COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Rules on breaks and rest periods rules in occasional bus and coach transport Accompanying the document Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EC) No 561/2006 as regards minimum requirements on minimum breaks and daily and weekly rest periods in the occasional passenger transport sector
Date: 2023-05-24
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: carriage of passengers, drivers, driving period, inland transport, international road transport, rest period, road safety, working conditions

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 24.5.2023  SWD(2023) 137 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  Rules on breaks and rest periods rules in occasional bus and coach transport Accompanying the document Proposal for a Regulation of the European Parliament and of the Council  amending Regulation (EC) No 561/2006 as regards minimum requirements on minimum breaks and daily and weekly rest periods in the occasional passenger transport sector     {COM(2023) 256 final} - {SEC(2023) 197 final} - {SWD(2023) 138 final}  
 
 
Table of contents 

1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ..................................... 1 

1.1.  Political context ................................................................................................. 1 
1.2.  Legal context ..................................................................................................... 3 
1.3.  Synergies with other EU policy instruments ..................................................... 5 
1.4.  Evaluation of the Regulation ............................................................................. 6 

2.  PROBLEM DEFINITION .......................................................................................... 7 

2.1.  What are the problems? ..................................................................................... 7 
2.1.1. Problem 1: Inability to organise efficient and high-quality occasional bus and 
coach services .................................................................................................... 7 
2.1.2. Problem 2: Inadequate working and driving conditions for drivers in occasional 
bus and coach transport ................................................................................... 12 
2.2.  What are the problem drivers? ........................................................................ 15 
2.2.1. Problem driver 1: Misalignment between the nature of occasional bus and coach 
services and the rules on break times and rest periods .................................... 15 
2.2.2. Problem driver 2: Unequal treatment between international and domestic bus 
and coach operations ....................................................................................... 15 
2.3.  How likely is the problem to persist? .............................................................. 17 

3.  WHY SHOULD THE EU ACT? .............................................................................. 17 

3.1.  Legal basis ....................................................................................................... 17 
3.2.  Subsidiarity: Necessity of EU action ............................................................... 17 
3.3.  Subsidiarity: Added value of EU action .......................................................... 18 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ..................................................... 18 

4.1.  General objectives ........................................................................................... 18 
4.2.  Specific objectives ........................................................................................... 19 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? .......................................... 19 

5.1.  What is the baseline from which options are assessed? .................................. 19 
5.2.  Description of the policy measures and policy options ................................... 21 
5.2.1. Policy Option A: Restricted adaptation to occasional passenger services ...... 23 
5.2.2. Policy  Option  B:  Semi-flexible  adaptation  to  occasional  transport  operations    

 ......................................................................................................................... 24 

5.2.3. Policy Option  C:  More flexible adaptation  to  occasional  transport operations    

 ......................................................................................................................... 25 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ................................. 26 

6.1.  Economic impacts ........................................................................................... 27 
6.1.1. Impact on bus and coach operators ................................................................. 27 
6.1.2. Impacts on small and medium enterprises (SMEs) ......................................... 30 
6.1.3. Impact on the functioning of the internal market and competition ................. 32 

I 

 
 
6.1.4. Impacts on compliance with the rules ............................................................. 33 
6.1.5. Impact on public authorities ............................................................................ 34 
6.2.  Social impacts .................................................................................................. 35 
6.2.1. Impacts on fundamental rights ........................................................................ 35 
6.2.2. Impacts on working conditions ....................................................................... 35 
6.2.3. Impacts on driver’s stress and fatigue, and road safety ................................... 38 
6.3.  Environmental impacts .................................................................................... 40 

7.  HOW DO THE OPTIONS COMPARE? .................................................................. 40 

7.1.  Effectiveness .................................................................................................... 40 
7.2.  Efficiency ........................................................................................................ 42 
7.3.  Coherence ........................................................................................................ 43 
7.4.  Subsidiarity and proportionality ...................................................................... 43 

8.  PREFERRED OPTION ............................................................................................. 44 

8.1. 
Identification of the preferred policy option and stakeholders views ............. 44 
8.2.  REFIT (simplification and improved efficiency) ............................................ 45 
8.3.  Application of the ‘one in, one out’ approach ................................................. 45 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? ....... 45 

ANNEX 1: PROCEDURAL INFORMATION ................................................................ 47 

ANNEX 2: STAKEHOLDER CONSULTATION ........................................................... 51 

ANNEX 3: WHO IS AFFECTED AND HOW? ............................................................... 58 

ANNEX 4: ANALYTICAL METHODS .......................................................................... 62 

ANNEX 5: EFFECTIVENESS OF THE DIFFERENT POLICY OPTIONS .................. 77 

II 

 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

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 

Confederation  of  Organisations  in  Road  Transport 
Enforcement  

COVID-19 

Coronavirus disease 2019 SARS-CoV-2 

CPC 

ECR 

ELA 

EPTO 

ETF 

ETSC 

EU 

Certificate of professional competence  

Euro Contrôle Route  

European Labour Authority 

European Passenger Transport Organisation 

European Transport Workers Federation  

European Transport Safety Council  

European Union 

EU-OSHA 

European Agency for Safety and Health at Work 

EWCS 

European Working Conditions Survey  

FeSMC-UGT 

FSC-CCOO 

Federación de Servicios, Movilidad y Consumo - Unión 
General de Trabajadores de España 

Federación de Servicios a la Ciudadanía  - Comisiones 
Obreras 

III 

 
 
GVA 

IA  

ISSG 

IRU 

ITF 

OECD 

PRM 

Gross Value Added 

Impact assessment 

Inter-service steering group 

International Road Transport Union 

International Transport Forum 

Organisation 
Development 

for  Economic  Co-operation 

and 

Persons with Reduced Mobility and other disabilities 

ROADPOL 

European Roads Policing Network  

SME 

SWOV 

TIS 

TUI 

Small and medium-sized enterprises 

Institute for Road Safety Research 

Consultores em Transportes Inovação e Sistemas, S.A. 

Touristik Union International 

UNECE 

United Nations Economic Commission for Europe 

IV 

 
1.  1. INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

1.1. 

1.1. 

Political context 

This  Impact  Assessment  accompanies  a  legislative  proposal  for  a  revision  of  Regulation  (EC)  No 
561/20061, which establishes rules on driving times, breaks and rest periods for professional drivers.  It 
focuses on the rules on the organisation of breaks and rest periods of drivers engaged in occasional services 
of carriage of passengers. 

The  objectives  of  Regulation  (EC)  No  561/2006,  as  amended  by  Regulation  (EU)  2020/10542,  are  to 
harmonise the conditions of competition between modes of inland transport, especially with regard to the 
road sector, and to improve working conditions and road safety3 for road transport operators in the passenger 
and freight transport sectors. The achievement of these policy objectives depends greatly on compliance 
with the EU rules by all actors in the transport operation chain, and in particular by drivers and operators. 

The occasional bus and coach sector4 represented 3.3% of the total number of passengers in the bus and 
coach sector in 2019 at EU level. It generated a total turnover of approximately EUR 6.3 billion in 20195, 
which  accounts  for  roughly  11% of the total turnover  of  road  passenger transport6.  It  employs  around 
202,6007 people, accounting for approximately 28%8 of the total number of persons employed in the road 
passenger sector. The number of companies operating in the occasional bus and coach sector is estimated 
at 6,0329. Occasional services are defined in point 4 of Article 2 of Regulation (EC) No 1073/2009, the 
main characteristic of which being the carriage of groups of passengers constituted on their own initiative 
or on the initiative of the carrier. These may be trips to carry out passengers to a ski resort and/or back, 
school  and  adult  excursions  of  one  single-day  or  multi-day  tours.  Most  passenger  transport  operators 
provide both single-day and multi-day trips’ services. 

The  legislation  in  force  applies  equally  to  the  road  transport  operators  and  their  drivers,  regardless  of 
whether they are involved in the carriage of passengers or goods or of whether, as regards the carriage of 

1 Regulation (EC) No 561/2006 of the European Parliament and of the Council of 15 March 2006 on the harmonisation 
of certain social legislation relating to road transport and amending Council Regulations (EEC) No 3821/85 and (EC) No 
2135/98 and repealing Council Regulation (EEC) No 3820/85 (OJ L 102, 11.4.2006, p. 1). 
2 Regulation (EU) 2020/1054 of the European Parliament and of the Council of 15 July 2020 amending Regulation (EC) 
No 561/2006 as regards minimum requirements on maximum daily and weekly driving times, minimum breaks and daily 
and weekly rest periods and Regulation (EU) No 165/2014 as regards positioning by means of tachographs (OJ L 249, 
31.7.2020, p. 1). 
3  Recital  (1)  of  Regulation  (EU)  2020/1054  amending  Regulation  (EC)  No  561/2006  confirms  that  the  aim  of  the 
Regulation is to ensure good working conditions for drivers and fair business conditions. 
4  Occasional  bus  and  coach  services  are  defined  in  Article  2(4)  of  Regulation  (EC)  No  1073/2009  of  the  European 
Parliament and the Council of 21 October 2009 on common rules for access to the international market for coach and bus 
services and amending Regulation (EC) N° 561/2006 (Recast) (OJ L 300, 14.11.2009, p. 88)  as services which do not 
fall within the definition of regular services, including special regular services, and the main characteristic of which is 
the carriage of groups of passengers constituted on the initiative of the customer or the carrier himself 
5 Expressed in 2021 prices. Source: Tetra Tech International et al. (2022), Support study for an impact assessment for a 
possible revision of Regulation (EC) No 561/2006. 
6 Based on data from Eurostat, the road passenger transport generated approximately EUR 59.5 billion in 2019 (expressed 
in 2021 prices). 
7 Tetra Tech International et al. (2022), Support study for an impact assessment for a possible revision of Regulation (EC) 
No 561/2006. 
8 Based on data from Eurostat, 728,004 people were employed in the road passenger sector in 2019. 
9 Tetra Tech International et al. (2022), Support study for an impact assessment for a possible revision of Regulation (EC) 
No 561/2006. 

1 

 
 
                                                 
passengers, the transport is regular or occasional. The appropriateness of “one-fit-all” rules has been 
challenged by the occasional bus and coach sector for many years. For the occasional passenger transport 
sector, there are distinct service particularities (e.g. high seasonality) and needs that are not present in freight 
transport  or  regular  passenger  transport,  including  the  need  to  accommodate  passenger  requests  for 
flexibility,  e.g.  regarding  additional  stops,  changes  of  route,  changes  in  departure  times,  etc.  Industry 
representatives argue that more flexibility in the application of the rules to deal with specific characteristics 
of occasional passenger transport operations and/or specific external circumstances is desired and would 
help to comply with the rules.  

Box 1: Specific characteristics of occasional bus and coach transport.  

Occasional passenger transport is characterised by a high seasonality (peaks in demand for passenger trips in certain seasons of the 
year, in particular during winter and summer holidays). Its main purpose from a business perspective is not to maximise the number 
of kilometres in a given time (as in the road transport of goods) or the number of passengers on the basis of a useful itinerary (as in 
the regular road transport of passengers) but to build an attractive touristic package. It is characterised by different driving lengths 
depending on the touristic activities undertaken by passengers such as visits and therefore by longer trips at the beginning and end 
of the tour and by shorter duration of driving time when the touristic activities take place. It needs to accommodate on the spot 
reasonable passenger requests in terms of additional stops, changes of routes, changes of schedule. There is less driving than in 
freight transport or in regular bus services. At the same time, drivers spend time to take care of passengers such as giving advice, 
selling snacks or taking photos. 

The issue of inadequacy  of the current social rules for the  occasional bus and coach sector has gained 
political importance in the context of the negotiations on the legislative proposal modernising the driving 
and rest time rules, as part of Mobility Package I. During the negotiations, the EU occasional bus and coach 
sector has been strongly advocating for recognising the inherent differences between the freight and regular 
passenger transport services on the one hand, and the occasional passenger transport on the other hand. They 
called  for  adapting  the  EU  legal  framework  to  the  operational  specificities  of  this  segment  (e.g.  high 
seasonality) and those of the work of occasional bus and coach drivers (e.g. meeting needs of passengers 
and their touristic programs).  

The  proposal  for  a  revised  Regulation  (EC)  No  561/2006,  adopted  by  the  Commission  as  part  of  the 
Mobility Package I in May 201710, focused on the issues concerning mainly freight transport and did not 
address the particular issues of occasional passenger transport by bus and coach. As a result, on 15 July 
2020, Article 8(10) of Regulation (EC) No 561/2006, was adopted by the European Parliament and the 
Council11.  It  requires  the Commission  to  assess  whether  more  appropriate  rules for drivers  engaged in 
occasional services of carriage of passengers, as defined in point 4 of Article 2 of Regulation (EC) No 
1073/2009, can be adopted. Hence, this initiative is a response to the legal requirement in Article 8(10) of 
Regulation (EC) No 561/2006.  

The initiative contributes towards Sustainable Development Goal (SDG) 8 (“Promote sustained, inclusive 
and sustainable economic growth, full and productive employment and decent work for all”) by making 
transport operations more efficient and competitive and by improving working conditions for drivers. It is 

10 https://ec.europa.eu/transport/modes/road/road-initiatives/fair-competition-workers-rights_en   
11 Regulation (EU) 2020/1054 of the European Parliament and of the Council of 15 July 2020 amending Regulation (EC) 
No 561/2006 as regards minimum requirements on maximum daily and weekly driving times, minimum breaks and daily 
and weekly rest periods and Regulation (EU) No 165/2014 as regards positioning by means of tachographs (OJ L 249, 
31.7.2020, p. 1) and Directive (EU) 2020/1057 of the European Parliament and of the Council of 15 July 2020 laying 
down specific rules with respect to Directive 96/71/EC and Directive 2014/67/EU for posting drivers in the road transport 
sector and amending Directive 2006/22/EC as regards enforcement requirements and Regulation (EU) No 1024/2012 (OJ 
L 249, 31.7.2020, p. 49). 

2 

 
                                                 
also in line with the EU’s policy objectives of a swift recovery of the hardest hit sectors from the COVID-
19 pandemic, a strong EU Single Market, conducive to high levels of growth and jobs and road safety. 

1.2. 

1.2. 

Legal context 

Under  the  current  EU  legal  framework,  professional  drivers  involved  in  the  occasional  carriage  of 
passengers by bus and coach are subject, except limited exceptions, to the same rules on the organisation of 
driving times, breaks and rest periods as truck drivers involved in the regular carriage of passengers and the 
carriage  of  goods  (Regulation  (EC)  No  561/2006,  as  amended  by  Regulation  (EU)  No  2020/1054). 
Regulation (EC) No 561/2006 applies to the transport of goods by vehicles whose mass exceeds 3,5 tonnes 
(it will apply as of 1 July 2026 also to vehicles beyond 2,5 tonnes in international transport operations) and 
the transport of passengers by vehicles which are constructed or permanently adapted for carrying more 
than nine persons, including the driver. It does not apply to the short-distance transport of passengers (less 
than 50 km). The Regulation applies, irrespective of the country of registration of the vehicle, to carriage by 
road  undertaken  exclusively  within  the  EU  or  between  the  EU,  Switzerland,  and  the  parties  to  the 
Agreement on the European Economic Area.  

The scope of the initiative is limited to occasional passenger services and does not cover regular passenger 
services. The definitions of occasional passenger services and regular (scheduled) passenger services are 
provided by Regulation (EC) No 1073/2009. According to Article 2(2) of the Regulation, ‘regular services’ 
mean services which provide for the carriage of passengers at specified intervals along specified routes, 
passengers being picked up and set down at predetermined stopping points. ‘Regular services’ also include 
‘special  regular  services’  (Article  2(3)  of  the  Regulation),  which  provide  for  the  carriage  of  specified 
categories of passengers to the exclusion of other passengers, notably the carriage of workers between home 
and work, and the carriage of school pupils and students to and from the educational institution.  

As regards occasional passenger services, Article 2(4) of Regulation (EC) No 1073/2009 defines these 
services as those which do not fall within the definition of regular services, with the main characteristic 
being the carriage of groups of passengers constituted on the initiative of the customer or the carrier.  

It is also important to indicate that Directive 2002/15/EC12 complements Regulation (EC) No 561/2006 as 
it establishes the requirements on maximum weekly working times, minimum breaks in work and night 
time  work.  It  applies  to  drivers  within  the  scope  of  Regulation  (EC)  No  561/2006.  More  specifically, 
Directive 2002/15/EC in Article 3(a) defines ‘working time’ as including all transport activities, such as: 
driving; loading and unloading; cleaning and technical maintenance; all other work intended to ensure safety 
of the vehicle, its cargo and passengers or to fulfil the legal or regulatory obligations directly linked to the 
specific transport operation; the times during which the driver cannot dispose freely of his/her time and is 
required to be at his/her workstation, ready to take up normal work, e.g. during periods awaiting loading or 
unloading where their foreseeable duration is not known in advance. As stipulated in Article 4 of Directive 
2002/15/EC, the average weekly working time may not exceed 48 hours. However, the maximum weekly 
working time may be extended to 60 hours if, over four months, an average of 48 hours a week is not 
exceeded. Despite the clear complementarity of the two legal acts (i.e. Directive 2002/15/EC and Regulation 
(EC) No 561/2006), this initiative will not affect working times, since no policy measures introduce any 
change in the maximum weekly working time.  

The same rules also apply regarding working time (Directive 2002/15/EC). Compliance with these rules is 
controlled by the Member States authorities at the roadside and at the premises of the companies in line 

12 Directive 2002/15/EC of the European Parliament and the Council of of 11 March 2002 on the working timeof persons 
performing mobile road transport activities (OJ L 80,23.3.2002, p. 35). 

3 

 
                                                 
with the minimum requirements for enforcement set out in Directive 2006/22/EC13. The main source of 
information about driver’s compliance with the driving and resting time provisions is a tachograph installed 
in the bus, coach or truck in accordance with the requirements on the installation and the use of the recording 
equipment established by Regulation (EU) No 165/201414.  

The implementation of the provisions of Regulation (EC) No 561/2006 is monitored by the Commission 
through:  (i)  regular  national  implementation  reports  submitted  by  Member  States  every  two  years,  (ii) 
regular meetings with the representatives of the national authorities, with the EU enforcement community 
and representatives of the industry and of the workers in the framework of the Committee on Road Transport 
and the Commission Enforcement Working Group, as well as (iii) on a case by case basis as a result of 
complaints or enquiries submitted to the Commission. 

The  implementation  reports  prepared  by  the  Commission  every  two  years,  based  on  the  national 
submissions by the Member States, show gradual improvement in compliance level. Still the number of 
infringements by drivers and road transport operators against the social provisions remains high: nearly 3.5 
million offences were detected in the reporting period 2017-201815. The infringements committed in the 
bus  and  coach  sector  constituted  almost  5%  of  all  infringements  detected  in  the  road  sector.  Breaks 
represented 17% of all infringements detected in the passenger transport and rest periods represented 28%, 
against 16% and 22% respectively in freight transport. The figures provided in the implementation reports 
do not, however, provide the breakdown of the infringements by type of transport service, which would 
show the share of infringements committed in the occasional passenger transport sector out of the total 
number of the detected infringements.    

Table 1 presents the rules for the occasional passenger transport relevant for this initiative16. As shown in 
the table, the driver is required to take an interrupted break of at least 45 minutes after 4.5 hours of driving. 
This break can be replaced by a break of at least 15 minutes followed by a break of at least 30 minutes, each 
break distributed over the period as to ensure that the driver takes the required amount of break after 4.5 
hours of driving. A break of at least 30 minutes followed by a break of at least 15 minutes is not a qualifying 
break. For example, if the driver takes first a break of 40 minutes and another break of 30 minutes at the 
end of 4.5 hours of driving, only 15 minutes of the first break may be taken into account as a qualifying 
break. The maximum daily driving period is 9 hours (for example under the following scheme: 4.5 hours 
of driving + 45 minutes’ break + 4.5 hours of driving), with an exemption twice a week when it can be 
extended to 10 hours. Daily rest periods are to last at least 11 hours and can be reduced to 9 hours no more 
than three times between any two weekly rest periods. A driver must complete a daily rest period within the 
24 hours, meaning that daily rest periods must fall within the 24 hours since the start of duty. Weekly rest 
must be taken after six days of working (i.e. 6 x 24-hour periods), except for coach drivers engaged in a 

13 Directive 2006/22/EC of the European Parliament and the Council of 15 March 2006 on minimum conditions for the 
implementation of Council Regulations (EEC) N° 3820/85 and (EEC) N° 3821/85 concerning social legislation relating 
to road transport activities and repealing Council Directive 88/599/EEC (OJ L 102, 11.4.2006, p. 35). 
14 Regulation (EU) N° 165/2014 of the European Parliament and the Council of 4 February 2014 on tachographs in road 
transport,  repealing  Council  Regulation  (EEC)  N°  3821/85  on  recording  equipment  in  road  transport  and  amending 
Regulation  (EC)  N°  561/2006  of  the  European  Parliament  and  the  Council  on  the  harmonisation  of  certain  social 
legislation relating to road transport (OJ L 60, 28.2.2014, p. 1). 
15 Report from the Commission to the European Parliampent and the Council on the implementation in 2017-2018 of 
Regulation (EC) No 561/2006 on the harmonisaton 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, 
COM(2021)610 final.     
16 These are general rules, which apply to freight transport, and regular and occasional passenger transport, except for the 
12-day rule which applies only to international occasional passenger transport.   

4 

 
                                                 
single occasional service of international transport of passengers who may postpone their weekly rest period 
for up to 12 days (so called ’12-day rule’).  

Table 1: Current rules on breaks, driving times and rest periods under Regulation (EC) No 561/2006 

Breaks  
(Article 7) 

Rests  
(Article 8) 

Breaks of at least 45 minutes shall be taken after 4.5 hours of driving.  

A break can be split into two periods, the first being at least 15 minutes and the second at 
least 30 minutes (which must be completed over 4.5 hours driving)   

Daily rest periods shall be at least 11 hours, which can be reduced to 9 hours no more than 
three times between any two weekly rest periods. Daily rest can be split into 3 hours of 
rest followed by 9 hours of rest, to make for a total of 12 hours of daily rest. 

Weekly rest  must be at least 45 continuous hours,  which can be reduced every second 
week  to  24  hours.  Compensation  arrangements  apply  for  reduced  weekly  rest  period. 
Weekly rest is to be taken after six days of working (i.e. 6 x 24-hour periods), except for 
coach  drivers  engaged  in  a  single  occasional  service  of  international  transport  of 
passengers  who  may  postpone  their  weekly  rest  period  for  up  to  12  days  (i.e.  12 
consecutive 24-hour periods). 

Driving times  
(Articles 6 and 12) 

Daily driving period shall not exceed 9 hours, with an exemption of twice a week when it 
can be extended to 10 hours. 

12-day rule 
(Article 8) 

Daily and/or weekly driving times may be exceeded in exceptional circumstances by up 
to  one  hour  to  enable  the  driver  to  reach  his/her  place  of  residence  or  the  employer’s 
operational centre in order to take a weekly rest period.  

Exceeding the daily and/or weekly driving times by up to two hours is also allowed to 
enable the driver to reach his/her place of residence or the employer’s operational centre 
in order to take a regular weekly rest period. 

By way of derogation from paragraph 6, a driver engaged in a single occasional service 
of international carriage of passengers, as defined in Regulation (EC) No 1073/2009 of 
the European Parliament and  of the Council of 21 October 2009 on common rules for 
access to the international market for coach and bus services, may postpone the weekly 
rest period for up to 12 consecutive 24-hour periods following a previous regular weekly 
rest period, provided that:  
(a) the service lasts at least 24 consecutive hours in a Member State or a third country to 
which this Regulation applies other than the one in which the service started;  
(b) the driver takes after the use of the derogation:  

- either two regular weekly rest periods; or  
- one regular weekly rest period and one reduced weekly rest period of at least 24 hours. 
However, the reduction shall be compensated by an equivalent period of rest taken en bloc 
before the end of the third week following the end of the derogation period. 

1.3. 

1.3. 

Synergies with other EU policy instruments  

The  initiative  presents  synergies  with  Regulation  (EU)  No  165/201417,  Directive  2002/15/EC18  and 

17 Regulation (EU) No 165/2014 of the European Parliament and of the Council of 4 February 2014 on tachographs in 
road transport, repealing Council Regulation (EEC) No 3821/85 on recording equipment in road transport and amending 
Regulation  (EC)  No 561/2006  of  the  European Parliament  and  of  the  Council  on  the  harmonisation  of  certain  social 
legislation relating to road transport (OJ L 60, 28.2.2014, p. 1). 
18 Directive 2002/15/EC of the European Parliament and of the Council of 11 March 2002 on the organisation of the 
working time of persons performing mobile road transport activities (OJ L 80, 23.3.2002, p. 35). 

5 

 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Directive  2006/22/EC19.  These  legal  acts  contribute  to  reaching  the  objectives  of  Regulation  (EC)  No 
561/2006.  Regulation  (EU)  No  165/2014  sets  out  the  requirements  on  the  installation  and  the  use  of 
tachographs in the vehicles in scope of Regulation (EC) No 561/2006, while Directive 2002/15/EC lays 
down  rules  on  the  organisation  of  the  working  time  of  drivers  and  Directive  2006/22/EC  determines 
minimum  levels  of  checks  of  drivers  and  undertakings  in  the  road  transport  sector.  The  initiative  also 
presents synergies with Regulation (EC) No 1073/200920 which establishes common rules for access to the 
international market for coach and bus services, both regular and occasional services.  

Moreover,  the  initiative  presents  synergies  with  other  EU  policies,  notably  those  aiming  directly  at 
increasing road safety, in particular Regulation (EU) 2019/214421 which requires motor vehicles for the 
carriage of passengers to be equipped with certain advance vehicle systems, including driver drowsiness 
and attention warning (DDAW) safety systems, as well as with some EU funding projects22.  

1.4. 

1.4. 

Evaluation of the Regulation 

The adequacy of the road transport social rules and efficacy of their enforcement for the occasional bus and 
coach  transport  were,  among  other  aspects,  subject  to  the  2017  ex-post  evaluation23.  The  evaluation 
concluded that some of the rules on the organisation of  breaks and rest periods may not be fit for the 
occasional passenger transport sector because of the distinct service needs.  

Based  on  the  findings  of  the  ex-post  evaluation,  the  Commission  considered  several  policy  options  to 
address the identified problems in the impact assessment accompanying the 2017 proposal for the revision 
of Regulation (EC) 561/200624, including those related to difficulties with compliance and high regulatory 
costs which result from rules not fitting the specific characteristics of the passenger transport. One of the 
policy options analysed in the impact assessment contained specific rules for occasional passenger transport. 
However, at that time it was decided to pursue a policy option addressing the most acute problems affecting 
mainly the freight transport, i.e. long periods away from home by drivers, inadequate working and resting 
conditions,  distortions  of  competition,  unfair  employment  practices,  and  ineffective  enforcement. 
Therefore, the legislative proposal for a targeted revision of Regulation (EC) No 561/2006 adopted by the 

19 Directive 2006/22/EC of the European Parliament and of the Council of 15 March 2006 on minimum conditions for 
the  implementation  of  Council  Regulations  (EEC)  No  3820/85  and  (EEC)  No  3821/85  concerning  social  legislation 
relating to road transport activities and repealing Council Directive 88/599/EEC (OJ L 102, 11.4.2006, p. 35). 
20 Regulation (EC) No 1073/2009 of the European Parliament and of the Council of 21 October 2009 on common rules 
for access to the international market for coach and bus services, and amending Regulation (EC) No 561/2006, OJ L 300, 
14.11.2009, p. 88. 
21  Regulation  (EU)  2019/2144  of  the  European  Parliament  and  the  Council  of  27  November  2019  on  type-approval 
requirements for motor vehicles and their trailers, and systems, components and separate technical units intended for such 
vehicles, as regards their general safety and the  protection of vehicle occupants and vulnerable road users, amending 
Regulation (EU) 2018/858 of the European Parliament and of the Council and repealing Regulations (EC) No 78/2009, 
(EC) No 79/2009 and (EC) No 661/2009 of the European Parliament and of the Council and Commission Regulations 
(EC)  No  631/2009,  (EU)  No  406/2010,  (EU)  No  672/2010,  (EU)  No  1003/2010,  (EU)  No  1005/2010,  (EU)  No 
1008/2010, (EU) No 1009/2010, (EU) No 19/2011, (EU) No 109/2011, (EU) No 458/2011, (EU) No 65/2012, (EU) No 
130/2012, (EU) No 347/2012, (EU) No 351/2012, (EU) No 1230/2012 and (EU) 2015/166 (OJ L 325, 16.12.2019, p. 1). 
22 For example, PANACEA, which is part of a Horizon funded project, focuses on fitness to drive of commercial drivers.   
23 SWD(2017)184 final, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52017SC0184   
24 Commission Staff Working Document Impact Assessment accompanying the document ‘Proposal for a Regulation of 
the European Parliament and of the Council amending Regulation (EC) 561/2006 as regards minimum requirements on 
maximum  daily  and  weekly  driving  times,  minimum  breaks  and  daily  and  weekly  rest  periods  and  Regulation  (EU) 
165/2014 as regards positioning by means of tachographs and Proposal for a Directive of the European Parliament and 
of the Council amending Directive 2006/22/EC as regards enforcement requirements and laying down specific rules with 
respect to Directive 96/71/EC and Directive 2014/67/EU for posting drivers in the road transport sector’, SWD(2017)186 
final.  

6 

 
                                                 
Commission as part of the Mobility Package I and in force since 20 August 202025 focused on the issues 
concerning freight transport. It did not address the particular issues of occasional transport by bus and coach. 

2.  2. PROBLEM DEFINITION 

2.1. 

2.1. 

What are the problems? 

