COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the documents Proposal for a Regulation of the European Parliament and of the Council amending Regulations (EC) No 261/2004, (EC) No 1107/2006, (EU) No 1177/2010, (EU) No 181/2011 and (EU) 2021/782 as regards enforcement of passenger rights in the Union Proposal for a Regulation of the European Parliament and of the Council on passenger rights in the context of multimodal journeys
Date: 2023-11-29
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: air transport, bus, carriage of passengers, combined transport, consumer information, indemnification, inland waterway transport, maritime transport, passenger rights, physically disabled person, rail transport

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 29.11.2023  SWD(2023) 386 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  Accompanying the documents Proposal for a Regulation of the European Parliament and of the Council amending Regulations (EC) No 261/2004, (EC) No 1107/2006, (EU) No 1177/2010, (EU) No 181/2011 and (EU) 2021/782 as regards enforcement of passenger rights in the Union Proposal for a Regulation of the European Parliament and of the Council on passenger rights in the context of multimodal journeys {COM(2023) 752 final} - {SEC(2023) 392 final} - {SWD(2023) 387 final} - {SWD(2023) 389 final}  
 
 
1 

INTRODUCTION ................................................................................................................................ 1 

1.1  Political and legal context ................................................................................. 1 
1.2  Scope of this Impact Assessment ...................................................................... 1 
1.3  Other policy initiatives regarding passenger rights ........................................... 3 
1.4  Synergies with other EU initiatives ................................................................... 5 

2 

PROBLEM DEFINITION .................................................................................................................... 6 

2.1  What are the problems and why are they a problem?........................................ 6 
2.2  What are the problem drivers? ........................................................................ 11 
2.3  How likely is the problem to persist? .............................................................. 16 

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

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

4 

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

4.1  General objectives ........................................................................................... 18 

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 options .................................................................... 22 

6 

IMPACTS OF THE POLICY OPTIONS ........................................................................................... 35 

6.1  Economic impacts ........................................................................................... 35 
6.2  Social impacts .................................................................................................. 61 
Impacts on fundamental rights ........................................................................ 62 
6.3 
6.4  Environmental impacts .................................................................................... 63 

7 

HOW DO THE OPTIONS COMPARE? ............................................................................................ 63 

7.1  Effectiveness .................................................................................................... 63 
7.2  Efficiency ........................................................................................................ 65 
7.3  Coherence ........................................................................................................ 70 
7.4  Subsidiarity and Proportionality ...................................................................... 71 

8 

PREFERRED OPTIONS .................................................................................................................... 73 

Identification of the preferred policy options and stakeholder views ............. 73 
8.1 
8.2  REFIT (simplification and improved efficiency) ............................................ 78 
8.3  Application of the ‘one in, one out’ approach ................................................. 80 

9 

HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................................. 80 

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

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) .................................................. 1 

1. 

CONSULTATION METHODS AND STAKEHOLDERS INVOLVED ............................................ 1 

ANNEX 3: WHO IS AFFECTED AND HOW? .......................................................................................... 18 

ANNEX 4: ANALYTICAL METHODS ..................................................................................................... 25 

1. 

Description of the analytical methods used ..................................................... 25 

 
 
 
2. 
Baseline scenario ............................................................................................. 26 
2.1.  Main assumptions of the baseline scenario ..................................................... 26 
2.2.  Baseline scenario results .................................................................................. 29 
3. 
Assessment of the economic impacts by policy measure ................................ 35 
3.1.  Problem area 1 - Enforcement of EU passenger rights legislation .................. 36 
3.2.  Problem area 2 - Protection of passengers performing multimodal journeys . 52 
3.3.  Problem area 3 - Reimbursement rules are unclear when flights were booked via 

an intermediary ................................................................................................ 81 

ANNEX 5: COMPETITIVENESS CHECK .............................................................................................. 101 

ANNEX 6: DISCARDED MEASURES .................................................................................................... 104 

ANNEX 7: DETAILED POLICY MEASURES ........................................................................................ 107 

ANNEX 8: SME TEST .............................................................................................................................. 116 

ANNEX 9: BACKGROUND ON THE DEVELOPMENT OF EU PASSENGER RIGHTS .................... 128 

ANNEX 10: PAYMENT FLOWS /  PROBLEM OF UNCLEAR REIMBURSEMENT RULES FOR TICKETS 

BOOKED VIA INTERMEDIARIES ................................................................................................ 138 

ANNEX 11: REIMBURSEMENT POLICIES FOR TICKETS BOOKED VIA INTERMEDIARIES ..... 139 

ANNEX  12:  INTERMEDIARIES’  TERMS  AND  CONDITIONS  ON  THEIR  REIMBURSEMENTS  TO 

CUSTOMERS ................................................................................................................................... 142 

ANNEX 13: CPC ACTION ........................................................................................................................ 145 

 
 
 
 
 
 
Term 
acronym 

or 

Meaning or definition 

Glossary 

ADR 

ASR 

BSP 

CJEU 

CPC 

CRS 

ECA 

GDS 

IA 

IATA 

ICAO 

MoR 

MS 

NEB 

OPC 

PRM 

PTD 

SSMS 

SME’s 

TFEU 

Alternative  Dispute  Resolution,  an  out-of-court  settlement  procedure  for  consumers  with  the 
assistance of an impartial dispute resolution body 

Air Services Regulation (Regulation (EC) No 1008/2008) 

Billing and Settlement Plan is run by IATA, a global airline association. 
BSP is a system designed to facilitate and simplify the selling, reporting and remitting procedures of 
IATA Accredited Passenger Sales Agents, as well as improve financial control and cash flow for 
BSP Airlines. 

Court of Justice of the European Union 

Consumer  Protection  Cooperation,  a  network  established  by  Regulation  (EU)  2017/2394  where 
national  consumer  authorities  and  the  Commission  can  coordinate  their  investigation  and 
enforcement actions to tackle widespread breaches to EU consumer laws 

Computerised  Reservation  Systems  are  computerised  tools  that  allow  travel  agents  and  online 
booking engines to get access to airlines’ fares, schedules and seat inventories and to book tickets 

European Court of Auditors 

CRSs (computerised systems) are also known as GDSs (Global Distribution Systems) 

Impact Assessment 

International Air Transport Association, the trade organisation for a majority of the world’s airlines 

International Civil Aviation Organisation 

Merchant of Record. An intermediary which is Merchant of Record books the passenger’s ticket by 
making the payment to the air carrier from its own bank account. This is in contrast to ‘pass-through 
agent’ intermediaries, which pass on the customer’s payment details (usually credit card details) to 
the carrier, so that the money for the ticket is withdrawn from the passenger’s bank account (and any 
reimbursement payment can be made directly to the passenger by the air carrier, as the air carrier has 
the bank details of the passenger for this.) Also see the information in annex 11. 

Member State 

National Enforcement Body 

Open Public Consultation 

Persons with disabilities and persons with reduced mobility 

Package Travel Directive (Directive (EU) 2015/2302) 

Sustainable and Smart Mobility Strategy, the European Commission’s mobility strategy 

Small and Medium-sized Enterprises 

Treaty on the Functioning of the European Union 

 
 
 
1 

INTRODUCTION 

1.1  Political and legal context 

This  Impact  Assessment  (IA)  accompanies  two  legislative  proposals  aimed  at  introducing 
common rules on the enforcement of passenger rights, passenger rights for multimodal journeys 
and rules for reimbursements of airlines to passengers when intermediaries are involved. 

Passenger rights are at the heart of the EU transport and consumer policy and are considered a 
flagship initiative of the EU. The European Union is the only area in the world where citizens are 
protected by a full set of passenger rights – whether they travel by air, rail, ship or bus and coach. 
A  solid  EU  framework  has  been  put  in  place  for  all  transport  modes  since  2004,  with  the 
adoption of four Regulations for air, waterborne, bus and coach and rail, plus a fifth Regulation 
addressing air transport for passengers with reduced mobility1. 

The Sustainable and Smart Mobility Strategy (SSMS)2 adopted in 2020 underlined that the shift 
towards  sustainable,  smart  and  resilient  mobility  must  be  just  and  fair.  Fair  mobility  means 
protection for passengers and their rights. To achieve the EU’s ambitious climate goals3, people 
need  to  have  the  tools  to  opt  for  a  seamless  multimodal  public  transport  throughout  their 
journey. To support this, people should be aware how they are protected in case of disruptions 
or cancellations on such journeys. In addition, the unprecedented mass cancellations that were 
seen  during  the  COVID-19  pandemic  showed  the  importance  of  EU-wide  rules  and  their 
uniform implementation and enforcement. 

With the SSMS, the Commission expressed its intention to review the existing framework in 
depth. In particular, it committed to take action to ensure that EU passenger rights are better 
implemented;  are  clearer  for  both  carriers  and  passengers;  offer  adequate  assistance  and 
reimbursement when disruptions arise; and provide for appropriate sanctions if the rules are not 
properly observed. Moreover, the Commission announced its intention to assess options for a 
multimodal  framework  for  passenger  rights  (Action  634),  and  for  an  adequate  financial 
protection scheme to protect passengers from carrier liquidity crisis or insolvency (Action 64)5. 
Both initiatives are listed in the Commission work programme 20236. 

1.2  Scope of this Impact Assessment  

The Call for Evidence, published in December 20217, covered both Action 63 and 64 of the 
SSMS. Based on the initially collected data, and various stakeholders’ views received after the 
Call  for  Evidence,  stakeholders  were  consulted  on  five  problem  areas:  1)  Lack  of  financial 
protection for air passengers against the risk of a liquidity crisis or an insolvency regarding the 
reimbursement  of  tickets  and  passengers'  repatriation,  if  needed  (covering  Action  64  of  the 
SSMS); 2) Delayed reimbursement of air passengers booking via an intermediary ticket vendor; 
3) Lack of reimbursement for flights cancelled by passengers as a result of a major crisis; 4) 
Insufficient  protection  for  passengers  making  multimodal  journeys;  and  5)  Insufficient 

1 See Annex 10 for more details on the creation and the development of EU passenger rights. 
2  Sustainable  and  Smart  Mobility  Strategy  –  putting  European  transport  on  track  for  the  future,  European 
Commission, Brussels, December 2020. 
3 The EU is committed to reducing its net greenhouse gas emissions by at least 55 per cent by 2030, compared to 
1990; 2030 Climate Target Plan. 
4 Action 63 of the SSMS: “Review of the passenger rights regulatory framework, including to ensure its resilience 
to extensive travel disruptions, and including options for multimodal tickets.” 
5 Action 64 of the SSMS: “Assess the options and propose, if appropriate, an adequate financial protection scheme 
to protect passengers against the risk of a liquidity crisis or an insolvency regarding the reimbursement of tickets 
and if needed their repatriation”. 
6 COM(2022)548 final, Annex II (REFIT initiatives) no 6. 
7 Have your say - Better protection for passengers and their rights. 

1 

 
 
 
enforcement  of  passenger  rights  in  all  modes.8  Two  of  these  initial  problem  areas  were 
eventually discarded from the IA, namely: 

•  Problem area 1: The air passenger rights Regulation (EC) No 261/2004 does not contain 
provisions ensuring the reimbursement of flight-only passengers in situations where a 
carrier becomes insolvent or faces a liquidity crisis, nor does it cover the repatriation of 
passengers stranded abroad (nor is this part of the proposal to amend this Regulation9). 
Meanwhile, the Package Travel Directive (EU) 2015/230210 obliges Member States to 
ensure  that  organisers  provide  security  for  the  refund  of  all  payments  in  case  of 
insolvency, and, if the package travel contract includes carriage, that organisers provide 
security for the travellers' repatriation. However, a major difference between the rules 
for EU package travel organisers and those for airlines is that EU airlines are subject to 
minimum financial requirements and ongoing financial oversight by national licensing 
authorities under the Air Services Regulation (EC) No 1008/200811. 

Coherence with the revision of the Air Services Regulation (Action 59 of the SSMS) is 
needed to improve the financial resilience of air carriers and price transparency. There 
is therefore a very close link between Action 64 and Action 59 of the SSMS. The impact 
of measures to mitigate the risk of a liquidity crisis or disorderly insolvency of an air 
carrier, and to better support reimbursement and repatriation in such cases, cannot be 
looked at in isolation. Therefore, the combined impacts of all these measures will be 
looked at in the impact assessment for a possible revision of the Air Services Regulation, 
where  work  is  still  ongoing12.  The  need  for  intervention  must  be  carefully  assessed. 
Before the COVID-19 crisis, it was estimated13 that between 2011 and October 2019, 
some 5.6 million passengers, or 0.04% of total EU passengers, were affected by airline 
insolvencies1415. The average loss of affected passengers is estimated to be €357, leading 
to detriment for travellers of €2bn in this period. In 2019, the rate of affected passengers 
was  0.14%.  During  the  COVID-19  pandemic,  national  licensing  authorities  were 
allowed to maintain airline operating licences even in case of financial difficulties, as 
long as safety was not at risk. However, problems resulting from insolvencies remained 
very limited during this period and problems related to deferred payments by airlines 
during  the  pandemic  were  subsequently  addressed  by  a  Consumer  Protection 
Coordination action16. 

•  Problem area 3 on passengers’ rights to reimbursement when self-cancelling due to a 
major crisis: The consultation not only showed that this issue is marginal, but also that 
any such right would apply under certain circumstances which are difficult to delineate, 

8 For problem areas 1) and 3) there was only evidence for air passengers that these were an issue, not for passengers 
of the other modes bus, ship and rail. 
9 Proposal COM(2013)130 to amend Regulation (EC) No 261/2004. 
10 Directive (EU) 2015/2302 of the European Parliament and of the Council of 25 November 2015 on package 
travel and linked travel arrangements. 
11 Regulation (EC) No 1008/2008 of the European Parliament and of the Council of 24 September 2008 on common 
rules for the operation of air services in the Community (Recast).  
12 Have your say - Revision of the Air Services Regulation. 
13 2020, European Commission, Study on the current level of protection of air passenger rights in the EU.  
14 European Commission, Directorate-General for Mobility and Transport, Study on the current level of protection 
of  air  passenger  rights  in  the  EU:  final  report:  study  contract,  Publications  Office,  2020,  available  at: 
https://data.europa.eu/doi/10.2832/529370. 
15 For the  other modes of transport the stakeholder consultation did not bring evidence that there was a major 
problem. 
16 The problem with delayed payments by airlines was addressed by a Consumer Protection Coordination action. 
Following dialogues with the Commission and national consumer authorities during 2021, 16 major airlines made 
far-reaching commitments to bring their practices back in line with EU consumer and passenger rights law with 
regard to flight cancellations. See CPC action on Airline cancellations. 

2 

 
 
 
 
thus making the passenger rights framework even more complicated. Consequently, for 
the sake of proportionality, this problem was discarded early on in the process17. 

Given the above, the scope of this IA has been narrowed down to three areas, starting with the 
area with the widest scope: 1) enforcement across all modes of transport, including multimodal 
transport, 2) multimodal passenger rights and 3) reimbursement of airline tickets when these 
were booked via intermediaries. They correspond to the abovementioned areas 2, 4 and 5 of the 
five areas on which stakeholders were consulted in an initial phase of the process.  

1.3  Other policy initiatives regarding passenger rights 

This impact assessment takes the state of play of the different passenger rights Regulations into 
account. 

With regard to air passenger rights, the Commission already stepped up efforts in 2013 to make 
passenger rights clearer and better applied by adopting a proposal18 to amend Regulation (EC) 
No 261/200419.  The  inter-institutional  process  on  this  proposal  is  not  completed  yet20  but  it 
remains  a  priority  pending  file  for  the  Commission21  and  is  also  listed  among  the  common 
legislative priorities of the three EU institutions for 2023 and 202422. The discussions on the 
proposal have especially highlighted the complexity of finding an adequate balance between 
rights of passengers and obligations of carriers. To support the deliberations on this proposal in 
the Council a study on the current level of protection of air passenger rights in the EU, published 
in January 202023, takes a comprehensive look at the topic by reflecting the evolution of the air 
travel market in recent years up until 2019. This fact-finding study showed that the need for 
reform  has  become  even  more  urgent  since  2013.  It  also  concluded  that  Interpretative 
Guidelines24  might  help  but  would  not  be  able  to  solve  all  problems  identified  with  the 
application. Therefore, problems dealt with in the proposal of 2013 to amend Regulation (EC) 
No 261/2004 are excluded from the scope of this IA and the policy measures presented in this 
IA are complementary to the legislative proposal of 2013. 

In  view  of  the  experience  with  the  abovementioned  legislative  proposal  of  2013  for  air 
passengers,  the  Commission  proposed  (only)  a  targeted  recast  of  the  rail  passenger  rights 
Regulation (EC) No 1371/200725 in 2017, which led to the adoption of the Regulation (EU) 
2021/78226 which is applicable as of 7 June 2023. This new Regulation introduces several new 
rules for rail passengers which could also be useful for the protection of passengers travelling 
with  other  modes  of  transport  (or  even  multimodal),  such  as  on  the  provision  of  real-time 
dynamic traffic  and travel  information,  a new EU-wide standardised form  for compensation 
and reimbursement requests, or better tools for national enforcement bodies (NEBs). The policy 
measures  presented  in  this  IA  are  therefore  complementary  to  the  new  rail  passenger  rights 

17 See details below under point 3.1.4. 
18 EUR-Lex - 52013PC0130 - EN - EUR-Lex (europa.eu), COM(2013)130 final. 
19 Regulation (EC) No 261/2004 of the European Parliament and of the Council of 11 February 2004 establishing 
common rules on compensation and assistance to passengers in the event of denied boarding and of cancellation 
or long delay of flights, and repealing Regulation (EEC) No 295/91 (OJ L 46, 17.2.2004, p. 1–8). 
20 The European Parliament adopted its position in first reading in 2014, confirmed it in 2019, while deliberation 
in Council is still pending. 
21 Commission work programme 2023, Annex II no 35. 
22 Common legislative priorities for 2023 and 2024. 
23 2020 Study on the current level of protection of air passenger rights in the EU. 
24 The Commission published Interpretative Guidelines on Regulation (EC) No 261/2004 on air passenger rights 
and on Council Regulation (EC) No 2027/97 on air carrier liability in the event of accidents in 2016. 
25  Regulation  (EC)  No  1371/2007  of  the  European  Parliament  and  of  the  Council  of  23 October  2007  on  rail 
passengers’ rights and obligations (OJ L 315, 3.12.2007, p. 14-41). 
26 Regulation (EU) 2021/782 of the European Parliament and of the Council of 29 April 2021 on rail passengers’ 
rights and obligations (recast), (OJ L 172, 17.5.2021, p. 1–52); see for more details the FAQ document. 

3 

 
 
 
 
Regulation as well. 

In 2021, the Commission also published three evaluations of the regulatory framework on 
the  rights  of  waterborne  passengers27,  bus  and  coach  passengers28,  and  persons  with 
disabilities  and  persons  with  reduced  mobility  when  using  air  transport29.  The  three 
evaluations show inter alia that there is room to improve the enforcement of these Regulations. 
NEBs often have very limited human resources to identify irregularities and act upon them, to 
enforce  the  Regulations,  and  their  approaches  differ  significantly:  some  are  proactive  and 
engage in different monitoring activities allowing for the detection and correction of recurrent 
non-compliances against passenger rights (e.g., regular dialogue with industry and passenger 
representatives, inspections, audits, review of operator homepages, etc), while others only react  
to complaints that passengers submit to them and do not carry out own-initiative  monitoring 
or enforcement activities.30 

As shown by several Eurobarometer surveys31, passengers’ lack of awareness of their rights, 
and problems with enforcing these rights, are a recurrent issue. The last survey of 2020 showed 
that only about one in three EU citizens knows that passenger rights exist in the EU (a similar 
result to the 2014 Eurobarometer). Therefore, the Commission regularly organises campaigns 
to  promote  passenger  rights  awareness32,  and  offers  information  on  the  Single  Digital 
Gateway ‘Your Europe’ on passenger rights as well as on a passenger rights app available 
in  all  official  EU  languages33.  The  lack  of  passenger  awareness  and  problems  with  the 
enforcement of their rights were also highlighted by the European Court of Auditors (ECA) 
in its report no 30/2018 “EU passenger rights are comprehensive, but passengers still need to 
fight for them”34. The COVID-19 pandemic also showed that passengers were not well aware 
of  their  rights  and  often  did  not  know  whom  to  turn  to  for  enforcement.  ECA’s  report  no 
15/2021  “Air  passenger  rights  during  the  COVID-19  pandemic:  Key  rights  not  protected 
despite Commission efforts” came to the same conclusion35. 

