  which  would  reduce  infringements  and  fines  for  operators, 
albeit only to a small extent.  

141 

 
 
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•  Drivers:  the  social  impacts  of  policy  option  1  would  affect  drivers  directly.  These 
were  found  to  be  net-positive,  with  improvements  in  terms  of  autonomy  and  an 
ability to take daily and weekly rests at convenient times outweighing the longer 
working  days  and  weeks  that  would  occur  in  some  circumstances  (e.g.  from 
increased  usage  of  the  12-day  rule).  The  adjusted  rules  would  also  facilitate 
compliance. Along with the lighter administrative requirements, this would lead to 
minor reductions in drivers’ levels of stress and fatigue, which would also improve 
road safety. Drivers (especially those who are self-employed) would be expected to 
experience  economic  benefits,  because  they  would  be  able  to  take  on  a  greater 
workload  –  and  thus  earn  additional  wages  –  during  peak  seasons.  Since  the 
preferred option is also expected to improve the economic outlook for the occasional 
bus  and  coach  sector  to  a  limited  extent,  this  would  also  increase  demand  for 
drivers, and thereby contribute to employment possibilities and wages.  

•  Public authorities: policy option 1 would not be expected to change reporting and 
enforcement  modalities,  but  minor  improvements  in  compliance  with  the  rules 
among occasional bus and coach operators would reduce enforcement burdens on 
public authorities to a limited extent. One-off costs for familiarisation and training 
are also expected in the first year of implementation (2025). The time required per 
enforcement officer to familiarise with the new rules and implement those in their 
planning  is  estimated  at  4  hours,  with  the  total  number  of  enforcement  officers 
involved in checks estimated at 54,679111 at EU level. In this regard, the one-off 
adjustment costs for Member States authorities in 2025 are estimated at EUR 5.4 
million  in  the  EU-27  relative  to  the  baseline  (in  2021  prices),  considering  the 
average cost per hour of EUR 24.9 at EU level.  

I. Overview of Benefits (total for all provisions) – Policy option 1 

Description 

Amount 

Comments 

Direct benefits 

Reduced  compliance  costs 
for occasional bus and coach 
operators 

Total  operational  cost  savings  of 
EUR 106.4  to  141.9  million  in  2025-
2050, expressed in present value 

Increased  remuneration  at 
peak  seasons  for  occasional 
bus and coach drivers 

While the evidence made the nature of 
these benefits clear, it did not allow for 
quantification. 

Policy  option  1  would  reduce  the  need  for  stops  and 
other  changes  to  occasional  itineraries  solely  for  the 
purpose of complying the rules, as well as increasing 
the proportion of itineraries that could be staffed with 
a single driver (rather than two drivers). The adjusted 
rules would also facilitate compliance, reducing  costs 
of fines for infringements. The result would be reduced 
costs to a certain extent, especially SMEs, who are less 
well-equipped  than  larger  companies  to  handle  the 
current rules.  

By increasing the proportion of trips to which the 12-
day  rule  could  be  applied,  drivers  (especially  those 
who are self-employed) would be able to increase their 
workload  during  peak  season  and  thereby  carry  out 
more remunerated work. 

Reduced  enforcement  costs 
for public authorities  

While the evidence made the nature of 
these benefits clear, it did not allow for 
quantification. 

Improved compliance in the occasional bus and coach 
sector would reduce costs for enforcement to a limited 
extent among public authorities.  

Indirect benefits 

Cheaper occasional  bus  and 
coach 
for 
consumers  

services 

While the evidence made the nature of 
these benefits clear, it did not allow for 
quantification. 

To a certain extent, reduced costs for operators would 
be  passed  onto  consumers  in  the  form  of  reduced 
prices for occasional services.  

Administrative cost savings related to the ‘one in, one out’ approach* 
The  preferred  option  does  not  entail  meaningful  changes  to  administrative  burdens  aside  from  minor  adjustment  costs, 
meaning that there are no ‘one-in, one-out’ implications.  

111  

Report  from  the  Commission  to  the  European  Parliament  and  the  Council  on  the 

implementation of Regulation (EC) No 561/2006 (forthcoming).  

142 

 
 
 
 
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II. Overview of costs – Policy option 1: Aside from one-off adjustment costs for businesses and administrations, no new 
costs are foreseen from the initiative. Types of costs with no implications are shaded grey. 

Citizens/Consumers 

Businesses 

Administrations 

One-off 

Recurr
ent 

One-off 

Recurrent 

One-off 

Recurrent 

Average costs of EUR 
100 per operator 
(i.e. 4 hours at an 
hourly wage of EUR 
24.90) to familiarise 
themselves with the 
rules and adapt 
compliance 
frameworks, making 
for a total of EUR 0.6 
million. 

Average cost EUR 100 
per officer, i.e. 4 hours 
of work at an average 
hourly wage of EUR 
24.90 for  
familiarisation with 
the rules and training, 
amounting to a total 
cost of EUR 5.4 million 
for 54,679 control 
officers involved in 
checks in the EU-27. 

Operation
al 
costs 
associated 
with 
implemen
tation  of 
rules 
the 
on  break 
times  and 
rest 
periods  in 
occasional 
bus 
and 
coach 
transport 

Direct 
adjustment costs 

Direct 
administrative 
costs 

Direct regulatory 
fees and charges 

Direct 
enforcement 
costs 

Indirect costs 

Costs related to the ‘one in, one out’ approach – the initiative has no ‘one-in, one-out’ implications 

Total   

Direct 
adjustment costs  

Indirect 
adjustment costs 

Administrative 
costs (for 
offsetting) 

For  occasional  bus 
and coach operators: 
in 
EUR  0.6  million 
2025, 
for 
familiarising with the 
rules. 
new 
Overcompensated by 
the adjustment costs 
savings 
the 
sector. 

for 

143 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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III. Overview of relevant Sustainable Development Goals – Policy option 1 

Relevant SDG 

Expected progress towards the Goal 

Comments 

SDG  no.  8  –  promoting 
growth, 
economic 
productive employment and 
decent work 

Minor  but  meaningful  contributions 
from  the  perspective  of  the  occasional 
bus and coach sub-sector  

Policy  option  1  is  expected  to  foster  the  economic 
development of the occasional bus and coach sector, 
which would in turn contribute to economic growth 
and  employment.  Moreover, 
improve 
working conditions for drivers in occasional bus and 
coach transport, contributing to decent work.   

it  would 

144 

 
 
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