The underlying problems, problem drivers and implications that are relevant for this initiative are presented 
in Figure 1. The evidence underpinning the problems and their drivers draw on the external support study26 
that has been carried out to support this Impact Assessment. 

Figure 1: Problem tree 

2.1.1.  2.1.1. 

Problem 1: Inability to organise efficient and high-quality occasional 

bus and coach services  

This  section  presents  Problem  1  from  the  perspective  of  business  associations,  operators  and  self-
employed drivers who provided most detailed feedback and who are directly more concerned as regards 
the organisation of occasional passenger services than other stakeholders groups. It was not possible to 
estimate quantitatively the size of the problem with regard to breaks and rest periods (including the 12-day 
derogation), due to lack of data. The evidence for this problem therefore relies on feedback received during 
various consultation activities27.  

Employed drivers, trade unions and enforcement authorities were also asked about this problem during the 
consultations. However, these groups did not provide detailed feedback on how the rules affect service 
quality  and  efficiency,  but  rather  focused  on  working  conditions  and  road  safety.  Therefore,  their 
perspective is presented in Problem 2 (section 2.1.2).  

Operators acknowledged being unable to organise services that are efficient and of high quality, due to the 
misalignment of the rules with the specific characteristics of occasional bus and coach services. The rules 
on breaks and rest times were designed with freight transport services in mind, but compared to freight 
transport  or  regular  (scheduled)  passenger  transport,  occasional  passenger  transport  presents  different 

25 For more information see the Commission’s dedicated page at: Mobility Package I (europa.eu).  
26 Tetra Tech International et al. (2022), Support study for an impact assessment for a possible revision of Regulation 
(EC) No 561/2006.  
27  Consultation  activities  consisted  in  feedback  to  the  inception  impact  assessment,  public  consultation,  targeted 
interviews and case studies. A summary of these activities can be found in Annex 2 and detailed results in Tetra Tech et 
al. study.  

7 

PROBLEM DRIVERSPROBLEMSIMPLICATIONSInability to organise efficient and high-quality occasional bus andcoachservices Insufficient demand and investment in the sectorInadequate working and driving conditions for drivers in occasional bus and coach transportsectorLow customer satisfactionRisk of non-compliance with the rulesHigh levels of stress and fatigue among drivers, with negative impacts on quality of life of drivers, attractiveness of the driving profession and road safety 
 
 
                                                 
operational and driving patterns. It is in large part dependent on holiday schedules, which are characterised 
by a high seasonality (peaks in demand for passenger trips in certain seasons of the year, in particular during 
winter and summer holidays). Tourism tours are often a combination of several breaks when tourists take 
part in holiday activities and different driving lengths, i.e. longer trips at the beginning and end of long-
distance tours and shorter duration of driving time during touristic visits. Overall, bus and coach drivers 
usually spend much less time driving than drivers in freight transport or in regular bus services. According 
to figures provided by the International Road Transport Union (IRU) members, the average daily driving 
time of a coach driver during a typical tourism trip is around 4.5 hours a day, while for drivers engaged in 
freight and regular passenger transport it is 9 hours a day.  

The need to fit occasional passenger transport into the same framework as freight and regular passenger 
transport, despite its specific characteristics, presents operators and drivers with an unenviable choice. Either 
they arrange services in a way that is inefficient and not in line with the demands of some customers, or 
they risk non-compliance in order to maintain sufficient quality and meet customer demands.  

Breaks  

Unlike in scheduled passenger and  in goods services, occasional transport rarely aims to maximise the 
number of kilometres driven in a certain time, but rather involves frequent, irregular stops, including 
unexpected ad-hoc stops requested by passengers. During the course of a day, a typical tourist tour may 
focus on a specific city or region, involving stops at several touristic sites of varying time length. In principle, 
these would provide drivers with ample opportunities for breaks. However, if the timing and length of the 
stops does not fit the precise requirements of the rules, even though accumulated breaks exceed the required 
quantity, then additional stops must be arranged, regardless of whether these fit adequately into the itinerary. 
For example, a coach may depart at 10:00, stop for an early lunch at 12:00, then continue to another location. 
However, since only 15 minutes of the stop for the lunch can be counted as qualified first split break, another 
stop of 30 minutes, after 2.5 hours of additional driving time, would be necessary within the original 4.5 
hours, even if otherwise inconvenient.  

During the public consultation28, 2 of the 12 business associations that replied to the question on breaks 
considered that the rules need major changes while 10 of them that the rules need minor refinements. 20 of 
the 78 companies that replied considered that the rules need major changes while 51 of them that the rules 
need minor refinements. As regards self-employed drivers, 13 of the 32 drivers that replied to the public 
consultation  believed  that  the  rules  need  major  changes  while  16  of  them  that  the  rules  need  minor 
refinements.  

In  addition,  all  the  12  business  associations  and  7  bus  and  coach  operators  participating  in  targeted 
interviews considered the rules insufficiently adapted to the needs of the occasional sector and stressed their 
importance for the tourism industry. The main complaint was that the break requirements were difficult 
to fit into trip itineraries, which in turn necessitated additional stops and delays. These were time-
consuming and difficult for customers to understand. One of the main motivations for customers to choose 
organised  trips  is  to  take  advantage  of  many  touristic  attractions  in  a  limited  time.  The  interviewed 
stakeholders confirmed the feedback on the inception impact assessment, where the prevailing view of 
business associations was that the rules on breaks are an obstacle to aligning breaks for drivers with the 
natural stops on touristic trips.  

28 Tetra Tech International et al. (2022), Support study for an impact assessment for a possible revision of Regulation 
(EC) No 561/2006.  

8 

 
                                                 
Rest periods, including 12-day rule 

Unlike scheduled passenger and goods services, occasional services often involve only short and sporadic 
amounts of driving. Trips may consist of an early morning journey followed by little-to-no daytime driving 
and an evening return that would often slightly exceed the duty cycle for a single driver, when passengers 
still need to be transported, e.g. back to the hotel after a day of sightseeing. Under the current rules, trips of 
over six days (i.e. the limit at which a weekly rest is required) must be staffed with two drivers, if a trip 
involves driving beyond six days.  

This means either refusing to schedule such trips or bringing on a second driver at significant expense, while 
rendering  certain  trips  unviable  either  on  economic  grounds  or  if  extra  drivers  cannot  be  found. 
Alternatively, a trip can be organised in a less appealing way, e.g. by forcing passengers to bring their 
evening to an unexpectedly early conclusion. Moreover, since occasional transport is tourism-dependent 
and thus highly seasonal, the current rules may exacerbate driver shortages during peak periods, further 
reducing the service offer and putting upward pressure on prices. 

The current 12-day rule, according to which the weekly rest period may be postponed up to 12 days for 
drivers engaged in a single service of occasional passengers, is only available for international trips. This 
creates an uneven playing field between providers of domestic and international services and is also not 
allowing  for  domestic  trips  a  potential  part-solution  to  the  issue  of  driver  availability  for  longer  trips. 
Importantly, according to stakeholders, trips of 7-8 days are fairly typical tours, rather than less common 
ones of 11-12 days. 

During the public consultation29, 4 of the 12 business associations that replied to the question on rest periods 
considered that the rules need major changes while 6 of them that the rules need minor refinements. 18 of 
the 76 companies that replied considered that the rules need major changes and 54 of them that that the rules 
need minor refinements. 10 of the 31 self-employed drivers that replied answered that the rules need major 
changes while 19 of them that the rules need minor refinements.  

All  the  12  business  associations  and  7  occasional  bus  and  coach  operators  taking  part  in  the  targeted 
interview, thought that the rules on rest periods harm the efficiency and quality of services. Criticism of 
the 12-day rule was the most severe and widespread: all 19 interviewees stated that being able to benefit 
from the derogation only in case of international trips was inappropriate and detrimental to their businesses. 
The reason given was that this makes domestic trips of over six days (which may be of the same or even 
longer distance than international ones) considerably more expensive than similar international trips, leading 
to higher prices for consumers and rendering some longer domestic trips unviable (see example in Box 2).  

Box 2: Domestic vs international trips and the 12-day rule – an example from Sweden and Denmark 
Tourists from both side of the Danish / Swedish border often take similar ski trips to the north of Sweden. A typical tour 
lasts eight days, with long-distance travel (about 750 km) on days 1 and 8, with short journeys back and forth to the slopes 
on the other days. Since the trips from Denmark to the north of Sweden are international, the driver can benefit from the 
12-day rule. This means that it is possible to carry out the  whole trip with one driver, who then gets a compensatory 
weekly rest at the end of the trip. Similar trips in terms of distance and duration, carried out from south to north of Sweden 
are domestic operations, meaning that the driver is not entitled to the 12-day rule. This means that an additional driver is 
needed for the  first and  last days of the trip. This increases the  cost and consumer price  by about 20%. It also  has a 
negative impact on the Swedish economy, since similar trips to ski resorts on the Norwegian side of the border can use 
the 12-day rule to lower costs. 
Source: Confederation of Swedish Enterprises 

All the 19 interviewees were also consistent in pointing out that the daily rest rules made it difficult to 

29 Tetra Tech International et al. (2022), Support study for an impact assessment for a possible revision of Regulation 
(EC) No 561/2006.  

9 

 
 
                                                 
organise trips in a logical way and to deal with unforeseen delays or events, and that complying with the 
weekly  rest rules made  drivers unavailable  at peak  seasonal  periods, contributing  to widespread driver 
shortages. However, most of the interviewees believed that a situation where 12 consecutive days of work 
becomes the norm should be avoided. In addition, all of the 13 business associations and 8 companies 
providing feedback on the inception impact assessment stressed that the current rules did not allow operators 
to tailor services to the needs of specific trips and customers.   

The  inability  to  organise  efficient  and  high-quality  occasional  bus  and  coach  services  results  in  low 
customer satisfaction, and insufficient demand and investment in the sector. The levels of customer 
satisfaction and demand in the sector are not only influenced by the rules on breaks and rests time but also 
by other factors like customer experience, comfort, fares, etc. It should however be emphasised that as 
regards these other factors operators compete while the rules on breaks and rest times are a legal constraint 
on which limited competition takes place. As explained above, some potentially attractive services may be 
deemed unviable economically and not take place at all, such as a domestic trip where the 12-day derogation 
is unavailable since involving a second driver (although potentially not necessary to prevent fatigue) is too 
costly.  

In the context of the public consultation, 25 of 154 respondents considered that the existing rules do ‘not at 
all’ contribute to high-quality services or contribute ‘only to a limited extent’ (78 of 154 respondents). There 
was little difference in views between stakeholders groups. The 12 business associations and 7 occasional 
bus and coach operators taking part in the targeted interviews expressed similar views and also mentioned 
that the rules lead to inconvenience during services and tend to reduce the offer of services, while also 
putting upward pressure on prices. While acknowledging the vital importance of harmonised standards for 
health and safety, the findings nonetheless suggest that industry stakeholders consider the rules difficult to 
deal with. 

It must be acknowledged that European consumer and passenger associations declined to participate in the 
interviews, despite being contacted several times, due to their limited knowledge of the sector and the way 
services  are  organised. Research on the topic is also very  limited,  and mostly  focuses  on urban  public 
transport and commuting services. Nevertheless, interviewees with a variety of profiles were selected (e.g. 
employed  versus  self-employed  drivers,  small  versus  larger  operators,  different  Member  States),  and 
interviews were conducted in national languages. Findings were also triangulated between different groups 
of stakeholders and data collection tools. 

Feedback received during the targeted interviews and public consultation emphasised that the occasional 
bus  and  coach  sector  is  small  and  characterised  by  SMEs  operating  on  low  margins.  Factors  that 
negatively affect business performance, such as costs, staffing shortages and reduced service offer 
engendered by the current rules, would make it more difficult to compete with other transport means such 
as flights and private cars30, and thereby depress demand and investment. Indeed, for smaller businesses 
the staffing of trips that require multiple drivers is an important issue. Second drivers were often unavailable 
to replace those who exceed their daily duty cycle, with negative impact such as changes to the itinerary 
(with related customer dissatisfaction) or the inability to take on additional orders, especially at peak season. 
Examples provided during the targeted interviews showed that small companies are also more likely than 
their larger counterparts to focus on domestic trips, which in turn gives them relatively limited access to the 

30 For example, a passenger may decide to get to a ski resort with an occasional coach service as part of a package with 
e.g. daily transport to and from the mountain. If the package offered is not sufficiently satisfactory, the passenger would 
rather opt for taking a flight, train, or scheduled bus service, and deal with other than transport aspects on his own. He 
could  also  when  available  opt  for  a  package  where  other  modes  of  transport  than  coach  are  included.  However,  no 
quantified evidence is available to substantiate the frequency of this problem.   

10 

 
                                                 
12-day rule (since this can only be used for international travel). Overall, small companies were poorly-
equipped to develop complex logistics plans involving drivers and operations in different locations.  

In  contrast,  larger  companies  still  experienced  the  problems  described,  but  the  impacts  were  less 
pronounced,  and they  were  relatively  better prepared to  take mitigating  measures.  For  example, large 
companies tend to have drivers and operate in different locations, meaning that they can find additional 
drivers with different ‘home bases’ if needed due to seasonal factors or due to issues that arise during the 
trip. Although large companies agreed that the rules increased costs and prices, and caused some logistical 
issues that negatively affect the service quality (e.g. the need to take a break at an inconvenient moment), 
the scale of the problems was manageable for them. 

The operators participating in the interviews and public consultation consistently attributed the current rules 
on breaks and rest periods to their difficulties to organise high-quality services that meet customer demand. 
In  other  words,  restricted  adaptability  to  client’s  needs  may  force  operators  to  present  a  less  attractive 
package for  a tour.  It is then  understandable that customer satisfaction is lower than it would be if the 
services  were  better.  Moreover,  while  it  was  not  possible  to  gather  evidence  to  compare  customer 
satisfaction and demand between occasional and regular passenger services, all decribed problems relate to 
the specificities of the occasional passenger transport only.  

The occasional bus and coach sector has also suffered disproportionately from the impacts of the COVID-
19 pandemic.  According  to  the  International  Road  Transport  Union  (IRU),  revenue  for bus  and  coach 
services related to tourism fell by 82% in 202031. Although data on the post-COVID recovery is scarce, to 
a certain extent the sector is also negatively affected by more recent high energy prices and staff shortages. 
This may exacerbate the inability to organise efficient and high-quality occasional bus and coach services. 

The links between occasional bus and coach services and tourism imply that occasional bus and coach 
transport – and hence the consequence of insufficient demand and investment in the sector – would be 
more prevalent in Member States with a high concentration of touristic activity. As shown in Figure 
2, tourism activities are highly concentrated in a few Member States. The tourism revenues are by far the 
highest in Spain, France, Italy and Germany, while in terms of share of GDP, tourism revenues are also 
especially important in other southern EU Member States, including Portugal, Greece, Croatia, Cyprus and 
Malta. Occasional bus and coach operators in these countries are expected to  especially experience the 
problem and its effects.  

Figure 2: Tourism activity in the EU, 2019 

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Source: Tetra Tech et al.; Eurostat (bop_c6_q, bop_eu6_q and nama_10_gdp) 

31 IRU, 2020, No end in sight to pandemic-induced passenger transport crisis, 
https://www.iru.org/resources/newsroom/no-end-sight-pandemic-induced-passenger-transport-crisis  

11 

 
 
                                                 
 
 
 
2.1.2.  2.1.2. 

Problem 2: Inadequate working and driving conditions for drivers in 

occasional bus and coach transport 

This section presents Problem 2 from the perspective of drivers, trade unions and public authorities32, 
who made most comments as regards the working and driving conditions33. Like for Problem 1, it was not 
possible to estimate quantitatively the size of the problem, due to lack of data. Therefore, the evidence 
underpinning this problem relies on the feedback received during different consultation activities34. While 
it was relatively easy to interview trade unions and business associations, it was extremely difficult to reach 
out to drivers, despite extensive consultation efforts.  

Problems related to working conditions and to the driver fatigue and stress can be mainly attributed to other 
factors that are beyond specific characteristics of occasional passenger transport. These other factors are for 
example  monotonous  driving  (e.g.  driving  on  motorways  for  several  hours),  loneliness  on  the  road, 
exposure to vibration, etc. This Impact Assessment mainly focuses on factors directly related to the issues 
in the scope of the occasional passenger segment such as difficulties to comply with the rules, customer 
demands that cannot be met, pressure to take on tasks during break time, etc.  

The  mismatch  between  the  existing  rules  and  the  specific  characteristics  of  the  occasional  passenger 
transport also plays a role, as confirmed by the drivers who responded to the consultation activities, who 
consider that more flexible rules would make them more relaxed and less stressed35.The targeted interviews 
and public consultation highlighted several elements, which show that, despite the vital role of mandated 
breaks and rest periods, the inflexibility of the rules may worsen working and driving conditions rather than 
improve them: 

  Difficulties to benefit from the required breaks: the break requirements often oblige drivers to take 
breaks at inconvenient moments, and the dynamics of occasional activities often place expectations on 
the driver to spend break time with passengers, by taking photos, giving advice on restaurants or sites, 
etc., even though the rules stipulate that breaks should be free of such tasks. This issue can be exacerbated 
if a break takes place not when passengers are busy with touristic activity, but rather are idle because the 
stop is being made only for the purpose of the driver’s break, leading to stress and pressure either to face 
dissatisfied and aggressive customers or to ignore the rules. Three of the 6 interviewed drivers36 noted 
this issue, underlining the importance of being able to organise breaks at more convenient times. During 
the public consultation37, all the 14 employed drivers that replied to the question on breaks considered 
that the rules need changes (1 referred to the need of major changes and 13 to minor changes). 2 of the 
6 trade unions that replied consider that the rules need major changes while 4 of them that the rules 
should not been changed. Public authorities were more reluctant as regards the changes, since 4 of the 

32 However, public authorities were most concerned about compliance. 
33  Industry  stakeholders’  views  on  the  topic  do  not  constitute  the  main  part  of  the  analysis  in  this  section,  since  the 
experiences and interests of these stakeholders naturally differ from employed drivers and trade unions.  
34  Consultation  activities  consisted  in  feedback  to  the  inception  impact  assessment,  public  consultation,  targeted 
interviews and case studies. A summary of each of these activities can be found in Annex 2 and detailed results in Tetra 
Tech et al. study. 
35 For example, one of the interviewed trade unions mentioned occasional services in an Eastern non-Schengen Member 
State, where drivers had to wait for hours to cross the border and then to immediately take a break to comply with the 
rules, causing anger and confusion among tourists on-board.  
36 Namely, employed drivers from the Netherlands, Spain and Sweden.  
37 Tetra Tech International et al. (2022), Support study for an impact assessment for a possible revision of Regulation 
(EC) No 561/2006. 

12 

 
                                                 
10 public authorities that replied  believe that only  minor changes are needed and 6 of them that no 
changes are needed.   

  Excessive time away from home: since the 12-day derogation is only available on international trips, 
drivers on domestic trips of over 6 days (which occur frequently) can be obliged to take a weekly rest 
while away from home. While respecting maximum driving times and minimum break times, which are 
essential for health and safety purposes, 338 of the 6 interviewed drivers would prefer to work more days 
without taking rest periods, and benefit from additional time off afterwards, at home with their families 
and friends. During the public consultation39, 15 of the 16 employed drivers that replied to the question 
on rest periods consider that the rules need changes (3 that major changes are needed and 12 that minor 
changes are needed). 3 of the 6 trade unions that replied consider that the rules need changes (2 that 
major changes are needed and 1 that minor changes are needed). 3 of the 10 public authorities believed 
that the rules need only minor changes while 7 of them that no changes are needed.    

  Inability to adapt the workload to seasonal demand: for a number of personal and lifestyle reasons 
(e.g. to earn more money during peak season, and take time off during lighter months) some drivers, 
especially the self-employed ones, would prefer to work more than the weekly rest periods allow during 
some periods, meaning that the current rules constrain their freedom in choosing working patterns and 
scheduling. This view was expressed by two self-employed Bulgarian drivers taking part in the targeted 
interviews. In addition, 29 out of the 31 self-employed respondents to the public consultation supported 
changes to the existing rules on rest periods, with ten of them citing an inability to work as desired. 

  Difficulties to stay within the duty cycle: in order to organise trips with broad touristic programme but 
in a limited time, as required by customers, drivers are often faced with unexpected issues. In addition 
to the issues that also occur in freight transport, such as traffic jams, drivers in the occasional passenger 
services are also faced with other issues, for example a tourism activity going over time, waiting for 
tourists, or delays to passengers’ upstream transport (e.g. delays of airplanes or ferries). This can in turn 
force drivers to rush at the end of a journey in order to avoid exceeding the maximum amount of time 
on-duty, regardless of the amount of actual driving that day. Aside from compromising safety (e.g. by 
speeding), such a dynamic leads to stress and harms drivers’ relation with passengers, which is important 
because the chance to meet people and engage in friendly relations is seen as a selling point for the job. 
Among interviewed  drivers, this  issue  was  raised by  two  self-employed  Bulgarian  drivers  (out of  6 
drivers interviewed), who thought that it would cause problems for drivers’ working conditions.  

As  a  consequence,  besides  the  driver  shortages  that  were  reported  by  nearly  all  of  the  12  business 
associations and 7 occasional bus and coach operators interviewed, the high level of stress and fatigue 
reduces the attractiveness of work in the sector. Fatigued and distracted drivers are also more prone to 
accidents, with negative impact on road safety. Working conditions and road safety are interrelated,  as 
difficult working conditions contribute to the drivers’ fatigue and fitness-to-drive40. Driver fatigue may be 
caused by factors other than working conditions, for example monotonous activities, such as driving on 
motorways  for many  hours. Establishing the  actual proportion  of  accidents  caused  by  driver  fatigue is 
difficult, and one of the reasons may be the fear of negative consequences if drivers admit to driving while 
fatigued41. Therefore, the link between the rules and the stress and fatigue of drivers seems to be only one 
factor among many others. Moreover, in response to the public consultation question on whether the rules 

38 Namely, one employed driver from Spain and two employed drivers from Sweden.   
39 Tetra Tech International et al. (2022), Support study for an impact assessment for a possible revision of Regulation 
(EC) No 561/2006. 
40 Katrin Vitols and Eckhard Voss, wmp consult, on behalf of ETF (2021), ‘Driver fatigue in European road transport’. 
41 Katrin Vitols and Eckhard Voss, wmp consult, on behalf of ETF (2021), ‘Driven to distraction? Bus and Coach drivers 
in the EU’.  

13 

 
                                                 
contribute to minimising stress and fatigue for drivers, the respondents replied that this was the case either 
‘to a great extent’ or ‘to some extent’ across all stakeholder groups, ranging from around 80% for business 
associations and public authorities (10 out of 11 and 8 out of 10 responses, respectively), to just under 60% 
for self-employed drivers (15 of 26 responses). Nonetheless, difficulties to comply with the rules, customer 
demands that cannot be met, the pressure to take on tasks during break time, etc. can also play a contributing 
role in stress and fatigue among drivers, implying a reduced quality of life for drivers.  

It is also important to stress that there are other initiatives and legal acts, which directly aim at increasing 
road safety, in particular Regulation (EU) 2019/214442 which requires motor vehicles for the carriage of 
passengers to be equipped with certain advance vehicle systems, including driver drowsiness and attention 
warning safety systems.  

The inadequate working and driving conditions for drivers in occasional bus and coach transport also results 
in risks of non-compliance with the rules. This negative consequence is expected to be experienced more 
acutely  in  the  Member  States  where  tourism  activities  play  a  larger  role.  The  nature  of  the  occasional 
passenger services makes compliance more difficult than for regularly scheduled passenger services or 
freight services. Combined with limited staff and financial resources of enforcement authorities of Member 
States43, this could lead to pressure on operators and drivers not to respect the rules.  

The results of the public consultation44 showed that 10 out of the 11 business associations that responded 
believe that the current rules pose difficulties for enforcement and compliance (3 to a great extent and 7 to 
some extent). Similarly, 22 out of the 25 self-employed drivers that responded to the public consultation 
expressed the view that the current rules pose difficulties for enforcement and compliance (13 to a great 
extent and 9 to some extent).  The only exceptions were trade unions and public authorities, whose views 
were more mixed. 

All the 5 trade unions and 6 drivers interviewed claimed that non-compliance with the rules was widespread 
in occasional bus and coach transport. This was due to the fact that they considered organising occasional 
services and dealing with unexpected issues (e.g. traffic, events running over time) within the framework 
imposed by the rules to be impossible in some cases45, but also invoked other types of infringements that 
go  beyond  the  scope  of  the  initiative  (e.g.  the  lack  of  records  for  other  work  than  driving  or 

42  Regulation  (EU)  2019/2144  of  the  European  Parliament  and  the  Council  of  27  November  2019  on  type-approval 
requirements for motor vehicles and their trailers, and systems, components and separate technical units intended for such 
vehicles, as regards their general safety and the protection of vehicle  occupants and vulnerable road users, amending 
Regulation (EU) 2018/858 of the European Parliament and of the Council and repealing Regulations (EC) No 78/2009, 
(EC) No 79/2009 and (EC) No 661/2009 of the European Parliament and of the Council and Commission Regulations 
(EC)  No  631/2009,  (EU)  No  406/2010,  (EU)  No  672/2010,  (EU)  No  1003/2010,  (EU)  No  1005/2010,  (EU)  No 
1008/2010, (EU) No 1009/2010, (EU) No 19/2011, (EU) No 109/2011, (EU) No 458/2011, (EU) No 65/2012, (EU) No 
130/2012, (EU) No 347/2012, (EU) No 351/2012, (EU) No 1230/2012 and (EU) 2015/166 (OJ L 325, 16.12.2019, p. 1). 
43  Report  on 
(EC)  No  561/2006,  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52021DC0610 
44 Tetra Tech International et al. (2022), Study supporting the Bus and Coach Impact Assessment. 
45 It should also be noted that all the interviewed authorities (Germany, the Netherlands and Sweden, as well as CORTE 
and Euro Contrôle Route) considered that the rules were difficult to enforce, but attributed this to the irregular rhythms 
in  occasional  transport,  which  are  not  conducive  to  monitoring  with  digital  tachographs  (since  these  cannot  measure 
aspects like whether a driver is fully unoccupied during a break, or whether a driver needs to conduct additional tasks 
after parking the bus at the end of a day, or drive for a long time to get home). These authorities saw such issues as more 
important  causes  of  problems  for  enforcement  than  the  rules  as  such.  Similarly,  all  five  interviewed  trade  union 
representatives (covering the EU level as well as the Netherlands, Spain and Sweden) considered enforcement to be an 
issue for a variety of reasons, and felt that the existing rules should either be maintained or made stricter. 

implementation  of  Regulation 

the 

14 

 
                                                 
misuse/manipulation of tachographs). According to the latest Commission report46 on the implementation 
of the Regulation, the offences regarding breaks constituted 17% of all offences detected, while the offences 
against rest periods constituted 23% of all offences detected.   

2.2. 

2.2. 

What are the problem drivers? 

2.2.1.  2.2.1. 

Problem driver 1: Misalignment between the nature of occasional bus 

and coach services and the rules on break times and rest periods 

Problem driver 1 is linked to both problem 1 and problem 2, and is driven by the specific characteristics of 
occasional bus and coach services and the fact that the current rules on breaks and rest periods were not 
designed with this in mind. When it comes to freight transport, the way in which breaks and rest periods are 
organised – while very important for ensuring driver welfare and road safety – is only material insomuch 
as it affects the overall amount of time needed for a service. In other words, as long as customers know 
when their goods depart from point A and when they arrive at point B, it is not relevant for them how the 
driver organises his/her time while en route. In contrast, the occasional bus and coach transport services are 
tailored to the needs and schedules of individual customers. This may sometimes mean moving a group 
from point A to point B (e.g. transporting by coach a group to a resort). But more often it is about tailored 
itineraries that are highly variable in terms of length of time and amount of driving.  

During the targeted interviews, operators and business associations, but also some drivers, described some 
ways in which this misalignment manifested itself:  

  Services are often irregularly placed and timed, and hence do not necessarily lend themselves to the 

required break and rest times. 

  Services  frequently  entail  non-driving  demands,  such  as  providing  touristic  advice,  eating  meals 
together and cleaning the coach, which according to the rules cannot be combined with official ‘breaks’. 
Indeed, breaks must be organised at other times or that there are risks of non-compliance. 

  Unlike regular transport, occasional services involve adapting to customers’ schedules, e.g. in case of 
delayed upstream transport or other sources of uncertainty that may occur when drivers are already ‘on 
the clock’. This can result in difficulties to stick to the duty cycle.  

  Many occasional services are seasonal, meaning high demand at certain times of the year, followed by 
much lighter months. Dealing with mandated rest periods may thus make it difficult for operators to 
staff services at peak season, especially when the specifics of a service require two drivers.  

  The rules differ depending on the length of the drive: if the drive is longer than 50km, the EU rules on 
driving time apply. This distinction is useful for differentiating long-haul and local goods transport but 
is reportedly difficult for tour coach drivers to adapt to. The application of different rules depending on 
the precise details of a service can make scheduling and staffing difficult for operators.  

The overarching principle was that occasional bus and coach services are typically not about covering a 
certain number of kilometres, but rather involve integrating transport services within a wider array of 
activities, such as visits to a number of locations during a tour. 

46  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 harmonisaton 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, 
COM(2021)610 final.     

15 

 
                                                 
2.2.2.  2.2.2. 

Problem  driver  2:  Unequal  treatment  between  international  and 

domestic bus and coach operations 

Problem driver 2 is linked to both problem 1 and problem 2. One of the stated aims of Regulation (EU) No 
561/2006, as defined in Article 1, is to “harmonise the conditions of competition between modes of inland 
transport, especially within the road sector”. While this is the case for most aspects of the rules on breaks 
and rest periods, there is one specific rule for which treatment differs depending on whether a service is 
domestic or international.  