The European Parliament “has always been a strong advocate of passenger rights irrespective 
of the mode of transport used. Its main aim is now to ensure that the texts adopted in recent 
years  are  properly  applied”36.  It  also  underlined  the  importance  of  implementing  passenger 
rights correctly during the COVID-19 pandemic37. The Council38 welcomed the Commission’s 
consideration of the ECA's recommendations and invited the Commission “to reflect on how to 
improve the current setup, based on the experiences, shortcomings and lessons learnt and the 
European Court of Auditors' Special report, as announced under the Commission’s Sustainable 
and Smart Mobility Strategy.” 

27 SWD(2021) 413 final.  
28 SWD(2021) 415 final.  
29 SWD(2021) 417 final.  
30 More details on the outcome of and the follow-up for these evaluations are presented in Annex 9.  
31 Special Eurobarometer 485 report on Passenger rights  - January 2020. Also the first Eurobarometer of 2007, 
which covered air passenger rights, concluded that 49% of EU citizens are not aware about passenger rights at 
airports in EU territory. 
32 Passenger rights campaign. 
33 Passenger rights on Your Europe. 
34 European Court of Auditors’ Special Report 30/2018: EU passenger rights are comprehensive, but passengers 
still need to fight for them.  
35 European Court of Auditors’ Special Report 15/2021: Air passenger rights during the COVID-19 pandemic: 
Key rights not protected despite Commission efforts. 
36 https://www.europarl.europa.eu/factsheets/en/sheet/48/passenger-rights.  
37 European Parliament resolution of 17 April 2020 on EU coordinated action to combat the COVID-19 pandemic 
and its consequences (2020/2616(RSP) - paragraph 44). 
38 Council conclusions of 28 September 2021 on the European Court of Auditor Special report no 15/2021: ‘Air 
passenger rights during the COVID-19 pandemic: Key rights not protected despite Commission efforts’, point 6  

4 

 
 
 
1.4  Synergies with other EU initiatives  

The Impact Assessment takes into consideration other EU legislation currently under revision 
or development. Throughout the process, it has been ensured that the review of the passenger 
rights framework does not overlap with these other initiatives, but instead complements them. 

•  Proposal amending Directive (EU) 2015/2032 on package travel and linked travel 
arrangements  (PTD)39:  coherence  has  been  ensured,  especially  regarding  rules  on 
intermediaries. Moreover, it should be clarified that the Package Travel Directive and 
the passenger rights Regulations, albeit both dealing with travel, concern two separate 
markets  and  hence  do  not  overlap  per  se.  Whereas  passenger  rights  exclusively  deal 
with    passenger  transport  services  (e.g.  flights,  rail  and  bus  services  -  including 
multimodal  combinations  of  such  services),  the  rules  on  package  travel  cover  a 
combination  of  different  travel  services  offered  by  an  organiser  (e.g.  a  package 
combining a flight and hotel accommodation).   

•  The  Regulation  (EU)  2017/2394  on  Consumer  Protection  Cooperation  (CPC)  40, 
establishing a pan-European enforcement network in EU/EEA, is also currently under 
revision41.  This  complementary  instrument  provides  a  cooperation  framework  for 
national authorities from all countries in the European Economic Area to jointly address 
breaches of consumer rules (including passenger rights) when the service provider and 
the consumer are established in different countries. The synergies can be seen in the 
context of the two CPC actions against airlines and intermediaries, regarding problems 
encountered  with  reimbursements  during  the  COVID-19  pandemic.  The  aim  of  the 
revision is to strengthen the enforcement of consumer law and maintain a level playing 
field for business, learning from the recent evolution of the market.  

•  Directive  2013/11/EU  (the  Alternative  Dispute  Resolution  Directive)  allowing 
consumers, including passengers, to seek the out-of-court settlement of their disputes 
arising from the breach of passenger rights throughout the EU using alternative dispute 
resolution  bodies,  is  also  currently  under  revision.  The  Commission  adopted  on  17 
October 2023  a proposal to amend this Directive: the amendment would include, among 
others,  broadening  the  Directive’s  scope  to  third  country  traders  (e.g  carriers,  ticket 
vendors) and to disputes arising not only from contractual relations but also from the 
pre-contractual  stages  and  from  certain  non-contractual  relationships,  thus  further 
enhancing the use of out-of-court settlement to solve passenger rights claims 42. 

The  initiative  contributes  towards  Sustainable  Development  Goals  (SDG)  #10  Reduce 
inequality  within  and  among  countries    (regarding  passengers  with  disabilities  and  reduced 
mobility), #13 Climate action (enhanced passenger rights may incentivise people to use more 
public  transport  instead  of  private  cars),  and  #16  Provide  access  to  justice  for  all  and  build 
effective, accountable and inclusive institutions (enhanced and accessible means of redress for 
passengers and better tools for enforcement for the administration). 

39 See also https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13117-Package-travel-
review-of-EU-rules_en. 
40 Regulation (EU) 2017/2394 of the European Parliament and of the Council of 12 December 2017 on cooperation 
between national authorities responsible for the enforcement of consumer protection laws and repealing Regulation 
(EC) No 2006/2004 (Text with EEA relevance) OJ L 345, 27.12.2017, pp. 1–26. 
41 Have Your Say - Consumer Protection. 
42 
complaint/alternative-dispute-resolution-consumers_en. 

https://commission.europa.eu/live-work-travel-eu/consumer-rights-and-complaints/resolve-your-consumer-

5 

 
 
 
2  PROBLEM DEFINITION 

2.1  What are the problems and why are they a problem?  

The EU passenger rights Regulations are at the core of European passenger transport, providing 
passengers with protection when they travel with one collective transport mode anywhere in 
the EU. These rules cover rights for passengers when a disruption occurs, information provision 
to passengers both before and during travel, and complaint possibilities in case the rules are not 
followed43. These rights are important to keep passengers’ confidence in collective transport 
modes. In 2019, a total of 13.4 billion passengers44 travelled in the EU by air, bus and coach, 
rail or waterborne transport including 8.6 billion rail passengers, 970 million air passengers, 
418  million  waterborne  passengers  and  3.3  billion  bus  &  coach  passengers  (of  which  369 
million  travelling  above  250  kilometres45).  Around  107  million  passengers’  services  were 
performed in 2019. Moreover, in 2019, it is estimated that 82.7 million requests were made for 
PRM assistance on all four modes of transport46. 

Analysis conducted for the preparation of the SSMS, evaluations of the existing Regulations, 
results  of  the  2020  Eurobarometer  on  passenger  rights,  reports  by  the  European  Court  of 
Auditors,  feedback  gathered  by  the  Commission  during  the  COVID-19  crisis,  and  the 
consultations undertaken for this impact assessment have highlighted the following problems:  

2.1.1  Problem  1:  Passengers  do  not  fully  benefit  from  their  rights  due  to  shortcomings  in 

implementation and enforcement 

Passengers of all modes of transport are affected by this problem. Passengers’ knowledge of 
their  rights  is  low:  only  43%  of  the  respondents  to  the  2020  Eurobarometer  survey47  who 
travelled with at least one transport mode in the past 12 months indicated that they were aware 
of the existence of passenger rights in the EU. Among the general sample of 27,973 respondents 
to  the survey, including those who had not  travelled recently, the awareness  level  was  even 
lower, standing at 32%. Only 40% of the 7,666 respondents travelling by air indicated that the 
carrier  informed  them  well  about  their  passenger  rights  before  their  journey.  Even  fewer 
respondents travelling by other transport modes indicated that they were well informed by the 
carrier  about  their  passenger  rights  (29%  of  2,414  respondents  for  ferry  and  cruise,  26%  of 
9,516 respondents for rail and 26 % of 4,473 respondents for bus and coach). Furthermore, 55% 
of  the  5,560  respondents  who  experienced  travel  disruptions  indicated  that  they  were  not 
satisfied with the way carriers informed them about their complaint handling procedures. Such 
procedures  can  be  complex  and  constrained  by  requirements  to  use  specific  formats  (e.g. 
electronic forms), making it difficult for passengers to provide all the information needed for 
the investigation of their complaints. 

Just about a quarter (26%) of the 5,560 respondents who experienced travel disruptions made 
an official  complaint. Among those who experienced a travel  disruption but  did  not  make a 
complaint, the most frequent reason for not complaining was the feeling that it would be useless 
(45%); for 25% of the concerned travellers, the involved amount was too small; while 16% said 
the  procedure  was  too  cumbersome.  The  results  of  this  survey  are  confirmed  by  the 
Commission’s 2020 study of the current level of protection of air passenger rights, cited above, 

43 Annex 10 – Background on the development of EU passenger rights. 
44 The term “passengers” refers to individual journeys. 
45 Only accounting for passengers travelling on regular services with a scheduled distance of more than 250 km. 
See Annex 4, 2.2. 
46 On the basis of figures in the Steer (2020), Study on the current level of protection of air passenger rights in the 
EU: final report, available at: https://data.europa.eu/doi/10.2832/529370 and the Steer (2021), Study on the EU 
Framework for Passenger Rights. 
47 Special Eurobarometer 485, published in January 2020, fieldwork conducted in February/March 2019. 

6 

 
 
 
which found that the process for passengers to obtain redress is lengthy, particularly for first 
time claimants, and can discourage them from making claims. 

The abovementioned study on air passenger rights and the Commission’s recent evaluations of 
the bus and coach, waterborne and air PRM Regulations show that, beyond claims related to 
compensation  for  cancellation  or  long  delays  of  flights48,  NEBs  have  received  very  few 
complaints. As reflected by the findings presented above, this results from a mix of factors: 
many  passengers  are  not  aware  of  their  rights,  the  procedure  to  submit  a  complaint  is  too 
cumbersome and passengers consider it useless to complain (either because the NEB cannot 
take a binding decision or in case of certain breaches of passenger rights passengers cannot get 
any  compensation  or  the  compensation  due  is  not  commensurate  to  the  effort  invested  in 
submitting a complaint).  

Although operators confirmed in the stakeholder consultation that they collect key performance 
indicators about their own compliance with passenger rights (number of complaints received 
and the problems raised in them, amount of money paid as compensation to passengers, results 
of passenger surveys, punctuality of services, etc.), according to information available to the 
Commission  such  information  is  not  shared  with  NEBs49.  The  2021  special  report  from  the 
ECA  concluded  that  NEBs  do  not  have  a  good  overview  of  operators’  compliance  with 
passenger  rights  and  cannot  focus  their  limited  resources  for  monitoring  and  enforcement. 
According to this ECA report, one of the problems is that most NEBs do not have the right to 
ask carriers  about  the number of  complaints they receive50. The Commission evaluations  of 
2021 also came to a similar conclusion about the NEBs’ resources available for monitoring and 
enforcement51. The ECA recommended in its report of 2018 that the NEBs should be provided 
with  further  tools  for  the  enforcement  of  passenger  rights,  e.g.  for  monitoring  the  carriers' 
policies on assistance, care, information and re-routing. The ECA also recommended that the 
Commission should explore how to receive the necessary information from the NEBs and how 
to help NEBs better control enforcement52. 

Organisations representing passengers indicated several times that various shortcomings in the 
enforcement  make  it  impossible  for  passengers  to  fully  enjoy  their  rights  and  called  on  the 
Commission to make a proposal to strengthen enforcement53. 

71%  (105  out  of  149)  of  respondents  to  the  targeted  stakeholder  consultation  strongly  or 
somewhat  agreed  that  carriers,  terminal  operators  and  NEBs  applying  EU  passenger  rights 
legislation in different ways is an important element of the problem. The 15 respondents who 
disagreed  were:  8  carriers  operating  in  transport  modes  other  than  aviation  (out  of  24 
responding),  2  NEBs  (out  of  47  NEBs  responding)  and  2  national  authorities  (out  of  9 
responding).  Similarly,  67%  (99  out  of  148)  of  respondents,  including  29  out  of  47  NEBs, 

48 Exceptionally, NEBs as well as European Citizens‘ Centres (ECCs) for cross-border cases received many more 
complaints also regarding reimbursements in money in the context of COVID-19, see the  ECC report of 2020 
which states that receive the most complaints relating to air passenger rights. 
49 Exceptionally, the Italian NEB responsible for waterborne passenger rights introduced an obligation on ferries 
to keep a record about the departure and arrival times, delays and cancellations and their reasons, and, if requested, 
share it with the NEB. Relevant passenger organisations strongly support this decision. See more in Study on the 
EU Regulatory Framework for Passenger Rights – Comparative analysis of good practices.  
50 This was one of the main conclusions, as regards NEBs responsible for Regulation (EC) No 261/2004, of the 
ECA Special Report 15/2021 on the protection of air passenger rights in the context of COVID-19. 
51 See points 6.2 of SWD(2021) 413 final, 5.2 of SWD(2021) 415 final and 5.1.3 of SWD(2021) 417 final. 
52 2018 ECA Special Report n°30 “EU passenger rights are comprehensive, but passengers still need to fight for 
them”, Recommendations 5a ii) and 5b, p. 35. 
53  See  BEUC’s  position  paper  on  the  Air  Passenger  Rights  Regulation  (2019),  BEUC’s  position  paper 
accompanying BEUC’s response to the Commission’s public consultation on the Better Protection of Passengers 
and their Rights (2021) and the European Passengers’ Federation’s (EPF) position paper (2023).  

7 

 
 
 
strongly or somewhat agreed that the enforcement of EU passenger rights legislation by NEBs 
is neither harmonised nor consistent. 

This confirms the findings of the evaluation of Regulation (EC) 1107/2006, Regulation (EU) 
1177/2010 and Regulation (EU) 181/2011 which concluded that the overall approach of NEBs 
toward  monitoring  the  implementation  of  the  Regulations  varies  significantly:  while  some 
NEBs  are  very  proactive,  others  appear  only  to  react  to  complaints  which  they  receive.  In 
addition,  only  a  small  proportion  of  NEBs  have  issued  penalties  for  the  breach  of  these 
Regulations, and even such penalties were generally small. 

2.1.2  Problem 2: Insufficient protection of passengers during multimodal journeys 

The SSMS confirmed the ambition of the European Green Deal54 to achieve a 90% reduction 
in transport emissions by 2050. An important element of making transport more sustainable is 
achieving effective multimodality, where passengers who wish to travel long distances can do 
so by combining several modes of transport while using the most sustainable and efficient mode 
for each leg of the journey. It is estimated that 91 million passengers performed multimodal 
journeys in 2019 (representing approximately 0.7% of the total number of passengers subject 
to passenger rights)55, and the number is expected to grow56. Protecting passengers in the event 
of travel disruptions is key to the attractiveness of multimodal travel. Failure to provide such 
support  could  itself  affect  market  growth,  with  some  passengers  choosing  to  travel  by  car 
instead of collective transport (judging car travel to be both more convenient and more reliable). 

Today, while passengers who travel with one mode (i.e. only by plane, train, bus or ship) enjoy 
rights in the event of travel disruptions, they are not entitled to similar rights when switching to 
another mode. This implies that there is also no clear framework for determining the respective 
obligations  and  liabilities  of  the  different  travel  service  providers  involved  in  a  multimodal 
journey57. National legal frameworks generally do not include provisions covering multimodal 
transport either58. In addition,  the current  offer of travel  insurances for multimodal journeys 
remains  limited.  The  rights  of  passengers  in  the  context  of  multimodal  journeys  depend 
therefore on the existence of a contract of carriage covering the switch between transport modes 
and on the concrete terms and conditions of such contracts.. 

Consequently,  passengers  lack  information  on  the  extent  of  their  rights  before  and  during 
multimodal travel and are not given information in real-time on possible travel disruptions and 
security alerts. In addition, those passengers do not receive assistance (e.g. reimbursement, re-
routing, accommodation, meals and refreshments) if a travel disruption occurs when switching 
between transport modes. Finally, passengers have difficulties to complain to carriers and other 
possible relevant actors (e.g. terminal operators, ticket vendors) about the lack of information 
or assistance, nor do they have clarity on which national authority to contact in such cases. This 
lack  of  a  specifically  designated  authority  also  leads  to  uncertainty  on  the  enforcement  of 
information and assistance to passengers during multimodal travel.  The consequences of the 
lack  of  information  and  assistance  to  passengers  when  switching  modes  include  loss  of 
connections and money for citizens, biased decisions from citizens towards less green solutions, 
possible undue profits for carriers, and ultimately a lack of consumer trust in multimodal travel 
options. 

The 2020 Eurobarometer survey shows that 25% of respondents using a multimodal ticket in 

54 COM(2019)640 final. 
55 See section 2.2 of Annex 4. 
56 See section 5.1. 
57 Not only transport operators, but also intermediaries such as travel agents as well as infrastructure managers. 
58 2019, European Commission, Exploratory study on passenger rights in the multimodal context, Chapter 4.1.2.3. 
("At national level, specific provisions regarding multimodal transport are rare"). 

8 

 
 
 
2019  experienced  a  problem  when  travelling.59  The  targeted  consultation  showed  varying 
perceptions of how severe this problem is: 62% (89 out of 145) of respondents to the survey 
strongly or somewhat agree that the problem is important, while 18% (26 out of 145) fully or 
somewhat  disagree.  The  latter  were  mainly  carriers  (for  all  modes  of  transport)  and  their 
umbrella organisations, who argued that the multimodal ticketing market is still at an early stage 
of development, and that multimodal agreements are limited in number due to their complexity. 
Intermediary ticket vendors generally regard the development of passenger protection during 
multimodal journeys as challenging in a context where carriers do not give them the information 
needed to sell such tickets.  

The lack of rules for multimodal journeys also means that PRM are not entitled to any assistance 
under EU law when transferring between transport modes, including at multimodal connecting 
points such as air-rail hubs. In the absence of such assistance, they are not able to benefit from 
the  same  travel  experience  as  other  passengers.  The  public  consultation  revealed  diverging 
views on this. For 18 out of 19 consumer organisations, all 7 PRM organisations, as well as 9 
out of the 19 public authorities responding, the absence of assistance for PRM when switching 
between  different  transport  modes  is  an  important  problem  aspect.  One  third  of  business 
associations (11 out of 33) and 29% of individual businesses (8 out of 27) also agreed with this 
statement, but respectively 42% (14 out of 33) and 37% (10 out of 27) of them disagreed, while 
the others were neutral or had no opinion.  

2.1.3  Problem  3:  Reimbursement  rules  are  unclear  when  flights  were  booked  via  an 

intermediary 

No EU rules exist nor have been proposed for reimbursement of air tickets that were booked 
via intermediary ticket vendors and are not part of a travel package. Passengers have no clarity 
on the following issues: 

-  who is responsible (the intermediary or the carrier) for the reimbursement to the passenger 

when the ticket was booked via an intermediary;  

-  which deadlines and procedures apply for reimbursements when a ticket was booked through 

an intermediary; 

-  whether intermediaries are allowed to charge fees for the reimbursement processing60. 

The problem of unclear reimbursement rules for air passengers when flights were booked via 
an intermediary affects all passengers who booked their tickets via intermediaries (450 million 
passengers in EU-27 in 2019, as explained in Annex 11)6162. It is estimated that around 3% of 
passengers who booked via intermediaries63 request a reimbursement, which amounts to around 
13.5 million passengers yearly. The problem also concerns 149 airlines and 123,000 air travel 
intermediaries in the EU.  

During  the  stakeholder  workshop,  different  stakeholder  groups  agreed  that  the  liability  and 
responsibilities  regarding  the  provision  of  information  to  passengers  and  the  processing  of 

59 Special Eurobarometer 485 report on Passenger rights - January 2020. See also chapter 2.2.4. 
60 Under the current rules, carriers are not allowed to do so. Some intermediaries charge a fee for carrying out the 
reimbursement process on behalf of the passenger.  
61 Information provided by IATA, the global trade association of airlines. 
62 See also annexes 12 and 13 for information on intermediaries‘ reimbursement policies and terms and conditions. 
63 According to evidence provided by one large network air carrier for 2019. One large OTA provided a similar 
figure for reimbursement request in 2019 (3.2%). However, evidence from an airline association shows that on 
average 6% of passengers booking via intermediaries request reimbursement. One large LCC pointed out that 
reimbursement requests represented 0.5% of passengers booking via intermediary ticket vendors. A mid-point 
between these figures was considered, i.e. on average 3% of passengers booking via intermediary ticket vendors 
request reimbursement. 

9 

 
 
 
 
refunds should be clearly defined in case an intermediary is involved. Such a view has also been 
stressed  by  passenger  organisations  in  response  to  the  call  for  evidence  and  by  business 
organisations and associations through the OPC. In the targeted consultation, most stakeholder 
groups confirmed the statement that air carriers cannot always meet the obligation to reimburse 
passengers within seven days following the cancellation of a flight booked via an intermediary 
ticket vendor (e.g. because the air carrier does not have sufficient information to make payments 
directly  to  passengers).  However,  13  out  of  the  14  intermediary  ticket  vendor  respondents 
disagreed. 