More specifically, Article 8 of the Regulation states that a ‘weekly rest’ should begin no later than at the 
end of six 24-hour periods from the end of the previous weekly rest. However, there is also a derogation, 
known  as  the  ’12-day  rule’,  which  allows  drivers  engaged  in  a  single  occasional  service  international 
carriage of passengers to postpone the weekly rest for up to twelve 24-hour periods, provided that two 
consecutive weekly rests are then taken. The purpose of the derogation is to facilitate the organisation of 
longer trips, while compensating drivers with additional time off. It can however result in unequal treatment 
for similar trips, solely based on whether they are of a national or international nature.  

Since  a  driver’s  rest  needs  are  completely  unrelated  to  the  crossing  of  borders,  the  derogation  places 
international and domestic services on an uneven playing field. As explained in section 2.1.1 (see box 2), it 
is hard to justify why a company transporting tourists from Denmark to the Swedish mountains can benefit 
from the derogation while different, stricter rules apply to a similar service departing from southern Sweden. 
Domestic services, expressed in passenger-kilometres, account on average for 68% of the transport activity 
of the occasional bus and coach sector47.  

The unequal treatment between international and domestic services has been criticised as arbitrary 
and unfair by operators and business associations, as well as self-employed drivers. The results of the 
public consultation48 showed that 12 of the 17 employed drivers that responded believe that the current rules 
do not contribute to fair competition between domestic and international services or only contribute to a 
little extent (11 believe that they do not contribute at all and 1 that they contribute to a little extent). 7 of the 
17  business  associations  that  responded  also  consider  that  the  current  rules  do  not  contribute  to  fair 
competition between domestic and international services or only contribute to a little extent (5 believe that 
they do not contribute at all and 2 that they contribute to a little extent). Similarly, 33 of the 60 companies 
that replied believe that the current rules are not favourable to fair competition or only favourable to a little 
extent (23 believe that they do not contribute at all and 10 that they contribute to a little extent). Only public 
authorities that responded to the public consultation expressed positive views, with 7 out of 10 respondents 
believing that the rules contributed to fair competition either ‘to a great extent’ or ‘to some extent’.  

During the targeted interviews, the 12 business associations, 7 occasional bus and coach operators and 
2 Bulgarian self-employed drivers agreed that the current application of the 12-day rule leads to 
unfair treatment between domestic and international services. The other stakeholders taking part in the 
interviews (drivers, trade unions and authorities) either agreed, or did not express a view on this topic49. 
Interviewees from Germany, Spain and Sweden were more critical, since in these countries, domestic trips 
exceeding the current limit of six days of driving before a weekly rest are common. The  2017 ex-post 

47 Tetra Tech International et al. (2022), Support study for an impact assessment for a possible revision of Regulation 
(EC) No 561/2006. 
48 Tetra Tech International et al. (2022), Support study for an impact assessment for a possible revision of Regulation 
(EC) No 561/2006. 
49 It should also be noted that all five trade union representatives that were interviewed felt that the 12-day derogation 
was incompatible with good working conditions, and that ensuring a level playing field should be achieved by abolishing 
the derogation rather than extending it. 

16 

 
                                                 
evaluation50 and the 2017 impact assessment51 reached a similar conclusion. In addition, the interviews with 
operators showed that occasional bus and coach transport is more important in peripheral areas, where rail 
connections are less developed, making occasional transport play a more important role.  

It should be highlighted that the larger operators carry out in general both domestic and international bus 
and coach transport services52. In addition, the current rules on breaks and rest times may lead to competition 
problems. As  reported by the Confederation of Swedish Enterprises,  the two services may be in direct 
competition, for example for trips such as those described in Box 2, where Swedish passengers, leaving 
close to the Danish border prefer to buy trips sold by Danish operators to travel from south to north of 
Sweden. Moreover, the evidence suggests that domestic trips of around one week are very frequent. The 
proportion of domestic services  that  would  potentially benefit from the 12-day rule would  then have a 
meaningful impact on the market. In any case, the providers of domestic services face disadvantageous 
conditions compared to international services, which means that there is no level playing field between the 
two sectors.  

2.3. 

2.3. 

How likely is the problem to persist? 

Problem 1 - Inability to organise efficient and high-quality occasional bus and coach services. Without 
mandatory rules at the EU level which are well adapted to the occasional passenger sector, the inability to 
organise  efficient  and  high-quality  occasional  bus  and  coach  services  is  likely  to  persist.  While  some 
changes  are  expected  in  the  coming  years,  with  the  adoption  of  technologies  to  organise  trips  more 
effectively,  these  changes  are  not  expected  to  have  a  significant  impact  on  the  occasional  passenger 
transport. This is because of the specific characteristics of the sector, entailing heterogeneous itineraries, 
frequent  and  irregular  stops  and  a  high  degree  of  seasonality.  As  a  consequence,  the  low  customer 
satisfaction, demand and investment in the sector is likely to persist, also considering the sector’s reliance 
on tourism, susceptible to fluctuations of the fuel prices, and difficulties to attract and retain staff. In turn, 
the low investments in the sector may make it even more difficult for operators to provide high quality 
services and attractive working conditions.   

Problem 2: Inadequate working and driving conditions for drivers in occasional bus and coach transport. 
Without EU level intervention, the issues related to inadequate working and driving conditions for drivers, 
related to existing rules on breaks and rest periods, are likely to persist. Drivers would continue to be under 
stress and fatigue, notably due to inadequate mandatory rules and customers’ dissatisfaction.  

3.  3. WHY SHOULD THE EU ACT? 

3.1. 

3.1. 

Legal basis 

The EU competence for this initiative derives from Title VI 'Transport' of the Treaty on the Functioning of 
the European Union (in particular Article 91). The applicability of Title VI to road transport is stipulated in 
Article 100. The Union competence represented by these Treaty articles is shared with the Member States.  

Within this legal framework, the EU provides for coordinated and harmonised rules on breaks and rest 
periods for the occasional bus and coach sector, protecting working conditions for drivers and road safety 

50 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52017SC0184   
51 https://eur-lex.europa.eu/resource.html?uri=cellar:f81a95b9-4627-11e7-aea8-
01aa75ed71a1.0001.02/DOC_1&format=PDF (Part 1/2) 
https://ec.europa.eu/transport/sites/transport/files/swd20170186-ia-part2-driving-times.pdf (Part 2/2)  
7 https://ec.europa.eu/transport/modes/ 
52 This seems to indicate a single relevant market from a supply side perspective. As to SMEs, most of their activity is 
domestic.   

17 

 
                                                 
for all users across the Union. This initiative considers the adjustment of the current rules, regulated at the 
EU level. Drivers, road transport operators and citizens in general can benefit from high standards on breaks 
and rest periods for occasional bus and coach services across the Union.  

3.2. 

3.2. 

Subsidiarity: Necessity of EU action 

Under the principle of subsidiarity, in areas which do not fall within its exclusive competence, the Union 
shall act only if and in so far as the objectives of the proposed action cannot be sufficiently achieved by the 
Member States. Since transport is not an exclusive Union competence pursuant to Article 4(2)(g) TFEU, 
the subsidiarity principle applies.  

In the absence of amendments to Regulation (EC) No 561/2006, the identified problems are likely to persist, 
putting  at  risk  the  competitiveness  and  working  conditions  of  occasional  bus  and  coach  sector.  The 
identified problems apply across the entire Union and have the same underlying causes. Thus, EU level 
action is needed to ensure high standards for social rules in order to improve working conditions, road safety, 
and prevent distortions of competition on the European market.  

3.3. 

3.3. 

Subsidiarity: Added value of EU action 

The 2017 ex-post evaluation of Regulation (EC) No 561/2006 recognised the EU-added value and EU-
wide positive results from harmonising the minimum working conditions, for drivers and operators engaged 
in domestic and cross-border transport activities in the EU.  

EU-level action would  contribute to  achieving  well-fitted  rules  for road occasional  passenger transport 
sector and also contribute to reducing the shortage of drivers, which is however a wider issue going beyond 
this initiative. EU-level action is expected to have a positive impact on travel and tourism operators. It will 
enable  the  operators  and  drivers  to  organise  transport  operations  more  efficiently,  while  ensuring  high 
standards for the working conditions for drivers, and enforcing the existing rules effectively and consistently 
across borders. Member States are responsible for the enforcement of the breaks, rest and driving times 
rules under Regulation (EC) No 561/2006. They are notably required to carry out checks at the roadside 
and at the premises. The checks aim to determine the number and types of offences detected which depend 
of course on the number of vehicles and drivers in the undertaking concerned. As explained in section 1.2, 
the Commission prepares the implementation reports on the checks and their results every two years, based 
on the national submissions by the Member States. These reports show that there are differences between 
Member States on how the current rules are enforced.  A more consistent enforcement could be achieved 
by well-fitted rules.  

4.  4. OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1. 

4.1. 

General objectives 

In view of the problems identified in section 2, the general objectives of this initiative are: 

  Ensure efficient and high-quality occasional bus and coach services; 

 

Improve working and driving conditions for drivers, including the aspects of stress and fatigue of drivers 
in occasional bus and coach transport.  

The  initiative  is  linked  and  fully  consistent  with  the  ambition  of  the  Sustainable  and  Smart  Mobility 

18 

 
Strategy53 with respect to the need of helping the sector and relevant ecosystems of the occasional passenger 
transport value chain – such as travel and tourism operators – to bounce back better from the COVID-19 
pandemic and become more resilient while fostering a more attractive working environment for transport 
workers.  More  broadly,  the  initiative  contributes  to  the  Sustainable  Development  Goal  (SDG)  8 
(“Promoting economic growth, productive employment and decent work”)54. 

4.2. 

4.2. 

Specific objectives 

The specific objectives (SOs) and their correspondence with the problem drivers are presented in Figure 3. 

Figure 3: Correspondence between the objectives and the problem drivers 

SO1: Ensure more flexible distribution of breaks and rest periods. Aligning the relevant rules on breaks 
and rest periods to the specific characteristics and needs of occasional bus and coach sector is essential to 
allow operators to provide better customer-oriented services and to reduce the level of stress and fatigue for 
drivers.  

SO2: Promote equal treatment between international and domestic bus and coach operations. While 
the international bus and coach operations benefit from the 12-day rule, this is not available for domestic 
operations. Allowing access for domestic coach and bus operations to the 12-day rule would guarantee that 
all services are subject to the same regulatory framework and is expected to improve the level playing field 
between companies. This would also address the misalignment between the nature of occasional bus and 
coach services and the rules on rest periods, in particular in relation to the 12-day rule.   

5.  5. WHAT ARE THE AVAILABLE POLICY OPTIONS? 

5.1. 

5.1. 

What is the baseline from which options are assessed? 

The EU Reference scenario 2020 (REF2020) is the starting point for the impact assessment of this initiative. 
The REF2020 takes into account the impacts of the COVID-19 pandemic that had a significant impact on 
the transport sector. More detailed information about the preparation process, assumptions and results are 
included in the Reference scenario publication55. Building on REF2020, the baseline has been designed to 
include the initiatives of the ‘Fit for 55’ package. More details are provided in Annex 4. 

53 European Commission, Sustainable and Smart Mobility Strategy – putting European transport on track for the future, 
2021, https://transport.ec.europa.eu/transport-themes/mobility-strategy_en  
54 Communication from the Commission to the European Parliament, the Council, the European Economic and Social 
Committee and the Committee of the Regions: Next steps for a sustainable future, European action for sustainability, 
COM(2016) 739 final.  
55 https://energy.ec.europa.eu/data-and-analysis/energy-modelling/eu-reference-scenario-2020_en 

19 

PROBLEM DRIVERSSPECIFIC OBJECTIVESGENERAL OBJECTIVESPromote equal treatment between international and domestic bus and coach operations(SO2)Ensure moreflexibledistribution of breaks and rests periods (SO1)Ensure efficient and high-quality occasional bus andcoach servicesImprove working and driving conditions for drivers, including the aspects of stress and fatigue of drivers, in occasional bus and coach transport sector 
 
                                                 
The  baseline  scenario  assumes  no  further  EU  level  intervention  beyond  the  current  Regulation  (EC) 
561/2006, as amended by Regulation (EU) 2020/1054. Without EU level intervention, the rules on breaks 
and rest periods will remain unchanged over time. The issues related to inadequate working and driving 
conditions would likely persist. Drivers would continue to be under stress and fatigue, among other factors 
due to inadequate mandatory rules and customers’ dissatisfaction. Thus, the problems that occasional bus 
and coach companies face with the organisation of their services are expected to continue. While some 
changes  are  expected  in  the  coming  years,  with  the  adoption  of  technologies  to  organise  travel  more 
effectively,  these  changes  are  not  expected  to  have  a  significant  impact  on  the  occasional  passenger 
transport. This is because of the specific characteristics of the sector, entailing heterogeneous itineraries, 
frequent  and  irregular  stops  and  a  high  degree  of  seasonality.  As  a  consequence,  the  low  customer 
satisfaction, demand and investment in the sector is likely to persist, also considering the sector’s reliance 
on tourism, susceptible to fluctuations in the fuel prices, and difficulties to attract and retain staff.  

Indeed, the road transport sector has been struggling for several years to fill in vacant positions. The Covid-
19 restrictions and the Russian aggression in Ukraine have further exacerbated the problem. According to 
the “Driver Shortage European Report 2022” of IRU56, in 2021, there were 12,000 unfilled bus and coach 
driver positions in the six European countries studied57,58 and in the baseline this shortage is expected to 
grow in parallel with the growing demand.  

The  fluctuations  in  the  fuel  prices  also  play  a  significant  role  in  the  occasional  bus  and  coach  sector, 
especially  for  SMEs,  which  operate  on  low  margins.  Fuel  prices  represent  around  30%  of  the  total 
operational costs in the bus and coach sector59. When the prices for a holiday programme have been fixed, 
the operators have little margin to change the price for the passengers. If the operators have to cancel tours, 
this can highly disappoint and damage customer confidence.  

In turn, the low investments in the sector may make it even more difficult for operators to provide high 
quality services and attractive working conditions.   

The analysis incorporates throughout its dimensions relevant foresight tools. It does so to build a robust, 
future-proof evidence base for its likely impact. The baseline therefore incorporates foresight Megatrends60 
and developments captured in the 2022 Strategic Foresight report61. Among others, it captures the trend of 
increasing  demand  for  transport  as  population  and  living  standards  grow,  the  links  between  digital 
technologies and greening road transport by making it more efficient, and the shift towards zero-emission 
vehicles, etc. In particular, the projected transport activity draws on the long-term population projections 
from Eurostat and GDP growth from the Ageing Report 202162 by the Directorate General for Economic 
and Financial Affairs. Another megatrend that specifically impacts how the problems will likely evolve is 
“Shifting health challenges”. As Europeans are living longer and healthier lives, the challenges that come 

56 https://www.iru.org/resources/iru-library/driver-shortage-european-report-2022 
57 Denmark, Germany, Poland, Romania, Spain and Sweden.  
58 For example, in September 2022, the main recruitment website/platforms registered a total of 6,601 open position, including 
1,677 vacancies in Germany. The average age of bus and coach drivers is higher than in the entire transport sector. Moreover, 
about 30% of bus and coach drivers are expected to retire in five years. 
59 For instance, according to CONFEBUS, on average and according to prices of July 2022, fuel costs account for 27.9% 
of  the  overall  operational  costs  of  bus  and  coach  companies  operating  vehicles  with  more  than  55  seats 
(http://www.confebus.org/documentos/categoria/1/observatorios). 

60 https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en#explore  
61 https://ec.europa.eu/info/strategy/strategic-planning/strategic-foresight_en 
62 The 2021 Ageing Report : Underlying assumptions and projection methodologies The 2021 Ageing Report: Underlying 
Assumptions and Projection Methodologies | European Commission (europa.eu)   

20 

 
                                                 
 
with  it  affect  their  fitness  to  drive  at  different  ages  and  would  be  a  positive  driver  for  the  demand  of 
occasional bus and coach services. 

The COVID-19 pandemic had a major impact on tourism and the occasional bus and coach sector in 2020, 
which only partially recovered in 2021, before a boom in summer 2022 in certain markets, due to relaxed 
travel restrictions within Europe, continued reticence to travel further afield and currency fluctuations that 
pulled in visitors from North America. At the same time, the war in Ukraine has caused unexpected shifts 
in travel patterns in Central and Eastern Europe.  

The number of passengers in the occasional bus and coach sector is estimated to have decreased by 86% in 
2020 relative to 2019. By 2025, at EU level the number of passengers in the occasional bus and coach sector 
is projected to recover close to pre-pandemic levels, driven by the recovery of the tourism sector. This is 
however  not  expected  to  be  the  case  in  all  Member  States  (i.e.  Eastern  European  Member  States,  in 
particular, still showing lower numbers of passengers in the occasional bus and coach sector by 2025 relative 
to 2019). The number of passengers in the occasional bus and coach sector is projected to grow by 15% by 
2030 and 38% by 2050, relative to 2019. Transport activity in the occasional bus and coach sector, expressed 
in passenger-kilometres, is projected to follow a similar trend and would grow by 16% by 2030 relative to 
2019 (41% increase for 2019-2050). 

The passengers in the occasional bus and coach sector represented 3.3% of the total number of passengers 
in the bus and coach sector in 2019 at EU level. Due to the pandemic, the share plummeted to 0.5% in 2020. 
Nonetheless, the share of occasional bus and coach sector is projected to reach 2.4% by 2025, driven by the 
partial recovery of the sector, and remain relatively stable over time reaching 2.4% by 2030 and 2.6% by 
2050.  

The  turnover  for  the  occasional  bus  and  coach  sector  is  projected  to  grow  in  line  with  the  number  of 
passengers in the sector and is estimated to reach EUR 7.5 billion by 2030 and EUR 8.9 billion by 2050. 
Operating costs are estimated to represent around 10% of the turnover. 

5.2. 

5.2. 

Description of the policy measures and policy options 

As  a  first  step,  a  comprehensive  list  of  possible  policy  measures  was  established  after  extensive 
consultations with stakeholders, expert meetings, and independent research in the context of the impact 
assessment support study63 and the Commission’s own analysis.  

The list of policy measures was further refined, and complemented with compensatory measures (PM4, 
PM5, PM7 and PM8) to address specific concerns expressed by stakeholders. These relate in particular to 
measures that would allow drivers involved in long services to postpone the start of the daily rest period. 
The purpose of these measures is to allow drivers to extend the working day only in certain circumstances. 
Stakeholders’ view was essential in this respect. This list was subsequently screened based on the likely 
effectiveness, efficiency, proportionality and coherence of the proposed measures in relation to the given 
objectives, as well as their legal, political and technical feasibility. 

Trade unions also voiced to remove the 12-day rule. As explained below, this measure has been discarded.  

As regards the need of longer breaks after 4.5 hours of driving, trade unions also voiced for longer than 
existing  minimum  breaks  or  for  keeping  at least  30-minutes breaks.  However,  one  30-minute break  is 
justified in case of freight and regular passenger transport where working day is mostly dedicated to driving. 
Occasional passenger drivers usually drive half of that time. They have many opportunities to have breaks 

63 Tetra Tech International et al. (forthcoming), Study supporting the Bus and Coach Impact Assessment.  

21 

 
                                                 
(to walk, read, or take a nap) when passengers participate in touristic activities. The current rules do not 
allow these breaks to be fully considered as qualifying breaks. For the same reason, longer than current 45 
minutes breaks after 4.5 hours driving would not be justified for the occasional passenger segment. As 
explained above, the driving of occasional coach drivers is less tiring than the driving of lorry drivers and 
drivers engaged in regular passenger transport as they drive much less.  

Discarded policy measures 

One policy  measure  has been discarded, namely, the measure removing the 12-day rule.  This measure 
would completely remove any differences between occasional passenger services and other road transport 
segments. It was then decided not to explore such  a measure, as this runs counter to the  2017 ex-post 
evaluation, which recognised distinct occasional passenger services needs, and consequently to the mandate 
established under Article 8(10) of the Regulation, i.e. to assess whether more appropriate rules in occasional 
passenger services can be adopted.  

Retained policy measures and policy options overview 

The retained policy measures have been grouped in 3 policy options (PO A, PO B and PO C) as presented 
in Table 2. The table presents the links of the retained policy measures with the specific policy objectives 
and the POs.  

The  policy  options diverge  in  terms  of the  flexibility  granted to breaks  rules, the  eligibility  criteria for 
postponing daily rest periods, and the need to cater for adaptable weekly rest periods. PO B, in particular, 
allows rest periods to be concentrated at times when the demand for services is lower. Further to this, PO C 
includes a specific measure that would allow bus and coach operators to organise more services during the 
peak season, by removing the obligation of taking two regular weekly rest periods after using the 12-day 
derogation and by removing the ´single service condition´ when using the 12-day rule (PM10). 

Table 2: Links between policy measures, policy options and specific objectives 

Specific objective  

Policy measure (PM) 

Policy option 

PO A  

PO B 

PO C 

Breaks 

Daily rest periods 

SO1 

SO1 

√ 

√ 

√ 

√ 

√ 

PM1: Allow drivers to split their 
break  of  minimum  45  minutes 
into  30  +  15  or  15  +  15  +  15 
minutes. 
PM2:  Allow  drivers  to  flexibly 
split  their  break  of  minimum  45 
minutes  over  the  period  of  4h30 
driving time. 

PM3:  Allow  drivers  involved  in 
services lasting at least 8 days to 
postpone the start of the daily rest 
period  by  1  hour  provided  that 
they  do  not  drive  more  than  7 
hours. 
PM4:  Allow  drivers  involved  in 
services lasting at least 8 days to 
postpone the start of the daily rest 
period  by  1  hour  provided  that 
they  do  not  drive  more  than  7 
hours.  This  could  only  be  used 
once  during  a  trip  and  not  every 
day of the same trip. 

22 

 
 
 
 
 
 
 
 
Specific objective  

Policy measure (PM) 

Policy option 

PO A  

PO B 

PO C 

PM5  Allow  drivers  involved  in 
services lasting at least 8 days to 
postpone the start of the daily rest 
period  by  1  hour  provided  that 
they  do  not  drive  more  than  7 
hours.  This  could  only  be  used 
twice during a trip and not every 
day of the same trip. 
PM6:  Allow  drivers  involved  in 
services lasting at least 8 days to 
postpone the start of the daily rest 
period  by  2  hours  provided  that 
they  do  not  drive  more  than  5 
hours.  
PM7:  Allow  drivers  involved  in 
services lasting at least 8 days to 
postpone the start of the daily rest 
period  by  2  hours  provided  that 
they  do  not  drive  more  than  5 
hours.  This  could  only  be  used 
once  during  a  trip  and  not  every 
day of the same trip.  
PM8:  Allow  drivers  involved  in 
services lasting at least 8 days to 
postpone the start of the daily rest 
period  by  2  hours  provided  that 
they  do  not  drive  more  than  5 
hours.  This  could  only  be  used 
twice during a trip and not every 
day of the same trip. 

of 

passengers 

PM9:  Allow  bus  and  coach 
drivers  in  domestic  occasional 
carriage 
to 
postpone  the  weekly  rest  period 
for up to 12 consecutive 24-hour 
periods  following  a  previous 
regular weekly rest period. 
PM10:  Removal  of  the  single 
service condition when using the 
12-day rule, to allow for a driver 
to  drive  multiple  tour  groups  (in 
addition to extending 12-day rule 
to domestic occasional carriage of 
passengers).  
PM11: Removal of the obligation 
of taking two regular weekly rest 
periods after using the derogation 
(in  addition  to  extending  12-day 
rule 
to  domestic  occasional 
carriage of passengers). 
PM12:  Flexible  distribution  of 
weekly  rests  over  a  10-week 
reference  period,  to  allow  that 
more  24-hour  rest  periods  could 
and 
a 
be 
compensated later. 

taken 

row 

in 

23 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

Weekly rest periods – 12-day rule 

SO2, SO1 

SO2, SO1 

 
  
  
 
 
 
 
 
 
 
 
 
 
 
  
 
5.2.1.  5.2.1. 

Policy  Option  A:  Restricted  adaptation  to  occasional  passenger 

services 

Policy option A (PO A) consists in introducing some flexibility to what concerns the distribution of breaks, 
by bringing them more in line with the rhythm of typical occasional passenger operations. This would allow 
drivers to split their breaks of minimum 45 minutes not only as currently allowed into 15+30 minutes, but 
also into 30+15 minutes or 15+15+15 minutes (PM1).  

In addition, PO A allows drivers engaged in services lasting at least 8 days and longer to postpone the start 
of their daily rest period by 1 hour, provided that the total daily driving time on that day does not exceed 7 
hours (PM4). In addition, under this policy option, drivers engaged in services that last at least 8 days and 
longer may be allowed to postpone the start of their daily rest period by 2 hours, provided that the total daily 
driving time that day does not exceed 5 hours (PM7). To avoid any increase in stress and fatigue levels 
(which would in turn jeopardise road safety), a restriction was introduced to mitigate potential negative 
effects. Access to either of these two measures can only be used once during a single service lasting at least 
8 days, making it impossible to use the flexibility on a regular basis. The rationale is that such multi-day 
services normally have very limited daily driving time, except for the first and last day of the journey.  

Policy  option  A  additionally  includes  changes  to  the  12-day  derogation,  which  currently  represents  a 
restricted postponement of the weekly rest period that allows drivers of domestic services to postpone their 
weekly rest periods for up to 12 consecutive 24-hour periods, as long as they have had a previous regular 
weekly rest period. This provision is currently only available for companies operating international services. 
Its  extension  to  domestic  services  (PM9)  would  place  domestic  services  on  a  level-playing  field  with 
international services, allowing them to organise long domestic operations under the same conditions as 
international services (e.g. obviating the need to staff certain trips with two drivers), while drivers could 
increase their workload if desired (e.g. during peak seasons) and make it easier to organise rest periods at 
home with their families rather than at a distant location during a trip.  

How does the policy option PO A address the specific objectives? 

SO1 – Ensure more flexible distribution of breaks and rest periods 
This option addresses SO1 by allowing drivers to split their breaks more flexibly (PM1). Higher levels of 
adaptability can be especially relevant when drivers carry out trips without a pre-determined itinerary, which 
is often the case in excursions. These services make drivers’ break times unpredictable, and they must cater 
to the customers’ needs and schedules. PO A foresees a provision that would allow drivers engaged in 
services that last at least 8 days to postpone the daily rest period by one hour, provided they do not drive 
more than 7 hours and they use this provision only once during a tour (PM4). They would also be able to 
postpone the start of the daily rest period by 2 hours provided they do not drive more than 5 hours and they 
use this not more than once during a tour (PM7). The extension of the 12-day derogation (PM9) additionally 
contributes to SO1. 

SO2 - Promote equal treatment between international and domestic bus and coach operations 
The extension of the 12-day derogation (PM9) ensures that all operators are bound by the same regulatory 
framework, favouring particularly those more reliant on domestic services. It therefore would be expected 
to have a strong impact on the level playing field between companies, favouring particularly those more 
reliant on domestic services. It may also be beneficial to Member States such as Germany and Bulgaria, 
facilitating longer domestic services.  

24 

 
5.2.2.  5.2.2. 

Policy  Option  B:  Semi-flexible  adaptation  to  occasional  transport 

operations 

Policy option B (PO B) includes further levels of flexibility to meet the occasional passenger sector’s needs. 
It would allow drivers to split their breaks in a completely flexible manner (PM2), which can be especially 
relevant for unpredictable trips. It also brings the possibility for drivers involved in services lasting at least 
8 days to distribute their weekly rest periods over 10 consecutive weeks (PM12). PM12 would have a 
significant impact on businesses, particularly on coach operators and self-employed drivers, who would be 
able to avoid prolonged inactivity (i.e. from longer resting periods) during the peak season. 

PO B would also give operators and drivers access to provisions that postpone daily rest periods whenever 
the driving time has not reached certain thresholds. In this regard, the policy option foresees a provision that 
would allow drivers engaged in services that last at least 8 days to postpone the daily rest period by one 
hour, provided they do not drive more than 7 hours and they use this provision not more than on two 
occasions during a tour (PM5). They would also be able to postpone the start of the daily rest period by 2 
hours provided they do not drive more than 5 hours and they use this not more than on two occasions (PM8). 
While  ensuring  working  conditions,  these  measures  would  enable  operators  to  organise  services  more 
efficiently (particularly avoiding the need for multiple drivers on certain trips) and in line with customer 
needs, as well as giving self-employed drivers the opportunity to take on more work during busy peak 
periods. 

How does the policy option PO B address the specific objectives? 

SO1 – Ensure more flexible distribution of breaks and rest periods 
PO  B  addresses  this  objective  as  it  allows  operators  and  drivers  to  have  greater  control  of  the  driving 
schedule and become fully able to organise stops according to service needs (PM2), which may include 
mini breaks of 5 minutes, thus aiming to reduce the stress and anxiety related to catering to passenger 
demands within rigid patterns of 30 and 15 minutes of break. The changes to rest time period rules (PM5 
and PM8) also address SO1. PM12 would increase flexibility for weekly rests, allowing more services to 
be organised during peak seasons.  

SO2 - Promote equal treatment between international and domestic bus and coach operations 
PM12 would make it easier for companies providing domestic services (and thus not having access to the 
12-day rule) to adapt weekly rests to operational needs, despite the fact that the 12-day rule would remain 
accessible only for international services. 

5.2.3.  5.2.3. 