2.1.4  Other problems on which stakeholders were consulted 

In addition, and as explained in section 1.2, stakeholders were consulted on two other problems, 
which were not pursued in this impact assessment, namely: 

First, the effectiveness of protection for air passengers against the risk of a liquidity crisis or an 
insolvency  affecting  an  airline’s  ability  to  reimburse  tickets  and/or  to  ensure  passengers' 
repatriation,  if  needed.  As  mentioned,  this  problem  and  possible  solutions  will  be  assessed 
together with another initiative: the review of the Air Services Regulation.  

Second, the lack of reimbursement for tickets cancelled by passengers themselves in the context 
of a major crisis. There were some indications that many passengers may not have been fully 
aware  of  their  rights,  leading  some  passengers  to  cancel  themselves  their  tickets  due  to  the 
unprecedented  situation  during  COVID-19.  Whether  they  had  a  right  to  reimbursement 
depended on the terms and conditions of the ticket: if they had not bought a flexible ticket, they 
did not receive a reimbursement. The EU passenger rights Regulations cover only cancellations 
by carriers, not by passengers. The fact that single ticket passengers do not have a statutory 
right under EU rules to receive reimbursement when cancelling themselves is a clear difference 
from the Package Travel Directive (PTD), which provides travellers with the right to receive a 
partial  or full  refund when they terminate the package travel  contract  before the start  of the 
package. This may confuse passengers when they find themselves in a crisis situation. The issue 
of these diverging rules was also mentioned by the European Court of Auditors64. However, 
after further analysis, the evidence showed that only very few passengers (well below 1%) were 
affected  by  this  situation  before  COVID-19,  and  2.87%  of  passengers  were  affected  during 
COVID-1965. 

In the context of the review of the Air Services Regulation, the services of the Commission are 
assessing measures to help passengers to make fully informed choices about what is included 
in their tickets and notably to be better informed about which elements of the ticket price are 
reimbursable and under which conditions, when they want to cancel their tickets themselves. 
The Air Services Regulation already contains requirements on price transparency66, with a view 
to  ensuring  that  customers  can  compare  effectively  the  prices  for  air  services  of  different 
airlines.  The  relevant  measures  under  consideration  in  this  context  would  require  the  clear 
display of information about the reimbursable amount in case the passenger cancels the ticket 
themselves  or  does  not  turn  up  for  boarding  (certain  taxes,  fees  and  charges  are  often 
reimbursable even when the ticket itself is non-refundable, though passengers may not be aware 
of this).  

64 European Court of Auditors’ Special Report 15/2021: Air passenger rights during the COVID-19 pandemic: 
Key rights not protected despite Commission efforts. 
65 See the support study for this IA, chapter 2.1. 
66 The final price including all unavoidable and foreseeable elements must be clearly displayed at all times, along 
with the breakdown into airfare, taxes, fees and charges (where these have been added to the fare).  See Art. 23 
Regulation (EC) No 1008/2008. 

10 

 
 
 
 
2.2  What are the problem drivers? 

The following problem drivers are related to problem 1: Passengers do not  fully benefit 
from their rights due to shortcomings in implementation and enforcement, as shown in Figure 
1 below: 

Figure 1 - Link between Problem Drivers 1-3 and Problem 1 

D1: NEBs lack the information base to carry out an 
effective enforcement 

D2: Insufficiently effective and uniform implementation 
and enforcement across all Member States 

D3: Passengers cannot submit their claims easily  

P1: Passengers do not fully benefit 
from their rights due to 
shortcomings in implementation 
and enforcement 

2.2.1  Problem Driver 1: NEBs lack the information base to carry out an effective enforcement 

The lack of information available to NEBs is undermining their ability to monitor operators’ 
compliance with EU passenger rights across all modes. The limited transparency of carriers’ 
and  terminal  operators’  compliance  with  passenger  rights  vis  à  vis  the  NEBs  has  also  been 
identified as an issue the following recent studies.  

In the study on air passenger rights of 202067 it was noted that NEB enforcement is very largely 
based only on complaints received (by the NEBs) as there is no obligation for airlines to report 
on compliance with the obligations stipulated in Regulation (EC) 261/2004 and that without 
such reports it is very difficult to monitor compliance with existing obligations. This finding 
was confirmed by ECA, which highlighted in  its report of June 2021 that  this was  an issue 
during the COVID-19 pandemic as well. 

The Commission’s evaluation reports on the rights of PRM when travelling by air68, on bus and 
coach69 and waterborne passenger rights70 of 2021 found that the NEBs often carry out their 
tasks with limited human resources, and that their monitoring and enforcement activities could 
be more efficient if they could rely on carriers’ data about compliance with passenger rights. 
During the consultation, several carriers across transport modes indicated that they collect data 
about their compliance with passenger rights (e.g. numbers of complaints received, issues raised 
and the outcome, level of cancellations and delays, passenger survey results, etc.). While very 
few operators publish detailed information about such data, most of them provide only limited 
summary data or no data at all. Some consulted carriers argued that such data is commercially 
sensitive,  and  one  waterborne  carrier  considered  that  if  such  data  were  to  be  published,  the 
public could draw wrong conclusions from them. On the other hand, EU level consumer and 
passenger  organisations  claimed  that  the  lack  of  publicly  available  data  not  only  makes  the 
monitoring and enforcement work of NEBs difficult, but also prevents passengers from making 
informed decisions about which operators to choose for their journeys.   

2.2.2  Problem Driver 2: Insufficiently effective and uniform implementation and enforcement 

across all Member States  

The evaluations published in 2021 as well as NEBs accounts from the Expert Group meetings 
show that there are substantial differences in how NEBs exercise their enforcement activities, 

67 2020 European Commission, Study on the current level of protection of air passenger rights in the EU.  
68  SWD(2021) 417 final.  
69  SWD(2021) 415 final.  
70 SWD(2021) 413 final.  

11 

 
 
 
 
in particular how they monitor compliance with passenger rights. Proactive NEBs perform a 
great  variety  of  monitoring  and  enforcement  activities  ranging  from  reviews  of  operators’ 
websites,  anonymous purchase tests,  regular dialogue with  operators, on the spot audits and 
inspections while other NEBs seem to limit their activities to complaint handling and imposing 
penalties in cases of severe breaches of the passenger rights Regulations.71.Certain NEBs are 
obliged to publish reports about their monitoring and enforcement activities,72 however they do 
not  have  to  indicate  in  those  activity  reports  the  approach  on  which  their  monitoring  and 
enforcement activities are based. As a consequence, the activity reports of NEBs  show a lack 
of consistency of NEB’s  monitoring and enforcement  activities across EU Member States. 

For several years, the Commission has highlighted in its reports that handling complaints and 
penalising non-compliance are just two of the possible measures that can be used to enforce 
passenger rights73, and that NEBs need to be more pro-active in monitoring, e.g. to carry out 
inspections74  In  2014,  the  Commission  concluded  that  while  some  NEBs  actively  take 
initiatives to improve the enforcement of PRMs' rights, more needs to be done by the majority 
of NEB75. The 2020 study on the state of play of  air passenger rights  concluded that NEBs 
should undertake monitoring activities to maintain oversight of the airlines’ compliance and 
highlighted the different approaches of the Member States. 

The stakeholder consultation confirmed that the enforcement of EU passenger rights legislation 
by NEBs is neither harmonised nor consistent. 67% (99 out of 148) of respondents strongly or 
somewhat agree that the problem is important, while 16% (23 out of 148) fully or somewhat 
disagree. In the OPC, 70% (117 out of 169) somewhat/fully agree with the importance of the 
statement that the enforcement of passenger rights varies greatly across the EU. 

2.2.3  Problem Driver 3: Passengers cannot submit their claims easily   

Two EU level passenger representative organisations expressed the view that there are multiple 
barriers  for  passengers  when  trying  to  contact  a  carrier  to  submit  a  claim76.  These  include 
malfunctioning  web  forms,  unavailable  email  addresses,  broken  links  to  claim  forms,  web 
forms not being available in the language of the passenger or a lack of clarity on the documents 
or  information  necessary  to  submit  the  complaint.  In  addition,  a  NEB  indicated  that  it  has 
received complaints from passengers about the difficulties of finding information on carriers’ 
websites, on where to direct complaints/claims, the appropriate forms to use and the languages 
in which they are explained. When facing these obstacles, passengers often give up, even if in 
theory they could exercise their rights. 

Another reason why passengers do not submit complaints when their rights are not respected is 
the fact that most passengers are still not aware of their rights, even though carriers and terminal 

71 See the above mentioned Commission evaluations on Regulation (EC) 1107/2006, Regulation (EU) 1177/2010 
and Regulation (EU) 181/2011 and the 2018 ECA Special Report on passenger rights. 
72 NEBs in charge of waterborne and bus and coach passenger rights are obliged to publish biennial activity reports 
since 2015, NEBs in charge of rail passenger rights will be obliged to publish such reports from 2025. The 2013 
Commission proposal on air passenger rights would oblige NEBs responsible for Regulation (EC) 261/2004 to 
publish annual reports, but many of them already do it as part of their annual reports based on national legislation.  
73 For waterborne passenger rights see COM (2016)274 final, p. 7 and 9; for bus and coach passenger rights see 
COM(2016)619 final, p. 8.  
74 COM(2013)587 final, p. 11 (regarding rail passenger rights). 
75  2014,  European  Commission,  Complaint  handling  and  enforcement by  Member  States  of  the  Air  Passenger 
Rights Regulation, SWD(2014) 156, p. 35. 
76 Annex 2 – Stakeholder consultation synopsis report. 

12 

 
 
 
managers are obliged to inform passengers of their rights77. 

The  following  problem  drivers  are  related  to  problem  2:  Insufficient  protection  of 
passengers during multimodal journeys, as shown in Figure 3 below: 

Figure 2 – Link between Problem Drivers 4-5 and Problem 2 

D4: Passengers are insufficiently informed, assisted or 
cared for in the context of travel disruptions when 
performing a journey involving different transport modes 

D5: Persons with disabilities or reduced mobility are not 
informed or assisted when switching between transport 
modes 

P2: Insufficient protection of 
passengers during multimodal 
journeys 

2.2.4  Problem Driver 4: Passengers are insufficiently informed, assisted or cared for in the 
context of travel disruptions when performing a journey involving different transport 
modes 

While still being relatively small, the size of the market for multimodal travel is expected to 
grow steadily, from 91 million passengers in 2019 up to around 103 million passengers for the 
EU-27 in 2030 and 150 million in 2050. Air-rail passengers represent over 60% of the total 
multimodal  passengers,  air-coach  passengers  above  30%,  while  the  share  of  rail-coach 
passengers is limited to around 1% of the total number of multimodal passengers78.  

Multimodal travel can involve travelling with separate tickets that passengers buy separately 
(‘category  C’  tickets).  Alternatively,  ticket  vendors  and  tour  operators  can  bundle  separate 
tickets  into a multimodal  product  on their own initiative and sell them to  passengers in  one 
single commercial transaction (‘category B’ tickets). A limited number of carriers also offer 
single contracts of carriage for a multimodal journey (‘category A’ tickets). The share of single 
multimodal contracts is estimated at around only 5% of the multimodal market79.  

The following table also provides an estimation of the number of stakeholders affected by the 
multimodal  market,  in  particular  carriers  throughout  all  transport  modes,  intermediaries  and 
multimodal terminal operators. 

Table 1: Number of stakeholders affected by multimodal travel  

Stakeholders 

Bus and coach carriers 

Railway undertakings 

Air carriers 

Waterborne carriers 

Intermediaries (e.g. ticket vendors, tour operators) 

Multimodal terminal operators 

Total 

3,778 

283 

149 

523 

123,000 

424 

Share of the 
multimodal 
market (%)80 

Multimodal 
operators 

4.6% 

24.4% 

7.5% 

1.0% 

0.1% 

100% 

173 

69 

11 

6 

123 

424 

77 As indicated in point 2.1.1, only 43% of the respondents to the 2020 Eurobarometer survey  who travelled with 
at least one transport mode in the past 12 months indicated that they were aware of the existence of passenger 
rights in the EU. 
78See Annex 4 – Analytical methods. 
79 European Commission, Exploratory study on passenger rights in the multimodal context, final report, June 2019. 
80 European Commission, Exploratory study on passenger rights in the multimodal context, final report, June 
2019. 

13 

 
 
 
 
Total number of stakeholders affected by multimodal 
travel 

806 

A  relatively  high  number  of  passengers  experience  problems  during  multimodal  travelling, 
especially  in  relation  to  missed  connections.  This  is  supported  by  the  2020  Eurobarometer 
survey, showing that of those respondents using a multimodal ticket in 2019, 25% experienced 
a problem when travelling, with 8% almost missing a connection due to a delay or cancellation 
and  9%  actually  missing  a  connection  for  this  reason.81  In  this  context,  and  as  already 
highlighted above, it is important to note that the current level of protection of passengers when 
switching  between  modes  would  depend  on  the  existence  of  a  single  contract  of  carriage 
covering the whole multimodal journey (category A), and the concrete terms and conditions of 
such contract.  

In the targeted consultations, 62% of respondents (89 out of 145) considered as an important 
problem the fact that passengers are not protected by existing rights when switching between 
transport modes, while 18% (26 out of 145, mostly carriers for all modes of transport and their 
umbrella  organisations)  disagreed  either  fully  or  somewhat.  The  latter  remarked  that  the 
multimodal market is still very limited and that it might be too early to regulate this sector. 
Conversely,  passenger  representative  organisations  and  one  rail  umbrella  organisation 
considered  that  the  protection  offered  to  passengers  making  multimodal  journeys  must  be 
improved if the market for multimodal transport is to develop82. 

2.2.5  Problem Driver 5: Persons with disabilities or reduced mobility are not informed  or 

assisted when switching between transport modes 

The obligations on carriers and infrastructure managers to provide PRMs with information and 
assistance set  out  in  the mode-specific rules on passenger rights  do not  apply  in the case of 
multimodal  travel,  which  particularly  affects  the  assistance  provided  at  connecting  points83. 
This implies, for example, that PRMs are only assisted within the perimeter of an individual 
airport,  railway  station,  bus  terminal  or  port,  but  do  not  receive  support  beyond  that  (e.g. 
assistance  from  a  railway  station  to  an  adjacent  bus  terminal);  or  that  several  operators  and 
terminal managers would have to be contacted in order to ensure the assistance of PRMs during 
a  given  journey.  The  2020  Eurobarometer  survey  also  found  that  almost  half  of  PRMs 
requesting assistance for a journey using more than one mode of transport were dissatisfied 
with the assistance they had received. 

50% of respondents to the targeted stakeholder consultations (69 out of 138) agreed that the 
absence  of  assistance  to  PRMs  when  switching  between  transport  modes  is  an  important 
problem, with 16% (22 out of 138) somewhat disagreeing, 14% (19 out of 138) being neutral 
and 20% (28 out of 138) having no opinion on the matter. There is also widespread acceptance 
throughout different categories of stakeholders representing consumers, transport operators and 
infrastructure  managers,  that  the  information  and  assistance  to  PRMs  switching  between 
transport modes should be improved84. 

The  following  problem  driver  is  related  to  problem  3:  Reimbursement  rules  are  unclear 
when flights were booked via an intermediary, as shown in Figure 4 below: 

81 Special Eurobarometer 485 report on Passenger rights - January 2020.  
82 Annex 2 – Stakeholder consultation Synopsis report. 
83 European Commission, Exploratory study on passenger rights in the multimodal context, final report, June 2019. 
84 Annex 2 – Stakeholder consultation synopsis report. 

14 

 
 
 
 
 
 
Figure 3 - Link between Problem Driver 6 and Problem 3 

D6: Legal rules and implementation in practice 
differ for air passengers requesting reimbursement 
for a ticket that they booked via an intermediary 

P3: Reimbursement rules are unclear when 
flights were booked via an intermediary 

2.2.6  Problem Driver 6: Legal rules and implementation in practice differ for air passengers 

requesting reimbursement for a ticket that they booked via an intermediary 

Regulation (EC) No 261/2004 stipulates passengers’ right to a reimbursement but stays silent 
on who shall reimburse the passenger. Intermediary ticket vendors are not included within the 
scope of the Regulation, only passengers and carriers are, which means that the onus is on the 
air carrier to communicate with and to reimburse the passengers in case of events triggering 
this right. However, many passengers have difficulties enforcing their right to reimbursement 
vis-à-vis the air carrier directly. De facto, many carriers (with the exception of large low-cost 
carriers  with  an  exclusive  direct  (online)  distribution  model)  ask  passengers  to  request  the 
reimbursement via the intermediary through which they booked85. The reason is that this is part 
of  the  service  package  offered  by  the  intermediary,  and  the  airlines  may  not  have  the 
passenger’s payment (or even contact) details for these tickets, and do not know the final price 
of the ticket that the passenger paid to the intermediary86. Industry rules support the ‘reversal 
of the payment flow’ method87, which, for tickets booked through credit cards, also avoids a 
credit card chargeback from the customer to the Merchant of Record intermediary88 (where the 
intermediary  is  responsible  for  the  financial  transaction),  and  thus  the  risk  to  the  airline  of 
paying  the  reimbursement  twice,  or  of  airlines’  liquidities  being  frozen  by  credit  card 
companies.89 Therefore, the large majority of airlines operating in the EU reverse the payment 
flow for the reimbursement of tickets booked via intermediaries (representing approximately 
92% of tickets booked via intermediaries and accounting for 416 million passengers in 2019), 
meaning that the money arrives with the Merchant of Record intermediary, which then needs 
to make the final reimbursement payment to the passenger.  

When Merchant of Record intermediaries are involved, the passenger is usually asked by the 
airline to turn to the intermediary for reimbursement. Given this practice, which is not mirrored 
in the current air passenger rights, passengers face difficulties to enforce their rights towards 
the intermediary. Furthermore, passengers are often confused about who is responsible for what 
and  when  the  payment  of  the  reimbursement  is  due  to  arrive  on  their  bank  account.  The 
coordinated  investigation  of  the  CPC  authorities  into  airlines’  cancellation  practices  of 

85 See Annex 13: it is common practice that carriers with an indirect distribution model (i.e. excluding large low-
cost carriers) refer the passenger to the intermediary first. Whilst there is no precise data available, it is assumed 
that this concerns a large majority of passengers (80%, i.e. those who did not book with large low-cost carriers). 
86 The intermediary may have sold the airline’s ticket at a discount or with a surcharge. The business model of 
many intermediaries foresees the complete decoupling of their customers from the airlines, e.g. by not providing 
the carrier with the passenger’s contact details. Also, the passenger may not be given the carrier’s booking 
reference, so that the passenger faces difficulties when wanting to contact the carrier directly.  
87 IATA resolution 824r foresees that refunds should be returned to the same form of payment with which the 
original  ticket  was  paid.  (Credit  card  rules  foresee  the  same.)  Refunds  under  IATA’s  BSP  cover  80%  of 
reimbursements (in paid amounts in the EU) for tickets booked via Merchant of Record intermediaries. 
88 And thus a potential double reimbursement payment from the airline to the passenger (if the passenger requested 
the  reimbursement  to  the  airline  directly  and  the  Merchant  of  Record  intermediary  through  the  chargeback 
mechanism, which is a type of credit card reimbursement insurance for services not rendered (including cancelled 
flights). A Merchant of Record intermediary is one which first takes the customer’s payment for the flight, and 
then makes the final payment for the flight to the carrier with its own means of payment (i.e. a switch in means of 
payment,  with  the  means  of  payment  of  the  passenger  not  being  known  to  the  airline  –  only  that  of  the 
intermediary). 
89 Credit card companies work with ‘acquirers’ which treat the unflown ticket paid by credit card as a liability until 
the  flight  is  either  flown  or  reimbursed,  because  of  the  risk  of  chargeback  for  services  not  rendered.  (IATA 
information). 

15 

 
 
 
 
2020/2021  confirmed  that  in  most  cases  where  passengers  booked  their  flights  via  an 
intermediary,  airlines  do  not  accept  direct  requests  for  reimbursement,  claiming  that  this 
responsibility  falls  on  the  intermediary90.  Consequently,  they  also  usually  do  not  offer  to 
passengers  who  booked  via  an  intermediary  to  request  a  direct  reimbursement  on  their 
websites91. 

2.3  How likely is the problem to persist? 

2.3.1  Problem  1:  Passengers  do  not  fully  benefit  from  their  rights  due  to  shortcomings  in 

implementation and enforcement 

Without EU intervention, the problem is likely to persist as not all NEBs dispose of effective 
tools to monitor compliance of operators, nor are they likely to acquire such tools. No evidence 
suggests that carriers or operators will publicise more information in the future, as their current 
hesitation  to  do  so  can  be  attributed  to  concerns  about  confidentiality  and  risk  of  losing 
passengers. As such, operators cannot be expected to be more willing in the future to provide 
NEBs  with  the  information  necessary  to  strengthen  NEBs’  monitoring  and  enforcement 
activities. Additionally, passengers will still not have access to a quick and efficient complaint 
handling system. While the prospect of a competitive edge might incentivize some carriers and 
intermediaries to better practices and more transparency in complaint handling, the extent and 
the pace of such a market-driven process are uncertain. The hassle costs related to individual 
redress  (e.g.  time  lost  while  searching  for  one’s  passenger  rights,  submitting  a  complaint 
through a difficult procedure and later possibly finding out that the NEB is not authorised to 
make a decision which is binging for the transport operator) will continue to cause significant 
personal  welfare  loss  and  the  loss  of  consumer  confidence  in  the  collective  transport  sector 
(because of the lack of transparency related to carriers and terminal managers compliance with 
passenger  rights  and  the  fear  that  passengers  will  not  be  respected  in  case  of  transport 
disruption) will also remain. 