Policy  Option  C:  more  flexible  adaptation  to  occasional  transport 

operations 

Policy option C (PO C) aims to full adaptation of the rules to meet market needs with regard to distributing 
breaks, daily rests and arrangements and for relaxing the needs for weekly rest for bus and coach drivers 
involved in domestic and international tours. Besides expanding the 12-day derogation (PM9), this policy 
option  would  remove  the  obligation  to  take  two  regular  weekly  rest  periods  after  using  the  12-day 
derogation (PM11). The combination of these provisions on rest periods is a crucial feature of this policy 
option, as it would allow bus and coach operators to schedule more tourist groups during the peak season. 
Moreover, this option would allow drivers to split their breaks in a completely flexible manner (PM2) and 
give them access to provisions that postpone daily rest periods whenever the driving time has not reached 
certain thresholds (PM3 and PM6). Finally, PO C also removes the single service condition when using the 
12-day rule (PM10), allowing coach companies to organise multiple tour groups while making use of the 
12-day derogation. 

25 

 
It is however important to emphasise that owing to the provision of less restrictive rules, the proposed 
measures could also be expected to have a negative impact on working condition and driver stress levels / 
fatigue and consequently face strong opposition of trade unions.   

How does this policy option address specific policy objectives? 

SO1 – Ensure more flexible distribution of breaks and rest periods 
PO  C  addresses  this  objective  as  it  allows  operators  and  drivers  to  have  greater  control  of  the  driving 
schedule and become fully able to organise stops according to service needs, which may include mini breaks 
of 5 minutes, thus aiming to reduce the stress and anxiety related to catering to passenger demands within 
rigid patterns of 30 and 15 minutes of break (PM2). PO C would also give operators and drivers access to 
provisions that postpone daily rest periods whenever the driving time has not reached certain thresholds. In 
this regard, the policy option foresees a provision that would allow drivers engaged in services that last at 
least 8 days to postpone the daily rest period by one hour, provided they do not drive more than 7 hours 
(PM3) or up to two hours provided they do not drive more than 5 hours (PM6), without any use limit during 
a trip. PM9, PM10 and PM11 additionally contribute towards SO1.  

SO2 - Promote equal treatment between international and domestic bus and coach operations 
PO C addresses this objective by extending the 12-day rule to domestic services (PM9) and removing the 
obligation for it to be employed only to a single service, opening it up to greater use (PM10). It also removes 
additional compensatory rest, allowing drivers to work more during the peak periods instead of having a 
prolonged rest after using the 12-day derogation (PM11). This can be particularly relevant for SMEs, as 
they typically rely on a smaller pool of available drivers, and it can also benefit self-employed drivers.  

6.  6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

This section summarizes the main expected economic, social and environmental impacts of each policy 
option  (PO)64.  The  proposed  measures  are  assumed  to  be  implemented  from  2025  onwards,  so  the 
assessment  has  been  undertaken  for  the  2025-2050  period  and  refers  to  EU27.  Costs  and  benefits  are 
expressed as present value over the 2025-2050 period, using a 3% discount rate. Further details on the 
methodological approach and impacts on costs and benefits by measure for the policy options are provided 
in Annex 4.  

Overall,  the  assessment  of  impacts  mostly  relies  on  stakeholders’  views.  Only  the  costs  related  to 
familiarising with the new rules and the benefits related to the reduction in operational costs were possible 
to quantify. For the working conditions only a qualitative assessment was possible. As explained above, this 
is because research on the topic is very limited and mostly focuses on urban public transport and commuting 
services.  

The scarcity of quantitative, granular data on the occasional bus and coach sector, limited the extent of the 
quantitative assessment to the impacts on costs and benefits. Given the small size of the occasional bus and 
coach sector65  and  the  relatively  limited  scope  of the  rules under  review, a  proportionate  analysis  was 
conducted in line with the Better Regulation toolbox.  

64 The analysis is based on the Tetra Tech International et al. (2022), Support study for an impact assessment for a possible 
revision of Regulation (EC) No 561/2006, and on the analysis of stakeholders' feedback. 
65 It should be noted that the size of the occasional bus and coach sector is small. In 2019 it represented 3.3% of the total 
number of passengers in the bus and coach sector at EU level and generated roughly 11% of the total turnover of road 
passenger transport. The sector is estimated to employ around 202,600 people. 

26 

 
                                                 
To ensure the validity of the results, to the extent possible this consisted of objective and factual input and 
concrete examples. Stakeholders on a wide geographical basis were consulted. This was done through the 
inception impact assessment, public consultation, targeted interviews and case studies. For the targeted 
interviews, the selection of interviewees was based on specific profiles to ensure that the main groups of 
stakeholders were covered and interviewees with a variety of profiles were selected (e.g. employed versus 
self-employed drivers, small versus larger operators, different Member States, trade unions). Findings were 
also  triangulated  between  different  groups  of  stakeholders  and  data  collection  tools.  Overall,  this  has 
allowed the results to be presented with sufficient confidence, for a sufficiently broad and detailed insight 
to be gathered, with the main stakeholder groups being covered and geographical diversity being respected. 
Nonetheless, the statistically representative samples method was only used in a few cases.  

6.1. 

6.1. 

Economic impacts 

This section provides the economic impacts of the POs on bus and coach operators. It also provides an 
assessment of impacts on small and medium enterprises (SMEs), the functioning of the internal market and 
competition, and on competitiveness. It also covers the impact on compliance with the rules and the impact 
on public authorities. The assessment of economic impacts draws on multiple data sources, including the 
targeted interviews and the public consultation, and findings from desk research.  

A quantitative assessment of the impacts of the policy measures and options on adjustment costs for bus 
and coach operators and on public authorities has been performed (see more details in Annex 4). This should 
however be regarded as a rough estimate, drawing on the replies to the stakeholders’ consultation. This is 
complemented, at the level of policy options, by a qualitative66 assessment of the combined impacts of the 
policy measures included in each PO.  

6.1.1.  6.1.1. 

Impact on bus and coach operators 

Administrative costs for bus and coach operators. None of the policy options introduces changes in the 
reporting relative to the baseline. Therefore, none of the policy options entail administrative costs relative 
to the baseline.  

Adjustment costs for bus and coach operators. All three policy options entail minor adjustments to the 
rules, that require bus and coach operators in the sector to familiarise themselves with the changes67. 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 24.968 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 (see Table 3). This should be regarded as an upper-
bound estimate, as it is very likely that familiarising with the new rules would take place in the context of 
the regular activities performed by the bus and coach operators.  

66 To mark the direction (positive or negative) and the scale of the impact, a scoring system is used to compare the options 
with  the  baseline  scenario.  From  “-----”  (significant  negative  impact)  through  “0”  (no  difference  from  baseline)  to 
“+++++” (significant positive impact). 
67 It is not possible to split the one-off adjustment costs for bus and coach operators, for familiarising with the new rules, 
by measure. Therefore, these costs are presented by policy option and cover the time needed for bus and coach operators 
to familiarise themselves with the changes related to all measures. 
68 Source: Eurostat database, Labour Cost Survey, ISCO 4 (Clerks)  

27 

 
                                                 
Cost  savings from  greater flexibility (adjustment  costs savings)  for  bus  and  coach operators.  All 
policy options enable to meet better the customer demand and improve the quality of services provided. 
They all result in adjustment costs savings for the bus and coach operators.  

More specifically, the higher flexibility of breaks relative to the baseline (i.e. measure PM1 in PO A, and 
PM2 in PO B and PO C) is expected to lead to higher passenger satisfaction. It would also allow transport 
operators to organise better passenger services, leading to a reduction in operation costs. For PM1, six bus 
and coach operators interviewed in the context of the targeted consultation estimate that this would generate 
operation cost savings of approximately 0.5% relative to the baseline. In turn, operators estimate that PM2 
could lead to operation cost savings of 0.5 to 1% relative to the baseline. These cost savings are expected to 
reach their maximum effect in the first two years of implementation of the new rules, and then decrease 
gradually over time, up to zero in the long-term (by 2050) relative to the baseline. For PM1 (included in PO 
A), the adjustment costs savings are estimated at EUR 3.2 million in 2025, EUR 2.7 million in 2030 and 
EUR 1.4 million in 2040, while for PM2 (included in PO B and PO C) they are estimated at EUR 3.2 to 6.4 
million in 2025, EUR 2.7 to 5.5 million in 2030 and EUR 1.4 to 2.7 million in 2040 (see Table 3). Over 25 
years of implementation, the adjustment costs savings related to the flexibility of breaks are estimated at 
EUR 35.5 million for PO A and at EUR 35.5 to 70.9 million for PO B and PO C, expressed as present value 
over 2025-2050 relative to the baseline (in 2021 prices).  

The higher flexibility of taking daily rest periods (i.e. measures PM4 and PM7 in PO A, PM5 and PM8 in 
PO B, and PM3 and PM6 in PO C) are expected to lead to a small but positive impact on the ability of 
companies to meet customer needs. All policy measures on daily rest periods would also likely help to cope 
with the overall shortage of drivers, guaranteeing a good service performance with one single driver. In 
addition, all measures are expected to lead to greater flexibility in tour planning, thus leading to a reduction 
in operation costs. The two measures related to daily rest periods included in each option (e.g. measures 
PM4 and PM7 in PO A) are expected to have a large degree of overlap in terms of reduction in the operation 
costs and are thus assessed together. Six bus and coach operators interviewed in the context of the targeted 
consultation estimated that the measures would generate operation cost savings of 0.5 to 1% relative to the 
baseline.  These  cost  savings  are  expected  to  reach  their  maximum  effect  in  the  first  two  year  of 
implementation of the new rules and then gradually decrease over time, with savings expected to be zero in 
the long-term (by 2050) relative to the baseline. The operation costs savings due to daily rest periods are 
expected to be relatively similar between PO A, PO B and PO C. No further distinction between these costs 
was possible. Thus, the adjustment costs savings for PO A, PO B and PO C are estimated at EUR 3.2 to 6.4 
million in 2025, EUR 2.7 to 5.5 million in 2030 and EUR 1.4 to 2.7 million in 2040 relative to the baseline 
(see Table 3). Over 25 years of implementation, the adjustment costs savings related to daily rest periods 
are estimated at EUR 35.5 to 70.9 million for all policy options, expressed as present value over 2025-2050 
relative to the baseline (in 2021 prices).  

As regards weekly rest periods (12-day rule), the impact of PM9 in PO A and PO C on customer demand 
was  found  to  be  only  indirect  and  limited.  Nonetheless,  allowing  bus  and  coach  drivers  in  domestic 
occasional carriage of passengers to use the 12-day rule would facilitate companies to offer longer domestic 
services, thus extending the range of available tourist tours. It would also ensure greater flexibility in driver 
assignment, thus reducing operation costs. Similarly, PM10 and PM11 in PO C and PM12 in PO B are also 
expected to have a positive impact on the business performance, by allowing to organise services more 
flexibly, particularly during peak seasons when driver shortages are most acute. In this regard, six bus and 
coach operators interviewed estimated that PM9, PM10 and PM11 would each generate operation cost 
savings of approximately 0.5% relative to the baseline, while PM12 would lead to operation cost savings 
of 0.5  to 1%.  These  cost  savings  are  expected  to reach their maximum  effect in  the  first  two  years  of 
implementation of the new rules, and then gradually decrease over time with savings expected to be zero in 
the long-term (by 2050) relative to the baseline. Thus, the adjustment costs savings related to weekly rest 
periods (12-day rule) are estimated (see Table 3) to be the highest in PO C (EUR 9.5 million in 2025, EUR 

28 

 
8.2 million in 2030 and EUR 4.1 million in 2040 relative to the baseline), followed by PO B (EUR 3.2 to 
6.4 million in 2025, EUR 2.7 to 5.5 million in 2030 and EUR 1.4 to 2.7 million in 2040 relative to the 
baseline), and PO A (EUR 3.2 million in 2025, EUR 2.7 million in 2030 and EUR 1.4 million in 2040). Over 
25 years of implementation, the adjustment cost savings related to weekly rest periods (12-day rule), are 
estimated at EUR 35.5 million in PO A, EUR 35.5 to 70.9 million in PO B and EUR 106.4 million in PO 
C, expressed as present value over 2025-2050 relative to the baseline69.   

Overall, PO A results in  adjustment costs savings for  bus and coach  operators of EUR  106.4 to 141.9 
million, expressed as present value over the 2025-2050 period relative to the baseline, while PO B results 
in adjustment costs savings of EUR 106.4 to 212.8 million and PO C in adjustment costs savings of EUR 
177.3 to 248.3 million. 

Table 3: Costs and costs savings for bus and coach operators by policy option and measure relative to the baseline (in 
million EUR), in 2021 prices 

Difference to the baseline 

PO A 

PO B 

PO C 

2025 

2030 

2040  2050  2025 

2030 

2040  2050  2025 

2030 

2040  2050 

0.6 

0.6 

0.6 

3.2  

2.7  

1.4  

0.0  

3.2-6.4  2.7-5.5  1.4-2.7  0-0  3.2-6.4  2.7-5.5  1.4-2.7  0-0 
3.2-6.4  2.7-5.5  1.4-2.7  0-0 

3.2-6.4  2.7-5.5  1.4-2.7  0-0 

3.2  

2.7  

1.4  

0.0  

3.2-6.4  2.7-5.5  1.4-2.7  0-0 

3.2-6.4  2.7-5.5  1.4-2.7  0-0 

3.2  
3.2  
3.2  

2.7  
2.7  
2.7  

1.4  
1.4  
1.4  

0.0  
0.0  
0.0  

Adjustment costs 
Adjustment costs 
savings 
PM1 
PM2 
PM3 and PM6 
PM4 and PM7 
PM5 and PM8 
PM9 
PM10 
PM11 
PM12 

Source: Tetra Tech International et al. (2022), Impact assessment support study 

Net costs savings for bus and coach operators. Considering both the adjustment costs and the adjustments 
costs savings discussed above, the net costs savings for the bus and coach operators are estimated to be the 
highest in PO C (EUR 176.7 to 247.7 million), followed by PO B (EUR 105.8 to 212.2 million) and PO A 
(EUR 105.8 to 141.3 million), expressed as present value relative to the baseline.  

With regard to competitiveness and the level of responsiveness to customer demand, all policy options 
are expected to lead to benefits, although PO C and PO B would offer greater benefits than PO A, as shown 
in Table 4. However, the impacts were hard to pin down in all cases, with stakeholders that responded to 
the consultation activities tending to suggest that only limited benefits could be expected from any of the 
proposed options.  

Table 4: Impacts of policy options on operational costs, service quality, demand and competitiveness 

PO A  

PO B  

PO C 

Breaks 

0/+ 

+ 

+ 

Reasoning 
Operators and business associations favoured changes 
to  make  the  break  time  rules  more  flexible  and 
provided  examples  of  how  these  would  improve  the 
level  of  services  and  help  to  increase  the  level  of 
compliance.  Nevertheless,  a  somewhat  stronger 
positive benefit is expected for PM2 (included in PO B 

69 While it was not possible to estimate the proportion of services that would benefit from extending the 12-day rule, this 
is expected to be significant based on the large proportion of services that are domestic and popularity of trips of around 
one full week. 

29 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
                                                 
PO A  

PO B  

PO C 

Daily rest 
periods 

+ 

+/++ 

++ 

Weekly rest 
periods 

+ 

+ 

++ 

Overall 

++/+++ 

+++/++++ 

+++++ 

Reasoning 
and PO C) relative to PM1 (included in PO A), given 
its greater flexibility relative to the current rules. 
Increased levels of eligibility for postponing daily rest 
periods in PO B and in particular in PO C may provide 
better customer-oriented services and make it easier to 
set  attractive  occasional  bus  and  coach  services.  All 
policy options are also expected to lead to cost savings 
related, for instance, to the need to staff a second driver 
during a service. 
While it was not possible to estimate the proportion of 
services that would benefit from extending the 12-day 
rule, this is expected to be  significantly based on the 
large  proportion  of  services  that  are  domestic  and 
popularity of trips of around one full week. This would 
make  such  trips  easier  to  organise,  especially  for 
SMEs,  and  thereby  improve  service  quality  and 
business  performance.  Both  PO  A  and  PO  B  are 
expected  to  generate  benefits  in  terms  of  reduced 
operational costs. These would likely be higher for PO 
C,  since,  without  the  requirement  for  compensatory 
rest after using the 12-day rule and the single-service 
condition, drivers could be deployed more often. 
All  three  options  got  support  from  bus  and  coach 
operators,  business  associations  and  self-employed 
drivers that responded to the consultation activities, as 
ways to adapt the rules to occasional services, thereby 
making it easier to ensure service quality at lower cost. 
The  benefits  are  expected  to  be somewhat higher  for 
PO C, since this option would make it easier to deal 
with  unexpected  events  (e.g.  traffic,  late-running 
activities),  without  resorting  to  costly  solutions  like 
additional  drivers  or  reducing  service  quality.  The 
benefit  of  the  12-day  rule  within  PO  C  would  be 
expected to be greater and more costs could be saved 
thanks to the lack  of compensatory measures to limit 
the  use  of  the  extended  duty  cycle,  the  provision  of 
more flexible breaks and the possibility to generalise 
the use of the extended duty cycle. 

Source: Tetra Tech International et al. (2022), Impact assessment support study 

6.1.2.  6.1.2. 

Impacts on small and medium enterprises (SMEs) 

SMEs play a significant role in the occasional bus and coach transport market. Therefore, the initiative is 
considered relevant for the SMEs and the SME test has been performed.  

The affected businesses (step 1 of the SME test) were estimated to account for around 85% of the occasional 
passenger  transport  drawing  on  studies  by  International  the  Road  Transport  Union  (IRU)70  and  the 
European Transport Workers’ Federation (ETF)71.   

SMEs were targeted explicitly in the consultation activities (step 2 of the SME test), both through dedicated 
questions in the public consultation and two case studies, one focused on small enterprises for Portugal and 
another one focused on medium enterprises for Germany and the Netherlands72. SMEs are more affected 

70 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. 
71  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.  
72 Tetra Tech International et al. (2022), Support study for an impact assessment for a possible revision of Regulation 
(EC) No 561/2006, in particular Annex 7. 

30 

 
 
                                                 
than larger businesses by the problems related to the current rules, e.g. because they have a smaller pool of 
drivers to deal with a complicated scheduling and trips requiring multi-manning. It is important to note that 
108 out of 158 of the responses to the public consultation were provided by micro or small companies. This 
comes out of the case studies performed.  

In relation to the measurement of the impact on SMEs (step 3 of the SME test),  as shown in  Table 5, 
measures on breaks (PM1 and PM2) would equally benefit SMEs and larger operators, while measures 
targeting daily rest periods (i.e. PM3 to PM8) and weekly rest periods (i.e. PM9 to PM12) would benefit 
SMEs more than larger companies. Indeed, the problems are experienced most acutely by SMEs, as such 
companies tend to operate with very little margin – they have a limited pool of drivers and buses, while the 
resources that they do have are geographically concentrated. They also face higher risks of non-compliance, 
as  companies  fight  to  address  driver  shortages,  and  the  need  to  deal  with  unforeseen  issues  at  distant 
locations.  

Given the particular difficulties faced by SMEs in dealing with the current rules, the analysis has shown that 
the simplifications would benefit more than larger operators from increased flexibility with regard to the 
weekly rest rules73. Table 5 summarises the impacts in relative terms. Importantly, the scores presented in 
the table depict the impacts relative to those foreseen for the occasional bus and coach sector as a whole, 
and not the absolute impacts. All three policy options are expected to lead to larger benefits for SMEs than 
for larger operators in the sector, with greater relative benefits expected for PO C due to the importance of 
PM11 (on removing the need for compensatory rest after using the 12-day rule) for SMEs. 

Table 5: Impacts of policy options on SMEs 
PO B 

PO A 

Break times 

0 

0 

PO C 

0 

Daily rest 
periods 

+ 

+ 

+ 

Weekly rest 
periods 

+ 

+ 

++ 

Overall 

++ 

++ 

+++ 

Reasoning 
While  SMEs  would  benefit  from  more  flexible  break 
times, these benefits would be similar to those expected 
for the larger operators in the sector. 
Increased levels of eligibility for postponing daily rest 
periods  would  improve  the  economic  performance  of 
SMEs  and  allow  them  to  compete  with  larger 
companies 
that  have  more  available  resources, 
particularly when it comes to the availability of drivers 
to  cover  services  that  are  typically  organised  at  late-
night  or  early-morning  periods  and  that  exceed  their 
regular duty service. PM5 and PM8 in PO B and PM6 
in  PO  C  are  also  expected  to  enable  cost  savings 
related, for instance, to the need to staff a second driver 
during a multi-day service, as they can be applied with 
less  restrictions  provided  that  drivers  are  engaged  in 
services lasting at least 8 days. In all cases, the benefits 
are expected to be more important for SMEs than for   
larger operators in the sector. 
Similar to daily rest periods, the measures for increased 
flexibility on weekly rest periods would  benefit more 
to SMEs than to larger overators in the sector, due to 
their limited resources. This was found especially to be 
the  case  for  PM11,  which  makes  PO  C  especially 
beneficial for SMEs, relative to larger operators in the 
sector. 
All three policy options are expected to lead to larger 
benefits  for  SMEs  than  for  larger  operators  in  the 
sector, with greater relative benefits expected for PO C 

73 The role that these measures can play for SMEs has been illustrated in specific case studies focused on this business 
segment, notably a case study on medium-sized companies based in north-western EU Member States and a case study 
that looked more in depth to the specificities of small companies based in peripheral countries with high tourism flows, 
such as Portugal. More information is available in  Tetra Tech International et al. (2022), Support study for an impact 
assessment for a possible revision of Regulation (EC) No 561/2006.   

31 

 
 
                                                 
PO A 

PO B 

PO C 

Reasoning 
due to the importance of PM11 (on removing the need 
for compensatory rest after using the 12-day rule) for 
SMEs. 

Source: Tetra Tech International et al. (2022), Impact assessment support study 

As explained in section 6.1.1, all policy options are expected to result in net costs savings for occasional bus 
and coach operators, estimated at EUR 176.7 to 247.7 million in PO C, followed by PO B with net costs 
savings estimated at EUR 105.8 to 212.2 million and PO A with net costs savings estimated at EUR 105.8 
to 141.3 million, expressed as present value relative to the baseline. Considering the large share of SMEs in 
the occasional bus and coach transport market a significant share of these net costs savings are expected to 
be attributed to them although the available data did not allow a split of operational costs between the two 
groups of occasional bus and coach operators (i.e. SME and others).  

In relation to minimizing negative impacts on SMEs (step 4 of the SME test), it should be noted that none 
of the proposed changes was identified to have negative impacts on SMEs, or to provide less benefits to 
SMEs than to other operators. On the contrary, the simplifications and benefits of the initiative are expected 
to be felt more strongly by SMEs than by the sector as a whole. 

6.1.3.  6.1.3. 

Impact on the functioning of the internal market and competition 

The measures on breaks (PM1 and PM2) and the measures on daily rest periods (i.e. PM3 to PM8) would 
equaly benefit domestic and international services in all policy options. On the other hand, the measures 
targeting  weekly  rest  periods  (i.e.  PM9  to  PM12),  are  expected  to  have  an  impact  on  the  competition 
between  international  and  domestic  services74.  The  current  12-day  rule  distorts  competition,  by  giving 
advantages to providers of international services over those providing domestic services.  It  also  affects 
companies differently: whereas a larger company would be able to send another driver in order to ensure 
the  continuity  of  service  provision,  SMEs  –  especially  during  peak  season  –  do  not  have  similar 
opportunities due to their limited pool of drivers.  

PM9 is expected to have a strong positive impact on levelling the playing field for companies reliant on 
domestic services. PM10 and PM11 would apply equally to domestic and international services and would 
also help to leverage a fair treatment of all operators regardless of the nature of the service they provide75. 
PM12 would contribute to a large extent to tackle the negative effects on competition between operators of 
domestic and international services, encouraging coach and bus companies to be more efficient, thereby 
creating more choice for consumers and ultimately reducing consumer prices and improving the quality of 
services. However, PM12 would not align fully domestic services with international services.  

Since  PM9,  which  is  expected  to  have  a  strong  positive  impact  on  domestic  occasional  services,  and 
significantly leverage the number of passengers in this sector, is included in two alternative policy options 
(i.e. PO A and PO C), the benefits on the functioning of the internal market and competition is expected to 
be similar in PO A and PO C. However, the impact would be somewhat  higher for PO C, since it will 

74 Tetra Tech International et al. (2022), Support study for an impact assessment for a possible revision of Regulation 
(EC) No 561/2006, estimated that international services, expressed in passenger-kilometres, account on average for 1.6% 
of  the  total  bus  and  coach  sector.  During  the  public  consultation  21  out  of  the  58  coach  companies  that  responded 
mentioned that they operate exclusively domestic occasional services, 3 coach companies stated that they carry out only 
international services, whilst the remaining 34 companies that responded to the public consultation informed that they 
provide both domestic and international services. 
75 To have a positive impact on levelling the playing field, these policy measures are implemented in conjunction with 
PM9. If implemented on their own, the impact would be small (since only a small proportion of trips are international) 
and negative (since they would exacerbate the differences in treatment between domestic and international occasional 
services). 

32 

 
 
                                                 
benefit from the combined effects of removing the obligation of taking two additional compensatory rest 
periods after using the derogation (PM11) and removing the single service condition when using the 12-
day rule (PM10), allowing for scheduling more passenger groups with the same driver. Table 6 presents the 
impacts of the policy options on the functioning of the internal market and competition between providers 
of international and domestic occasional bus and coach services.  

Table 6: Impacts of policy options on competition between providers of international and domestic occasional bus and 
coach services 

PO A 

PO B 

PO C 

Break times 

Daily rest periods 

0 

0 

0 

0 

0 

0 

Weekly rest 
periods 

++ 

+ 

+++ 

Overall 

++ 

+ 

+++ 

that  both 

Reasoning 
The measures are expected to benefit  domestic and 
international services equally. 
The measures are expected to benefit domestic and 
international services equally. 
Extending  the  12-day  rule  to  domestic  services 
(PM9) as in PO A would level the playing field by 
international  and  domestic 
ensuring 
services face the same weekly rest time rules. PM12 
(in  PO  B)  does  not  cater  for  the  harmonisation  of 
rules  but  can  make  the  organisation  of  domestic 
services  easier  for  occasional  domestic  operators. 
Providers  of  domestic  services  would  get  a  further 
significant benefit if – as in PO C and besides PM9 – 
the  requirement  for  compensatory  rest  is  also 
removed from the rule (PM11) and the single service 
condition is abolished (PM10), as this would allow 
them to schedule more services at peak times. PM10 
and  PM11  would  apply  to  both  international  and 
domestic occasional bus and coach services and thus 
ensure equal treatment.  
The measures related to weekly  rest periods would 
have  a  more  significant  postitive  impact  on  the 
functioning of the internal market and competition. 
This  impact  is  more  pronounced  in  policy  options 
that  entail  further  levels  of  adaptability  on  weekly 
rest periods, and is expected to be the highest in PO 
C, followed by PO A. 

Source: Tetra Tech International et al. (2022), Impact assessment support study 

6.1.4.  6.1.4. 

Impacts on compliance with the rules 

While the evidence on compliance was limited, it suggested that the impacts would differ depending on the 
nature of each policy measure. Overall, more derogations from the general rules pose more challenges to 
enforcement authorities in terms of compliance. Every control of a derogation starts from checking whether 
the conditions for the derogation are fulfilled (e.g. the trip is occasional, lasts more than 8 days, etc.). If the 
conditions for derogations are not fulfilled, the enforcement officers look at general rules and ascertain 
infringement of the general rules.  

As regards rules on breaks under PO A, they would be easy to enforce and would improve the compliance 
by reducing the number of situations where drivers face pressure to contravene the rules (e.g. due to the 
need to reach a hotel after spending time in unexpected traffic), as long as compensatory measures were in 
place to ensure that the measures were only applied in exceptional circumstances (PM4 and PM7). On the 
contrary, rules on breaks under PO B and PO C would be more difficult to report on and enforce.  

Concerning rules on daily and  weekly  rest periods,  the  enforcement  becomes very  complex in  case of 
drivers who are involved in mixed-activities, that is on some days they perform transport of passengers 
falling under general rules (e.g. regular services or occasional trips of less than 8 days) and on other days 
they perform transport operations benefitting from derogation (e.g. occasional trip of more than 8 days). For 
instance, under PO B and PO C, drivers performing mixed activities, could in some weeks benefit from 
flexible arrangements of the weekly rest over a period of 10 weeks and in other weeks they would have to 

33 

 
 
follow the general rule on a weekly rest. This would make the compliance more difficult for drivers and 
more complex for enforcement officers which would have to first verify the type of operation in which the 
driver was involved over the past weeks to conclude in which weeks drivers should follow general rules 
and in which weeks they could derogate from those rules. In contrast, the enforcement of the derogation 
regarding daily rest periods under PO A is easy to control, since there is only once a derogation during the 
entire journey.  

The 12-day derogation was designed to address the compliance challenge of drivers performing longer trips 
with a group of passengers where the driver is expected to stay at the service of passengers over the length 
of the trip, which makes the compliance with the general rule on weekly rest a challenge. Removing single 
service obligation would be in contradiction to the key issue that the derogation aimed to solve. On the 
enforcement side, it would be challenging to verify whether a driver can benefit from the 12-day derogation 
if the driver is involved in a number of consecutive occasional trips of shorter duration, including identifying 
after which trip the driver would be obliged to take a postponed weekly rest. Removing the obligation of 
compensatory rest after the 12-day derogation, does not make enforcement easier or more difficult. The 
tachograph records on the duration of rest period (after 12-day rules was used) are equally easy to analyse. 
Removing these two obligations could lead to abuse by employers making their drivers engage in a number 
of consecutive occasional trips and systematically delaying their weekly rest by 12-days.  