2.3.2  Problem 2: Insufficient protection of passengers during multimodal journeys 

As mentioned above, while still being relatively small, the size of the market for multimodal 
travel is expected to grow steadily, from 91 million passengers in 2019 up to around 103 million 
passengers  for  the  EU-27  in  2030  and  150  million  in  205092.  At  the  same  time,  transport 
operators are cautious as to the potential for  growth in the availability of single contracts of 
carriage for multimodal journeys. Products and supporting mechanisms allocating liabilities in 
the event of disruption to connecting services, need to be economically viable for all involved. 
So  far,  these  multimodal  products  are  rare  (an  estimated  5%  of  the  multimodal  market  as 
mentioned above) and take time to develop given the need for negotiation between different 
service  providers.  National  policies  to  support  such  development  are  nearly  inexistent93. 
Incentives to inform and assist passengers when they combine separate tickets for a multimodal 
journey – either at their own initiative or with the involvement of a ticket vendor  - are also 
missing.  

Hence, market-based solutions to address this problem are unlikely to be developed sufficiently 
rapidly  to  materially  improve  the  experience  of  passengers,  including  PRMs,  in  the  coming 
years. Consequently, passengers will still lack information  on their rights  before  and during 
multimodal travel, and they will not be informed in real-time on possible travel disruptions and 
security alerts. They will not get assistance (e.g. reimbursement, re-routing, accommodation, 

90 Overview of measures proposed by CPC Network , see last row. 
91 Annex 13 - CPC action. 
92 Annex 4 – Analytical methods. 
93 European Commission, Exploratory study on passenger rights in the multimodal context, see in particular section 
4.1.2.3 (“At national level, specific provisions regarding multimodal transport are rare”). 

16 

 
 
 
meals and refreshments) in the event of a travel disruption when switching between transport 
modes and will have to fully bear the burden of such events. Finally, they will continue to face 
difficulties to complain to carriers and other possible relevant actors (e.g. terminal operators, 
ticket  vendors) about  the lack of information  or assistance. The lack of a clearly designated 
authority to enforce such level of service provision during multimodal travel is likely to persist. 
Therefore,  it  is  expected  that  the  issues  identified  will  not  be  resolved  through  the  further 
expansion of this market segment in the foreseeable future. 

2.3.3  Problem  3:  Reimbursement  rules  are  unclear  when  flights  were  booked  via  an 

intermediary 

The problem  identified is  likely  to  persist without  EU intervention, given  that market-based 
solutions  are  unlikely  to  develop.  The  current  main  market  practice  of  reimbursements  for 
indirect bookings has in fact diverged from the legal framework: the CPC action against airlines 
(see Annex 13) provides evidence that many airlines with an indirect distribution model first 
refer the passenger to the intermediary for the reimbursement. The fact that airlines deal with 
intermediary  ticket  vendors  differently,  depending  on  their  distribution  model￼,  adds 
confusion for the passenger. This  is  unlikely  to  change in  the  future.  It is also  unlikely  that 
intermediary ticket vendors will exit the market. 

The  CPC  action  on  intermediaries94,  that  started  in  autumn  2022  and  closed  in  June  2023, 
showed  how  difficult  it  is  to  solve  these  problems  with  voluntary  commitments  of 
intermediaries  if  the  substantive  law  to  be  enforced  is  not  clear  enough.  The  unclear  and 
inefficient reimbursement claim system will continue to lead to time lost by consumers when 
they try to find out whom to contact for their reimbursement through a trial-and-error approach 
and when the terms and conditions of (Merchant of Record) intermediaries set reimbursement 
deadlines from the intermediary to the customer (after receipt of the carrier’s payment) of more 
than 7 days, or do not provide any information on this at all.  

When  passengers  who  booked  a  ticket  via  an  intermediary  with  a  carrier  with  an  indirect 
distribution model insist to receive the reimbursement from the carrier, they will most likely 
continue to face considerable hassle costs. Airlines will likewise incur considerable costs in this 
case. The only element for which the hassle costs could possibly reduce in the future concerns 
the airline’s identity check of the passenger who booked via a Merchant of Record intermediary. 
The possible use of European Digital Identity Wallets by private parties (provided for in the 
provisional political agreement of the Council and European Parliament on the core elements 
of a new framework for a European digital identity (eID) of 29/6/202395) could potentially lead 
to the future uptake of eIDs by the airline industry, instead of other identity checks which are 
more burdensome. These developments are however unlikely to compensate for the consumer 
personal welfare loss and risk of loss of consumer confidence in the transport sector. 

3  WHY SHOULD THE EU ACT? 

3.1  Legal basis 

Article 91(1) of the Treaty on the Functioning of the European Union (TFEU) serves as the 
legal  basis  for  the  adoption  of  EU  legislation  related  to  a  common  transport  policy.  This 
provision is the legal basis for the passenger rights Regulations currently in force. Furthermore, 
pursuant to Article 100(2) TFEU the Union legislator may lay down appropriate provisions for 
sea transport. 

94 CPC action on airline intermediaries. 
95  Available  at:  https://www.consilium.europa.eu/en/press/press-releases/2023/06/29/council-and-parliament-
strike-a-deal-on-a-european-digital-identity-eid/. 

17 

 
 
 
3.2  Subsidiarity: Necessity of EU action 

The level of protection of passengers was rather limited before the passenger rights Regulations 
were adopted. A large number of carriers (not only airlines but also railway undertakings and 
shipping  companies,  and  increasingly  bus  companies)  provide  their  services  in  different 
Member States and even beyond. Harmonisation of passenger rights at EU level is therefore 
necessary  to  ensure  a  level  playing  field  for  all  stakeholders  involved  in  the  provision  of 
transport  services  (e.g.  carriers,  infrastructure  managers  (especially  relevant  for  PRM), 
intermediaries etc.). Passengers must be able to assert their rights in the same manner and to 
benefit from the same protection regardless of the Member State where they travel. For these 
reasons, the problems mentioned above need action at EU level. 

3.3  Subsidiarity: Added value of EU action 

The new measures related to enforcement would allow making existing rights more effective 
by making sure that NEBs’ enforcement practices would incentivise carriers, terminal operators 
and intermediaries to deliver the best protection to passengers and by removing obstacles that 
prevent  citizens  from  effectively  exercising  their  rights  under  EU  law.  The  added  value  of 
passenger  rights  for  multimodal  journeys  lies  in  the  continuity  of  the  passenger  protection 
across  the  journey;  protecting  passengers  travelling  multimodal  would  be  an  additional 
contribution to the new approach promoted by the common transport policy and the European 
Green  Deal  to  incentivise  the  use  of  more  sustainable  transport  modes.  Finally,  the  new 
measures  will  also  contribute  to  enhance  the  protection  for  air  passengers  across  the  EU, 
ensuring that clear rules will be in place for air tickets booked via an intermediary.  

4  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1  General objectives 

The  general  objective  of  this  intervention  is  to  ensure  the  proper  functioning  of  the  single 
market for passenger transport and to achieve a high level of consumer protection for passengers 
when travelling within one mode or when switching modes during their journey, by enabling 
carriers, 
terminal  operators  and  national 
administrations to apply and enforce these rights in an efficient and effective manner.  

intermediaries  and  (especially  for  PRM) 

4.2  Specific objectives 

The following specific objectives correspond to problem drivers 1-3, related to Problem 1: 
Passengers do not fully benefit from their rights due to shortcomings in implementation and 
enforcement, as shown in Figure 5. 

Figure 4 - Link between Problem Drivers and Specific Objectives for Problem 1 

D1: NEBs lack the information base to 
carry out an effective enforcement 

D2: Insufficiently effective and uniform 
implementation and enforcement across 
all Member States 

D3: Passengers cannot submit their claims 
easily 

SO1: Ensure effective and efficient 
enforcement across all MS (Member 
States) 

SO2: Ensure effective complaint 
handling for passengers 

SO1: Ensure effective and efficient enforcement across all Member States. This objective 
aims to ensure that NEBs have effective tools for the monitoring of operators’ compliance with 

18 

 
 
 
passenger rights.   

SO2:  Ensure  effective  complaint  handling  for  passengers.  This  objective  focuses  on 
providing passengers with a quick, simple and accessible system of complaint handling. The 
objective is to ensure that passengers can enjoy their rights to the fullest, which also means to 
be able to complain to the carriers, intermediaries and terminal operators if something has gone 
wrong during their travel.  

The following specific objectives correspond to problem drivers 4 and 5, related to Problem 
2: Insufficient protection of passengers during multimodal journeys, as shown in Figure 6. 

Figure 5 - Link between Problem drivers and Specific Objectives for Problem 2 

D4: Passengers are insufficiently informed, 
assisted or cared for in the context of travel 
disruptions when performing a journey 
involving different transport modes 

SO3: Increase protection of passengers facing 
travel disruptions in the context of multimodal 
journeys 

D5: Persons with disabilities or reduced 
mobility are not informed or assisted when 
switching between transport modes 

SO4: Increase information for and assistance of 
persons with disabilities or reduced mobility when 
switching between transport modes 

SO3:  Increase  protection  of  passengers  facing  travel  disruptions  in  the  context  of 
multimodal journeys. The aim of this objective is to raise protection standards for passengers 
during a multimodal journey, in particular in the form of information, assistance and care.  

SO4:  Increase  information  for  and  assistance  of  persons  with  disabilities  or  reduced 
mobility  when  switching  between  transport  modes.  This  objective  aims  to  foster  the 
protection of persons with disabilities or reduced mobility when they undertake a multimodal 
journey. In particular, it aims to improve the assistance of those passengers when they transfer 
from one transport mode to another during such a journey.  

The  following  specific  objective  corresponds  to  problem  driver  6,  related  to  Problem  3: 
Reimbursement rules are unclear when flights were booked via an intermediary, as shown in 
Figure 7. 

Figure 6 - Link between Problem drivers and Specific Objectives for Problem 3 

D6: Legal rules and implementation in practice 
differ for air passengers requesting 
reimbursement when they booked via an 
intermediary 

SO 5: Ensure a clear reimbursement 
process when air passengers booked 
via an intermediary 

SO  5:  Ensure  a  clear  reimbursement  process  when  air  passengers  booked  via  an 
intermediary. This objective aims to ensure that the reimbursement process becomes clear for 
all actors involved (carriers, intermediaries and passengers). 

5  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

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  initiative96.  The  REF2020  takes  into  account  the  significant  impacts  of  the  COVID-19 

96 European Commission, Directorate-General for Climate Action, Directorate-General for Energy, Directorate-
General for Mobility and Transport, De Vita, A., Capros, P., Paroussos, L. et al., EU reference scenario 2020  – 
Energy, 
2021, 
https://data.europa.eu/doi/10.2833/35750. 

2050,  Publications  Office, 

and  GHG 

–  Trends 

emissions 

transport 

to 

19 

 
 
 
 
 
pandemic  on  the  transport  sector.  More  detailed  information  about  the  preparation  process, 
assumptions  and  results  are  included  in  the  Reference  scenario  publication97.  Building  on 
REF2020, the baseline has been designed to include the initiatives of the ‘Fit for 55’ package 
proposed by the Commission on 14 July 202198 and the initiatives of the RePowerEU package 
proposed by the Commission on 18 May 202299.  

In terms of passenger rights, the baseline scenario assumes no further EU level intervention beyond 
the current Regulations in place100 and the proposal to amend Regulation (EC) No 261/2004 on 
air passenger rights101, currently under discussion by the co-legislators.  

As  regards  the  reimbursement  of  air  tickets  when  booked  via  intermediaries,  the  baseline 
scenario includes: 

-  The possible use of European Digital Identity Wallets by private parties (provided for in the 
provisional political agreement of the Council and European Parliament on the core elements 
of  a  new  framework  for  a  European  digital  identity  (eID)  of  29/6/2023102)  that  could 
potentially  lead  to  future  uptake  of  eIDs  by  the  airline  industry.  This  would  most  likely 
facilitate  the  airline’s  check  of  the  identity  of  the  passenger.  It  is  currently  part  of  the 
additional information required by airlines when the ticket was paid by an intermediary on 
behalf of a passenger, and the passenger approaches the airline directly for a reimbursement. 

-  In case of insolvency of the entity which sold the passenger the air ticket, Regulation (EU) 
261/2004 applies. The transport contract is always concluded between the passenger and the 
airline. The onus for the passenger’s reimbursement  lies with  the airline, except  where it 
already  transferred  the  reimbursement  money  to  an  intermediary  which  holds  a  valid 
mandate from the passenger to receive the airline’s reimbursement payment on his or her 
behalf.  Such a mandate depends on national law and the terms and conditions of the contract 
between passenger and intermediary. If the airline goes bankrupt and did not yet pay out to 
the intermediary (with a valid mandate), the passenger becomes the creditor of the airline. If 
the  intermediary  goes  bankrupt  without  having  received  the  carrier’s  reimbursement 
payment, the passenger can request it from the carrier directly. 

-  The Digital Services Act (DSA)103, that sets up a single point of contact for intermediaries104. 
The  Consumer  Rights  Directive  2011/83/EU,  Art.  6(1)c,  stipulates  that  the  trader  is  to 
provide the consumer with its telephone, fax and email address. The E-Commerce Directive, 
Art. 5(1)c, stipulates that the service provider is to provide the recipient of the service with 
an email address. However, these two articles do not apply to air carriers. 

The baseline also incorporates foresight megatrends105 and developments captured in the 2022 
Strategic Foresight Report106. More specifically, it captures the trend of increasing demand for 
transport as population and living standards grow. The projected transport activity draws on the 
long-term  population  projections  from  Eurostat  and  GDP  growth  from  the  Ageing  Report 

97 EU Reference scenario 2020. 
98 European Green Deal. 
99 RePower EU press release. 
100 Regulations (EC) No 261/2004 (air), (EC) No 1107/2006 (air PRM), (EU) No 1177/2010 (sea and inland 
waterways), (EU) No 181/2011 (bus and coach), (EU 2021/782 (rail). 
101 EUR-Lex - 52013PC0130 - EN - EUR-Lex (europa.eu), COM(2013)130 final. 
102 Available at: https://www.consilium.europa.eu/en/press/press-releases/2023/06/29/council-and-parliament-
strike-a-deal-on-a-european-digital-identity-eid/. 
103 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022R2065. 
104 The assessment of which intermediary is covered by the DAS needs to be done on an individual basis. 
105 Megatrends. 
106 COM(2022) 289 final. 

20 

 
 
 
2021107 by the Directorate General for Economic and Financial Affairs. 

The total number of passengers in the EU travelling by air, bus and coach, rail and waterborne 
transport is projected to grow from 13.4 billion in 2019 to 15.4 billion in 2030 and 19.8 billion 
in 2050 (15% increase for 2019-2030 and 48% increase for 2019-2050), following the recovery 
from the COVID pandemic. The number of passengers travelling by air would increase from 
970 million in 2019 to 1.1 billion in 2030 and 1.4 billion in 2050 (9% growth for 2019-2030 
and 41% for 2019-2050), maintaining a relatively stable share in the total number of passengers 
between 2019 and 2050. The number of passengers travelling by rail is projected to increase 
faster than for air (from 8.7 billion in 2019 to 9.7 billion in 2030 and 13.3 billion by 2050), 
driven  in  particular  by  the  completion  of  the  TEN-T  core  network  by  2030  and  of  the 
comprehensive network by 2050, supported by the CEF, Cohesion Fund and ERDF funding, 
but also by measures of the ‘Fit for 55’ package that increase to some extent the competitiveness 
of rail relative to road and air transport. The number of passengers travelling by bus and coach 
is projected to increase from 3.3 billion in 2019 to 4.1 billion in 2030 and 4.6 billion by 2050, 
with the passengers travelling above 250 km representing around 11% of the total number of 
passengers travelling by bus and coach. The number of passengers travelling by waterborne 
transport would also increase in the baseline scenario, from 418 million in 2019 to 459 million 
in 2030 and 569 million in 2050. Drawing on the projected number of passengers, seat capacity 
and occupancy rates, the total number of passenger services by air transport, rail, bus and coach 
and waterborne transport are estimated to increase from 107 million in 2019 to 109.1 million 
in 2030 and 133.8 million in 2050.  

Drawing on data for the historical period collected in the context of the exploratory study on 
passenger rights in the multimodal context108, the number of multimodal passengers is projected 
to increase from 91 million in 2019 to 103.6 million in 2030 and 150.9 million in 2050 in the 
baseline  scenario.  The  air-rail  passengers  represent  over  60%  of  the  total  multimodal 
passengers, air-coach passengers above 30%, while the share of rail-coach passengers is limited 
to around 1% of the total number of multimodal passengers. In terms of market size, the air-rail 
passengers represented 6.3% of the total number of passengers travelling by air in 2019 and 
their share is projected at 6.3% in 2030, following the recovery from the COVID pandemic, 
going  up  to  6.9%  by  2050.  The  air-coach  passengers  represented  around  0.9%  of  the  total 
number of bus and coach passengers in 2019, going up to 1.2% by 2050 in the baseline scenario, 
while the rail-coach passengers represent below 0.05% of the bus and coach passengers over 
the  whole  time  horizon.  Expressed  as  share  of  the  total  number  of  passengers,  multimodal 
passengers are estimated to increase from 0.7% in 2019 to 0.8% by 2050. 

In the baseline scenario, the costs for airlines, bus and coach operators and the rail sector for 
the provision of passenger rights are projected to increase from EUR 15.7 billion in 2019 to 
EUR 16.8 billion in 2030 and EUR 20 billion in 2050, driven by the increase in the number of 
passengers over time. 

The  total  number  of  PRM  requests  for  air,  bus  and  coach,  rail  and  waterborne  transport  is 
projected to increase from 82.7 million in 2019 to 115.6 million in 2030 and 199.7 million in 
2050, driven by the ageing population.  

More details, by transport mode, are provided in section 2 of Annex 4. 

107 The 2021 Ageing Report: Underlying assumptions and projection methodologies. 
108 EY (2019), Exploratory study on passenger rights in the multimodal context.  

21 

 
 
 
5.2  Description of the 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  study  and  the  Commission’s  own  analysis.  This  list  was 
subsequently screened based on the likely effectiveness, efficiency and proportionality of the 
proposed  measures  in  relation  to  the  given  objectives,  as  well  as  their  legal,  political  and 
technical feasibility. 

5.2.1  Discarded policy measures  

Annex  6  presents  the  possible  policy  measures  that  were  initially  considered  but  were  discarded 
following  the  screening/analysis  mentioned  above.  A  detailed  overview  of  the  reasons  for 
discarding the policy measures can also be found in Annex 6. 

5.2.2  Retained policy measures and policy options  

The retained policy measures have been grouped into policy options to address separately each 
of  the  three  problems,  as  presented  in  the  tables  below.  More  detailed  explanations  of  the 
measures included in each policy option are provided in Annex 7. 

Measures and options addressing problem 1 (Passengers do not fully benefit from their rights 
due to shortcomings in implementation and enforcement) 

Table 2 provides the links between the policy measures, policy options, problem drivers and 
specific objectives related to problem 1.  

Table 2: Links between policy measures, policy options, problem drivers and specific objectives for problem 1 

Retained policy measures 

PM 
A.1 

PM 
A.2 

PM 
A.3 

PM 
A.4 

PM 
A.5 

PM 
A.6 

Industry stakeholders shall share relevant information with 
NEBs (all modes except rail) 

Carriers  and  terminal  operators  shall  establish  service 
quality standards, implement a quality management system 
and report on results (all modes except rail) 

Adoption  of  an  EU-wide 
for 
reimbursements  and  compensation  requests  (all  modes 
except rail) 

standardised 

form 

NEBs  shall  perform  compliance  monitoring  activities  of 
the industry stakeholders based on a risk assessment 

improve 

the 
terminal  operators  shall 
Carriers  and 
information to passengers about their rights, in particular at 
the time of booking and during journey disruptions with the 
view to raise awareness of passengers about those rights  
NEBs (all modes except rail) shall provide information on 
ADR 
to 
passengers  

(Alternative  Dispute  Resolution)  bodies 

Policy options 

Problem 
drivers 

Specific 
objectives 

PO1.1  PO1.2 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

D1 

SO1 

D1 

SO1 

D3 

SO2 

D2 

SO1 

  ✓ 

D3 

SO2 

✓ 

✓ 

D3 

SO2 

Both  policy  options  envisage  introducing  into  all  other  passenger  rights  Regulations  certain 
measures already existing in Regulation (EU) 2021/782 for rail passenger rights or contained 
in the Commission’s 2013 proposal to amend Regulation (EC) No 261/2004 on air passenger 
rights. PM A.1, PM A.2, PM A.3 and PM A.6 are already applicable in the rail passenger rights 
Regulation. This means that these measures would only be proposed for non-rail carriers.  These 

22 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
measures  increase  coherence  of  passenger  rights  between  modes  and  Regulations,  enabling 
passengers to exercise their rights and creating a level playing field for industry stakeholders. 

The main difference between the two policy options is that PO 1.1 does not go further than 
the harmonisation with the rail passenger rights Regulation and with the proposed amendment 
for  the  air  passenger  rights  Regulation,  while  PO  1.2  would  introduce  two  additional  and 
complementary measures which would be new for passenger rights of all modes.  

PM A.1 is based on Regulation (EU) 2021/782 on rail passenger rights, Article 32(2). 49 out of 
140 respondents to the targeted stakeholder consultation considered that this measure would 
bring a very strong or strong contribution. In particular, NEBs (66%, 29 out of 44) chose this 
response.  At  a  dedicated  expert  group  meetings  some  NEBs  indicated  that  such  a  measure 
already exists under their national law, this is why for them it has little added value, but it could 
have  a  strong  contribution  for  other  NEBs.  In  addition,  50%  (8  out  of  16)  of  the  passenger 
organisations consider that it would bring a very strong or strong contribution. At the same time 
35 stakeholders indicated that this measure would bring slight contribution or no contribution 
at all, including mostly air carriers (83% of them, 14 out of 17) and carriers in other transport 
modes (35% of them, 7 out of 20). 

PM A.2 is based on Regulation (EU) 2021/782 on rail passenger rights, Article 29. 34 out of 
140 respondents to the targeted stakeholder consultation considered that this measure would 
bring a strong or very strong contribution. 50% of the consumer organisations (8 out of 16) and 
50% of NEBs (22 out of 44) chose this response. At the same time 32% of stakeholders (46 out 
of 140) indicated that this measure would bring slight contribution or no contribution: mostly 
air  carriers  (94%,  16  out  of  17)  and  other  carriers  (60%,  12  out  of  20)  subscribed  to  this 
response. 25% of the stakeholders replying to this question did not have an opinion. 

PM A.3 is based on Regulation (EU) 2021/782 on rail passenger rights, Article 18(6), 18(5), 
19(5)  and  19(6).  PRM  associations  expressed  very  strong  support  for  this  measure  (other 
consumer associations had mixed views). 25 out of 44 (57%) NEBs that replied to this question 
in  the  targeted  online  survey  expressed  a  favourable  view  towards  this  policy  measure  by 
claiming it would have a strong or very strong contribution. 24% of carriers that replied agreed 
that its contribution would be moderate. On the other hand, 65% of air carriers (11 out of 18) 
and 45% of other carriers (9 out of 19) opposed (very strongly) this policy measure. 

PM A.4 is a new measure. It was inspired by ECA’s recommendation “to give the Commission 
mandate  to  perform  quality  control  of  the  enforcement  practices  of  NEBs”.  However, 
stakeholders were divided: 41 out of 146 of the stakeholders (strongly) supported it (including 
7 out of 8 consumer and passenger organisations that expressed its opinion and a majority of 
NEBs) while 39 out of 146 (almost all carriers, and 34% of the NEBs) (strongly) opposed the 
ECA recommendation. Accordingly, it was decided to assess the impacts of a slightly different 
policy measure which would require NEBs to perform their monitoring activities according to 
a risk assessment and would possibly allow the Commission to assess such risk assessments 
and to confirm whether the monitoring activities implemented by the NEBs reflect the risks 
they have identified.  

PM A.5 is also a new measure. It emerged during the targeted stakeholder consultation when 
all EU-level consumer and passenger representative organisations highlighted109 the need to do 
more  to  raise  the  awareness  of  passengers  about  their  rights,  in  particular  to  get  accurate 
information from transport operators on passenger rights when booking their journeys, when a 
disruption  occurs  and  on  the  complaint  handling  mechanisms.  Eurobarometer  surveys  also 
show that there is a lack of awareness of passengers on their rights, so there is a need for action. 

109 Annex 2 – Stakeholder consultation synopsis report. 

23 

 
 
 
Accordingly,  carriers  and  terminal  operators  will  be  obliged  to  improve  the  information  to 
passengers about their rights ad on how to seek individual redress in particular at the time of 
booking and during journey disruptions with the view to raise awareness of passengers about 
those rights. 

In  relation  to  PM  A.6,  ADR  bodies  (3  out  of  4)  agree  this  measure  would  have  a  strong 
contribution. 9 of 14 (64%) infrastructure managers that replied to this question in the targeted 
online survey consider the measure to have a very strong or strong contribution. 22 of 46 (48%) 
NEBs that replied to this question in the targeted online survey showed their support towards 
the  measure  by  claiming  that  it  would  have  a  strong  or  very  strong  contribution.  Similarly, 
infrastructure managers (64% - 9 out of 14) consider the measure to have a very strong or strong 
contribution.  Other stakeholders did  not  have such a  favourable view of this  measure: most 
airlines (63% - 12 out of 19) considered that it would bring no contribution, while ticket vendors 
(62% - 8 out of 13) and passenger organisation (50% - 8 out of 16) believe it would bring only 
a moderate contribution.  

PM  A.1,  PM  A.2  and  PM  A.4  contribute  towards  SO1  (ensure  effective  and  efficient 
enforcement  of  passenger  rights  in  all  Member  States).  Concretely,  carriers,  terminal  and 
infrastructure managers, ticket vendors and tour operators will have to provide the NEBs with 
relevant  documents and  information  at  the NEB’s request  without undue delay (PM  A.1) in 
order  to  help  NEBs  to  carry  out  their  monitoring  tasks.  For  the  same  purpose,  carriers  and 
terminal managers will be required to establish service quality standards, implement a quality 
management system, and additionally carriers will be also required to publish reports on the 
results (PM A.2). PM A.4 also contributes to SO1 by requiring NEBs to perform compliance 
monitoring  activities (e.g. on the spot audits and inspections, verifications, website reviews, 
dialogue with operators etc.) based on a risk assessment they would carry out. On that basis, it 
is ensured that NEBs take a proactive role in assessing the need for monitoring and oversight 
in their Member State. The specific design of the risk assessment will be left to the Member 
States,  as  they  know  the  best  their  own  transport  systems,  individual  needs  and  transport 
operators  active  on  their  territory.  The  requirement  of  publishing  them  will  enable  the 
Commission to assess the monitoring activities of the NEBs, enhance transparency and would 
lead to a better level playing field for passengers and industry stakeholders alike. 

PM A.3, PM A.5 and PM A.6 contribute towards SO2 (ensure effective complaint handling for 
passengers). The Commission will adopt standardised compensation and reimbursement forms 
available in all official languages and in accessible formats for persons with disabilities; the 
forms will help citizens to submit a complete file with all the relevant details, and operators will 
be obliged to accept these forms (PM A.3). As under the new rail passenger rights Regulation 
(EU) 2021/782, NEBs responsible for the other modes and for multimodal passenger rights will 
also be obliged to inform passengers about the right to approach ADR bodies to seek individual 
redress  in  cases  where  the  NEBs  themselves  do  not  have  an  alternative  dispute  resolution 
function110  (PM  A.6).  PM  A.6  will  require  carriers  and  terminal  operators  to  improve  the 
information  on  passenger  rights  in  particular  at  the  time  of  booking  and  when  a  transport 
disruption  occurs    to  increase  the  awareness  of  passengers  about  their  rights.  This  policy 
measure emerged during the targeted stakeholder consultation when consumer and passenger 
representative  organisations  highlighted111  the  need  to  do  more  to  raise  the  awareness  of 
passengers about their rights, in particular to get accurate information from transport operators 
on passenger rights when booking their journeys, when a disruption occurs and on the complaint 
handling mechanisms. 

110 A few NEBs also act as an ADR depending on the countries and the Regulations. Most recently, the Spanish 
air NEB started to act as an ADR for Regulation (EU) N°261/2004 on 2 June 2023.  
111 Annex 2 – Stakeholder consultation synopsis report. 

24 

 
 
 
Policy option 1.1 (PO 1.1) 

The aim of this policy option – as a moderate policy option - is harmonising existing (for rail) 
or proposed (for air) enforcement and complaint handling rules.  

NEBs will be able to request carriers, terminal and infrastructure managers, ticket vendors and 
tour operators to provide them with relevant documents and information without undue delay 
and  in  any  event  within  one  month  from  the  receipt  of  the  requests.  NEBs  will  use  such 
information  both  to  carry  out  their  general  monitoring  and  enforcement  tasks  and  to  handle 
individual cases. This measure (PM A.1) already exists for rail passenger rights and it would 
be extended to the other transport modes. 

On the basis of certain basic criteria established in the annex of the legislation to be adopted, 
carriers will be required (PM A.2) to establish standards on which their service quality will be 
measured  (e.g.  on  the  punctuality  of  their  services,  about  the  way  they  sell  tickets  to  their 
customers, about how to measure consumer satisfaction, etc.). Carriers and terminal operators 
will have to monitor their performance on the basis of these standards: carriers will have to 
publish the results while terminal operators have to collect data about the results and send it to 
the responsible NEB if that NEB requests it. The information provided by carriers and terminal 
operators will help NEBs to plan and carry out their monitoring and enforcement authorities. 
Passengers will be able to compare the performance of different carriers and make informed 
decisions about which carrier to choose in the future. This measure also exists for rail passenger 
rights and it would be extended to the other transport modes. 

The  Commission  will  adopt  an  EU-wide  standardised  form  for  reimbursements  and 
compensation requests via an implementing act. Carriers, ticket vendors and tour operators will 
be obliged to accept this form, but passengers will not be forced to use it. This measure (PM 
A.3) also exists for rail passenger rights and it would be extended to the other transport modes. 

NEBs will have to inform passengers about the possibility to use alternative dispute resolution 
in case they do not handle individual complaints. This measure (PM A.6) also exists for rail 
passenger rights and it would be extended to the other transport modes. 

Policy option 1.2 (PO 1.2) 

This  policy  option  contains  all  the  policy  measures  listed  in  PO  1.1  and  adds  two  policy 
measures  which  apply  to  all  modes  and  contribute  to  SO1  (Ensure  effective  and  efficient 
enforcement  across  all  Member  States)  and  SO2  (Ensure  effective  complaint  handling  for 
passengers).   

First,  NEBs  will  have  to  design  and  implement  a  risk  assessment  related  to  the  operators’ 
compliance  with  passenger  rights.  On  this  basis,  NEBs  will  have  to  perform  compliance 
monitoring  activities  of  the  carriers,  terminal  operators,  ticket  vendors  and  tour  operators 
corresponding  to  the  findings  of  the  risk  assessment.  Minimum  requirements  for  NEBs 
monitoring programmes will be defined to ensure consistency at EU level and to ensure that 
operators perform according to passenger rights rules (PM A.4). Second, carriers and terminal 
operators will have to improve information on passenger rights to increase the awareness of 
passengers on their rights especially when booking their journeys and when a disruption occurs 
including on how to submit a complaint.  

25 

 
 
Measures and options addressing problem 2  (Insufficient protection of passengers during 
multimodal journeys)  

The policy measures included in the options addressing problem 2 are differentiated between 
ticket  categories112. Table 3 provides  the links  between the policy measures, policy options, 
problem drivers and specific objectives related to problem 2.  

Table 3: Links between policy measures, policy options, problem drivers and specific objectives for problem 2 

Retained policy measures 

PM 
B.1 

PM 
B.2 

PM 
B.3a 

PM 
B.3b 

PM 
B.4a 

PM 
B.4b 

PM 
B.5 

PM 
B.6 

PM 
B.7 

PM 
B.8 

information 

to  provide  real-time 

Industry  stakeholders  shall  provide  guidance  to 
passengers  on  minimum  connecting  times  and 
other useful information when switching between 
modes of transport (category A+B+C) 
Carriers and ticket vendors/tour operators (except 
SMEs) 
to 
passengers (category A+B) 
Right  to  pre-purchase  information,  right  to 
reimbursement  or  re-routing,  right  to  care  and 
right to PRM assistance for passengers having a 
single contract of carriage (category A) 
Enhanced  package  of  rights  for  passengers 
holding a single contract of carriage (category A) 
(i.e.  same  rights  as  under  PM  B.3a  +  right  to 
conclude an alternative contract) 
Essential  set  of  rights  for  passengers  holding 
separate  tickets  (category  B)  (i.e.  right  to  pre-
purchase  information  +  right  to  reimbursement 
and  penalty  of  75%  from  ticket  vendor/tour 
operator, unless where passengers were properly 
informed of separate nature of the tickets) 
Enhanced rights for passengers holding separate 
tickets (category B) (i.e. same B.3b). The  ticket 
vendor is liable to ensure these rights towards the 
passenger unless where passengers were properly 
informed of the separate nature of the tickets 
Ensure 
the 
that  Member  States 
establishment  of  “Single  Points  of  Contact” 
(SPC) for PRM at multimodal passenger hubs in 
urban nodes on their territory (category A+B+C) 
Member States may require the establishment of 
“Single  Points  of  Contact”  (SPC)  to  PRMs  at 
other  multimodal  passenger  hubs  on 
their 
territory. (category A+B+C) 
Industry  stakeholders  to  establish  complaint-
handling mechanisms for multimodal passengers. 
(category A+B+C) 
Member  States 
multimodal 
(category A+B+C) 

handle 
passengers 

complaints 

authorities 

require 

from 

shall 

Policy options 

PO2.1  PO2.2   PO2.3 

Problem 
drivers 

Specific 
objectives 

✓ 

✓ 

✓ 

  D4/D5 

SO3/SO4 

✓ 

✓ 

  D4 

SO3 

✓ 

✓ 

D4 

SO3 

✓ 

  D4 

SO3 

✓ 

D4 

SO3 

✓ 

  D4 

SO3 

✓ 

✓ 

  D5 

SO4 

✓ 

✓ 

  D5 

SO4 

✓ 

✓ 

✓ 

✓ 

✓ 

  D4/D5 

SO3/SO4 

✓ 

  D4/D5 

SO3/SO4 

All policy options aim to introduce measures to increase the level of protection of passengers 
undertaking a multimodal journey, including PRM, by mirroring measures which have already 
been implemented for travel with a single mode under the existing regulations on passenger 

112 See point 2.2.4 above: Multimodal travel typically involves travelling with a number of separate tickets that 
passengers buy separately (‘category C’ tickets). At the same time, some ticket vendors and tour operators bundle 
such separate  tickets into a multimodal product on their own initiative  and sell it as such to passengers in one 
single commercial transaction (‘category B’ tickets). A limited number of carriers also offer single contracts of 
carriage for a multimodal journey (‘category A’ ticket). 

26 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
rights (in particular Regulation (EU) 2021/782 on rail passengers’ rights and obligations). These 
options  also  take  into  account  the  outcomes  and  recommendations  of  the  Commission’s 
exploratory study of 2019 on passenger rights in the multimodal context.113  

Three policy measures are common to all policy options: PM B.1, PM B.7 and PM B.8 and 
contribute to SO3 (Increase protection of passengers facing travel disruptions in the context of 
multimodal journeys). Concretely, carriers, ticket vendors/tour operators and multimodal hub 
managers  should  provide  guidance  to  all  passengers  (categories  A,  B  and  C)  on  minimum 
connecting times and other useful information when switching between modes of transport, e.g. 
on accessibility of transport infrastructure. The information to be provided is established on an 
EU-wide  basis  and  would  apply  to  all  the  above  mentioned  actors  (PM  B.1).  Each  carrier 
offering  single  transport  contracts  for  multimodal  journeys  (category  A  tickets),  each  ticket 
vendor and tour operator offering combined tickets for such journeys (category B tickets) and 
each multimodal hub manager should also provide for an online and offline complaint-handling 
mechanism to deal with any issues faced by multimodal passengers (categories A, B and C - 
PM B.7). In addition, Member States would have to designate an authority to handle complaints 
from multimodal passengers (categories A, B and C). This authority would not need to be a 
new one, as this competence could also be added to (one of) the existing NEBs. Where the NEB 
and the complaint-handling body are different in a given Member State, they would have to 
cooperate by sharing information and identifying a lead body that serves as a single point of 
contact (PM B.8). 

Furthermore, PM B.1 would also contribute to SO4 (Increase information for and assistance of 
persons  with  disabilities  or  reduced  mobility  when  switching  between  transport  modes),  as 
carriers,  ticket  vendors/tour  operators  and  infrastructure  managers  would  have  to  provide 
guidance to passengers on the accessibility of transport infrastructure when switching between 
modes  of  transport  (categories  A,  B  and  C).  In  addition,  PM  B.7  and  PM  B.8  would  also 
contribute to SO4, where they ensure that PRM would be able to submit a complaint through 
the  online  and  offline  complaint-handling  mechanism  of  the  above  mentioned  undertakings 
(PM B.7), respectively could turn to a NEB (PM B.8) (categories A, B and C for both PMs).  

With regard to PM B.1 on providing useful information to passengers when switching between 
modes  of  transport,  airlines  and  their  representative  organisations  remarked,  during  the 
dedicated stakeholder workshop, the difficulties in obtaining information that they often do not 
have (e.g. on connecting times), and the increase in the operational costs related to the required 
changes to the IT systems supporting booking arrangements and to additional resources needed 
to  identify  the  mentioned  information.  On  the  other  hand,  ticket  vendors  are  generally 
supportive of the introduction of a measure encouraging carriers and ticket vendors to provide 
passengers with information such as time schedules on every part of their multimodal trip. One 
organisation  of  airports  and  one  organisation  for  rail  stations  stressed  the  importance  of 
adequate communication channels in this context. 

As regards PM B.7 on the establishment of offline and online complaint handling mechanisms 
by industry stakeholders, 56 out of 136 respondents (41%) to the targeted stakeholder survey 
stated that this measure would provide a (very) strong contribution to solving the problem, of 
which  11  out  of  16  passengers  and  consumer  organisations  (69%),  3  out  of  3  PRM 
organisations, 3 out of 4 ADR bodies (75%), 6 out of 11 infrastructure managers (54%) and 25 
out of 42 NEBs (60%). On the other hand, 10 out of 13 air carriers (76%), 11 out of 25 carriers 
for other modes (44%) and 4 out of 11 infrastructure managers (36%) replied that this measure 
would bring a slight or no contribution. On PM B.8 on the designation of a national authority 
to handle multimodal complaints, 43 out of 144 respondents to the targeted stakeholder survey 
(30%) agreed that this measure would bring a (very) strong contribution to solving this problem, 

113 European Commission, Exploratory study on passenger rights in the multimodal context. 

27 

 
 
 
including  9  out  of  17  passengers  and  consumer  organisations  (57%),  3  out  of  3  PRM 
organisations, and 17 out of 42 NEBs (40%). On the other hand, 5 out of 12 air carriers (42%), 
9  out  of  25  carriers  for  other  modes  (36%)  and  8  out  of  42  NEBs  (20%)  consider  that  this 
measure would only bring a slight or no contribution. 

Policy Option 2.1 (PO 2.1) 

The  objective  of  PO  2.1  is  to  provide  passengers  with  all  ticket  categories  a  basic  level  of 
protection  to  ensure  that  they  receive  information  and  assistance  when  they  undertake  a 
multimodal journey. This policy option aims at providing some basic rules, in particular for 
passengers  having  concluded  a  single  contract  of  carriage  with  a  carrier  for  a  multimodal 
journey (category A), except where these contracts concern journeys with an air leg.114 For the 
more  frequent  cases  of  passengers  having  separate  tickets  (whether  they  were  bundled  by 
intermediaries  (category  B) or by passengers themselves (category C)), the policy measures 
would ensure that carriers, intermediaries and terminal operators provide useful information to 
all passengers, e.g. on the type of ticket they bought and on minimum connecting times (PM 
B.1). Under PO 2.1, passengers having a single contract of carriage for a multimodal journey 
(category  A)  would  be  granted  a  number  of  key  rights,  in  particular  the  right  to  have  pre-
purchase  information  on  a  number  of  elements  relevant  to  the  journey,  the  right  to  choose 
between reimbursement or re-routing in the event of a missed connection, as well as the right 
to care (e.g. refreshments, meals, accommodation). In addition, PRM would have a right to non-
discriminatory transport contract conditions for single contracts for multimodal journeys, and 
those contracts should entail a right to free assistance of PRM (PM B.3a). This measure would 
therefore address both SO3 and SO4.  