Overall, this means that the impacts of PO A would be positive, while PO B and PO C are expected to have 
negative impacts on compliance with the rules.   

Table 7: Impacts of the policy options on compliance with the rules  

PO A  

PO B  

PO C  

Breaks 

Daily rest 
periods 

Weekly rest 
periods 

Overall 

+ 

+ 

0 

+ 

-/0 

-/0 

-/0 

-/0 

- 

- 

-/-- 

-/-- 

Reasoning  
Increased flexibility of breaks would reduce pressure on 
drivers to engage in non-compliant behaviour, generating 
positive  impacts  under  PO  A.  However,  increased 
flexibility  would  make  break  times  more  difficult  to 
report  on  and  enforce,  offsetting  any  benefits  from 
facilitated  compliance  and  leading  to  neutral  impacts 
overall.  
Extending  the  duty  cycle  in  exceptional  circumstances 
would  reduce  pressure  on  drivers  to  engage  in  non-
compliant  behaviour,  generating positive  impacts  under 
PO A. However, more flexible rules under PO B and PO 
C  could  make  non-compliance  more  difficult  to  detect, 
leading to marginally negative impacts.    
While extending the 12-day rule to domestic transport in 
PO  A  would  not  affect  compliance,  the  increased 
flexibilities in PO B and PO C could increase complexity 
and  difficulties  with  enforcement,  opening  the  door  to 
abuse and leading to negative impacts.  
PO  A  would  help  to  address  the  current  issues  with 
compliance  difficulties  while  avoiding  changes  that 
would  make  the  rules  more  difficult  to  report  on  and 
enforce, thus generating a net positive impact. For PO B 
and  PO  C,  any  benefits  would  be  more  than  offset  by 
increased  difficulties  for  the  authorities  to  enforce  the 
rules and would be expected to reduce compliance levels 
overall. 

Source: Tetra Tech International et al. (2022), Impact assessment support study 

6.1.5.  6.1.5. 

Impact on public authorities 

All three policy options entail minor adjustments to the rules, that require Member States authorities to 
familiarise  themselves  with  the  changes.  These  entail  one-off  adjustment  costs  for  Member  States 
authorities. The time required per enforcement officer to familiarise with the new rules and implement those 

34 

 
 
in their planning is estimated at 4 hours. The average cost per hour at EU level is estimated at EUR 24.976 
in 2021 prices and it is assumed to remain constant over time in real prices. The total number of enforcement 
officers involved in checks is estimated at 54,67977 at EU level. Thus, the one-off adjustment costs for 
Member States authorities in 2025 are estimated at EUR 5.4 million relative to the baseline (in 2021 prices).  

This should be regarded as an upper-bound estimate, as it is very likely that familiarising with the new rules 
would take place in the context of the regular activities performed by the enforcement officers. In addition, 
the Commission will prepare an addendum on new rules to be incorporated into the existing guidelines and, 
if necessary, together with European Labour Authority (ELA), will organise a workshop for control officers 
and  business  organisations,  to  facilitate  the  understanding  of  the  revised  rules.  This  would  not  entail 
additional costs for the EU budget, as these costs can be accommodated under the current budgets of the 
Commission and the ELA. On the basis of the Commission’s guidelines, Member States will disseminate 
information about new rules to their controllers and operators (via information published on their websites 
or in internal circulars).  

On the other hand, none of the policy options introduces changes in the reporting or enforcement modalities 
relative to the baseline. Therefore, no change in administrative costs and enforcement costs are expected for 
the Member States authorities relative to the baseline. Nevertheless, as explained in section 6.1.4, while PO 
A would avoid changes that would make the rules more difficult to enforce, PO B and PO C may lead to 
increased difficulties for the authorities to enforce the rules and may reduce compliance levels overall. 

6.2. 

6.2. 

Social impacts 

This section assesses the impacts of the policy options on fundamental rights, on working conditions of 
drivers  (including  the  impacts  on  gender  equality),  on  driver’s  stress  and  fatigue  and  road  safety.  The 
evidence was mainly provided by trade unions (as representatives of many employed drivers) and individual 
drivers  (self-employed  and  employed)  during  targeted  interviews  and  the  public  consultation.  Industry 
stakeholders that replied to the consultation activities largely supported almost all of the proposed changes, 
but due to their specific role and interests, their motivation was mostly economic and presented in section 
6.1. It was not possible to quantify the social impacts, due to the lack of data available for the sector. Hence, 
the impacts are discussed in terms of expected direction of the changes and their likely magnitude, relative 
to the baseline scenario.  

6.2.1.  6.2.1. 

Impacts on fundamental rights  

The policy options were assessed to determine if they have an impact on the fundamental rights and/or equal 
treatment of EU citizens. The starting point for the assessment of the fundamental rights is the Charter of 
Fundamental Rights of the European Union78. All three POs were assessed having regard to the relevant 
EU instrument and it was concluded that they maintain full respect for human and fundamental rights and 
none will have any negative impact thereon. 

6.2.2.  6.2.2. 

Impacts on working conditions  

Overall more flexibility in arranging breaks and rest periods could improve working conditions of drivers, 
or at least avoid causing harm. Difficult working conditions contribute directly to the drivers’ fatigue and 

76   Source: Eurostat database, Labour Cost Survey, ISCO 4 (Clerks)  
77   Report from the Commission to the European Parliampent and the Council on the implementation of Regulation (EC) 

No 561/2006 (forthcoming).  

78 OJ C 326 of 26.10.2012 p.2 

35 

 
                                                 
fitness-to-drive and have a negative impact on road safety79.  

In relation to working conditions, it should be noted that the trade unions that replied to different consultation 
activities and some interviewed drivers were overall negative on all policy measures, mainly on the grounds 
that the currently proposed modification of rules would pave the way for further changes in the future, and 
not necessarily in relation to the merits or disadvantages of the proposed measures. Consultation results also 
show (see Table 8) that drivers that responded, including employed drivers, are generally more positive than 
trade  unions  regarding  the  proposed  measures  and  their  impacts  on  working  conditions.  This  may  be 
explained by the fact that trade unions represented drivers across all road transport segments, and mostly 
drivers employed in regular passenger and freight services, which are predominant in the road transport 
sector. 

Improving the flexibility of breaks under PM1 (in PO A) is expected to enable drivers to avoid taking breaks 
at inconvenient times and thus lead to a slight improvement in working conditions. In contrast, more flexible 
rules on breaks under PM2 (in PO B and PO C) would increase autonomy and reduce work stress of drivers.  
However,  they  could  result  in  drivers  taking  mostly  or  only  breaks  that  are  too  short  to  recuperate 
sufficiently, which is likely to lead to a negative impact on working conditions.  

While none of the five trade unions taking part in the targeted interviews advocated for either PM1 or PM2, 
views  were  relatively  neutral  on  the  former  and  strongly  opposed  to  the  latter.  The  trade  unions  also 
emphasised that at least one longer break every 4.5 hours of driving was needed. These views were echoed 
by six interviewed drivers who did not explicitly oppose PM1, but were against PM2, because they thought 
that longer breaks were needed to avoid situations where time that should be devoted to breaks would 
instead be fully consumed with activities such as helping passengers on and off the bus, giving advice, 
offering drinks, etc.  

In the public consultation, the views of trade unions were similar to those from the targeted interviews: out 
of the six trade unions expressing an opinion, one supported PM1, while none were in favour of PM2. 
Drivers (both employed and self-employed) that expressed an opinion were more positive, even though few 
drivers opposed both measures (see Table 8).  

Table 8: Support for PM1 and PM2 among trade unions and drivers taking part in the public consultation 

PM 1: Allow drivers to split their break of 
minimum 45 minutes into 30+15 or 15+15+15 
minutes 
PM 2: Breaks can be split in a fully open manner 
their break of minimum 45 minutes over the period 
of 4h30 driving time 

Self-employed 
drivers 

16 / 4  

15 / 0  

Employed drivers   Trade unions 

16 / 7  

10 / 0  

1 / 5  

0 / 6  

Source: public consultation; Legend: each cell is presented as: “Number supporting / number opposing”  

As regards postponement of daily rest periods, all policy measures (i.e. PM3 to PM8) related to this aspect 
would lead to  an improvement  of  working  conditions.  The  current  rules  were  found to  affect  working 
conditions  adversely  mainly  because  of  unexpected  issues  (e.g.  traffic,  an  activity  taking  longer  than 
foreseen or delays to passengers’ upstream transport) and could force drivers to rush or impose stops that 
passengers perceive as inconvenient. In particular, these policy measures would make it easier for drivers 
to  maintain  positive  relations  with  their  passengers,  which  all  six  drivers  taking  part  in  the  targeted 
interviews saw as of key importance for the job. Since the amount of driving time on long occasional trips 

79 Katrin Vitols and Eckhard Voss, wmp consult, on behalf of ETF (2021), ‘Driver fatigue in European road transport’. 

36 

 
  
                                                 
(except for first and last day) is often far from daily driving limit, more flexibility can be allowed without 
harming working conditions.  

However, six drivers and five trade unions taking part in the targeted interviews opposed both PM3 and 
PM6, arguing that, despite not reaching maximum driving times, the current duty cycle already entailed a 
long day of working, involving a range of both driving and non-driving tasks. They were concerned that the 
extension of the duty cycle would regularly subject drivers to excessive working hours. It thus seems that, 
on balance, PM3 and PM6 would have more negative impacts on working conditions than benefits. As for 
the rules on breaks, all trade unions taking part in the public consultation were opposed to PM3 and PM6, 
while employed and self-employed drivers that took part in the public consultation were largely positive 
(Table 9).  

Table 9: Support for PM3 and PM6 among trade unions and drivers taking part in the public consultation 

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 6: Allow drivers on trips lasting 8 days and 
longer to postpone the start of the daily rest period 
by 2 h in certain conditions  

Self-employed 
drivers 

16 / 8  

15 / 1  

Employed drivers   Trade unions 

11 / 10  

13 / 3  

0 / 6  

0 / 6  

Source: public consultation; Legend: each cell is presented as: “Number supporting / number opposing”  

To  address  the  concerns  expressed  by  drivers  and  trade  unions,  the  initial  policy  measures  were 
complemented by measures to ensure that extensions to the duty cycle are applied only in exceptional 
circumstances. These policy measures (i.e. PM4 to PM8) were defined after the consultation activities and 
thus could not be tested with stakeholders. Nonetheless, PM4 and PM7, which limit the usage of these 
measures to once per trip are expected to have a positive impact on working conditions.  

The policy measures related to weekly rest periods (i.e. PM9 to PM12) address a key concern related to 
working  conditions, namely  that of  excessive time  away  from  home that  the current rules  cause  when 
weekly rest is required in the middle of a long trip. Spending more time with family and friends is thereby 
expected to improve the quality of life of drivers. This would benefit especially to women bus drivers, and 
thereby have a small positive impact on gender equality, since they are more likely than men to have family 
obligations that are incompatible with time away from home.  

However, positive impacts on working conditions from the three policy measures (PM10, PM11 and PM12) 
relate essentially to driver’s autonomy and discretion to decide how much work to take on, an issue that is 
especially  important  given  the  seasonal  nature  of  occasional  transport  services.  While  none  of  these 
measures would address core issues with working conditions in occasional bus and coach sector, they would 
generate some positive impacts by giving drivers more control over their lives, as well as making it possible 
to drive more during peak seasons and increase their earnings. However, all these three policy measures 
have some drawbacks for working conditions. The removal of the single-service condition under PM10 
would generalise the use of 12-day rule, while PM11 would mean that the use of the 12-day rule would not 
be compensated with extra time off. Under PM12 drivers could be scheduled for consecutive trips over a 
series of weeks with only 24 hours of rest between them. Therefore, PM10, PM11 and PM12 would have 
significant negative impacts on working conditions.  

The slightly net positive impact on working conditions for PM9 and the considerable net negative impacts 
for PM10, PM11 and PM12 was also shown by the feedback from trade unions and drivers. In the targeted 
interviews, none of the policy measures were actively supported by any of these stakeholders. However, the 
opposition was much weaker for PM9. For example, the five trade unions taking part in the interviews 
mainly expressed concern that extending the scope of the 12-day rule would be a slippery slope that would 

37 

 
  
open the door to further liberalisation, rather than criticising the measure itself. The six drivers were neutral 
with regard to PM9, seeing both benefits and minor drawbacks. For the other three policy measures (PM10, 
PM11 and PM12), all interviewed drivers and trade unions were strongly opposed, primarily because of 
their expected negative impacts on working conditions.  

Trade unions responding to the public consultation did not support any of the measures on weekly rest 
periods. Those that replied identifying themselves as drivers (either employed or self-employed) were to a 
large extent positive (see Table 10).  

Table  10:  Support  for  PM9,  PM10,  PM11  and  PM12  among  trade  unions  and  drivers  taking  part  in  the  public 
consultation 

Self-employed 
drivers 

Employed drivers   Trade unions 

PM 9: Extension of the 12-day rule to domestic 
transport operations 
PM 10: Removal of the single-service condition 
when using the 12-day rule 
PM 11: Remove the compensatory rest after use of 
the 12-day rule 
PM 12: Flexible distribution of weekly rests over a 
10-week reference period 

25 / 2  

18 / 5  

22 / 5  

17 / 4  

15 / 1  

14 / 1  

16 / 0  

15 / 1  

1 / 5  

0 / 6  

0 / 6  

0 / 6  

Source: public consultation; Legend: each cell is presented as: “Number supporting / number opposing”  

Given the way the policy measures are grouped into policy options, compared to the baseline scenario, 
positive  impacts  on  working  conditions  would  only  be  expected  for  PO  A.  PO  A  is  also  expected  to 
contribute towards Sustainable Development Goal (SDG) 8 (“Promote sustained, inclusive and sustainable 
economic  growth,  full  and  productive  employment  and  decent  work  for  all”)  by  improving  working 
conditions for drivers. On the other hand, PO B and PO C are expected to have negative impacts on working 
conditions (see Table 11).  

Table 11: Impacts of policy options on working conditions 
PO C 

PO B  

PO A 

Breaks 

0/+ 

Daily rest 
periods 

0/+ 

Weekly rest 
periods 

+ 

- 

- 

- 

- 

-- 

-- 

Overall 

+/++ 

--- 

----- 

38 

Reasoning 
PO  A  would  enable  drivers  to  avoid  taking  breaks  at 
inconvenient times. In PO B and PO C flexible rules on 
breaks would increase autonomy and reduce work stress. 
However, they could result in drivers getting mostly or 
only breaks that are too short to recuperate sufficiently, 
leading to a negative impact on working conditions. 
Extending  the  duty  cycle  could  improve  drivers’ 
interactions  with  passengers,  marginally  improving 
working conditions. Under PO A, compensatory  action 
would ensure that any countervailing negative effects is 
minimal,  leading  to  a  net  positive  impact  on  working 
conditions. In contrast, extensions of the duty cycle could 
be used frequently in PO B and PO C, meaning that the 
impact on working conditions would be negative.   
Extending the use of the 12-day rule under PO A would 
allow drivers to avoid excessive  time away  from home 
during  long  trips,  generating  a  meaningful  benefit  to 
working conditions, while preserving the single-service 
condition  and  compensatory  rest  would  minimise  any 
negative  impacts.  PO  B  and  PO  C  would  both  entail 
significant  changes to the rules on weekly rest periods, 
leading to negative impacts on working conditions that 
would more than offset any benefit from increased driver 
autonomy and freedom over their workload. 
PO A would address the problems that the current rules 
cause for working conditions while using compensatory 
action  to  mitigate  the  risks.  Thus  PO  A  is  expected  to 
have a postive impact on working conditions. PO B and 
PO C would also address these problems, but may create 

 
  
 
PO A 

PO B  

PO C 

Reasoning 
new issues that would have negative impacts on working 
conditions.   

Source: Tetra Tech International et al. (2022), Impact assessment support study 

6.2.3.  6.2.3. 

Impacts on driver’s stress and fatigue, and road safety 

Difficult working conditions were found to contribute to driver stress, fatigue and fitness-to drive, which in 
turn reduce drivers’ quality of life and the attractiveness of work in the sector, and also have a negative 
impact on road safety80. A study conducted on behalf of European Transport Workers’ Federation (ETF)81 
shows the impact of fatigue on road safety following a survey where the respondents were asked whether 
they had experienced an accident owing to driver fatigue in the previous 12 months. 5% of bus and coach 
drivers reported being involved in an accident at least once in that period owing to fatigue. The survey 
covered 673 bus and coach drivers but it does not distinguish between the occasional and regular bus and 
coach sector. The study also does not quantify the relationship between the working conditions and road 
safety, although it acknowledges to be one factor out of others. Another study conducted on behalf of IRU82 
also recognises that other factors beyond working conditions, for example monotonous activities such as 
driving for many hours, can contribute to drivers’ fatigue and fitness-to-drive. Customers’ dissatisfaction, 
or even aggressive behaviour, may also increase drivers’ stress and may potentially lead to an accident. 
Therefore, the link between the rules and the stress and fatigue of drivers was presented as only one factor 
among many others.  

The consultation activities did not provide much evidence on how the policy measures would be expected 
to affect stress and fatigue. For this reason, the impacts are considered mainly in terms of the combined 
effects of each measure on working conditions and compliance, as drivers for stress and fatigue. As already 
said, the assessment of impacts mostly relies on stakeholders’ views. As explained above, this is because 
research on the topic is very limited and mostly focuses on urban public transport and commuting services 
and quantified data are scarce. Nevertheless, interviewees with a variety of profiles were selected (e.g. 
employed  versus  self-employed  drivers,  small  versus  larger  operators,  different  Member  States,  trade 
unions). Findings were also triangulated between different groups of stakeholders and data collection tools.  

PO A consists only of policy measures (PM1, PM4, PM7 and PM9) that are expected to have a positive or 
neutral impact on working conditions and compliance. Therefore, it is also expected to reduce driver stress 
and fatigue to some extent, with potential positive impact on road safety. PO B and PO C would both lead 
to  negative  impacts  on  working  conditions  and  compliance,  especially  due  to  the  inclusion  of  policy 
measures PM10 and PM11 in PO C and PM12 in PO B, which increase the amount of time worked between 
extended rest periods. Thus, both PO B and PO C are expected to lead to more stress and fatigue for drivers, 
with  potential  negative  impact  on  road  safety.  The  impacts  are  summarised  in  Table  12.  In  deriving 
qualitative scores for each option, the impacts on working conditions have been weighted more than the 
impacts on compliance, due to their predominant role on driver stress and fatigue.  

Table 12: Impacts of the fully fledged policy options on driver stress and fatigue  
PO B 

PO A 

PO C 

Breaks 

0/+ 

- 

- 

Reasoning  
The  positive  impact  of  PM1  on  working  conditions, 
which is included in PO A, would translate into a small 
reduction in stress and fatigue, as drivers would be able 
to organise breaks more easily. PO B and PO C would 

80 Katrin Vitols and Eckhard Voss, wmp consult, on behalf of ETF (2021), ‘Driver fatigue in European road transport’. 
81 Katrin Vitols and Eckhard Voss, wmp consult, on behalf of ETF (2021), ‘Driver fatigue in European road transport’. 
82 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   

39 

 
 
 
                                                 
 
PO A 

PO B 

PO C 

Daily rest 
periods 

+ 

- 

-- 

Weekly rest 
periods 

+ 

-- 

-- 

Overall 

++/+++ 

---- 

----- 

Reasoning  
also produce this benefit, but  this would be offset by a 
reduction  in  the  quality  of  breaks  and  increased 
enforcement difficulties.  
Extending the duty cycle in exceptional circumstances in 
PO  A  would  reduce  stress  among  drivers  by  allowing 
them to handle unforeseen events better and avoid issues 
with compliance. However, more flexible rules in PO B 
and PO C, could lead to excessively long working days 
on a regular basis, as well as making compliance more 
difficult to enforce. This would add to drivers’ stress and 
fatigue.  
The only change to weekly rest periods in PO A is PM9 
on  the  extension  of  the  12-day  rule,  which  would 
improve  working  conditions  by  making  it  easier  for 
drivers  to  take  weekly  rests  at  home,  where  they  can 
recuperate better from long periods of driving. This was 
seen  as  neutral  from  the  perspective  of  enforcement, 
leading to a positive impact overall. PO B and PO C both 
include measures that would be detrimental to working 
conditions (because they would normalise long working 
weeks) and compliance (because they would render this 
more complex and difficult for authorities), thus adding 
to  drivers’  stress  and  possibly  resuling  in  negative 
impacts on road safety. 
By 
facilitating 
compliance  to  a  certain  extent,  PO  A  strikes  the  right 
balance  between 
the 
principles  of  the  current  rules,  thereby  leading  to 
reduced driver stress and fatigue. Both PO B and PO C 
would have negative impacts on working conditions and 
compliance,  increasing  the  risk  that  drivers  would  be 
unable  to  rest  properly,  and  generating  high  levels  of 
stress.  

improving  working  conditions  and 

flexibility  and  maintaining 

Source: Tetra Tech International et al. (2022), Impact assessment support study 

6.3. 

6.3. 

Environmental impacts 

All policy options may generate an increase in services volume, albeit to a minor extent that has not been 
possible to quantify. Since at least some of this increase would be expected to result from passengers shifting 
to bus and coach from other means of transport, particularly private cars, it follows that the impact on the 
environment would be marginally positive. Marginal reductions in greenhouse gas emissions and other air 
pollutants would be expected, although not possible to quantify. Following the analysis above, no significant 
harm is expected on the environment by any of the policy options. All policy options are consistent with the 
environmental objectives of the European Green Deal and the European Climate Law83.    

7.  7. HOW DO THE OPTIONS COMPARE? 

7.1. 

7.1. 

Effectiveness 

The assessment of effectiveness looks at the extent to which the general and specific objectives (SO) of the 
intervention, as previously described, are met. Table 13 presents the link between policy objectives and 
assessment criteria. 

83 Regulation (EU) 2021/1119 of the European Parlaiment and of the Council of 30 June 2021 establishing the framework 
for achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU) 2018/1999 (‘European Climate 
Law’) (OJ L243, 9.7.2021, p1). 

40 

 
 
                                                 
Table 13: Link between objectives and assessment criteria 

General objectives 
The general objectives are: 
(i) to ensure efficient and 
high-quality occasional bus 
and coach services, (ii) to 
improve working and 
driving conditions for 
drivers 

Specific objective 
SO1 – Ensure more flexible distribution 
of breaks and rest periods  

Assessment criteria 
Expected  improvement  in  operators’  ability  to  meet 
customer demand and provide high-quality services 
Expected improvement in working conditions for drivers 

SO2  –  Promote  equal 
treatment 
between international and domestic bus 
and coach operations  

Expected 
competitiveness of domestic bus and coach operations  

improvement 

providing 

increased 

in 

All three policy options are expected to make progress towards the specific objectives compared to the 
baseline scenario. Despite the lack of quantitative data, the analysis of impacts showed clear differences in 
their likely effectiveness. These differences relate primarily to the level of flexibility offered by each policy 
option, and the need to balance between economic and social considerations.  

All three policy options are expected to generate some progress towards the general objectives by ensuring 
efficient and high-quality services. PO C would be more effective in ensuring efficient and high-quality 
services than PO A and PO B, since it would eliminate the difference between international and domestic 
services and provide operators and drivers with maximum flexibility for the organisation of occasional bus 
and coach services. PO A and PO B are also effective in ensuring efficient and high-quality services because 
they would reduce the number of situations where operators and drivers need to alter trip itineraries and take 
on additional drivers in order to comply with the rules. On the other hand, with respect to improving working 
conditions for drivers, progress is only expected for PO A. This is because PO A will combine the aspects 
of increased flexibility - that would be beneficial for working conditions (e.g. the extension of the daily duty 
cycle to allow better relations with passengers, and the use of the 12-day rule to allow drivers to take more 
weekly rests at home) - with restrictions that would ensure high working standards. In contrast, both PO B 
and PO C are expected to extend daily duty cycles, which would offset other benefits, leading to a negative 
impact overall.  

Concerning SO1, PO A would allow breaks and daily rests to be organised more in line with trip itineraries, 
while avoiding the risk that drivers would be given insufficient time to recuperate during breaks. For weekly 
rest periods, in PO A the extension of the 12-day rule to domestic trips, while other conditions of its use 
would be kept in order to maintain good working conditions, is expected to improve the operators’ ability 
to meet customer demand and provide high-quality services. For both daily and weekly rests, the increased 
flexibility will have a greater impact on SMEs, which are less equipped than larger companies to staff trips 
with multiple drivers. 

PO B would allow the greatest flexibility to operators in terms of break times (which could be organised 
with almost full flexibility). While these would increase autonomy and reduce work stress they could result 
in drivers getting mostly or only breaks that are too short to recuperate sufficiently, leading to a negative 
impact on working conditions. PO B would also allow daily rests to be organised more in line with trip 
itineraries.  At  the  same  time,  PO  B  would  bring  a  major  change  in  weekly  rest  periods,  allowing  the 
flexibility in their distribution over a 10-week reference period, greatly enhancing drivers’ ability to work 
during  busy  peak  seasons  and  helping  to  address  driver  shortages,  albeit  while  opening  the  door  to 
circumstances where drivers would be working for consecutive weeks without extended weekly rest. The 
improvement in operators’ ability to meet customer demand and provide high-quality services is expected 
to be higher in PO B relative to PO A.  

PO C offers the greatest flexibility to operators in terms of break times (which could be organised with 
almost full flexibility), daily rests (which could be used with minimum restrictions regarding the length of 
the daily duty cycle) and weekly rests (where the 12-day rule would be extended to domestic trips, as well 
as being no longer subject to the single-service condition and compensatory extra rest). PO C is expected to 
generate the largest positive impacts in terms of improving operators’ ability to meet customers demand 

41 

 
 
 
and provide efficient and high-quality services. On the other hand, it is expected to lead to negative impacts 
on  the  working  conditions.  Therefore,  when  considering  both  the  expected  improvement  in  operators’ 
ability  to  meet  customer  demand  and  provide  high-quality  services,  and  the  expected  improvement  in 
working conditions for drivers, PO A is assessed to be most effective in addressing SO1, followed by PO 
B and PO C.   

Concerning SO2,  both  PO  A  and  PO C  extend the  use of 12-day  rule to domestic trips, thereby  fully 
addressing this specific objective. In contrast, the 12-day rule will remain accessible only to international 
trips under PO B. However, PM12 in PO B will greatly increase the flexibility for weekly rests, by allowing 
them to be  freely  distributed  over  a  10-week reference period. Since this  would  reduce  operators’  and 
drivers’ need for the 12-day rule, the disparity between international and domestic services is be expected 
to decrease somewhat, albeit to a lesser extent than under PO A and PO C. Thus, PO A and PO C are more 
effective than PO B in addressing SO2. A more detailed presentation is provided in Annex 5. 

7.2. 

7.2. 

Efficiency 

Efficiency concerns "the extent to which objectives can be achieved for a given level of resource/at least 
cost". The costs and benefits are summarised in Table 14. 

All three policy options would consist of adjustments to the current rules, while leaving the current reporting 
and enforcement mechanisms intact. Total costs are estimated at around EUR 6 million in all policy options, 
expressed as present value over 2025-2050 relative to the baseline. The main part of these costs (EUR 5.4 
million) represents one-off adjustment costs for Member States authorities, for familiarising themselves 
with the new rules. The rest of the costs represent one-off adjustment costs for bus and coach operators, for 
familiarising themselves with the new rules.  

Total benefits are estimated to be the highest in PO C (EUR 177.3 to 248.3 million), followed by PO B 
(EUR 106.4 to 212.8 million) and PO A (EUR 106.4 to 141.9 million). The benefits are related to a reduction 
in operational costs for bus and coach operators, driven by the new rules. More specifically, the largest 
adjustment costs savings category in PO A relates to measures to improve the flexibility of taking daily rests 
although the costs savings for measures leading to higher flexibility of breaks and those addressing weekly 
rest periods are only slightly lower than those for daily rests periods. For PO B the costs savings are equally 
distributed  between  the  three  groups  of  measures,  while  in  PO  C  the  largest  adjustment  costs  savings 
category relates to measures addressing weekly rest periods.  

The impacts on  working  conditions  were  not possible to quantify,  although  a qualitative  assessment  is 
provided in section 6.2.2 and reflected in Table 14. PO A would address the problems that the current rules 
cause for working conditions while using compensatory action to mitigate the risks. Thus PO A is expected 
to have a postive impact on working conditions. PO B and PO C would also address these problems, but 
create new issues that would have negative impacts on working conditions.   

Table 14: Summary of costs and benefits of policy options – present value for 2025-2050 compared to the baseline (in 
million EUR), in 2021 prices 

Member States authorities 

Adjustment costs  

Businesses 

Adjustment costs 
Adjustment costs savings 

Impacts on working conditions 
Impacts on working conditions 

PO A 

5.4 

Difference to the baseline 
PO B 

5.4 

PO C 

5.4 

0.6 
106.4-141.9 

0.6 
106.4-212.8 

0.6 
177.3-248.3 

+/++ 

--- 

----- 

42 

 
  
 
 
 
Total costs 
Total benefits 
Net benefits 
Source: Tetra Tech International et al. (2022), Impact assessment support study 

PO A 
6.0  
106.4-141.9 
100.4-135.8 

Difference to the baseline 
PO B 
6.0  
106.4-212.8 
100.4-206.8 

PO C 
6.0  
177.3-248.3 
171.3-242.2 

All policy options would result in net benefits relative to the baseline. Net benefits are estimated to be the 
highest in PO C (EUR 171.3 to 242.2 million), followed by PO B (EUR 100.4 to 206.8 million) and PO A 
(EUR 100.4 to 135.8 million). PO C also shows the highest benefit to cost ratio, followed by PO B and PO 
A. However, there is large uncertainly regarding these estimates, which rely on input provided by six bus 
and coach operators. To acknowledge the uncertainty, the impacts have been provided in ranges.  