With regard to PM B.3a, 73 out of 134 (54.5%) of stakeholders that replied to this question 
during the targeted consultation consider that the introduction of a right to reimbursement or 
re-routing for passengers having a single contract of carriage would provide a strong or very 
strong  contribution  to  solving  the  problem.  In  particular,  passengers  and  consumer 
organisations (13 out of 16 – 81%), intermediary ticket vendors (9 out of 11 – 82 %) and NEBs 
(28 out of 42 – 66%) consider that such a measure would bring a (very) strong contribution to 
solving the problem, while air carriers (7 out of 12 – 58%) and carriers for other modes (13 out 
of 25 – 52%) believe that such a measure would have a slight or no contribution. A similar 
picture can be drawn with regard to the introduction of a right to care, where 70 out of 133 
(52.6%) stakeholders responding to this question during the targeted stakeholder consultation 
consider that introducing such a measure for passengers having a single contract of carriage 
would provide a strong or very strong contribution to solving the problem. In particular, 13 out 
of 16 (81%) passengers and consumers organisations; 7 out of 10 (70%) intermediary ticket 
vendors; and 28 out of 45 (67%) NEBs consider that such a measure would bring a (very) strong 
contribution  to  solving  the  problem,  whereas  most  carriers  for  air  (7  out  of  12  –  58%)  and 
almost half of carriers for other modes (12 out of 25 – 48%) consider that such a measure would 
bring a slight or no contribution to solving the problem. 

Policy Option 2.2 (PO 2.2) 

This  option  aims  at  providing  a  more  comprehensive  level  of  protection  for  passengers 
travelling in a multimodal context than PO 2.1. In particular, it is foreseen under PO 2.2 that 
passengers (category A and B) should get  real-time information on disruptions and possible 

114 The proposal to amend Regulation (EC) No 261/2004 on air passenger rights of  March 2013 (see section 1.2) 
already includes a reference to single contracts for a multimodal journey with an air leg, where it provides under the 
new Article 3(4) of that Regulation that  “(…) where  a  part  of  the  journey  is  carried  out,  in  accordance  with  a 
contract of carriage, by another mode of transport [than air transport by fixed wing aircraft] (…), this Regulation 
shall apply for the whole journey and the part of the journey carried out by another mode of transport shall be 
considered as a connecting flight for the purposes of this Regulation.”, COM(2013)130 final. 

28 

 
 
 
next connections during the journey (where technically feasible). The obligation to provide real-
time information would not apply to SMEs (PM B.2). In addition, passengers having booked a 
multimodal journey comprising of separate tickets by means of a single commercial transaction 
through a ticket  vendor  or tour operator (category  B) would be better protected.  In case the 
intermediary  does  not  inform  the  passengers  correctly  that  they  bought  separate  tickets,  the 
intermediary would be liable and owe the passenger a right to pre-purchase information, a right 
to reimbursement and a penalty of 75%of the ticket price (PM B.4a).115  

Whereas PM B.2 and PM B.4a would tackle SO3, PO 2.2 would also see the introduction of 
rules on the establishment of “Single Points of Contact” (SPC) to ensure assistance to PRM 
when  switching  between  modes  at  multimodal  passenger  hubs  in  urban  nodes  and  possibly 
beyond (PM B.5 and PM B.6 – both categories A, B and C), thereby contributing to achieving 
SO4. The terminal manager(s) and carriers operating at the multimodal passenger hub would 
have to cooperate to set up the SPC.  These hubs are connection points between at least two 
transport  modes  for  passengers,  where  travel  information,  access  to  public  transport  and 
transfers  between  modes  are  ensured  (i.e.  specific  airports,  railway  stations,  ports  or  bus 
terminals). The SPC would accept individual requests for assistance at multimodal passenger 
hubs and communicate these to terminal operators and carriers. 

As regards PM B.2 (provision of real-time information), one consumer organisation argued that 
in case of travel disruptions, intermediaries should be held liable to inform consumers in real-
time and to inform them on the possible re-routing options. Airlines and their representative 
organisations  highlighted  the  difficulties  in  providing  real-time  information  on  journey 
disruption  where  passengers  booked  via  a  ticket  vendor.  One  rail  carrier  referred  to  current 
technical limitations making it difficult to implement this measure. Ticket vendors specified 
that such a measure would only be feasible if carriers were obliged to share information with 
intermediaries.  

With regard to PM B.4a, 39 out of 133 stakeholders (29.3%) that contributed during the targeted 
stakeholder  consultation  believe  that  introducing  a  right  to  reimbursement  for  passengers 
having a ticket category B, on the condition that ticket vendors/tour operators did not properly 
inform them of the separate nature of the transport contracts sold to them, would bring a (very) 
strong contribution to solving the problem (including 43% of NEBs – 18 out of 41 - and 32% 
of  passengers  and  consumer  organisations  –  5  out  of  16).  At  the  same  time,  41  out  of  133 
stakeholders  (30.8%)  stated  that  such  a  measure  would  bring  a  slight  or  no  contribution 
(including 67% of air carriers – 8 out of 14; 40 % of carriers for other modes 10 out of 25; 55% 
of intermediary ticket vendors – 6 out of 11; and 25% of passengers and consumer organisations 
– 4 out of 16). 

As regards the introduction of “Single Points of Contact” for PRM (PM B.5 and B.6), 60 out of 
143  stakeholders  (42%)  consider  that  this  would  (very)  strongly  contribute  to  solving  the 
problem, while 50 out of them (35%) consider that such a measure would bring only a slight or 
no contribution. It follows from the targeted stakeholder consultation that views on the matter 
are mixed throughout all stakeholder categories. 

Policy Option 2.3 (PO 2.3) 

This option aims to introduce a further level of protection for multimodal passengers compared 
to PO2.2. In particular, this option would bring an additional right to passengers having a single 
contract of carriage (category A) where they miss a connection during a multimodal journey 

115 This sanction, including the penalty threshold of 75%, is directly inspired from Article 12 (4) of Regulation 
(EU) 2021/782 that provides for an identical sanction in the context of rail travel. Therefore, in order to ensure 
coherence, no other thresholds were considered. 

29 

 
 
 
compared to what is provided under PM B.3a and would therefore come on top of the right to 
reimbursement/re-routing, the right  to  care  and the right to  PRM  assistance. This  additional 
right  would  consist  of  the  entitlement  for  a  passenger  to  conclude  an  alternative  transport 
contract  with  other  transport  providers  where  a  carrier  does  not  make  provision  for  the 
continuation of a passenger’s journey within a defined time limit, and to the reimbursement of 
the  costs  incurred  by  the  passenger  to  this  effect  (PM  B.3b).  In  addition,  this  option  would 
provide  stronger  sanctioning  rules  in  case  ticket  vendors  and  tour  operators  do  not  inform 
passengers  having  category  B  tickets  correctly  about  the  separate  tickets  they  received: 
passengers would be protected as if they had bought a single ticket with a full set of rights (i.e. 
right to  reimbursement or re-routing,  right  to  care, right to  conclude  an alternative contract, 
right  to  non-discrimination and free assistance for PRM). Ticket  vendors and tour operators 
would however be exempted from any liability where they properly informed passengers of the 
separate nature of the tickets (PM B.4b).  

The targeted stakeholder consultation on PM 3b shows that 60 out of 134 respondents (44.8%) 
would bring a (very) strong contribution to solving the problem (including 81% of passengers 
and consumer organisations – 13 out of 16; 64% of intermediary ticket vendors – 10 out of 11; 
and 45% of NEBs – 19 out of 42), while 33 out of 134 respondents (26.2%) stated that this 
would bring a slight or no contribution (including 75% of air carriers – 9 out of 12; and 60 % 
of carriers for other modes – 15 out of 25). On PM B.4b, 55 out of 134 stakeholders (41%) that 
replied to this question consider that this would (strongly) contribute to solving the problem 
(including 91% of intermediary ticket vendors – 10 out of 11; 45% of NEBs – 19 out of 42; and 
32% of passengers and consumer organisations – 5 out of 16), while 39 out of them (29.1%) 
believe  that  such  a  measure  would  bring  a  slight  or  no  contribution  (including  92%  of  air 
carriers – 11 out of 12;, 36% of carriers for other modes – 9 out of 25; and 44% of passengers 
and consumer organisations – 7 out of 16). 

Table 4 summarises the ramifications of each of the policy options for every type of multimodal 
ticket. 

Table 44: Overview of policy options and policy measures per multimodal ticket category 

Category A 
(Single contract) 

PO 2.1  Pre-purchase information  

(PM B.1) 
Basic set of passenger rights 
(PM B.3a) 
Complaint-handling by 
industry and NEBs  
(PM B.7 & B.8) 
PO 2.2  Pre-purchase information  

(PM B.1) 
Real-time information  
(PM B.2) 
Basic set of passenger rights 
(PM B.3a) 
Single Point of Contact  
(PM B.5 & B.6) 
Complaint-handling by 
industry and NEBs  
(PM B.7 & B.8) 

PO 2.3  Pre-purchase information  

(PM B.1) 
Real-time information  
(PM B.2) 

Category B 
(Separate tickets combined and 
sold by ticket vendor) 

Pre-purchase information  
(PM B.1) 
Complaint-handling by industry 
and NEBs  
(PM B.7 & B.8) 

Category C 
(Separate tickets at 
passenger’s own initiative) 
Pre-purchase information  
(PM B.1) 
Complaint-handling by 
industry and NEBs  
(PM B.7 & B.8) 

Pre-purchase information  
(PM B.1) 
Real-time information  
(PM B.2) 
Information on separate nature of 
tickets 
(PM B.4a) 
Single Point of Contact  
(PM B.5 & B.6) 
Complaint-handling by industry 
and NEBs  
(PM B.7 & B.8) 
Pre-purchase information  
(PM B.1) 
Real-time information  
(PM B.2) 

30 

Pre-purchase information  
(PM B.1) 
Single Point of Contact  
(PM B.5 & B.6) 
Complaint-handling by 
industry and NEBs  
(PM B.7 & B.8) 

Pre-purchase information  
(PM B.1) 
Single Point of Contact  
(PM B.5 & B.6) 

 
 
 
Category A 
(Single contract) 

Enhanced set of passenger 
rights  
(PM B.3b) 
Single Point of Contact  
(PM B.5 & B.6) 
Complaint-handling by 
industry and NEBs  
(PM B.7 & B.8) 

Category B 
(Separate tickets combined and 
sold by ticket vendor) 
Information on separate nature of 
tickets  
(PM B.4b) 
Single Point of Contact  
(PM B.5 & B.6) 
Complaint-handling by industry 
and NEBs (PM B.7 & B.8) 

Category C 
(Separate tickets at 
passenger’s own initiative) 
Complaint-handling by 
industry and NEBs  
(PM B.7 & B.8) 

Measures and options addressing problem 3 (Reimbursement rules are unclear when flights 
were booked via an intermediary) 

Table 5 provides the links between the policy measures, policy options, problem drivers and 
specific objectives related to problem 3. 

Table 5: Policy measures, policy options, problem drivers and specific objectives for problem 3 

Retained policy measures 

Policy Options 

Problem 
drivers 

Specific 
objectives 

PO3.1  PO3.2  PO3.3 

PM C.1a 

Intermediaries and carriers to inform passengers on 
the  reimbursement  process.  The  carrier  has  to 
reimburse the passenger always directly even when 
an  intermediary  is  involved.  The  passenger  may 
only request  it to the carrier, which  performs it 
without the involvement of the intermediary. 

PM C.1b 

PM C.1c 

Intermediaries and carriers to inform passengers on 
the reimbursement process. The carrier can decide 
whether  the  passenger  has  to  request  the 
reimbursement from the (MoR) intermediary or 
the  carrier.  It  can  do  so  on  an 
individual 
intermediary basis. 
The MoR intermediary can disagree with processing 
reimbursement  requests  for  (certain  or  all)  carriers 
and needs to inform about this. If the carrier decides 
to carry out the reimbursement by itself: like PO 3.1). 

Intermediaries and carriers to inform passengers on 
the reimbursement process. The passenger has the 
option  to  choose  between  (MoR)  intermediary 
and  carrier  for  requesting  reimbursement  (when 
carrier: like PO 3.1; when intermediary: like PO 3.2, 
with the difference that the intermediary may charge 
a fee for processing the reimbursement request). 
Intermediaries to inform whether they charge a fee 
for the reimbursement request 

✓ 

  D6 

SO5 

  ✓ 

  D6 

SO5 

  ✓ 

  D6 

SO5 

PM C.2a 

Intermediary may not charge a fee for processing 
the passenger’s reimbursement request 

  ✓ 

D6 

SO5 

PM C.2b 

PM C.3 

Intermediary  may  charge  a  fee  for  processing  the 
passenger’s reimbursement request 
MoR  Intermediary  to  enable  the  passenger  (with 
the  data  needed,  and  which  only  the  intermediary 
has, such as carrier booking reference) to request the 
reimbursement directly to the carrier 

  ✓ 

D6 

SO5 

✓ 

D6 

SO5 

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Policy Options 

Problem 
drivers 

Specific 
objectives 

PO3.1  PO3.2  PO3.3 

  ✓ 

  ✓ 

D6 

SO5 

Retained policy measures 

Additional rules when intermediaries which are a 
‘Merchant of Record’ are involved: 

1.  When the passenger requests the reimbursement: intermediary 
to enable the passenger (with the data needed and which only 
the  intermediary  has,  such  as  carrier  booking  reference)  to 
request  the  reimbursement  directly  to  the  carrier.  If  the 
intermediary  does  not  agree  to  process  the  reimbursement 
request, it shall enable the passenger at booking, with the data 
needed and which only he has, to request the reimbursement 
directly from the carrier.  

PM C.4 

2.  Carrier shall reimburse the intermediary at the latest within 7 
days, in one transaction, via the same payment method used at 
the time of booking and linking the payment with the original 
booking  reference.  The  intermediary  has  to  reimburse  the 
passenger at the latest within another 7 days. 

3.  If the intermediary did not receive the carrier’s reimbursement, 
with  the  result  that  the  intermediary  did  not  reimburse  the 
passenger within 14 days, 
a.  The  passenger  can  request  the  reimbursement  from  the 
carrier. The carrier shall reimburse the passenger within 7 
days, or: 

b.  The 

intermediary  can 

reimburse 
passenger by advancing the money to the carrier.116 

(voluntarily) 

the 

4. If  the  intermediary  received  the  carrier’s  reimbursement  and 
did not reimburse the passenger within 14 days, the passenger 
can request the reimbursement from the carrier.   

Three policy options have been developed to address problem 3 and contribute to SO5. They 
provide  clarity  to  all  parties  concerned  (passengers,  air  carriers,  intermediaries)  on  the 
reimbursement  process  and  responsibilities.  All  options  foresee  obligations  on  carriers  and 
intermediaries to inform passengers about the reimbursement process. They complement what 
is  already  foreseen  in  the  Commission  proposal  of  2013  to  revise  rules  in  the  air  transport 
sector117 on information obligations during disruptions and passenger claims.  

Policy Option 3.1 (PO 3.1) 

PO 3.1 foresees that the passenger may only request the reimbursement from the carrier. This 
option reflects best the current legal situation in the sense that it is the air carrier’s responsibility 
to reimburse the passenger. The option implies that intermediaries must enable passengers to 
do so, by providing them with the necessary data118, i.e. usually the carrier’s booking reference 
or the carrier’s e-ticket number or the passenger name record (PNR) number119.  

116 No right of redress is foreseen for the intermediary against the carrier as it already exists due to the carrier’s 
obligation to reimburse the intermediary within 7 days. 
117  COM(2013)  130  final  of  13/03/2013,  Art.  14.5-7:  In  the  event  of  cancellation  or  delay  in  departures,  the 
operating air carrier shall inform passengers who booked via an intermediary, if the intermediary provided the 
airline with the contact details of the passenger (for which the passenger needs to give his explicit and written 
authorisation, on an “opt-in” basis). Alternatively, the intermediary may use an “alternative system of informing 
passengers if it can prove the existence of an alternative system that ensures that the passenger is informed without 
the transmission of the relevant contact details”. See also Art. 16a on air carrier contact addresses for passengers 
to submit claims. 
118  According  to  stakeholder  evidence,  not  all  intermediaries  provide  the  passenger  with  the  carrier’s  booking 
reference. 
119 ‘PNR’ means a record of each passenger's travel requirements which contains information necessary to enable 
reservations to be processed and controlled by the booking and participating air carriers for each journey booked 
by or on behalf of any person. 

32 

 
 
 
 
 
 
 
 
 
 
 
 
In  the  targeted  stakeholder  consultation,  9  out  of  17  (53%)  consumer  organisations  that 
participated supported this option, as well as 17 out of 30 (57%) NEBs. 17 out of 18 (94%) 
airlines and 7 out of 14 (50%) intermediaries claimed that this option120 would not bring any 
contribution, while 5 out of 14 (35%) ticket vendors consider that the measure has a very strong 
or  strong  contribution.  The  airlines  opposing  this  option  do  so  because  administrative  costs 
would increase for them: the requests addressed to airlines would need to be dealt with mostly 
in  a  manual  way  (need  for  identification,  bank  account,  checking  whether  the  passenger 
launched a credit card chargeback as well). Intermediaries which oppose it do so because they 
want  to  continue  processing  their  customers’  reimbursements  and  retaining  the  exclusive 
relationship  with  them121.  The  credit  card  companies  involved  in  the  consultation  process 
stressed  the  importance  of  holding  the  “Merchant  of  Record”  (actor  responsible  for  the 
processing  of  the  payment)  liable  for  the  reimbursement,  using  the  same  channel  for  the 
purchase of the ticket, in line with the “reversal of the original payment flow” principle122. PO 
3.1 is not in line with this principle. 

Policy Option 3.2 (PO 3.2) 

Option  3.2  foresees  that  the  carrier  can  decide  whether  the  passenger  has  to  request  the 
reimbursement from the intermediary (provided the intermediary agrees to this) or the carrier 
(in this case, the procedure is the one outlined under PO 3.1). In both cases, the reimbursement 
process is free of charge for the passenger. The carrier can take different decisions on the way 
forward involving particular or all intermediaries123. This option reflects best the different ticket 
distribution models of air carriers currently being practiced on the market: some (the majority) 
do involve intermediaries, and some do not (or prefer not to), and how air carriers currently 
reimburse passengers. Under the intermediary procedure, a new, separate payment deadline of 
7 days for the Merchant of Record intermediary is introduced: the carrier pays the intermediary 
within  7  days,  after  which  the  intermediary  pays  the  passenger  within  an  additional  7-day 
period124.  

The carrier remains ultimately responsible: if the carrier decided in favour of processing the 
reimbursement via the intermediary and did not pay the intermediary in time, with the result 
that the intermediary did not pay the passenger within 14 days, the passenger has the right to 
request the reimbursement from the carrier. In this case, as in PO 3.1, the intermediary needs 
to provide the passenger with the data needed to request the reimbursement from the carrier. If 
the  intermediary  received  the  carrier’s  reimbursement  and  did  not  reimburse  the  passenger 
within 14 days, the passenger can also request the reimbursement from the carrier.  

In the targeted stakeholder consultation, the procedure via the intermediary125 (without any pre-
financing by the intermediary) was supported by 18 of 19 (90%) carriers that responded to this 
question, 12 of 13 (93%) intermediaries, 11 of 30 (37%) NEBs, 4 of 6 (67%) national public 
authorities,  and  10  of  17  (59%)  passenger  and  consumer  organisations.  A  carrier  umbrella 

120 Measure 2.2.8 of the targeted stakeholder consultation: “Passenger requests and receives reimbursement only 
from the carrier. Ensure that air carriers implement an accessible procedure to allow passenger to easily identify 
themselves and provide the payment details to the airline, at no cost to the passenger, including by means of an 
online form on the carrier’s website and a call centre.” 
121 A European umbrella organisation of online travel agents expressed its disagreement with this option, inter alia 
because it would force intermediaries to hand over passengers’ data to the airlines even when they could process 
the refund request themselves and retain their relationship with the customer. 
122 Original payment flow is passenger to intermediary to ticket vendor (2 separate transactions). 
123 This means that the carrier can decide the intermediary procedure for intermediary X, and the carrier procedure 
for intermediary Y. 
124 The additional 7-day payment deadline for the Merchant of Record intermediary would also create an 
alignment with the Package Travel Directive, which foresees that the organiser (a Merchant of Record 
intermediary) refunds all payments made not later than 14 days. 
125 Option A, Policy measure 2.2.1. of the targeted stakeholder consultation. 

33 

 
 
 
organisation and intermediaries and their associations have advocated for an additional 7-day 
timeframe for the situation when an additional financial transaction by the intermediary to the 
passenger  is  required,  which  this  option  foresees.  For  the  case  where  the  airline  does  not 
reimburse the intermediary in time, an association of intermediary ticket vendors asked for the 
intermediary  to  be  able  to  choose  whether  to  pre-finance  the  reimbursement,  or  to  refer  the 
customer to the airline for the reimbursement, which PM C4 also foresees.   