In addition, it should be noted that the quantified benefit to cost ratio does not reflect the impacts on the 
working conditions. This is because the impacts on the working conditions could not be quantified. The 
qualitative assessment on the working conditions indicates that the benefit to cost ratio of PO A would be 
higher than actually quantified.   

7.3. 

7.3. 

Coherence 

Coherence  is  considered  in  terms  of  internal  coherence  among  the  measures  under  consideration  and 
coherence with other relevant EU objectives and policies.  

Internal  coherence.  The  internal  coherence  concentrates  on  how  the  different  elements  within  the 
Regulation work together to achieve the objectives. Although all three POs address the identified problems, 
they do so in different ways. While PO A and PO C fully address the two problem drivers, PO B only partly 
addresses problem driver 2 on unequal treatment between international and domestic occasional services. 
Regarding  working  conditions,  PO  A  is  expected  to  have  a  positive  impact  on  working  conditions  by 
addressing the problems caused by the current rules while using compensatory action to mitigate the risks. 
PO B and PO C would also address these problems, but may create other issues, so their impact on working 
condition is negative.  

External coherence. The external coherence concentrates on the compliance of the Regulation with key 
EU policy  objectives  and  policies.  Both  PO  A  and  PO  C  eliminate the  current  disparities  in treatment 
between international and domestic services, contributing to the aims of the Single Market. PO B is less 
coherent, since disparities would remain to a certain extent. The coherence can also be examined in terms 
of impacts on gender equality. While none of the policy options were found to have significant impacts in 
this area, extension of the 12-day rule in PO A and PO C will allow drivers to spend more time at home 
rather than being forced to take weekly rests at a distant location. This could generate marginal positive 
impacts on gender equality, since women drivers are likelier than men to have family obligations that would 
make time away from home difficult. The marginal positive impact of all three options on the environment 
means that no issues with coherence were found in this area. 

7.4. 

7.4. 

Subsidiarity and proportionality 

The revision of the Regulation is required since, in the absence of EU level action, the problems identified 
would  most  likely  persist.  As  highlighted  in  section  3  above,  the  identified  problems  have  the  same 
underlying  causes  across  the  EU.  The  flexibility  on  breaks  and  rest  periods  for  occasional  passenger 
transport services constitute significant added value by providing businesses and drivers with well-fitted 
rules, enabling them to organise transport operations more efficiently and ensuring high standards for the 
working conditions of drivers. These problems cannot be addressed by Member States individually. The 
subsidiarity requirement is fulfilled for all options, as they all ensure harmonisation of the legal framework. 

43 

 
  
All options are also considered proportionate, because they will not alter the scope of the rules. However, 
in terms of the balance between measures providing more flexibility in organising breaks and rest periods, 
on the one hand, and maintaining drivers’ working conditions, on the other hand, PO A is considered more 
proportionate than PO B and to a greater extent than PO C. 

8.  8. PREFERRED OPTION 

8.1. 

8.1. 

Identification of the preferred policy option and stakeholders views 

Although  each  of  the  policy  options  addresses  the  problems  identified,  their  drivers  and  the  specific 
objectives, some options are more effective in achieving the specific and general objectives. Based on the 
assessment done, PO B and PO C would be more effective in addressing the general objective related to 
efficient and high-quality services, but at the expense of negative impacts on working conditions. On the 
other hand, with respect to improving working conditions for drivers, a positive impact is only expected for 
PO A. PO A is also more effective in addressing SO1 (Ensure more flexible distribution of breaks and rest 
periods) than PO B and PO C. With respect to SO2 (Promote equal treatment between international and 
domestic bus and coach operations), PO A and PO C are equally effective and more effective than PO B. 
Considering the elements above, PO A is consider as the most effective policy option.  

With  respect  to  efficiency,  all  policy  options  result  in  net  benefits  relative  to  the  baseline,  with  PO  C 
showing the highest net benefits and the highest benefits to costs ratio. PO B is also somewhat more efficient 
than PO A. As explained in section 7.2, this is however expected to be counterbalanced to some extent by 
the positive impacts of PO A on working conditions, which however could not be quantified.   

On internal coherence, PO A is the most coherent with the objectives of Regulation (EC) No 561/2006 of 
harmonising the  conditions of  competition  between  modes of  inland  transport, notably  equal treatment  
between international and domestic occasional services, and of improving working conditions. It is also the 
most coherent with the objective (albeit to a minor extent) of gender equality. External coherence will be 
guaranteed  for  all  policy  options,  although  PO  B  is  less  externally  coherent,  since  disparities  between 
domestic and international occasional services will remain to a certain extent. The marginal positive impact 
of all three options on the environment means that no issues with coherence were found in this area.  

The  subsidiarity  requirement  is  fulfilled  for  all  options.  All  options  are  also  considered  proportionate. 
However, in terms of the balance between measures providing more flexibility in organising breaks and rest 
periods,  on  the  one  hand,  and  maintaining  drivers’  working  conditions,  on  the  other  hand,  PO  A  is 
considered more proportionate than PO B and to a greater extent than PO C.  

Overall, the difference in terms of net benefits between PO A on the one hand and PO B and PO C on the 
other hand would be partially counterbalanced by the positive impacts of PO A on working conditions, 
which however could not be quantified. On the other hand, improving working conditions is one of the 
general objectives of the initiative. The impact assessment does not provide for road safety as an explicit 
objective, but rather as a constraint. The choice of the preferred policy option relies on the fact that PO A is 
considered as the most effective policy option and the policy option that is  the most coherent with the 
objective of Regulation (EC) No 561/2006 of improving working conditions. Thus, PO A is selected as the 
preferred policy option despite its lower benefit to cost ratio relative to PO C and PO B. It should however 
be  emphasised  that  the  calculated  benefit  to  cost  ratio  does  not  reflect  the  impacts  either  on  working 
conditions or on environment and that the quantitative and qualitative assessments need to be combined to 
allow a fully informed view. The qualitative assessment on the working conditions indicates that the benefit 
to cost ratio of PO A would be higher than actually quantified. 

Industry stakeholders taking part in the targeted interviews and in the public consultation generally support 
all  the  proposed  measures,  since  they  would  increase  their  ability  to  organise  services  according  to 

44 

 
operational and customer needs. Trade unions, drivers and authorities were more reluctant. All those that 
responded to  the  consultation  opposed  certain measures, in particular the  removal  of the  single-service 
condition and compensatory rest when using the 12-day rule (which are part of PO C) and the flexible 
distribution of weekly rests across a 10-week reference period (which is part of PO B).  

While  the  measures  included  in  PO  A  did  not  receive  outright  support  from  trade  unions,  drivers  and 
authorities,  opposition  of  those  that  replied  to  the  consultation  activities  was  far  less  pronounced.  The 
measures included in PO A would also address their main concerns. More specifically, PM1 on breaks will 
address the concern that 5 minutes breaks are too short to allow proper recuperation. PM4 and PM7 would 
ensure that extensions of the duty daily cycle will be used only in exceptional circumstances, addressing a 
concern that the proposed changes would increase the length of the working day. The extension of the 12-
day rule to domestic trips (PM9), while preserving other conditions for its use, will prevent extra-long weeks 
from becoming the norm, a key concern of trade unions and drivers. Overall, this suggests that PO A may 
be more accepted, while PO B and PO C would only appeal to industry stakeholders.  

On the basis of what precedes and the analysis above it can be concluded that PO A is the preferred policy 
option.  

8.2. 

8.2. 

REFIT (simplification and improved efficiency) 

The initiative, by adapting the current rules to the specificities of the occasional bus and coach sector, will 
make it easier for operators and drivers to organise efficient and high quality services, which will have 
positive impact on their business performance, including costs savings and increased service offer. The net 
costs savings for businesses are estimated at EUR 105.8 to 141.3 million, expressed as present value over 
2025-2050 relative to the baseline. Particularly SMEs, which tend to operate with a limited pool of drivers 
and buses, will benefit most from the proposed measures. Public administrations may incur some limited 
costs for getting familiar with the new rules, estimated at EUR 5.4 million, expressed as present value over 
the 2025-2050 period relative to the baseline. At the same time positive impacts are expected in addressing 
current compliance difficulties, although the benefits could not be quantified.     

8.3. 

8.3. 

Application of the ‘one in, one out’ approach  

As  explained  in  section  6.1.1,  the  preferred  policy  option  is  not  expected  to  result  in  additional 
administrative costs for the private sector, or for the citizens. PO A is estimated to result in adjustment costs 
of EUR 0.6 million, linked to the need of getting familiar with the new rules. These will be however more 
than offset by the adjustment costs savings estimated at EUR 106.4 to 141.9 million, expressed as present 
value over 2025-2050 relative to the baseline.  

9.  9. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

The Commission services will monitor the application and effectiveness of this initiative through a number 
of actions that will measure progress towards achieving the general and specific  objectives. Both economic 
impacts,  as  well  as  the  impacts  on  working  conditions  and  drivers’  well-being  will  be  monitored  and 
evaluated, with due involvement from the Member States and social partners, to confirm that the changes 
do  not  negatively  affect  social  conditions  in  particular.  Actions  foreseen  for  verifying  implementation 
include: 

-  National monitoring reports according to the existing requirements will monitor infringement detection 
rates. These reports will be included and assessed in the Commission’s biennial reports on the application 
of Regulation (EC) No 561/2006, under Article 17 of the Regulation.  

45 

 
-  The Commission will also undertake an evaluation survey on the level of drivers’ fatigue and stress to 
assess  how  the  new  rules  contributed  to  reduction  of  drivers’  stress  and  improvement  in  working 
conditions. 

-  The Commission services will also monitor the development in the level of passenger transport activity, 
both  domestic  and  international,  in  terms  of  passenger-kilometres  (Eurostat).  For  the  sake  of 
completeness, impacts on road safety will be also monitored.   

-  The implementation and enforcement of the new rules will be also regularly monitored and assessed by 
the  Committee  on  Road  Transport,  and  via  direct  contacts  with  social  partners  and  Commission’s 
registered correspondence/complaints with different stakeholders.  

Two  operational  objectives  have  been  identified:  (i)  provide  for  uniform  interpretation  and 
application of break and rest period rules that are adapted to occasional bus and coach transport and 
ease compliance (linked to SO1) and (ii) facilitate the organisation of domestic and international bus 
and coach activities via harmonised rules (linked to SO2). Table 15 presents the indicators and data 
sources  proposed  for  the  two  operational  objectives.  Data  for  some  of  these  indicators  should  be 
available and it should be possible to include this data in the biennial implementing reports submitted 
by national authorities or collected directly by the Commission services. Other aspects will have to 
be covered as part of the evaluation of the Regulation, where surveys and other tools could be used 
to collect relevant information.  

Table 15: Proposed indicators for monitoring and evaluation of the preferred policy option 

Operational objective 

Main indicator 

Source(s) of information 

for 

Provide 

OO1: 
uniform 
interpretation  and  application  of 
break  and  rest  period  rules  that  are 
adapted to occasional bus and coach 
transport and ease compliance  

Infringement detection rates  

National monitoring reports 

Level  of  satisfaction  with  the  rules 
with regard to compliance costs and 
working conditions  

Targeted  surveys  and  interviews  of 
business associations, bus and coach 
operators, 
drivers’ 
authorities, 
representatives and drivers  

Level of driver stress and fatigue  

Targeted  surveys  and  interviews  of 
drivers’ representatives and drivers  

 OO2:  Facilitate  the  organisation  of 
domestic  and  international  bus  and 
coach activities via harmonised rules 

Level  of  road  occasional  passenger 
(domestic  and 
transport  activity 
international 
in 
passenger-kilometres   

operations) 

Eurostat  

Number  of  operators  engaged  in 
domestic  and  international  coaching 
services, particularly SMEs   

Eurostat  and  interviews  of  business 
associations  and  bus  and  coach 
operators 

Number  of  operators  using  the  12-
day derogation for domestic use   

Targeted  surveys  and  interviews  of 
business  associations  and  bus  and 
coach operators  

46 

 
 
  
  
 
  
  
  
 
 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

1.  Lead DG, Decide Planning/CWP references 

Directorate-General for Mobility and Transport (DG MOVE), Unit C1: Road Transport Policy, is the lead 
DG for this legislative proposal aimed at esnuring fair, efficient and high quality occasiona bus and coach 
services  and  imrpoving  working  and  driving  conditions  for drivers,  including  the  aspects  of  stress  and 
fatigue of drivers, and road safety. This initiative’s DECIDE reference number is PLAN/2019/5424. The 
Inception Impact Assessment was published in Janaury 202184.  

2.  Organisation and timing 

The  impact  assessment  accompanying  the  legislative  proposal  for  a  revision  of  Regulation  (EC)  No 
561/2006 has been consulted within the Inter-Service Steering Group (ISSG) comprising the following 
members: Secretariat-General, Legal Service, Directorate-General for Mobility and Transport (MOVE), 
Directorate-General  for  Employment,  Social  Affairs  and  Inclusion  (EMPL),    Directorate-General  for 
Internal Market, Industry, Entrepreneurship and SMEs (GROW), Directorate-General for Climate Action 
(CLIMA), Directive-General of Regional and Urban Policy (REGIO), Directorate-General for Economic 
and Financial Affairs (ECFIN), In total, 5 meetings were organised to discuss this impact assessment. Many 
written consultations of the ISG took place by email at various stages and on various drafts of this impact 
assessment. The last ISG meeting took place on 10 November 2022.  

3.  Consultation of the Regulatory Scritiny Board (RSB) 

The draft report was submitted to the RSB on 16 November 2022. On 16 December 2022, the RSB issued 
a positive opinion with reservations. The RSB comments were addressed in the revised IA report as follows:  

RSB comments 

Modification of the IA report 

1 

to 

the 

and 

contributions 

that  contribute 

The  report  should  better  describe  how  the 
from 
evidence 
stakeholders  were  combined 
to  draw 
conclusions on the low customer satisfaction 
and demand and how this is impacted by the 
driving and rest times. It should identify any 
further  factors 
these 
problems  and  indicate  how  significant  the 
contribution  of  the  flexibility  of  driving  and 
rest times is.  It should provide evidence that 
confirms  the  specificities  of  occasional  bus 
and  coach  transport  services  compared  to 
regular  bus  and  coach  services  and  to  road 
freight  services.  It  should  demonstrate  with 
evidence to what extent there is a meaningful 
competition  or  level  playing  field  problem 
international  bus 
between  domestic  and 
transport services given that, from a demand 

Section 2.1.1 better explains that the evidence 
mostly relies on the feedback from stakeholders. 
Nevertheless,  interviewees  with  a  variety  of 
profiles  were  selected  and  findings  were  also 
triangulated  between  different  groups  of 
stakeholders and data collection tools. Since the 
current  rules  on  breaks  and  rest  periods  were 
attributed by stakeholders to their difficulties to 
that  meet 
organise  high-quality  services 
customer  demands,  it  was  concluded  that 
customer satisfaction is lower than it would be 
in case of high-level services.  

Section 2.1 identifies other factors than the rules 
on breaks and rests time, which contribute to the 
low  customer  satisfaction  and  demand  in  the 
sector,  like  customer  experience,  comfort  or 
fares.  Moreover,  it  was  emphasised  that  as 

84  Source:  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12488-Bus-and-coach-drivers-EU-
rules-on-driving-and-rest-times_en 

47 

 
 
                                                 
side  perspective,  these  services  seem  to 
represent different relevant markets. 

2  The report should better describe the baseline, 
by  considering  additional  factors  impacting 
the identified problems on top of the evolution 
of the traffic. It should better explain how the 
options were designed, including by clarifying 
if they were suggested by stakeholders. 

3  The report should better justify the choice of 
It  should 
the  preferred  policy  option. 
emphasise  that  the  calculated  Benefit  Cost 
Ratio does not reflect the impact on working 
conditions  and  that  the  quantitative  and 
qualitative assessments need to be combined 
to allow a fully informed view. 

regards  these  other  factors  operators  compete 
while the rules on breaks  and  rest times  are  a 
legal  constraint  on  which  limited  competition 
takes place. 

A new Box (i.e. Box1), summarising the main 
characteristics of the occasional bus and coach 
sector  was  added 
in  section  1.1.  More 
explanation on the legal specific characteristics 
of  the  occasional  bus  and  coach  transport 
services  has  been  provided  in  section  1.2  and 
section 2.1.1 presents the factual characteristics 
of these services, like heterogeneous itineraries, 
frequent and irregular stops and a high degree of 
seasonality. 

Section  2.2  better  explains  competition/level 
playing  field  problem  between  domestic  and 
international  bus  and  coach  services.  All 
consulted  stakeholders  agreed  that  the  current 
application  of  the  12-day  rule  leads  to  unfair 
treatment  between  domestic  and  international 
services, or did not express a view on this topic. 
Beyond  stakeholders  views  there  is  very  little 
evidence  on  the  occasional  bus  and  coach 
segment. This has been better acknowledged in 
the revised report.  

Section 5.1 has been revised to better describe 
the baseline. It considers additional factors, such 
as megatrends.  

Section  5.2  better  explains  how  the  policy 
options were identified, i.e. in consultation with 
stakeholders, in particular regarding mitigation 
measures (PM4, PM5, PM7 and PM8). 

Sections  7.2  and  8.1  have  been  revised  to 
address this comment. The qualitative impacts 
on  the  working  conditions  have  been  better 
reflected  in  in  the  efficiency  section  (section 
7.2). In addition, section 8.1 of the revised report 
has been reinforced, also explaining that PO A 
is the policy option that is most coherent with 
the objective of Regulation (EC) No 561/2006 
of improving working conditions.  

4  The 

report  should  better  explain  how 
stakeholders’  contributions,  relevant  experts’ 
views  and  studies  were  integrated  in  the 
assessment of the impact of the policy options 

Section 6 has been revised to better explain how 
stakeholders’  contributions  and  studies  were 
integrated  in the  assessment  of the  impacts  of 
the  policy  options,  including  the  uncertainties 

48 

 
on  the  working  conditions,  competition,  and 
road  safety  (including  on  the  relationship 
between  driving  and  rest  times  and  road 
should  highlight 
safety).  The  analysis 
uncertainties  and  clearly  describe 
the 
underlying assumptions. 

and  underlying  assumptions.  In  particular, 
section 6.2.3. better explains the little evidence 
available  on  working  conditions  and  the 
relationship between driving and rest times and 
road  safety.  The  scarcity  of  evidence  for 
quantification of impacts is also highlighted in 
section 6. 

5  The  report  should  ensure  that  stakeholders’ 
views are taken into account in a sufficiently 
balanced way reflecting adequately the often 
small  samples  of 
In 
particular, it should clarify how the views of 
employed  bus  and  coach  drivers  and  unions 
were taken into account in the analysis. 

received. 

replies 

6  The  report  should  further  develop  the  SME 
test  given  the  importance  of  SMEs  for 
occasional  bus  and  coach  services.  It  should 
highlight the information on SMEs contained 
in  the  relevant  annexes  and  in  the  support 
study (e.g. case studies) and it should describe 
the specific consultation activities carried out 
on SMEs. 

Section 6 explains better that due to the small 
size  of  the  occasional  passenger  sector  and 
limited  nature  of  the  proposed  changes,  a 
proportionate analysis was conducted. To taken 
into account in a sufficiently balanced way the 
stakeholders’  views,  reflecting  adequately  the 
often  small  samples  of  replies  received, 
interviewees  were  selected  based  on  specific 
profiles  allowing  to  guarantee  that  the  main 
groups were covered.  

Annex  4  explains  how  factual  input  and 
concrete  examples  contributed  to  ensure  the 
validity  of  the  results.  Findings  were  also 
triangulated  between  different  groups  of 
stakeholders and data collection tools.   

Section  6.1.2  has  been  improved  to  detail  all 
stages  of  SMEs  test.  It  also  better  reflects  the 
consultation  activitiers  carried  out  relevant for 
SMEs  and  makes  reference  to  the  impact 
assessment support study. 

4.  Evidence, sources and quality 

The impact assessment is based on a several sources, using both quantitative and qualitative data, collected 
from Member States and industry. This includes: 

  The 2017 ex-post evaluation SWD(2017)184 final85  

  Stakeholder consultation activities (see Annex 2) 

  External support study carried out by an independent consultant (Tetra Tech International et al.) 

85 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52017SC0184   

49 

 
 
 
  
                                                 
  Commission experience in monitoritung and implementing the Directive.  

50 

 
ANNEX 2: STAKEHOLDER CONSULTATION  

1.  INTRODUCTION 

This annex provides a summary of the outcomes of the consultation activities which have been carried out 
for the review of Regulation (EC) No 561/2006, including in the context of the external support study86. 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 objective of the consultation activities was to collect information and opinions of stakeholders on the 
key problems and associated drivers, definition of relevant policy objectives linked to those problem areas 
and the identification, definition and screening of policy measures that could eventually be incorporated 
into policy options for this Impact Assessment, as well as gather information and opinions on their likely 
impacts.  

2.  METHODOLOGY 

The consultation strategy87 was developed from the start of the impact assessment process and included 
three types of consultation activities: consultation on Inception Impact Assessment, public consultation and 
targeted  interviews,  including  three  case  studies.  Across  the  different  consultation  activities,  input  was 
sought from the following types of stakeholders, which were mapped early in the process:  

-  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; 
-  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 for the specific rules under review;  

-  Experts: the study was also open to input from other experts, on topics such as fatigue and road safety; 
-  Non-governmental organisations (NGOs) and citizens in the EU-27, other EEA countries, Switzerland 

and UK.  

In addition, the Commission discussed the initiative with ETF on 21 June 2022, where ETF expressed its 
opposition to the proposed changes, mainly on the grounds that they would pave the way for further changes 
in the future. Another meeting   on occasional passenger transport was organised by the European Labour 
Authority on 5 October 2022. This meeting gathered social partners and national authorities.       

86 Tetra Tech International et al. (2022), Support study for an impact assessment for a possible revision of Regulation 
(EC) No 561/2006. 
87  Source :  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12488-Bus-and-coach-drivers-EU-
rules-on-driving-and-rest-times_en 

51 

 
 
 
 
 
                                                 
2.1. Feedback on the Inception Impact Assessment 

The Commission received 79 responses88 to the Inception Impact Assessment for this initiative between 21 
January 2021 and 18 February 2021.  

The following stakeholder categories provided feedback to the Inception Impact Assessment. 

Figure 4: Feedback received by category of respondent 

3; 4% 1; 1%

1; 1%

8; 10%

11; 13%

38; 46%

21; 25%

EU citizen

Trade Union

Business association

Company/business organisation

Other

Public authority

Non-EU citizen

In terms of country coverage (Figure 5), the majority of respondents were from Germany (37), followed by 
respondents from Italy (15) and Belgium (13). 

Figure 5: Country of origin of respondents89 

Respondents seem to be split into two groups. On the one side, trade unions and EU citizens (who were 
probably drivers in many cases) expressed resistance to changes to the current provisions on breaks and rest 
periods, which were reported as seen as harmful to occasional bus drivers’ wellbeing and in terms of road 
safety.  On  the  other  side,  companies  and  business  associations  were  in  favour  of  introducing  specific 

88 The number of total valid feedback replies received amounts to 87, some of them came from the same public/private 
entities. 
89  “Other”  includes  respondents  from:  CZ,  DK,  ES,  SK,  RO,  UK  and  an  international  organisation.  “EU”  includes 
respondents from Europe-wide organisations (e.g. EU Trade Unions and business associations). 

52 

 
 
 
                                                 
solutions for the sector, which they felt would help to better respond to the needs of coach and bus drivers, 
to increase passengers satisfaction, and to increase profit margins. The only public authority who provided 
feedback in the consultation shared some of the concerns expressed by trade unions and citizens, while 
recognising the need to increase the flexibility of legislation. 

2.2. Public consultation 

The Commission received 170 responses to the public consultation, which was open between 23 November 
2021 and 18 February 2022. The set of questions contained both general questions addressed at all interested 
parties, and more detailed questions aim at ‘specialist’ respondents who have a good knowledge of the topic, 
such  as  trade  unions,  drivers,  operators  and business  associations.  Figure  6  presents the distribution of 
responses across categories90.  

Figure 6: Categories of respondents  

Company/business organisation

Other

33, 19,4%

Business association

18, 10,6%

Trade union

EU citizen

Public authority

14, 8,2%

12, 7,1%

10, 5,9%

83, 48,8%

Source: Public consultation (170 respondents) 

0%

10%

20%

30%

40%

50%

60%

In terms of country of origin, 77 respondents came from Germany, followed by Austria (17), Italy (16), 
Belgium (11) and the Czech Republic (8). Among third country residents, responses were submitted from 
the United Kingdom, Norway and Switzerland. Table 15 presents the respondents’ country of origin.  

Table 16: 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 

Czech Republic 

France 

Spain 

Sweden 

Luxembourg 

Netherlands 

Greece 

77 

17 

16 

11 

8 

8 

6 

4 

3 

2 

2 

2 

45.3% 

10.0% 

9.4% 

6.5% 

4.7% 

4.7% 

3.6% 

2.4% 

1.8% 

1.2% 

1.2% 

1.2% 

Slovenia 

Romania 

Latvia 

Hungary 

Slovakia 

Ireland 

Estonia 

Switzerland 

Bulgaria 

Norway 

Finland 

Poland 

2 

2 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1.2% 

1.2% 

0.6% 

0.6% 

0.6% 

0.6% 

0.6% 

0.6% 

0.6% 

0.6% 

0.6% 

0.6% 

90 As the  main profile question is pre-defined for all public  consultations, it  was  not possible to include a choice  for 
‘drivers’. Instead, drivers were asked to select ‘other’ (which 24 out of 33 ‘other’ respondents did), and then to confirm 
their status as a driver in the next question, as well as to indicate whether they were employed or self-employed. Some 
drivers misunderstood the instructions, indicating themselves to be drivers even though they did not identify themselves 
as ‘other’ in the  first profile  question. Overall, there  were  57 drivers among the respondents, of  whom 34  were self-
employed, 21 employed, and 2 did not answer. 

53 

 
 
                                                 
Source: Public consultation  

Out of the 83 companies that participated in the public consultation, 62 (i.e. nearly 75%) employed between 
1 and 49 employees (i.e. they were either micro or small companies), whilst 21 medium and large companies 
accounted together for 25.3% of all businesses that took part to the public consultation (Figure 7). 

Figure 7: Organisation size 

Micro (1 to 9 employees)

Small (10 to 49 employees)

Medium (50 to 249 employees)

Large (250 or more)

4, 4,8%

25, 30,1%

37, 44,6%

17, 20,5%

Source: Public consultation (83 respondents) 

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

50%

It must 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  closed  and  open  questions.  These 
entailed three clusters 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), as well as 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.  

It was observed that the views of respondents identifying  themselves  as drivers (particularly employed 
drivers) in the public consultation were inconsistent with the findings from the targeted interviews, whose 
driver identities were carefully checked.   

With  regard  to  the  current  rules,  nearly  all  consulted  stakeholders  considered  at  least  minor  changes 
necessary.  In  open-text  replies,  companies,  associations  and  drivers  considered  the  current  rules  to  be 
insufficiently adapted to the needs of the occasional passenger sector. As for trade unions and authorities, 
they were more likely to support keeping the current rules in place, while open-text replies focused on 
enforcement measures and/or making the rules stricter.  

Figure 8: Overall, do you think that the existing rules on break times are appropriate, or should they be changed? 

Business associations (n=12)

2

Employed drivers (n=14)

1

Companies (n=78)

20

Self-employed drivers (n=32)

Public authorities (n=10)

Trade unions (n=6)

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  

54 

 
 
 
Figure 8: 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  

With regard to potential changes, stakeholder views were similar to those expressed on the current rules, 
i.e.  with  strong  support  for  change  from  business  associations,  companies  and  self-employed  drivers, 
moderate support from employed drivers, and trade unions and authorities opposing all proposed changes 
(Table 16).  

Table 17: Views by stakeholder group of the proposed policy measures 

PM 1: Allow drivers to split their 
break of minimum 45 minutes into 
30+15 or 15+15+15 minutes 
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 6: 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 9: Extension of the 12-day rule 
to domestic transport operations 
PM 10: Removal of the single-
service condition when using the 
12-day rule 
PM 11: Remove the compensatory 
rest after use of the 12-day rule 
PM 12: Flexible distribution of 
weekly rests over a 10-week 
reference period 

Business 
associations  
9  / 2  

Companies 

38 / 9 

Self-
employed 
16 / 4  

Employed 
drivers  

15 / 0  

Trade 
unions 

1 / 5  

Public 
authorities 

2 / 8  

5 / 6  

30 / 25  

16 / 7  

10 / 0  

0 / 6  

1 / 9  

7 / 3  

37 / 18  

16 / 8  

15 / 1  

0 / 6  

4 / 6  

5 / 6  

32 / 20  

11 / 10  

13 / 3  

0 / 6  

2 / 8  

10 / 1  

55 / 2  

25 / 2  

15 / 1  

7 / 2  

45 / 8  

18 / 5  

14 / 1  

9 / 2  

7 / 4  

47 / 10  

22 / 5  

16 / 0  

42 / 11  

17 / 4  

15 / 1  

1 / 5  

0 / 6  

0 / 6  

0 / 6  

3 / 7  

3 / 7  

0 / 10  

0 / 10  

Source: Public consultation; Legend: each cell is presented as: “Number supporting / number opposing”  

2.3. Exploratory interviews and targeted interviews 

The targeted interviews took place in two steps, namely 9 exploratory interviews with stakeholders at the 
European and international levels, which served to gather initial input and identify relevant stakeholders, 
and a second step consisting of 29 interviews in five Member States (Bulgaria, Germany, the Netherlands, 
Spain  and  Sweden),  which  were  selected on  the basis of  geographical diversity  and  the importance  of 
tourism (as a proxy for the importance of occasional bus and coach transport). The interviews covered both 
the  current  situation  and  potential  changes  to  the  rules.  In  addition,  about  ten  more  interviews  were 
conducted with stakeholders to feed into the three thematic case studies (focused on small, medium-sized 
and large operators), and to elicit additional information and clarifications during the latter stages of the 
work.  

55 

 
 
  
The interviews were carried out between June 2021 and January 2022. In-depth interviews were a crucial 
source of information considering the technical nature of the rules and niche status of occasional bus and 
coach transport, as well as the lack of evidence. Due to factors such as survey fatigue, an unfamiliarity with 
foreseen policy development and consultation, and limited knowledge of occasional services, it was difficult 
to gather feedback from certain target groups. Thus, while it was possible to interview trade unions in 3 
Member  States  and business  associations  in  all  five Member States,  individual  drivers were  extremely 
difficult to reach for the targeted interviews, despite extensive information activities. 

Table 18: Breakdown of the targeted interviews  

Business 
associations  

Bus & coach 
operators 

Trade 
unions 

Authorities 

Drivers 

Experts 
and 
others 

Total 

EU 

Bulgaria  

Germany  

Netherlands 

Spain 

Sweden 

5 

2 

1 

1 

1 

2 

- 

2 

2 

1 

1 

1 

1 

- 

- 

1 

2 

1 

2 

- 

1 

1 

- 

2 

Total 

7 
Source: Tetra Tech International et al. (2022), Impact assessment support study 

12 

6 

5 

- 

2 

- 

1 

1 

2 

6 

1 

- 

- 

- 

- 

1 

2 

9 

6 

4 

5 

5 

9 

38 

In terms of key findings and conclusions, the consultation exercise also showed that views on the current 
rules and potential changes are highly polarised between employers and employees and small companies 
versus large companies.  

With  regard  to  the  current  rules,  five  trade  unions,  four  employed  drivers  and  five  Member  States 
enforcement agencies/authorities tend to support the maintenance of the status quo, or even ask for stricter 
rules (e.g. removal of the existing “12-day derogation”). While there are some exceptions (e.g. certain self-
employed drivers, who desire greater autonomy/flexibility to define their schedules), these stakeholders feel 
that fairly stringent rules and rigorous enforcement are needed to ensure adequate working conditions. In 
contrast, most operators, especially small ones, believe that certain refinements of the rules are needed in 
order to ensure a high quality and efficient service provision.  

There  is  a  similar  polarisation  with  regards  to  potential  changes  to  the  rules.  For  the  most  part,  the 
interviewed trade unions and most (employed) drivers are against new flexibilities in the organisation of the 
work and rest periods of bus and coach drivers, because they feel that these would deteriorate working 
conditions. Nonetheless, drivers show willingness for some changes in the rules, for instance on extension 
of the 12-day rule to domestic occasional trips and – to a lesser extent – adjustments to the rules on break 
times with regard to splitting mandatory breaks. The most vocal opposition concerns the changes to the 
distribution of daily and weekly rest time periods. In contrast, the large majority of bus and coach operators 
and their representatives favour extensive changes to the rules on the distribution of breaks, daily and weekly 
rest periods in order to address the specificities of this segment (e.g. high seasonality) and accommodate 
better the needs of passengers.  

2.4. Case studies  

Three  case studies  were  carried  out  within  the targeted interviews:  Case  study  1  focused on small  bus 
operators; Case study 2 on large EU-wide operators and Case study 3 on medium-sized operators. They 
confirmed that smaller companies, which mostly operate only occasional passenger services, are much more 
dependent  on  occasional  passenger  services  than  medium  or  large-size  companies,  the  latter  being 
characterised for running different types of services simultaneously (i.e. occasional and regular passenger 

56 

 
 
services). In contrast, large companies face relatively fewer issues with the current legislation than their 
smaller competitors, notably thanks to the ability to deploy more drivers to work within the framework of 
the rules, resulting in fewer issues with the compliance. This does not mean that larger companies do not 
experience problems in similar ways, but only that their financial performance would be impacted less 
significantly from changing the rules.  

57 

 
 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

1.  Practical implications of the initiative 

The preferred option (PO A) entails adjustments to the breaks and rest period rules that will apply only to 
drivers in the occasional transport of passengers by bus and coach. While these rules will differ from the 
ones that are currently applicable, they will not involve changes to the nature of the rules. More specifically, 
drivers will still be subject to requirements in terms of the amount of breaks for every 4.5 hours of driving, 
a minimum length of the daily rest periods, and the length of weekly rest periods. The amount of total 
driving  time  per  day  will  remain  unchanged,  as  well  as  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 in the administrative or 
enforcement costs are foreseen relative to the baseline.  

The preferred option has implications for the following stakeholders’ groups: 

-  Occasional bus and coach operators  

-  Drivers driving within occasional bus and coach operations 

-  Public authorities responsible for implementing rules on breaks and rest periods 

-  Passengers of occasional bus and coach operations. 

Occasional bus and coach operators will be affected in the following way: firstly the rules for operators 
will  be  less  restrictive  than  this  is  currently  the  case,  meaning  that  the  operators  will  benefit  from  an 
improved regulatory environment for arranging occasional bus and coach services, which (albeit to a limited 
extent)  may  lead  to  increased  service  volumes  and  revenues.  The  preferred  option  is  also  expected  to 
facilitate compliance with the rules and to lead to significant operation costs savings for the occasional bus 
and coach operators.  

Drivers: PO A will affect drivers directly. The improvements in terms of autonomy and the ability to take 
breaks, daily and weekly rests at convenient times outweigh the longer daily working cycle and postponed 
weekly rests that would occur in some circumstances (e.g. from the 12-day rule). The adjusted rules will 
also facilitate compliance. This may lead to some reduction in drivers’ levels of stress and fatigue, which 
may  also  have  a  positive  impact  on  road  safety.  Drivers  (especially  those  who  are  self-employed)  are 
expected to experience economic benefits, because they would be able to take on a greater workload – 
during peak seasons.  

Public  authorities  are  not  expected  to  change  reporting  and  enforcement  modalities,  but  minor 
improvements  in  compliance  with  the  rules  among  occasional  bus  and  coach  operators  may  reduce 
enforcement burden on public authorities to a limited extent. On the other hand, public authorities would 
incur some limited costs for getting familiar with the new rules.  

Consumers: since it is envisaged that the rules will 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. 

2.  Summary of costs and benefits 

58 

 
I. Overview of Benefits (total for all provisions) – Preferred Option (Policy option A) 

Description 

Amount 

Comments 

Direct benefits 

EUR 106.4  to 141.9  million 

Adjustment  costs  savings 
for  occasional  bus  and 
coach operators, expressed 
as  present  value  over 
2025-2050  relative  to  the 
baseline 

impact  on 

Positive 
the 
functioning of the internal 
market and competition 

Positive impact on 
compliance with the rules 

Positive impact on 
working conditions 

Positive impact on 
driver’s stress and fatigue 

Higher-quality 
and 
cheaper  occasional  bus 
and  coach  services  for 
consumers  

- 

- 

- 

- 

- 

The preferred policy option would reduce the need 
for stops and other changes to itineraries solely for 
the  purpose  of  complying  to  the  rules,  as  well  as 
increasing the proportion of itineraries that could be 
staffed  with  a  single  driver  (rather  than  two 
drivers).  The  result  would  be  reduced  operation 
costs  for  occasional  bus  and  coach  operators, 
especially SMEs, who are less well-equipped than 
larger companies to handle the current rules.  

Allowing  bus  and  coach  drivers  in  domestic 
occasional  carriage  of  passengers  to  postpone  the 
weekly rest period for up to 12 consecutive 24-hour 
periods,  following  a  previous  regular  weekly  rest 
period, is expected to have a strong positive impact 
on levelling the playing field for companies reliant 
on domestic services and thus is expected to have a 
positive  impact  on  the  competition  between  the 
international  and  domestic  services,  and 
the 
functioning of the internal market. 

The preferred policy option would help to address 
the  current  issues  with  compliance  difficulties, 
while avoiding changes that would make the rules 
more  difficult  to  report  on  and  enforce,  thus 
generating a net positive impact. 

The  preferred  policy  option  would  address  the 
problems  that the current rules cause  for  working 
conditions,  while  using  compensatory  action  to 
mitigate  the  risks.  Thus  the  revised  rules  are 
expected  to  have  a  positive  impact  on  working 
conditions. 

By  improving  working  conditions  and  facilitating 
compliance  with  the  rules,  the  preferred  policy 
option strikes the right balance between flexibility 
and maintaining the principles of the current rules, 
thereby leading to reduced driver stress and fatigue 
for drivers. 

Indirect benefits 

The revised rules are expected to make it easier for 
operators to arrange services in a high-quality and 
efficient way. To a certain extent, reduced costs for 
operators  are  expected  to  be  passed  on  the 
consumers  in  the  form  of  reduced  prices  for 
occasional services.  

Administrative cost savings related to the ‘one in, one out’ approach* 

- 

- 

- 

59 

 
II. Overview of costs – Preferred option (Policy option A) 

Direct adjustment costs 

Direct administrative costs 

Direct enforcement costs 

Citizens/Consumers 

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

- 

- 

- 

- 

- 

- 

For occasional bus and coach 
operators: EUR 0.6 million in 
2025 

- 

- 

For Member States 
administrations: EUR 5.4 million, 
expressed as present value 
relative to the baseline 

- 

- 

- 

- 

- 

- 

- 

- 

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: EUR 0.6 million in 
2025, for getting familiar with 
the new rules. 
Overcompensated by the 
adjustment costs savings for 
the sector.  

- 

- 

60 

 
 
 
 
 
 
 
 
 
 
3.  Relevant sustainable development goals 

III. Overview of relevant Sustainable Development Goals – Preferred option (Policy option A) 
Expected progress towards the Goal 
Relevant SDG 

Comments 

PO  A  is  expected  to  improve  the  business 
performance of the occasional bus and coach 
operators,  which  could  in  turn  contribute  to 
economic 
employment. 
Moreover, 
improve  working 
conditions  for drivers in occasional bus and 
coach transport, contributing to decent work.   

growth 
it  would 

and 

SDG no. 8 – promoting 
economic growth, 
productive employment and 
decent work 

impact  on 

Limited  positive 
the  business 
performance  of  the  occasional  bus  and  coach 
sector and positive impact on working conditions 
for drivers in occasional bus and coach transport. 

61 

 
 
ANNEX 4: ANALYTICAL METHODS 

1.  Description of the analytical methods used  

The main model used for developing the baseline scenario for this initiative is the PRIMES-TREMOVE 
transport model by E3Modelling, a specific module of the PRIMES models. The model has a successful 
record of use in the Commission's energy, transport and climate policy assessments. In particular, it has 
been used for the impact assessments underpinning the “Fit for 55” package91, the impact assessments 
accompanying  the  2030  Climate  Target  Plan92  and  the  Staff  Working  Document  accompanying  the 
Sustainable and Smart Mobility Strategy93, the Commission’s proposal for a Long Term Strategy94 as well 
as for the 2020 and 2030 EU’s climate and energy policy framework. Building on the PRIMES-TREMOVE 
model results, the baseline projections for the number of passengers in the occasional bus and coach sector 
have been developed by Tetra Tech International et al. in the context of the impact assessment support 
study95.  

For the assessment of the impacts of the policy options, an excel-based tool has been developed by Tetra 
Tech International et al., which draws on the Standard Cost Model. The proposed measures which involve 
the  amendment  of  the  Regulation  are  assumed  to  be  implemented  from  2025  onwards,  so  that  the 
assessment  has  been  undertaken  for  the  2025-2050  period  and  refers  to  EU27.  Costs  and  benefits  are 
expressed as present value over the 2022-2050 period, using a 3% discount rate. 

PRIMES-TREMOVE model  

The PRIMES-TREMOVE transport model projects the evolution of demand for passengers and freight 
transport,  by  transport  mode,  and  transport  vehicle/technology,  following  a  formulation  based  on 
microeconomic  foundation  of  decisions  of  multiple  actors.  Operation,  investment  and  emission  costs, 
various policy measures, utility factors and congestion are among the drivers that influence the projections 
of the model. The projections of activity, equipment (fleet), usage of equipment, energy consumption and 
emissions (and other externalities) constitute the set of model outputs.  

The PRIMES-TREMOVE transport model can therefore provide the quantitative analysis for the transport 
sector in the EU, candidate and neighbouring countries covering activity, equipment, energy and emissions. 
The model  accounts  for  each  country  separately  which means that the detailed long-term outlooks  are 
available both for each country and in aggregate forms (e.g. EU level). 

In  the  transport  field,  PRIMES-TREMOVE  is  suitable  for  modelling  soft  measures  (e.g.  eco-driving, 
labelling); economic measures (e.g. subsidies and taxes on fuels, vehicles, emissions; ETS for transport 
when linked with PRIMES; pricing of congestion and other externalities such as air pollution, accidents and 
noise; measures supporting R&D); regulatory measures (e.g. CO2 emission performance standards for new 

91 Delivering the European Green Deal | European Commission (europa.eu) 
92 SWD(2020)176 final. 
93 EUR-Lex - 52020SC0331 - EN - EUR-Lex (europa.eu)  
94 Source: 2050 long-term strategy (europa.eu)   
95 Tetra Tech International et al. (2022), Support study for an impact assessment for a possible revision of Regulation 
(EC) No 561/2006.  

62 

 
 
 
                                                 
light  duty  vehicles  and  heavy  duty  vehicles;  EURO  standards  on  road  transport  vehicles;  technology 
standards  for  non-road  transport  technologies,  deployment  of  Intelligent  Transport  Systems)  and 
infrastructure  policies  for  alternative  fuels  (e.g.  deployment  of  refuelling/recharging  infrastructure  for 
electricity, hydrogen, LNG, CNG). Used as a module that contributes to the PRIMES energy system model, 
PRIMES-TREMOVE can show how policies and trends in the field of transport contribute to economy-
wide trends in energy use and emissions. Using data disaggregated per Member State, the model can show 
differentiated trends across Member States.  

The PRIMES-TREMOVE has been developed and is maintained by E3Modelling, based on, but extending 
features of, the open source TREMOVE model developed by the TREMOVE96 modelling community. Part 
of the model (e.g. the utility nested tree) was built following the TREMOVE model.97 Other parts, like the 
component on fuel consumption and emissions, follow the COPERT model. 

Data inputs 

The  main  data  sources  for  inputs  to  the  PRIMES-TREMOVE  model,  such  as  for  activity  and  energy 
consumption, come from EUROSTAT databases and from the Statistical Pocketbook "EU transport in 
figures98. Excise taxes are derived from DG TAXUD excise duty tables. Other data comes from different 
sources such as research projects (e.g. TRACCS project) and reports. 

In the context of this exercise, the PRIMES-TREMOVE transport model is calibrated to 2005, 2010 and 
2015 historical data. Available data on 2020 market shares of different powertrain types have also been 
taken into account. 

Model for the occasional bus and coach sector  

The  PRIMES-TREMOVE  model  provides  projections  for  the  buses  and  coaches  sector  but  does  not 
distinguesh the ocassional buses and coaches sector. For this reason, a multi-variate regression model99 has 
been established by Tetra Tech International et al. in the context of the impact assessment support study100, 
aimed  at  ‘translating’  the  PRIMES-TREMOVE  projections  to  the  occasional  bus  and  coach  sector.  In 
practice, this meant identifying and assessing the relationship (i.e. correlation) between a key ‘dependent 
variable’ which is related to the occasional bus and coach sector – in this case the number of passengers – 
and a relevant number of independent variables, for the countries for which data on the occasional bus and 
coach sector is available. If a strong correlation (i.e. a high goodness of fit) is obtained, the behaviour of the 

96 Source: https://www.tmleuven.be/en/navigation/TREMOVE  
97 Several model enhancements were made compared to the standard TREMOVE model, as for example: for the number 
of  vintages  (allowing  representation  of  the  choice  of  second-hand  cars);  for  the  technology  categories  which  include 
vehicle types using electricity from the grid and fuel cells. The model also incorporates additional fuel types, such as 
biofuels  (when  they  differ  from  standard  fossil  fuel  technologies),  LPG,  LNG,  hydrogen  and  e-fuels.  In  addition, 
representation of infrastructure for refuelling and recharging are among the model refinements, influencing fuel choices. 
A major model enhancement concerns the inclusion of heterogeneity in the distance of stylised trips; the model considers 
that  the  trip  distances  follow  a  distribution  function  with  different  distances  and  frequencies.  The  inclusion  of 
heterogeneity was found to be of significant influence in the choice of vehicle-fuels especially for vehicles-fuels with 
range limitations. 
98 Source: https://ec.europa.eu/transport/facts-fundings/statistics_en  
99  A  multi-variate  regression  model  looks  at  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. 
100 Tetra Tech International et al. (2022), Support study for an impact assessment for a possible revision of Regulation 
(EC) No 561/2006.  

63 

 
 
                                                 
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 as independent variables the GDP and tourism activity 
served as the basis to project the number of passengers in the occasional buses and coaches sector until 
2050. This in turn allowed to estimate the market share of the occasional transport within the overall bus 
and coach market, drawing on PRIMES-TREMOVE model projections and the multi-variate regression 
model.  

For countries where data on the occasional bus and coach sector is not available, estimates had first to be 
prepared for the base year. Based on data available for 9 countries (Belgium, Czech Republic, Estonia, 
Germany, Hungary, Lithuania, Poland, Portugal and Romania) and considering 2019 as base year, data on 
transport activity (in terms of passenger-kilometres and thousands of passengers) was extrapolated to the 
remaining 18 EU Member States. First, the share of national occasional bus and coach transport activity and 
international occasional bus and coach transport activity in the total bus and coach activity was estimated 
for 2019. In order to establish a correlation between the countries with data available for 2019 and those 
with missing data, some relevant indicators from EUROSTAT 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;  ii)  motorisation  rate  (per  1,000  inhabitants);  iii)  rail  passengers  per  inhabitant.  In  the 
following step, projections for the transport activity for these 18 Member States were established building 
on the results of the multi-variate regression model. 

The correlations established on the market share of occasional bus and coach sector were used to make 
projections for other relevant indicators (employment levels and turnover). These projections were 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 project the fleet size for the occasional bus and coach sector. This 
is  because  the  sector’s  fleet  is  typically  characterised  by  a  mix  of  vehicles  that  operate  in  regular  and 
occasional services.  

Data inputs 

The main data sources, for the number of bus and coach passengers and for the number of persons employed 
in the passenger land transport, are EUROSTAT database and the Statistical Pocketbook "EU transport in 
figures”101.  Other  data  comes  from  different  sources  such  as  UNECE,  World  Tourism  Organisation, 
national databases and some national/social representatives’ reports. In relation to the evidence gathered, 
it should be noted that the size of the occasional bus and coach sector is small. In 2019 it represented 
3.3% of the total number of passengers in the bus and coach sector at EU level and generated roughly 
11%  of  the  total  turnover  of  road  passenger  transport.  The  sector  is  estimated  to  employ  around 
202,600 people.  

Given the small size of the occasional bus and coach sector and the relatively limited scope of the 
rules under review, a proportionate analysis was conducted in line with the Better Regulation toolbox. 
While this means that the data collection exercise was not extensive, it still allowed for sufficiently 
broad and detailed insight to be gathered, covering the main stakeholder groups as well as accounting 
for geographical diversity.  

101 https://transport.ec.europa.eu/media-corner/publications_en 

64 

 
 
                                                 
The scarcity of quantitative, granular data on the occasional bus and coach sector, limited the extent 
of the quantitative assessment to the impacts on costs and benefits for operators and costs for public 
administrations. To ensure the validity of the results, to the extent possible this consisted of objective 
and factual input and concrete examples. Findings were also triangulated between different groups 
of stakeholders and data collection tools. Overall, this has allowed the results to be presented with 
sufficient  confidence.  Nonetheless,  it  should  be  noted  that  few  of  the  findings  are  based  on 
statistically representative samples. Stakeholder groups on a wide geographical basis were consulted. 
Stakeholders  have  been  consulted  on  all  elements  of  the  impact  assessment,  including  the  policy 
measures.  This  was  done  through  the  inception  impact  assessment,  public  consultation,  targeted 
interviews and case studies. For the targeted interviews, the selection of interviewees was based on 
specific profiles to ensure that the main groups of stakeholders were covered.   

2.  Baseline scenario 

In  order  to  reflect  the  fundamental  socio-economic,  technological  and  policy  developments,  the 
Commission prepares periodically an EU Reference Scenario on energy, transport and GHG emissions. 
The socio-economic and technological developments used for developing the baseline scenario for this 
impact assessment build on the latest “EU Reference scenario 2020” (REF2020)102. The same assumptions 
have been used in the policy scenarios underpinning the impact assessments accompanying the “Fit for 55” 
package103.  

Main assumptions of the Baseline scenario 

The main assumptions related to economic development, international energy prices and technologies are 
described below. 

Economic assumptions  

The modelling work is based on socio-economic assumptions describing the expected evolution of the 
European society. Long-term projections on population dynamics and economic activity form part of the 
input  to  the  model  and  are  used  to  estimate  transport  activity,  particularly  relevant  for  this  impact 
assessment.  
Population  projections  from Eurostat104  are  used to estimate the  evolution  of  the  European  population, 
which is expected to change little in total number in the coming decades. The GDP growth projections are 
from the Ageing Report 2021105 by the Directorate General for Economic and Financial Affairs, which are 
based on the same population growth assumptions. 

Table 19: Projected population and GDP growth per Member State 

EU27 

Austria 

Belgium 

Bulgaria 

Population 

GDP growth 

2020 
447.7 

8.90 

11.51 

6.95 

2025 
449.3 

9.03 

11.66 

6.69 

2030 
449.1 

9.15 

11.76 

6.45 

2020-‘25 
0.9% 

0.9% 

0.8% 

0.7% 

2026-‘30 
1.1% 

1.2% 

0.8% 

1.3% 

102 EU Reference Scenario 2020 (europa.eu) 
103 Policy scenarios for delivering the European Green Deal (europa.eu) 
104 EUROPOP2019 population projections: Eurostat - Data Explorer (europa.eu)   
105  The  2021  Ageing  Report :  Underlying  assumptions  and  projection  methodologies  The  2021  Ageing  Report: 
Underlying Assumptions and Projection Methodologies | European Commission (europa.eu)   

65 

 
 
 
  
                                                 
Croatia 

Cyprus 

Czech Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

Population 

GDP growth 

2020 
4.06 

0.89 

10.69 

5.81 

1.33 

5.53 

67.20 

83.14 

10.70 

9.77 

4.97 

60.29 

1.91 

2.79 

0.63 

0.51 

17.40 

37.94 

10.29 

19.28 

5.46 

2.10 

47.32 

10.32 

2025 
3.94 

0.93 

10.79 

5.88 

1.32 

5.54 

68.04 

83.48 

10.51 

9.70 

5.27 

60.09 

1.82 

2.71 

0.66 

0.56 

17.75 

37.57 

10.22 

18.51 

5.47 

2.11 

48.31 

10.75 

2030 
3.83 

0.96 

10.76 

5.96 

1.31 

5.52 

68.75 

83.45 

10.30 

9.62 

5.50 

59.94 

1.71 

2.58 

0.69 

0.59 

17.97 

37.02 

10.09 

17.81 

5.44 

2.11 

48.75 

11.10 

2020-‘25 
0.2% 

2026-‘30 
0.6% 

0.7% 

1.6% 

2.0% 

2.2% 

0.6% 

0.7% 

0.8% 

0.7% 

1.8% 

2.0% 

0.3% 

1.4% 

1.7% 

1.7% 

2.7% 

0.7% 

2.1% 

0.8% 

2.7% 

1.1% 

2.1% 

0.9% 

1.4% 

1.7% 

2.0% 

1.7% 

2.6% 

1.2% 

1.0% 

0.7% 

0.6% 

2.6% 

1.7% 

0.3% 

1.9% 

1.5% 

2.0% 

4.1% 

0.7% 

2.4% 

0.8% 

3.0% 

1.7% 

2.4% 

1.6% 

2.2% 

Beyond the update of the population and growth assumptions, an update of the projections on the sectoral 
composition of GDP was also carried out using the GEM-E3 computable general equilibrium model. These 
projections take into account the potential medium- to long-term impacts of the COVID-19 crisis on the 
structure  of  the  economy,  even  though  there  are  inherent  uncertainties  related  to  its  eventual  impacts. 
Overall, conservative assumptions were made regarding the medium-term impacts of the pandemic on the 
re-localisation of global value chains, teleworking and teleconferencing and global tourism. 

International energy prices assumptions  

Alongside socio-economic projections, transport modelling requires projections of international fuel prices. 
The projections of the POLES-JRC model – elaborated by the Joint Research Centre and derived from the 
Global Energy and Climate Outlook (GECO106) – are used to obtain long-term estimates of the international 
fuel prices. The table below shows the oil prices assumptions of the baseline and policy options of this 
impact assessment.  

Table 20: Oil prices assumptions  

in $'15 per boe 
Oil 

2015 
52.3 

2020 
39.8 

2030 
80.1 

2040 
97.4 

2050 
117.9 

106 https://ec.europa.eu/jrc/en/geco  

66 

 
 
 
  
                                                 
in €'15 per boe 
Oil 

2015 
47.2 

2020 
35.8 

2030 
72.2 

2040 
87.8 

2050 
106.3 

Source: Derived from JRC, POLES-JRC model, Global Energy and Climate Outlook (GECO) 

Technology assumptions 

Modelling scenarios is highly dependent on the assumptions on the development of technologies, both in 
terms of performance and costs. For the purpose of the impact assessments related to the “Climate Target 
Plan”  and  the  “Fit  for  55”  policy  package,  these  assumptions  have  been  updated  based  on  a  rigorous 
literature  review  carried  out  by  external  consultants  in  collaboration  with  the  JRC107.  Continuing  the 
approach  adopted  in  the  long-term  strategy  in  2018,  the  Commission  consulted  on  the  technology 
assumption with stakeholders in 2019. In particular, the technology database of the PRIMES and PRIMES-
TREMOVE  models  (together  with  GAINS,  GLOBIOM,  and  CAPRI)  benefited  from  a  dedicated 
consultation  workshop  held  on  11th  November  2019.  EU  Member  States  representatives  also  had  the 
opportunity to comment on the costs elements during a workshop held on 25th November 2019. The updated 
technology  assumptions  are  published  together  with  the  EU  Reference  Scenario  2020108.  The  same 
assumptions have been used in the context of this impact assessment. 

Policies in the Baseline scenario  

Building on the EU Reference scenario 2020, the baseline scenario for this impact assessment has been 
designed to include the initiatives of the ‘Fit for 55’ package109. The Baseline scenario assumes no further 
EU level intervention beyond the current rules on breaks and rest periods established by Regulation (EC) 
No 561/2006, as amended by Regulation (EU) 2020/1054.  

Baseline scenario results 

Evolution of the number of passengers in the occasional bus and coach sector. The COVID-19 pandemic 
had  an  unprecedented  impact  on  the  passenger  transport  sector  and  on  tourism,  with  touristic-related 
activities reaching a standstill throughout most of 2020. The number of passengers in the occasional bus 
and coach sector is estimated to have decreased by 86% in 2020 relative to 2019 (see Table 20). By 2025, 
at EU level the number of passengers in the occasional bus and coach sector is projected to recover close to 
pre-pandemic levels, driven by the recovery of the tourism sector. This is however not expected to be the 
case in all Member States (i.e. Eastern European Member States, in particular, still showing lower number 
of passengers in the occasional bus and coach sector by 2025 relative to 2019). The number of passengers 
in occasional bus and coach sector is projected to grow by 15% by 2030 and 38% by 2050, relative to 2019. 

Table 21: Projected evolution of the number of passengers in the occasional bus and coach sector in the baseline 
scenario 

AT 
BE 
BG 
CZ 
CY 
DE 

2019  
4,521 
3,511 
15,857 
72,472 
6,851 
130,040 

2020  
901 
1,016 
4,366 
25,449 
1,624 
25,913 

2025  
4,973 
3,511 
13,479 
55,804 
6,919 
143,044 

2030  
5,749 
3,822 
15,873 
69,674 
8,920 
165,352 

2050  
7,062 
4,051 
17,388 
88,839 
9,906 
203,111 

107 JRC118275  
108 EU Reference Scenario 2020 (europa.eu) 
109 Delivering the European Green Deal | European Commission (europa.eu) 

67 

 
 
  
                                                 
 
 
 
 
 
 
2025  
167,554 
7,164 
54,576 
89,507 
15,387 
73,304 
19,159 
133,023 
5,884 
190,363 
603 
11,374 
1,900 
2,778 
39,854 
19,072 
23,109 
46,498 
7,519 
7,475 
12,860 
1,156,695 
Source: Tetra Tech International et al. (2022), Impact assessment support study 

2019  
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 
1,182,801 

2020  
30,353 
1,286 
3,255 
6,737 
2,920 
14,607 
1,714 
15,870 
1,117 
8,972 
56 
1,141 
132 
224 
7,220 
1,712 
1,054 
2,086 
1,461 
963 
3,015 
165,164 

DK 
EE 
ES 
EL 
FI 
FR 
HR 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
EU27 

2030  
193,684 
8,436 
62,217 
115,394 
17,787 
84,736 
23,121 
160,528 
6,802 
217,015 
710 
14,664 
2,196 
3,581 
46,069 
22,459 
26,344 
54,756 
8,692 
9,637 
14,866 
1,363,082 

2050  
237,913 
9,241 
76,929 
128,144 
21,849 
104,085 
26,899 
186,758 
8,355 
268,333 
777 
16,284 
2,698 
3,977 
56,590 
24,603 
32,574 
59,982 
10,676 
10,702 
18,260 
1,635,988 

The passengers in the occasional bus and coach sector represented 3.3% of the total number of passengers 
in the bus and coach sector in 2019 at EU level. Due to the pandemic, the share plummeted to 0.5% in 2020. 
Nonetheless, the share of occasional bus and coach sector is projected to reach 2.4% by 2025, driven by the 
partial recovery of the sector, and remain relatively stable over time reaching 2.4% by 2030 and 2.6% by 
2050. 