Policy Option 3.3 (PO 3.3) 

PO 3.3 allows the passenger to choose to request the reimbursement either to the intermediary 
or to the carrier, but in the latter case, the intermediary may charge a fee for processing the 
reimbursement request (PM C.2b). The procedure for the case that the passenger chooses to go 
via the intermediary is the same as the intermediary procedure under PO 3.2; for the carrier-
only procedure, it is the same as under PO 3.1. 

This  option  comes  closest  to  the  proposal  of  a  European  consumer  organisation126,  namely 
“joint  and  several  liability”  between  the  online  intermediaries  and  the  transport  operators, 
allowing consumers to direct their claim to both. However, the Commission did not retain the 
principle of joint and several liability and discarded this measure (see annex 6 for reasons), but 
chose to retain the principle of the passenger being allowed to approach either of the two (air 
carrier or intermediary). PO 3.3 was not part of the stakeholder consultation. It can be expected 
that, similar to PO 3.1, airlines which currently use the reversal of the payment flow method 
would, in  general,  oppose this option, as it would most likely  increase the amount of direct 
reimbursement requests made to them (and possibly to intermediaries at the same time). There 
would also be an increased risk of double payments by the airlines.  

Intermediaries which want to retain the exclusive relationship with the customer would possibly 
also be against this option (but still favour it over PO 3.1.), as a certain percentage of passengers 
who,  under  the  baseline,  would  have  their  reimbursement  request  processed  by  the 
intermediary,  might  choose  the  carrier  instead.  A  positive  point  for  them  would  be  the 
possibility to charge fees for processing the refund request. In a position paper, the European 
umbrella  association  of  online  intermediaries  disagreed  with  any  legislation  restricting  the 
commercial decision of intermediaries whether to charge a fee or not for the refund request. 

6 

IMPACTS OF THE POLICY OPTIONS 

This section summarises  the main  expected  economic, social  and  environmental impacts  of  each 
policy option (PO)127. 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,  including  the  assumptions  used  for  the  estimations  and 
detailed tables on costs and costs savings by policy option, measure and stakeholder group for 
2025-2050 and individual years (2025, 2030 and 2050) relative to the baseline are provided in Annex 
4 (section 3). 

6.1  Economic impacts  

This section provides the economic impacts of the policy options on carriers, terminal operators, 
intermediaries, public authorities, claim agencies and passengers and consumers. It also provides 

126 See BEUC position paper “Passenger Rights 2.0: Towards Better Consumer Protection and a More Resilient 
travel Sector (https://www.beuc.eu/sites/default/files/publications/BEUC-X-2022-
125_Better_Protection_of_Passengers_and_their_Rights.pdf), p. 9: “joint and several liability between online 
intermediaries and transport operators, which would allow consumers to direct their claims to both”. 
127 The analysis in this section is based on the IA support study and on the analysis of stakeholders' feedback. 

34 

 
 
 
an assessment of impacts on SMEs, functioning of the internal market and competition, digitalisation 
and  territorial  impacts.  The  assessment  of  economic  impacts  draws  on  multiple  data  sources, 
including the targeted stakeholders’ consultation (interviews and survey) and public consultation, and 
findings from desk research in the context of the impact assessment support study.  

6.1.1 

Impacts on carriers 

It has been estimated that a total of 4,733 carriers are affected by this initiative: 3,778 are bus 
and coach operators, 523 waterborne transport operators, 238 railway undertakings and 149 air 
carriers (section 2.2 of Annex 4 provides details on the sources of the data used). The number 
of operators by transport mode are assumed to remain stable over time. New rules applying to 
air carriers will apply to EU and non-EU carriers operating flights departing from an airport 
located on the territory of an EU Member State. 

6.1.1.1  Administrative costs for carriers  

Options related to enforcement (problem area 1). Both PO 1.1 and PO 1.2 are expected to 
lead  to  administrative  costs  for  air,  bus  and  coach  and  waterborne  carriers,  relative  to  the 
baseline. No additional costs are envisaged for rail carriers, since the respective obligations are 
part of the baseline. These costs are generated by the requirement to report by carriers (PM A.2) 
on the result of the implementation of the quality standards set up under the policy measure and 
are expected to lead to recurrent administrative costs estimated at EUR 5.1 million per year 
from 2025 onwards (EUR 34,782 for air carriers, EUR 4.4 million for bus and coach operators 
and  EUR  0.6  million  for  waterborne  transport  operators),  amounting  to  EUR  93.1  million 
expressed  as  present  value  over  2025-2050  (EUR  640  thousand  for  air  carriers,  EUR  81.2 
million for bus and coach operators and EUR 11.2 million for waterborne transport operators). 
The reason for the high  costs for the bus and coach sector, is  the relatively  high  number of 
operators (3,778 bus and coach operators) out of the 4,450 carriers affected by PM A.2 (149 air 
carriers, 3,778 bus and coach operators and 523 waterborne carriers).  

The  administrative  costs  per  carrier  are  however  estimated  to  be  limited,  at  EUR  1,136  on 
average per year (EUR 233 on average per year per air carrier and EUR 1,167 on average per 
year per bus and coach and waterborne transport operator). The proposed reporting obligations 
for operators are essential to ensure proper monitoring and enforcement of passenger rights by 
the NEBs. They directly address shortcomings identified by the European Court of Auditors in 
its report. They will also allow passengers to make informed decision about which carrier to 
choose based on their record of complying with passenger rights. More transparency brought 
by these reports will increase competition between carriers and make an impetus for them to 
better comply with passenger rights. 

Options related to multimodal passenger rights (problem area 2). Policy options PO 2.2 and 
PO 2.3 are expected to lead to small recurrent administrative costs for carriers, estimated in 
total at EUR 6,770 per year from 2025 onwards (EUR 467 for air carriers, EUR 6,069 for bus 
and  coach  operators  and  EUR  233  for  waterborne  carriers)  or  EUR  124,649  expressed  as 
present value over 2025-2050 relative to the baseline (EUR 8,596 for air carriers, EUR 111,754 
for bus and coach operators and EUR 4,298 for waterborne transport operators). These costs 
are associated to the obligation on carriers to provide real-time information to passengers (PM 
B.2)128. Only a small number of carriers would be affected (29 carriers in total, of which 2 air 
carriers,  26  bus  and  coach  operators  and  1  waterborne  transport  operator)  due  to  the  SME 

128 The one-off costs due to PM B.2 serve a broader scope than pure information reporting. By implementing real-
time  information  provisions  and  integrating  communication  systems  to  multimodal  passengers,  their  aim  is  to 
enable better services for multimodal passengers in case of disruptions and delays. For this reason, the one-off 
costs have been classified as adjustment costs. 

35 

 
 
 
exemption  applied  to  this  measure.  The  administrative  costs  per  carrier  are  estimated  to  be 
limited, at EUR 233 on average per year per carrier.  

Options related to intermediaries (problem area 3). When reimbursements are carried out by 
air carriers, i.e. not via the Merchant of Record intermediary who booked the tickets, the former 
are  expected  to  incur  additional  recurrent  administrative  costs  associated  with  processing 
manual reimbursements (as automatic reversal of payment is not possible). This is expected to 
lead  to  recurrent  administrative  costs  under  PO  3.1  (EUR  73.9  million  in  2025,  EUR  80.6 
million in 2030 and EUR 104.1 million in 2050)129 and, to a lesser extent, under PO 3.3 (EUR 
14.8 million in 2025, EUR 16.1 million in 2030 and EUR 20.8 million in 2050)130. In PO 3.2, 
no additional recurrent administrative costs for carriers are projected as it is expected that the 
number of requests for reimbursement to carriers remains unchanged compared to the baseline.  

In addition, limited one-off administrative costs are expected in PO 3.1, PO 3.2 and PO 3.3 to 
update the information disclosed to passengers on their reimbursement process. These costs are 
estimated in total at EUR 69,563 in 2025 for the 149 air carriers affected, or EUR 467 per air 
carrier. 

Expressed as present value over 2025-2050, total one-off and recurrent administrative costs for air 
carriers are estimated at EUR 1.6 billion in PO 3.1, at EUR 0.07 million in PO 3.2 and EUR 323.5 
million in PO 3.3. 

6.1.1.2  Adjustment costs for carriers 

Options related to enforcement (problem area 1). Under both PO 1.1 and PO 1.2, carriers are 
expected  to  incur  one-off  adjustment  costs  to  establish  service  quality  standards  and  to 
implement  the  quality  management  system  (PM  A.2)131,  amounting  in  total  at  EUR  10.2 
million in 2025 (see Table 6). Of these, approximately EUR 8.8 million are costs for the bus 
and coach sector, EUR 1.2 million for the waterborne sector and EUR 174 thousand for all air 
carriers. Per carrier, they are estimated at EUR 2,334 on average for the bus and coach and 
waterborne transport operators and at EUR 1,167 for air carriers.     

Additionally, adapting carriers’ complaint handling systems to be able to handle standardised 
reimbursement and compensation claims (PM A.4) is estimated to lead to one-off adjustment 
costs of EUR 519 thousand in PO 1.1 and PO 1.2, assuming half a working day per carrier to 
adjust their information systems. Costs for rail carriers are not considered as they are already 
subject to this obligation under the baseline. Of these, approximately EUR 441 thousand are 
costs for bus and coach operators, EUR 61 thousand for waterborne transport operators and 
EUR 17 thousand for air carriers. Per carrier, the one-off adjustment costs are estimated at EUR 
117 in 2025. 

Moreover, PO 1.2 also requires carriers to adapt their communication systems to improve the 
provision of information to passengers about their rights especially when booking the ticket and 
when  a  disruption  occurs  (PM  A.6)  which  is  estimated  to  lead  to  EUR  5.3  million  one-off 
adjustment costs, relative to the baseline132. Of these costs, approximately EUR 4.4 million are 

129 Per air carrier, they are estimated at around EUR 619 thousand on average per year for 2025-2050. 
130 Per air carrier, they are estimated at around EUR 124 thousand on average per year for 2025-2050.  
131 Air carriers already publish reports and comply with normative standards that could be used to comply with 
this measure, hence 5 additional working days are estimated to be needed for air carriers, while 10 working days 
are estimated to be needed for bus and coach, and waterborne carriers. 
132 This is based on the assumption that rail carriers need one additional working day (per carrier) and air carriers, 
bus and coach and waterborne carriers 5 additional working days to adapt their communication systems. The effort 
for the rail carriers is expected to be lower due to the provisions included in Articles 30 and 33(1) of Regulation 
(EU) 2021/782. Thus, a large part of the costs related to this measure for rail carriers are part of the baseline.  

36 

 
 
 
incurred by bus and  coach operators, EUR 610 thousand by  waterborne transport operators, 
EUR 66 thousand by rail operators and EUR 174 thousand by air carriers. 

Overall, PO 1.1 is expected to lead to one-off adjustment costs estimated at EUR 10.7 million 
and PO 1.2 at EUR 16 million in 2025 (see Table 6). The higher costs in PO 1.2 are explained 
by PM A.6, which is only included in this option.    

Options  related  to  multimodal  passenger  rights  (problem  area  2).  Under  PO  2.1,  carriers 
would be required to provide guidance to passengers on minimum connecting times and other 
useful information when switching between modes of transport (PM B.1); would have to ensure 
a basic set of rights for passengers holding a single contract of carriage (category A) (PM B.3a); 
and would have to establish an online and offline complaint-handling mechanism (PM B.7). 
The  total  adjustment  costs  for  PO  2.1  are  estimated  at  EUR  20.6  million  for  all  carriers, 
expressed as present value over 2025-2050.  

PO 2.2 leads to higher adjustment costs, estimated at EUR 35.2 million expressed as present 
value over 2025-2050 for all carriers, generated by the requirement that carriers provide real-
time  information  to  passengers  (PM  B.2)133  and  by  an  essential  set  of  rights  for  passengers 
having bought separate tickets from a ticket vendor/tour operator for a multimodal journey (PM 
B4.a).  Finally, PO 2.3 leads to the highest adjustment costs for all carriers, estimated at EUR 
38.9 million expressed as present value over 2025-2050, which is justified by the fact that it 
enhances the package of  rights to both ticket categories A and B passengers (PM B.3b and PM 
B4.4b).  

Out of the total adjustment costs presented above, one-off costs for all carriers represent EUR 
0.12 million in PO 2.1, and around EUR 14.7 million in PO 2.2 and PO 2.3. 

Options  related  to  intermediaries  (problem  area  3).  No  adjustment  costs  for  carriers  are 
expected due to PO 3.1, PO 3.2 and PO 3.3.  

Table 6: Recurrent and one-off costs for carriers for policy options under problem area 1, expressed as present 
value over 2025-2050 relative to the baseline, in million EUR (2021 prices) 

Administrative costs   
PM A.2 
Adjustment costs   
PM A.2 
PM A.4 
PM A.6 
Total costs 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

Difference to the Baseline 

PO 1.1 

PO 1.2 

93.07 
93.07 
10.73 
10.21 
0.52 

103.80 

93.07 
93.07 
15.99 
10.21 
0.52 
5.26 
109.06 

Table 7: Recurrent and one-off costs for carriers for policy options under problem area 2, expressed as present 
value over 2025-2050 relative to the baseline, in million EUR (2021 prices) 

Administrative costs  
PM B.2 

Difference to the Baseline 

PO 2.1 

PO 2.2 

PO 2.3 

0.00 

0.12 
0.12 

0.12 
0.12 

133  The  one-off  adjustment  costs  due  to  PM  B.2  serve  a  broader  scope  than  pure  information  reporting.  By 
implementing real-time information provisions and integrating communication systems to multimodal passengers, 
their aim is to enable better services for multimodal passengers in case of disruptions and delays. For this reason, 
the one-off costs have been classified as adjustment costs rather than administrative costs. 

37 

 
 
 
  
 
  
 
Adjustment costs  
PM B.1 
PM B.2 
PM B.3a 
PM B.3b 
PM B.4a 
PM B.4b 
PM B.7 
Total costs 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

Difference to the Baseline 

PO 2.1 

PO 2.2 

PO 2.3 

20.60 
0.12 

20.10 

0.39 
20.60 

35.22 
0.12 
14.50 
20.10 

0.12 

0.39 
35.34 

38.95 
0.12 
14.50 

23.83 

0.12 
0.39 
39.07 

Table 8: Recurrent and one-off costs for carriers for policy options under problem area 3, expressed as present 
value over 2025-2050 relative to the baseline, in million EUR (2021 prices) 

Difference to the Baseline 
PO 3.2 

PO 3.1 

PO 3.3 

Administrative costs  
PM C.1a 
PM C.1b 
PM C.1c 
Total costs 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

1,617.22 
1,617.22 

0.07 

323.50 

0.07 

1,617.22 

0.07 

323.50 
323.50 

6.1.1.3  Benefits for carriers 

Options related to enforcement (problem area 1). PO 1.1 and PO 1.2 offer indirect benefits 
for carriers. More specifically, PM A.1 will allow NEBs to deal with non-compliance faster as 
they can request documents needed within clear deadlines from all involved, which will lead to 
quicker and more efficient procedures for the NEBs which will also help carriers. PM A.2 will 
lead to increased transparency about the compliance of all operators. As carriers will be obliged 
to publish reports134 on their service quality performance, including customer satisfaction and 
compliance with passenger rights, passengers will have an increased insight into the different 
carrier’s  performance,  and  be  able  to  use  this  information  to  decide  which  carrier  to  use.  
Compliant operators can benefit from this transparency and may gain a competitive advantage 
thanks to their good reputation, as passengers will be more likely to choose a well performing 
carrier over a carrier which shows lower customer satisfaction and compliance rates.  If carriers 
will use the common form for reimbursement and compensation requests foreseen in PM A.3 
as a model to design their IT systems for handling such requests, carriers will then have the 
necessary information  faster and the cooperation  with  the NEBs and ADR bodies regarding 
such requests will also have the potential to become more efficient. If NEBs inform passengers 
regularly about  ADR as required in PM A.6, this may save carriers litigation costs, because 
ADR  procedures  tend  to  be  much  less  expensive,  not  only  for  passengers,  but  also  for 
operators135. 

The benefits for carriers in PO 1.2 are expected to be higher than in PO 1.1. PM A.4 would 
allow a level playing field for operators because their compliance costs would be more similar: 
currently compliance cost depend on a great extent whether the NENs supervising the carrier 

134 This new reporting obligation will be introduced in case of modes (air, bus and coach and waterborne) where 
such obligation does not exist yet. In case of rail transport, the obligation is already in place. Therefore this policy 
measure will not apply to rail transport and the reporting obligation of rail operators will not be duplicated.  
135 See impact assessment for the review of the ADR Directive SWD (2023) 335. 

38 

 
 
 
  
  
  
  
  
  
  
  
 
  
  
 
 
  
  
 
in question are more passive or lenient or active and very stringent. Published risk assessments, 
which NEBs will base their monitoring on, will allow carriers to know what parameters they 
are judged upon and this will enable them to more effectively comply and thus prevent having 
to allocate resources to the additional monitoring by NEBs. Additionally, PM A.5 will enable 
passengers to submit more well-informed claims, as they become more knowledgeable on the 
rights. This will add to the efficiency of the carriers’ internal claims handling procedures, as 
passengers are more likely to provide all the necessary information with the initial claim, which 
will reduce the time carriers spend on the claim. Additionally, more well-informed passengers 
are less likely to make unjustified claims due to uncertainty of their rights, which will again 
reduce time spend by carriers on claims.   

Options related to multimodal passenger rights (problem area 2). PO 2.2 and PO 2.3 offer 
indirect benefits to carriers. The proposed measures specifically target category B tickets (PMs 
B.4a  and  B.4b)  and  put  the  onus  for  information  to  passengers  and  liability  in  the  event  of 
missed connections during a multimodal journey on ticket vendors and tour operators.  

In addition, all policy options (PO 2.1, PO 2.2 and PO 2.3) are expected to result in hassle costs 
savings for multimodal transport operators due to less time spent for handling complaints (PM 
B.7).  Under  a  conservative  approach,  the  hassle  costs  savings  for  multimodal  transport 
operators are estimated at EUR 35.3 million expressed as present value over 2025-2050 relative 
to the baseline136. 

Options  related  to  intermediaries  (problem  area  3).  PO  3.2  offers  the  substantial  indirect 
benefit to carriers that they will be able to (continue to) invest in the reimbursement procedure 
for  indirect  bookings  that  best  suits  their  business  model  –  even  on  the  level  of  particular 
intermediaries, if they want to. If they choose the intermediary procedure, they will be able to 
refuse to process direct requests by passengers and benefit from the easier and cheaper ‘reversal 
of  the  payment  flow’,  as  long  as  they  pay  the  intermediary  within  the  deadline  (and  the 
intermediary also respects its payment deadline). If they choose the carrier-only procedure, they 
will  be  able  to  refuse  to  cooperate  with  intermediaries  for  the  reimbursement,  which  is 
particularly relevant for airlines which do not authorise or do not prefer using intermediaries 
(and intermediaries purchase their tickets nevertheless, on behalf of the passenger). PO 3.3 does 
not offer this benefit of the carrier’s choice of procedure, as the passenger can choose. PO 3.1 
is  only  of  benefit  to  the  (minority  of)  air  carriers  which  currently  choose  to  carry  out  the 
reimbursement procedure fully on their own. PO 3.2 is also very well suited for a carrier with 
an  exclusive  direct  distribution  model,  which  can  decide  not  to  involve  intermediaries. 
Intermediaries whom the carrier did not authorise to carry out the reimbursement will no longer 
be  able  to  include  the  reimbursement  in  their  business  model  and  circumvent  the  carriers’ 
prohibition  or  dislike  of  involving  them.  Both  carrier  and  intermediary  will  need  to  clearly 
communicate  the  carrier’s  decision  through  the  information  obligation.  PO  3.2  and  PO  3.3 
contain  rules  that  facilitate  the  B2B  relationship  of  airlines  with  intermediaries  for  the 
processing of reimbursements. 

136 Drawing on a study by the World Bank (Source:  
https://thedocs.worldbank.org/en/doc/3ecf7262788a3ec69c8a45bbd3342a28-0080022021/related/Spring2021-
governance-talk-asli-0525.pdf), each complaint handling would benefit of 15 minutes saved under a conservative 
approach (lower bound) and up to 60 minutes saved (upper bound).  In order to calculate the hassle costs 
savings, an hourly worker’s wage corresponding to ISCO 3 (Technicians and associate professionals) is assumed 
and an even repartition of complaints between transport operators and intermediary ticket vendors, in lack of 
detailed information. Under a conservative approach (lower bound estimates), the hassle costs savings for 
multimodal transport operators are estimated at EUR 35.3 million expressed as present value over 2025-2050. 
For the upper bound, they are estimated at EUR 141.3 million. More details on the estimates are provided in 
Annex 4 (section 3.2). 