Evolution  of  transport  activity  in  the  occasional  bus  and  coach  sector.  The  transport  activity  in  the 
occasional bus and coach sector is projected to follow a similar evolution to the number of passengers in 
the sector. Transport activity expressed in billion passenger-kilometers is estimated to have decreased by 
88% between 2019 and 2020 and would grow by 16% by 2030 relative to 2019 driven by the post-COVID 
recovery (41% increase for 2019-2050).  

Table 22: Projected evolution of transport activity (in Gpkm) in the occasional bus and coach sector in the baseline 
scenario 

AT 
BE 
BG 
CZ 
CY 
DE 
DK 
EE 
ES 
EL 
FI 

2019  
2.6 
3.2 
1.5 
5.6 
0.3 
16.5 
1.7 
0.6 
9.2 
3.5 
2.1 

2020  
0.5 
0.4 
0.2 
1.1 
0.0 
3.3 
0.3 
0.1 
0.6 
0.3 
0.4 

68 

2025  
2.9 
3.2 
1.3 
4.3 
0.3 
18.2 
1.9 
0.5 
9.7 
3.6 
2.2 

2030  
3.4 
3.5 
1.5 
5.4 
0.4 
21.0 
2.2 
0.6 
11.1 
4.7 
2.5 

2050  
4.1 
3.7 
1.6 
6.9 
0.4 
25.8 
2.7 
0.7 
13.7 
5.2 
3.1 

 
 
  
  
FR 
HR 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
EU27 

2019  
14.3 
1.4 
6.7 
3.1 
30.9 
0.2 
0.6 
0.4 
0.1 
1.5 
4.7 
1.9 
2.5 
2.5 
0.8 
1.5 
120.0 

2020  
2.9 
0.1 
0.6 
0.6 
1.6 
0.0 
0.1 
0.0 
0.0 
0.3 
0.4 
0.1 
0.1 
0.5 
0.1 
0.3 
14.9 

2025  
14.3 
1.1 
5.4 
3.2 
32.6 
0.2 
0.5 
0.4 
0.1 
1.7 
4.0 
2.0 
2.1 
2.5 
0.7 
1.2 
120.2 

2030  
16.6 
1.3 
6.5 
3.7 
37.1 
0.2 
0.7 
0.4 
0.1 
2.0 
4.7 
2.3 
2.5 
2.9 
0.9 
1.4 
139.6 

2050  
20.4 
1.6 
7.5 
4.6 
45.9 
0.2 
0.8 
0.5 
0.2 
2.4 
5.2 
2.9 
2.7 
3.6 
0.9 
1.8 
169.0 

Source: Tetra Tech International et al. (2022), Impact assessment support study 

Turnover for the occasional bus and coach sector. The turnover for the occasional bus and coach sector is 
projected to grow in line with the number of passengers in the sector and is estimated to reach EUR 7.5 
billion by 2030 and EUR 8.9 billion by 2050. Operating costs are estimated to represent around 10% of the 
turnover.  

Table 23: Projected evolution of the turnover for the occasional bus and coach sector in the baseline scenario (in EUR 
million) 

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

2019  
        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  

2020  
          66.2  
          26.7  
          13.7  
          36.9  
            2.4  
        131.0  
          17.3  
            3.3  
            9.6  
          77.9  
          26.7  
        340.9  
            6.0  
          23.6  
          26.6  
          27.7  
            0.1  
            1.3  
            2.7  
            1.7  
          62.2  
            4.3  
            7.0  

69 

2025  
        365.3  
          92.4  
          42.3  
          81.0  
          10.1  
        723.0  
          95.7  
          18.4  
        161.7  
     1,035.1  
        140.5  
     1,711.0  
          67.2  
        197.6  
        140.0  
        587.6  
            1.0  
          12.7  
          39.6  
          20.5  
        343.3  
          48.0  
        152.9  

2030  
        422.3  
        100.6  
          49.8  
        101.1  
          13.0  
        835.8  
        110.6  
          21.7  
        184.3  
     1,334.5  
        162.4  
     1,977.8  
          81.0  
        238.5  
        161.9  
        669.8  
            1.2  
          16.3  
          45.8  
          26.4  
        396.8  
          56.5  
        174.3  

2050  
        518.7  
        106.6  
          54.6  
        128.9  
          14.4  
     1,026.6  
        135.9  
          23.8  
        227.9  
     1,481.9  
        199.4  
     2,429.5  
          94.3  
        277.5  
        198.8  
        828.3  
            1.3  
          18.1  
          56.2  
          29.3  
        487.4  
          61.9  
        215.5  

 
 
  
  
RO 
SE 
SI 
SK 
EU27 

        119.2  
          78.2  
          40.4  
          29.1  
        6,353  
Source: Tetra Tech International et al. (2022), Impact assessment support study 

            5.3  
          15.2  
            5.2  
            6.8  
           948  

        140.2  
          76.3  
          47.5  
          34.2  
        6,275  

        140.4  
          90.4  
          52.1  
          33.6  
        7,499  

        153.8  
        111.1  
          57.8  
          41.3  
        8,981  

Number of companies in the occasional bus and coach sector. 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.  

3.  Costs of individual policy measures 

This section explains the inputs used and provides the assessment of costs of the policy measures included 
in the policy options. It also provides the common costs of the policy options for Member States authorities 
and bus and coach operators, for familiarising with the new rules.   

The estimation of the costs draws on the impact assessment support study110, including input collected 
through  desk  research  and  stakeholder  interviews  during  the  impact  assessment  process.  It  should  be 
however noted that these costs and costs savings should only be regarded as an estimation of the order of 
magnitude, drawing mainly on stakeholder interviews. The presentation distinguishes between different 
stakeholders groups (transport operators and Member States authorities) and between one-off and recurrent 
(annual) costs, and provides the present value for 2025-2050 assuming a discount rate of 3%.  

Common costs to all policy options 

All three policy options entail minor adjustments to the rules, that require Member States authorities and 
bus  and  coach  operators  in  the  sector  to  familiarise  themselves  with  the  changes.  These  entail  one-off 
adjustment costs for Member States authorities and for bus and coach operators. On the other hand, none of 
the policy options introduces changes in the reporting or enforcement modalities relative to the baseline. 
Therefore, no change in administrative costs and enforcement costs are expected for the Member States 
authorities relative to the baseline.  

It is not possible to split the one-off adjustment costs for Member States authorities and for bus and coach 
operators, for familiarising with the new rules, by measure. Therefore, these costs are presented below by 
policy option and cover the time needed for Member States authorities and for bus and coach operators to 
familiarise themselves with the changes related to all measures.  

Adjustment costs for Member States authorities 

The time required per enforcement officer to familiarise with the new rules and implement those in their 
planning is estimated at 4 hours. The average cost per hour at EU level is estimated at EUR 24.9111 in 2021 
prices and it is assumed to remain constant over time in real prices. The total number of enforcement officers 
involved in checks is estimated at 54,679112 at EU level. Thus, the one-off adjustment costs for Member 
States authorities in 2025 are estimated at EUR 5.4 million relative to the baseline (in 2021 prices). This 

110  Tetra Tech International et al. (2022), Support study for an impact assessment for a possible revision of Regulation 

(EC) No 561/2006. 

111  Source: Eurostat database, Labour Cost Survey, ISCO 4 (Clerks)  
112  Report from the Commission to the European Parliampent and the Council on the implementation of Regulation (EC) 

No 561/2006 (forthcoming).  

70 

 
 
                                                 
should be regarded as an upper-bound estimate, as it is very likely that familiarising with the new rules 
would take place in the context of the regular activities performed by the enforcement officers. 

Adjustment costs for transport operators 

The workload required by bus and coach companies to familiarise with the new rules and implement those 
in their planning is estimated at 4 hours per company. The average cost per hour at EU level is estimated at 
EUR 24.9113 in 2021 prices and it is assumed to remain constant over time in real prices. 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 (in 2021 prices). As for the Member States authorities, this should be regarded as an 
upper-bound estimate, as it is very likely that familiarising with the new rules would take place in the context 
of the regular activities performed by the bus and coach companies.  

Policy measures addressing flexibility of breaks 

PM1:  Allow drivers  to  split  their  break of minimum 45 minutes into  30 + 15 or 15 + 15 + 15 
minutes 

Adjustment costs savings for transport operators 

The increase in the  flexibility of breaks relative to the baseline scenario, driven by PM1 (in PO A), is 
expected to lead to higher passenger satisfaction as a result of greater adaptability to breaks. It would also 
allow transport operators to better organise passenger services. According to stakeholders’ feedback, the 
drivers’ breaks will be more in line with the customers’ needs and companies are also expected to benefit 
financially from this increased flexibility. 

For PM1, six out of the six interviewed companies argue that on average this would lead to savings in 
operation costs of approximately 0.5% relative to the baseline. These cost savings are expected to have full 
effect in the first two years of implementation of the new rules (i.e. 2025 and 2026) and decrease gradually 
over time until 2050, when the effect would be zero relative to the baseline114. The adjustment costs savings 
for transport operators are estimated at EUR 3.2 million in 2025 relative to the baseline, EUR 2.7 million in 
2030  and  zero  by  2050.  Expressed  as  present  value  over  2025-2050,  the  adjustment  costs  savings  are 
estimated at EUR 35.5 million.  

113  Source: Eurostat database, Labour Cost Survey, ISCO 4 (Clerks)  
114 To estimate  the likely  savings due  to the  policy  measures, a questionnaire exercise  was carried out  with the  main 
sectoral association, based on input from their members. It appeared that the factors that determine operational costs are 
uncertain  and  cannot  be  assumed  to  remain  stable  over  the  coming  decades.  To  reflect  this  growing  uncertainty,  the 
methodological choice was to assume maximal savings during the first two years of implementation of the new rules (i.e. 
2025 and 2026) and then to reduce the estimated savings gradually over time until zero in 2050. In this way, the input 
from  stakeholders  was  fully  taken  into  account,  while  maintaining  an  appropriate  degree  of  caution  and  avoiding 
overestimating the impacts. The same method has been used across all policy measures. 

71 

 
 
                                                 
Table 24: Adjustment costs savings for transport operators due to PM1 in PO A, relative to the baseline (in million 
EUR)  

Costs savings relative to the baseline (in million 
EUR), in 2021 prices 
Operation costs savings for occasional bus and coach 
companies 

2025 

2030 

3.2 

2.7 

2040 

1.4 

2050 

0 

Source: Tetra Tech International et al. (2022), Impact assessment support study 

PM2:  Allow drivers to flexibly split their break of minimum 45 minutes over the period of 4h30 
driving time 

Adjustment costs savings for transport operators 

As for PM1, the increase in the flexibility of breaks relative to the baseline scenario driven by measure PM2 
(in PO B and PO C) is expected to lead to higher passenger satisfaction as a result of greater adaptability to 
breaks.  Although  it  would  be  harder  to  introduce  PM2  due  to  the  greater  opposition  from  national 
authorities, trade unions and employed drivers, this measure is expected to lead to slightly larger positive 
impact on business performance than PM1. According to stakeholders’ feedback, the drivers’ breaks will 
be more in line with the customers’ needs and companies are also expected to benefit financially from this 
increased flexibility. 

For PM2, six out of the six interviewed companies argue that on average this will lead to operation cost 
savings of 0.5-1% relative to the baseline. These cost savings are expected to have full effect in the first two 
years of implementation of the new rules (i.e. 2025 and 2026) and decrease gradually over time until 2050, 
when the effect would be zero relative to the baseline. The adjustment costs savings for transport operators 
are estimated at EUR 3.2 to 6.4 million in 2025 relative to the baseline, EUR 2.7 to 5.5 million in 2030 and 
zero by 2050. Expressed as present value over 2025-2050, the adjustment costs savings are estimated at 
EUR 35.5 to 70.9 million.  

Table 25: Adjustment costs savings for transport operators due to PM2 in PO B and PO C, relative to the baseline (in 
million EUR) 
Costs savings relative to the baseline (in million EUR), in 
2021 prices 

2040 

2025 

2030 

2050 

Operating costs savings for occasional bus and coach companies 

Low 
High 

3.2 
6.4 

2.7 
5.5 

1.4 
2.7 

0.0 
0.0 

 Source: Tetra Tech International et al. (2022), Impact assessment support study 

Policy measures addressing daily rest periods 

PM3:  Allow drivers involved in services lasting at least 8 days to postpone the start of the daily 
rest period by 1 hour provided that they do not drive more than 7 hours  

Adjustment costs savings for transport operators 

Changes to the rules on daily rest periods affect the way that operators organise occasional services and 
thereby affect their operation costs. For example, if a trip that requires two drivers under the current rules 
could be carried out with one driver due to changes to the rules, this would lead to a reduction in operation 
costs.  

72 

 
 
 
 
PM3 and PM6 (“Allow drivers involved in services lasting at least 8 days to postpone the start of the daily 
rest period by 2 hours provided that they do not drive more than 5 hours”), both included in PO C, are 
expected to have a large degree of overlap in terms of reduction in operation costs and are thus assessed 
together. Estimates in terms of impacts expected were provided by the IRU, in terms of percentage changes 
compared to the baseline. The reduction in operation costs is estimated at 0.5-1% relative to the baseline, 
and is expected to have full effect in the first two years of implementation of the new rules (i.e. 2025 and 
2026) and decrease gradually over time until 2050, when the effect would be zero relative to the baseline. 
The adjustment costs savings for transport operators are estimated at EUR 3.2 to 6.4 million in 2025 relative 
to the baseline, EUR 2.7 to 5.5 million in 2030 and zero by 2050. Expressed as present value over 2025-
2050, the adjustment costs savings are estimated at EUR 35.5 to 70.9 million.  

 Table 26: Adjustment costs savings for transport operators due to PM3 and PM6 in PO C, relative to the baseline (in 
million EUR) 
Costs savings relative to the baseline (in million EUR), in 
2021 prices 

2050 

2025 

2030 

2040 

Operating costs savings for occasional bus and coach companies 

Low 
High 

3.2 
6.4 

2.7 
5.5 

1.4 
2.7 

0.0 
0.0 

 Source: Tetra Tech International et al. (2022), Impact assessment support study 

PM4:  Allow drivers involved in services lasting at least 8 days to postpone the start of the daily 
rest period by 1 hour provided that they do not drive more than 7 hours. This could only be used 
once during a trip and not every day of the same trip 

Adjustment costs savings for transport operators 

PM4 and PM7 (“Allow drivers involved in services lasting at least 8 days to postpone the start of the daily 
rest period by 2 hours provided that they do not drive more than 5 hours. This could only be used once 
during a trip and not every day of the same trip”), included in PO A, are also expected to lead to a reduction 
in operation costs for the operators. Similar to PM3 and PM6, due to the large degree of overlap expected 
in terms of impacts, these two measures have been assessed together. In addition, the impacts on costs are 
assessed to be relatively similar to those of PM3 and PM6, based on input from stakeholders, although the 
precise difference cannot be assessed. Thus, the adjustment costs savings for transport operators in PM4 
and PM7 (included in PO A) are estimated at EUR 3.2 to 6.4 million in 2025 relative to the baseline, EUR 
2.7 to 5.5 million in 2030 and zero by 2050. Expressed as present value over 2025-2050, the adjustment 
costs savings are estimated at EUR 35.5 to 70.9 million.       

PM5:  Allow drivers involved in services lasting at least 8 days to postpone the start of the daily 
rest period by 1 hour provided that they do not drive more than 7 hours. This could only be used 
twice during a trip and not every day of the same trip 

Adjustment costs savings for transport operators 

PM5 and PM8 (“Allow drivers involved in services lasting at least 8 days to postpone the start of the daily 
rest period by 2 hours provided that they do not drive more than 5 hours. This could only be used twice 
during a trip and not every day of the same trip”), included in PO B, are also expected to lead to a reduction 
in operation costs for the operators. Similar to PM3 and PM6, due to the large degree of overlap expected 
in terms of impacts, these two measures have been assessed together. In addition, the impacts on costs are 
assessed to be relatively similar to those of PM3 and PM6, based on input from stakeholders, although the 
precise difference cannot be assessed. Thus, the adjustment costs savings for transport operators in PM5 

73 

 
 
and PM8 (included in PO B) are estimated at EUR 3.2 to 6.4 million in 2025 relative to the baseline, EUR 
2.7 to 5.5 million in 2030 and zero by 2050. Expressed as present value over 2025-2050, the adjustment 
costs savings are estimated at EUR 35.5 to 70.9 million.       

PM6:  Allow drivers involved in services lasting at least 8 days to postpone the start of the daily 
rest period by 2 hours provided that they do not drive more than 5 hours  

The adjustment costs savings for transport operators in PM6 have been assessed together with PM3 and are 
provided above. 

PM7:  Allow drivers involved in services lasting at least 8 days to postpone the start of the daily 
rest period by 2 hours provided that they do not drive more than 5 hours. This could only be used 
once during a trip and not every day of the same trip 

The adjustment costs savings for transport operators in PM7 have been assessed together with PM4 and are 
provided above. 

PM8:  Allow drivers involved in services lasting at least 8 days to postpone the start of the daily 
rest period by 2 hours provided that they do not drive more than 5 hours. This could only be used 
twice during a trip and not every day of the same trip 

The adjustment costs savings for transport operators in PM8 have been assessed together with PM5 and are 
provided above. 

Policy measures addressing weekly rest periods – 12-day rule 

PM9:  Allow bus and coach drivers in domestic occasional carriage of passengers to postpone the 
weekly rest period for up to 12 consecutive 24-hour periods following a previous regular weekly 
rest period 

Adjustment costs savings for transport operators 

As regards weekly rest periods (12-day rule), the impact of PM9 (included in PO A and PO C) on customer 
demand was found to be only indirect and limited. Nonetheless, allowing bus and coach drivers in domestic 
occasional carriage of passengers to use the 12-day rule would facilitate companies to offer longer domestic 
services, thus extending the range of available tourist tours.  During the targeted interviews, bus and coach 
operators argued that this measure  will allow for greater flexibility in driver assignment, thus reducing 
operation costs, especially with regard to driver shortages in high season periods. 

For PM9, six out of the six interviewed operators argue that on average this will lead to operation cost 
savings of approximately 0.5% relative to the baseline. These cost savings are expected to have full effect 
in the first two years of implementation of the new rules (i.e. 2025 and 2026) and decrease gradually over 
time until 2050, when the effect would be zero relative to the baseline.  The adjustment costs savings for 
transport operators are estimated at EUR 3.2 million in 2025 relative to the baseline, EUR 2.7 million in 
2030  and  zero  by  2050.  Expressed  as  present  value  over  2025-2050,  the  adjustment  costs  savings  are 
estimated at EUR 35.5 million. 

74 

 
 
Table 27: Adjustment costs savings for transport operators due to PM9 in PO A and PO C, relative to the baseline (in 
million EUR)  

Costs savings relative to the baseline (in million 
EUR), in 2021 prices 
Operation costs savings for occasional bus and coach 
companies 

2025 

2030 

3.2 

2.7 

2040 

1.4 

2050 

0 

Source: Tetra Tech International et al. (2022), Impact assessment support study 

PM10: Removal of the single service condition when using the 12-day rule, to allow for a driver to 
drive multiple tour groups (in addition to extending 12-day rule to domestic occasional carriage of 
passengers) 

Adjustment costs savings for transport operators 

PM10 (included in PO C) is expected to have an additional positive impact for the business performance in 
the sector, relative to PM9, due to the removal of the single service condition when using the 12-day rule 
(to  allow  for  a  driver  to  drive  multiple  tour  groups).  The  impacts  will  be  more  important  for  SMEs, 
especially small companies, which are less able than larger companies to cope with peak tourist periods 
(e.g. by pulling drivers from other services).  Bus and coach companies argue that this measure will require 
less drivers, thus decreasing operation costs. 

For PM10, six out of the six interviewed companies argue that on average this will lead to operation cost 
savings of approximately 0.5% relative to the baseline. These cost savings are expected to have full effect 
in the first two years of implementation of the new rules (i.e. 2025 and 2026) and decrease gradually over 
time until 2050, when the effect would be zero relative to the baseline.  The adjustment costs savings for 
transport operators are estimated at EUR 3.2 million in 2025 relative to the baseline, EUR 2.7 million in 
2030  and  zero  by  2050.  Expressed  as  present  value  over  2025-2050,  the  adjustment  costs  savings  are 
estimated at EUR 35.5 million. 

PM11: Removal  of  the  obligation  of  taking  two  regular  weekly  rest  periods  after  using  the 
derogation (in addition to extending 12-day rule to domestic occasional carriage of passengers) 

Adjustment costs savings for transport operators 

PM11 (included in PO C) is expected to have an additional positive impacts for the business performance 
in the sector relative to PM9 and PM10, due to the removal of the obligation of taking two regular weekly 
rest periods after using the derogation. Moreover, the impacts will be more important for SMEs, especially 
small companies, which are less able than larger companies to cope with peak tourist periods (e.g. by pulling 
drivers from other services).  Bus and coach companies argue that this measure will lead to greater flexibility 
in driver assignment, thus reducing operating costs. 

For PM11, six out of the six interviewed companies argue that on average this will lead to operation cost 
savings of approximately 0.5% relative to the baseline. These cost savings are expected to have full effect 
in the first two years of implementation of the new rules (i.e. 2025 and 2026) and decrease gradually over 
time until 2050, when the effect would be zero relative to the baseline.  The adjustment costs savings for 
transport operators are estimated at EUR 3.2 million in 2025 relative to the baseline, EUR 2.7 million in 
2030  and  zero  by  2050.  Expressed  as  present  value  over  2025-2050,  the  adjustment  costs  savings  are 
estimated at EUR 35.5 million. 

75 

 
 
PM12: Flexible distribution of weekly rests over a 10-week reference period, to allow that more 
24-hour rest periods could be taken in a row and compensated later 

Adjustment costs savings for transport operators 

PM12 (included in PO B) is expected to have a positive impacts for the business performance in the sector, 
due to the flexible distribution of weekly rests over a 10-week reference period. Similarly to PM10 and 
PM11, the impacts will be more important for SMEs, especially small companies, which are less able than 
larger companies to cope with peak tourist periods (e.g. by pulling drivers from other services).  Bus and 
coach companies argue that this measure will lead to greater flexibility in driver assignment, thus reducing 
operation costs.  

For PM12, six out of the six interviewed companies argue that on average this will lead to operation cost 
savings of 0.5-1% relative to the baseline. For the present calculations, a cost saving of 0.6% was selected. 
These cost savings are expected to have full effect in the first two years of implementation of the new rules 
(i.e. 2025 and 2026) and decrease gradually over time until 2050, when the effect would be zero relative to 
the baseline. The adjustment costs savings for transport operators are estimated at EUR 3.2 to 6.4 million 
in 2025 relative to the baseline, EUR 2.7 to 5.5 million in 2030 and zero by 2050. Expressed as present 
value over 2025-2050, the adjustment costs savings are estimated at EUR 35.5 to 70.9 million.  

Table 28: Adjustment costs savings for transport operators due to PM2 in PO B and PO C, relative to the baseline (in 
million EUR) 
Costs savings relative to the baseline (in million EUR), in 
2021 prices 

2025 

2030 

2040 

2050 

Operating costs savings for occasional bus and coach companies 

Low 
High 

3.2 
6.4 

2.7 
5.5 

1.4 
2.7 

0.0 
0.0 

 Source: Tetra Tech International et al. (2022), Impact assessment support study 

As  shown  above,  all  measures  (i.e.  PM1  to  PM12)  are  expected  to  lead  to  greater  flexibility  in  driver 
assignment, thus reducing operating costs, especially with regard to driver shortages in high season periods. 
Operators argue that this will save money on planning and other planning-related overhead costs, while not 
jeopardising safety.  

76 

 
 
ANNEX 5: EFFECTIVENESS OF THE DIFFERENT POLICY OPTIONS  

The table below provides a detailed assessment on the effectiveness of the policy options in relation to the general and specific objectives and related assessment 
criteria. 

Key: Impacts expected 

 

 

O 

 

 

Strongly negative 

Negative 

No or negligible impact 

Positive 

Strongly positive 

PO A 

PO B 

Unclear 

PO C 

SO1 – Ensure more flexible distribution of breaks and rest periods  

Expected improvement in operators’ 
ability to meet customer demand and 
provide high-quality services 

PO  A  would  allow  breaks  and  daily  rests  to  be 
organised  more  in  line  with  trip  itineraries.  For 
weekly rest periods, in PO A the extension of the 12-
day rule to domestic trips is expected to improve the 
operators’  ability  to  meet  customer  demand  and 
provide high-quality services. 

in  weekly  rest  periods,  allowing 

PO  B  would  allow  the  greatest  flexibility  to 
operators  in  terms  of  break  times  (which  could  be 
organised with almost full flexibility). PO B would 
also  allow  daily  rests  to be organised  more  in  line 
with  trip  itineraries.  PO  B  would  bring  a  major 
change 
the 
flexibility  in  their  distribution  over  a  10-week 
reference period, greatly enhancing drivers’ ability 
to  work  during  busy  peak  seasons  and  helping  to 
address driver shortages. Thus, the improvement in 
operators’  ability  to  meet  customer  demand  and 
provide  high-quality  services  is  expected  to  be 
higher relative to PO A.  

PO  C offers  the  greatest  flexibility  to  operators in 
terms of break times (which could be organised with 
almost full flexibility), daily rests (which could be 
used with minimum restrictions regarding the length 
of the daily duty cycle) and weekly rests (where the 
12-day rule would be extended to domestic trips, as 
well as being no longer subject to the single-service 
condition  and  compensatory  extra  rest).  PO  C  is 
expected to generate the largest positive impacts in 
terms  of  improving  operators’  ability  to  meet 
customers  demand  and  provide  high-quality 
services. 

Expected  improvement  in  working 
conditions for drivers 

PO A would enable drivers to avoid taking breaks at 
inconvenient times. Extending the duty cycle could 
interactions  with  passengers, 
improve  drivers’ 
marginally  improving  working  conditions.  At  the 
same  time,  compensatory  action  would  ensure  that 

In  PO  B  flexible  rules  on  breaks  would  increase 
autonomy  and  reduce  work  stress.  However,  they 
could result in drivers getting mostly or only breaks 
that are too short to recuperate sufficiently, leading 
to  a  negative  impact  on  working  conditions.  The 

In  PO  C  flexible  rules  on  breaks  would  increase 
autonomy  and  reduce  work  stress.  However,  they 
could result in drivers getting mostly or only breaks 
that are too short to recuperate sufficiently, leading 
to  a  negative  impact  on  working  conditions.  The 

77 

 
 
 
 
Key: Impacts expected 

 

 

O 

 

 

Strongly negative 

Negative 

No or negligible impact 

Positive 

Strongly positive 

PO A 

PO B 

Unclear 

PO C 

any  countervailing  negative  effects  is  minimal, 
leading  to  a  net  positive  impact  on  working 
conditions.  Extending  the  use  of  the  12-day  rule 
under PO A would allow drivers to avoid excessive 
time away from home during long trips, generating a 
benefit  in  terms  of  working  conditions.  Preserving 
the  single-service  condition  and  compensatory  rest 
would minimise any negative impacts. 

extension of the duty cycle could be used frequently 
in  PO  B,  meaning  that  the  impact  on  working 
conditions  would  be  negative.  PO  B  would  entail 
significant  changes  to  the  rules  on  weekly  rest 
periods,  leading  to  negative  impacts  on  working 
conditions that would more than offset any benefit 
from  increased  driver  autonomy  and  freedom  over 
their workload.  

extension of the duty cycle could be used frequently 
in  PO  C,  meaning  that  the  impact  on  working 
conditions  would  be  negative.  PO  C  would  entail 
significant  changes  to  the  rules  on  weekly  rest 
periods,  leading  to  negative  impacts  on  working 
conditions that would more than offset any benefit 
from increased driver autonomy and freedom over 
their workload.  

SO2 – Promote equal treatment between international and domestic bus and coach operations  

Expected improvement in providing 
increased competitiveness of 
domestic bus and coach operations  

PO  A  extends  the  use  of  12-day  rule  to  domestic 
trips, increasing the competitiveness of domestic bus 
and  coach  operations  and  ensuring  equal  treatment 
between  the  domestic  and  international  bus  and 
coach operations. 

PO  C  extends  the  use  of  12-day  rule  to  domestic 
trips,  increasing  the  competitiveness  of  domestic 
bus  and  coach  operations  and  ensuring  equal 
treatment  between  the  domestic  and  international 
bus and coach operations. 

In PO B, the 12-day rule will remain accessible only 
to  international  trips.  However,  PM12  (Flexible 
distribution  of  weekly  rests  over  a  10-week 
reference  period,  to  allow  that  more  24-hour  rest 
periods  could  be  taken  in  a  row  and  compensated 
later) in PO B will greatly increase the flexibility for 
weekly  rests,  by  allowing  them  to  be  freely 
distributed over a 10-week reference period. Since 
this  would  reduce  operators’  and  drivers’  need  for 
the 12-day rule, the disparity between international 
and  domestic  services  is  be  expected  to  decrease 
somewhat, albeit to a lesser extent than under PO A 
and PO C. 

78