39 

 
 
 
6.1.2 

Impacts on terminal operators 

6.1.2.1  Administrative costs for terminal operators 

Options related to enforcement (problem area 1). As regards PO 1.1 and PO 1.2, PM A.2 will 
require  terminal  operators  to  report  at  the  request  of  NEBs  about  the  results  of  the 
implementation  of  their  quality  standards.  This  will  add  administrative  costs  for  terminal 
operators. Based on the assumption that this would require 5 additional working days per year 
for each of the 546 terminal operators, the recurrent administrative costs per year are estimated 
at EUR 127 thousand, or EUR 2.3 million expressed as present value over 2025-2050 (see 
Table 9). Per terminal operator, they are estimated at EUR 233 per year. 

Options related to multimodal passenger rights (problem area 2) and intermediaries (problem 
area 3). None of the policy options related to multimodal passenger rights (PO 2.1, PO 2.2 and 
PO  2.3)  or  intermediaries  (PO  3.1,  PO  3.2  and  PO  3.3)  are  expected  to  lead  to  additional 
administrative costs for terminal operators. 

6.1.2.2  Adjustment costs for terminal operators 

Options  related  to  enforcement  (problem  area  1).  Under  both  PO  1.1  and  PO  1.2,  the 
establishment  of  service  quality  standards  and  the  implementation  of  a  quality  management 
system (PM A.2), is expected to lead to one-off adjustment costs for terminal operators of EUR 
1.3  million137.  In  addition,  PO  1.2  leads  to  one-off  adjustment  costs  for  adapting  terminal 
operators’  communication  systems  to  better  inform  passengers  about  their  rights,  especially 
when booking a ticket or when a transport disruption occurs (PM A.5), estimated at EUR 637 
thousand138. In total,  PO  1.1 is  estimated to  result in  one-off adjustment  costs of  EUR 1.3 
million for terminal operators relative to the baseline, and PO 1.2 at costs of EUR 1.9 million. 
The higher costs in PO 1.2 are explained by PM A.5, which is only included in this option (see 
Table 9).    

Options related to multimodal passenger rights (problem area 2). Under all options (PO 2.1, 
PO  2.2  and  PO  2.3)  terminal  operators  acting  as  multimodal  hub  managers  are  required  to 
provide  guidance  to  passengers  on  minimum  connecting  times  and  other useful  information 
when switching between modes of transport (PM B.1), and to establish an online and offline 
complaint-handling  mechanism  (PM  B.7).  The  one-off  adjustment  costs  due  to  PM  B.1  are 
estimated at EUR 0.2 million in 2025 and the recurrent adjustment costs due to PM B.7 at EUR 
49,488 per year (EUR 0.9 million expressed as present value over 2025-2050) relative to the 
baseline (see Table 10). 

In addition, PM B.5, that is only included in PO 2.2 and PO 2.3, requires the establishment of 
Single Points of Contact (SPC) for PRM at multimodal hubs, which leads to significantly higher 
adjustment costs (both one-off and recurrent) under these two options. The one-off adjustment 
costs are estimated at EUR 4.2 million, while the recurrent adjustment costs at EUR 21.2 million 
in 2025, and around EUR 17 million in 2030 and 2050. Expressed as present value over 2025-
2050, total adjustment costs due to PM B.5 are estimated at EUR 316.5 million relative to the 
baseline. The costs are associated to additional personnel needed to implement the SPC devoted 
to arranging the assistance of passengers with disabilities or reduced mobility (PRMs), and the 
establishment  of  a  central  point  which  connects  the  already  existing  request  procedures  for 
passenger  assistance  in  each  mode.  There  would  be  no  additional  costs  under  this  measure 
related  to  the  actual  provision  of  assistance  to  PRM,  as  the  SPC  would  act  as  a  central 

137 This is based on the assumption that 10 working days would be required to implement the system. 
138 This is based on the assumption that 5 additional working days would be needed to update and implement the 
communication systems. 

40 

 
 
 
communication point between PRMs requesting assistance, on the one hand, and the existing 
PRM assistance mechanisms of terminal operator(s) and carriers, on the other hand. 

These SPCs are assumed to be operated by one main terminal manager (airport, station, port or 
bus terminal manager) operating at a multimodal passenger hub, who would have to cooperate 
with other carriers and other terminal managers (if several of the latter are active at a given 
hub). It is assumed that all costs are borne by the main terminal manager, and that the amount 
of the costs would not vary depending on the nature of the terminal manager (i.e. regardless, of 
whether they are an airport, station,  port or bus terminal  manager).  Individual  arrangements 
might be put in place for specific Single Points of Contacts where carriers might also take up 
part of the costs, but this would depend on a case-by-case basis. For this reason, it is not possible 
to  estimate  the  costs  for  carriers.  In  addition,  it  should  be  noted  that  none  of  the  terminal 
operators at multimodal hubs fall in the category of SMEs. Thus, none of the adjustment costs 
due to PM B.5 are borne by SMEs.  

Thus, the total adjustment costs for all terminal operators, expressed as present value over 2025-
2050, are estimated at EUR 1.1 million for PO 2.1 and EUR 317.6 million for PO 2.2 and PO 
2.3 (see Table 10). 

Options  related  to  intermediaries  (problem  area  3).  No  impacts  are  expected  for  terminal 
operators for the policy options addressing problem area 3. 

Table 9: Recurrent and one-off costs for terminal operators for policy options under problem area 1, expressed 
as present value over 2025-2050 relative to the baseline, in million EUR (2021 prices) 

Administrative costs   
PM A.2 
Adjustment costs   
PM A.2 
PM A.5 
Total costs 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

Difference to the Baseline 

PO 1.1 

PO 1.2 

2.35 
2.35 
1.27 
1.27 

3.62 

2.35 
2.35 
1.91 
1.27 
0.64 
4.26 

Table 10: Recurrent and one-off costs for terminal operators for policy options under problem area 2, expressed 
as present value over 2025-2050 relative to the baseline, in million EUR (2021 prices) 

Difference to the Baseline 
PO2.2 

PO2.3 

PO2.1 

Adjustment costs  
PM B1 
PM B5 
PM B7 
Total costs 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

1.11 
0.20 

0.91 
1.11 

317.64 
0.20 
316.53 
0.91 
317.64 

317.64 
0.20 
316.53 
0.91 
317.64 

6.1.2.3  Benefits for terminal operators 

Options related to enforcement (problem area 1). PO 1.1 and PO 1.2 offer indirect benefits 
for terminal operators, similar to those described for carriers. The benefits for terminal operators 
are expected to be higher in PO 1.2 relative to PO 1.1, due to PM A.5 which is only included 
in PO 1.2. 

Option related to enforcement (problem area 2). In addition, PO 2.2 and PO 2.3 are expected 
to result in indirect benefits for terminal operators operating at multimodal passenger hubs. In 

41 

 
 
 
  
 
  
particular,  the  establishment  of  Single  Points  of  Contact  (PM  B.5)  would  lead  to  improved 
communication channels,  not  only  with other carriers but  also  with  other terminal  operators 
where several of them are operating at the same hub.  

6.1.3 

Impacts on intermediaries 

6.1.3.1  Administrative costs for intermediaries 

There  are  no  impacts  on  administrative  costs  expected  for  intermediaries  for  policy  options 
addressing problem area 1. 

Options related to multimodal passenger rights (problem area 2). Policy options PO2.2 and 
PO2.3 are expected to lead to small recurrent administrative costs for intermediaries due to PM 
B.2,  estimated  at  EUR  1,401  per  year  for  the  6  intermediaries  affected  (EUR  233  per 
intermediary). Expressed as present value over 2025-2050, they amount to EUR 25,789 relative 
to the baseline. 

Options  related  to  intermediaries  (problem  area  3).  Under  all  POs  3.1,  3.2,  and  3.3 
intermediaries  would  incur  one-off  administrative  costs  of  EUR  57.4  million  for  informing 
passengers about the reimbursement process (equivalent to two working days of a worker per 
intermediary). Those intermediaries that currently take longer than 7 days to reimburse to their 
customers might have to invest in processes to expedite this. Under the CPC action against three 
major online intermediaries, these three agreed to transfer refunds received from airlines within 
seven  days,  which  supposes  that  this  measure  will  not  be  too  difficult  for  intermediaries  to 
meet139.  In addition, the new PM C4 will facilitate the task of intermediaries, as it expected 
that carriers will have to link each reimbursement payment to the original booking number, and 
transfer  the  amount  to  the  intermediary  in  one  single  transaction  to  the  original  method  of 
payment (something which was, according to intermediaries, often missing in the past and made 
their work more difficult).  

Under PO 3.2, a carrier with an exclusive direct distribution model can decide not to involve 
intermediaries  for  the  reimbursement.  Intermediaries  which  so  far,  despite  the  carrier’s 
prohibition, processed the reimbursement and offered this as part of their business model, will 
no longer be able to do so. However, we consider that in this case, the intermediary will recover 
this loss through a minor increase of another fee charged to the passenger, and that this will not 
impact the intermediary’s business model. 

6.1.3.2  Administrative cost savings for intermediaries 

No administrative costs savings are expected for intermediaries for policy options addressing 
problem area 1 and 2. 

Options related to intermediaries (problem area 3). Under PO 3.1, intermediaries would save 
administrative costs of EUR 37.8 million in 2025, EUR 41.3 million in 2030 and 53.3 million 
in 2050, because they would no longer be handling passengers’ reimbursement requests. Under 
PO 3.3, assuming that intermediaries would no longer process 20% of reimbursement requests 
which they would have handled under the baseline, cost savings for intermediaries are estimated 
at  EUR  7.6  million  in  2025,  EUR  8.3  million  in  2030  and  EUR  10.7  million  in  2050140. 

The 

press 

release 

139 
on 
https://ec.europa.eu/commission/presscorner/detail/en/ip_23_3521. 
140 However, intermediaries may incur indirect costs as a result of no longer being able to offer the processing of 
reimbursements to their customers (and to airlines, as part of their agreements with them) as part of their service 
package. It may also damage to a certain extent their business model of maintaining an exclusive relationship 

action  was 

this  CPC 

published 

June 

27 

on 

2023: 

42 

 
 
 
Intermediaries may lose the revenues they may have through handling fees for reimbursement 
requests. However, given that these fees are likely to represent a small increase in the average 
ticket fare in percentage terms, this is unlikely to have a considerable negative effect on the 
business model of intermediary ticket vendors141. Expressed as present value over 2025-2050, 
administrative cost savings under PO 3.1 amount to EUR 828.5 million and under PO 3.3 to 
EUR 165.7 million. 

6.1.3.3  Adjustment costs for intermediaries 

Options related to enforcement (problem area 1). Under both PO 1.1 and PO 1.2 (see Table 
11),  intermediaries  incur  one-off  adjustment  costs  of  EUR  14.4  million  associated  to  the 
obligation  to  accept  standardised  claim  forms  for  reimbursement  and  compensation  and  the 
need to adjust their information systems (PM A.3)142.  

Options  related  to  multimodal  passenger  rights  (problem  area  2).  Adjustment  costs  for 
intermediaries  relative  to  the  baseline  are  driven  by:  (i)  two  measures  common  to  all  three 
policy  options  (i.e.  PM  B.1  requiring  intermediaries  to  provide  guidance  to  passengers  on 
minimum  connecting times and other useful information when switching between modes of 
transport, and PM B.7 requiring intermediaries to establish an online and offline complaint-
handling  mechanism);  (ii)  a  policy  measure  common  to  PO  2.2  and  PO  2.3  which  obliges 
intermediaries to put in place a system for providing real-time information to passengers (PM 
B.2); (iii) a policy measure common to PO 2.1 and PO 2.2 (PM B.3a) concerning a set of rights 
that apply to single contracts of carriage (category A), and which is included in an enhanced 
version (i.e. PM B.3b gives passengers having such contract a  “right to self re-routing”) in PO 
2.3; and (iv) a policy measure included in PO 2.2 ensuring information to passengers holding 
separate  tickets  for  a  multimodal  journey  acquired  from  an  intermediary,  failing  which 
intermediaries have to ensure essential rights towards the passenger (category B) (PM B.4a), 
which is included in PO 3.2 in its enhanced version (PM B.4b). Expressed as present value over 
2025-2050, intermediary ticket vendors are expected to incur total adjustment costs of EUR 0.4 
million in PO 2.1, EUR 3.4 million in PO 2.2 and EUR 3.6 million in PO 2.3 (see Table 12). 
Out of these, EUR 0.1 million in PO 2.1, EUR 3.2 million in PO 2.2 and EUR 3.3 million in 
PO 2.3 are one-off costs. 

No adjustment costs are expected for intermediaries for policy options addressing problem area 
3. 

Table 11: Recurrent and one-off costs for intermediaries for policy options under problem area 1, expressed as 
present value over 2025-2050 relative to the baseline, in million EUR (2021 prices) 

Adjustment costs   
PM A.3 
Total costs 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

Difference to the Baseline 

PO 1.1 

PO 1.2 

14.36 
14.36 
14.36 

14.36 
14.36 
14.36 

Table 12: Recurrent and one-off costs for intermediaries for policy options under problem area 2, expressed as 
present value over 2025-2050 relative to the baseline, in million EUR (2021 prices) 

with their customers. No data on this is available, but during the stakeholder consultation, intermediaries and 
their associations have pointed out that they want to continue processing the reimbursements of their customers. 
141 PM C4 will facilitate the reimbursement processing of intermediaries by obliging the carriers to add the relevant 
data to each booking, and to transfer the money in one transaction to the original payment method. According to 
intermediaries’  feedback,  this  is  often  missing  today,  which  makes  their  task  much  more  difficult.  Also,  if 
intermediaries do not want to forego any reimbursement fee, they can decide to not carry out the reimbursement. 
142 This implementation cost per intermediary is estimated at EUR 117. An additional half a working day would 
be needed for each of the 123,000 intermediaries to implement these changes. 

43 

 
 
 
 
Difference to the Baseline 
PO2.2 

PO2.1 

PO2.3 

Administrative costs  
PM B.2 
Adjustment costs 
PM B.1 
PM B.2 
PM B.3a 
PM B.3b 
PM B.4a 
PM B.4b 
PM B.7 
Total costs 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

0.00 

0.38 
0.06 

0.06 

0.26 
0.38 

0.03 
0.03 
3.44 
0.06 
3.00 
0.06 

0.06 

0.26 
3.46 

0.03 
0.03 
3.55 
0.06 
3.00 

0.11 

0.11 
0.26 
3.58 

Table 13: Recurrent and one-off costs for intermediaries for policy options under problem area 3, expressed as 
present value over 2025-2050 relative to the baseline, in million EUR (2021 prices) 

Difference to the Baseline 
PO3.2 

PO3.1 

PO3.3 

Administrative costs  
PM C.1a 
PM C.1b 
PM C.1c 
Administrative costs savings 
PM C.1a 
165.69 
PM C.1c 
108.27 
Net costs savings 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: negative values represent net costs. 

828.47 
828.47    

57.42 
57.42    

57.42 
165.69 

57.42    

771.04 

-57.42 

57.42 

57.42 

0.00 

6.1.3.4  Benefits for intermediaries 

Options related to enforcement (problem area 1). PO 1.1 and PO 1.2 offer indirect benefits 
for intermediaries, similar to those for carriers, and terminal operators. PM A.1 will help NEBs 
to  deal  with  non-compliance  faster  when  they  can  request  documents  needed  within  clear 
deadlines from all involved. This leads to quicker and more efficient procedures of information 
sharing between NEBs and intermediaries, which in turn will require less resources from the 
intermediary. Having deadlines aligned across Member State NEBs, will also make the process 
easier  for  the  intermediary,  as  the  process  does  not  differ  from  NEB  to  NEB.  With  the 
introduction of an EU-wide standardised form for reimbursement and compensation requests 
due to PM A.4, intermediaries can – while not being obliged to – use this form as a model to 
design their IT systems for handling such requests. Intermediaries will then have the necessary 
information  for  claim  handling  faster  and  the  cooperation  with  the  NEBs  and  ADR  bodies 
regarding such requests will also have the potential to become more efficient and require less 
resources for the intermediary.  

The benefits are expected to be higher in PO 1.2 relative to PO 1.1, because PM A.4 further 
expands  the  competitive  advantage  of  well  performing  intermediaries.  Published  risk 
assessments, which NEBs will base their monitoring on, will ensure that intermediaries know 
what  parameters  they  are  judged  on,  which  will  enable  intermediaries  to  more  effectively 
comply and thus prevent having to allocate resources to additional monitoring by NEBs.  

Options related to multimodal passenger rights (problem area 2). All policy options (PO 2.1, 
PO 2.2 and PO 2.3) are expected to result in hassle costs savings for intermediaries due to less 

44 

 
 
 
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
time spent for handling complaints (PM B.7). Under a conservative approach, the hassle costs 
savings for intermediaries are estimated at  EUR 24 million expressed as  present value over 
2025-2050  relative  to  the  baseline143.  PO  2.2  and  2.3  offer  additional  indirect  benefits  to 
intermediaries  (ticket  vendors/tour  operators).  The  policy  measures  targeted  to  Category  B-
tickets (PM B.4a and B.4b) provide for a possible exemption to liability towards the passenger 
in the event of a missed connection during a multimodal journey. This is conditional on the 
provision of information to passengers that the tickets bought from the intermediary constitute 
separate transport contracts. 

Options related to intermediaries (problem area 3). PO 3.2 and 3.3 offer indirect benefits for 
intermediaries (under the procedure that includes the intermediary). If the carrier, under PO 3.2, 
or  the  citizen,  under  PO  3.3,  so  decides,  the  intermediary  receives  an  official  role  in  the 
reimbursement process, and rules on ‘who pays whom first’, and what happens when this is not 
adhered to. This facilitates the B2B relationship between airline and intermediary. If the carrier 
does not pay the intermediary in time, the intermediary can send the passenger to the carrier, 
and its role in the reimbursement procedure ends. If intermediaries voluntarily reimburse to the 
passenger without having received the payment from the carrier first, they have an implicit right 
of redress towards the carrier, due to the obligatory transaction from the carrier to them within 
7  days.  PO  3.1  is  beneficial  for  those  intermediaries  who  do  not  want  to  deal  with 
reimbursements. Under PO 3.2 and 3.3, intermediaries can also refuse to process reimbursement 
requests, but will then have to pass on certain data to the passenger, at booking, which may not 
be in the intermediary’s interest. 

6.1.4 

Impacts on national public authorities 

6.1.4.1  Administrative costs for national public authorities  

Options  related  to  enforcement  (problem  area  1).  PO  1.2  is  expected  to  lead  to  recurrent 
administrative costs for national public authorities, for designing and regularly updating their 
risk  assessment  (PM  A.4).  Under  a  conservative  approach,  10  working  days  per  year  per 
national public authority are expected to be needed, resulting in administrative costs estimated 
at  EUR  1.4  million  (see  Table  14),  expressed  as  present  value  over  2025-2050  (EUR  76 
thousand per year). No administrative costs are expected for PO 1.1. 

There are no impacts on administrative costs expected for national public authorities for policy 
options addressing problem area 2 and 3.  

6.1.4.2  Adjustment costs for national public authorities  

Options related to enforcement (problem area 1).  In both PO 1.1 and PO 1.2 NEBs would 
have to inform passengers about their option to use ADR bodies to seek individual redress as 
well as refer them to the ADR (PM A.6). This is expected to be achieved by adding information 
on  the  ADR  process  and  a  reference  to  the  EU  ADR  Database  on  their  website.  The  effort 

143 Drawing on a study by the World Bank (Source:  
https://thedocs.worldbank.org/en/doc/3ecf7262788a3ec69c8a45bbd3342a28-0080022021/related/Spring2021-
governance-talk-asli-0525.pdf), each complaint handling would benefit of 15 minutes saved under a conservative 
approach (lower bound) and up to 60 minutes saved (upper bound).  In order to calculate the hassle costs 
savings, an hourly worker’s wage corresponding to ISCO 3 (Technicians and associate professionals) is assumed 
and an even repartition of complaints between transport operators and intermediary ticket vendors, in lack of 
detailed information. Under a conservative approach (lower bound estimates), the hassle costs savings for 
intermediaries are estimated at EUR 24 million expressed as present value over 2025-2050. For the upper bound, 
they are estimated at EUR 96 million. More details on the estimates are provided in Annex 4 (section 3.2). 

45 

 
 
 
required has been estimated at half a working day on one-off basis per NEB, leading to one-off 
adjustment costs estimated at EUR 24,439 in 2025 relative to the baseline144. 

There are no impacts on adjustment costs expected for national public authorities for policy 
options addressing problem area 2 and 3. 

6.1.4.3  Enforcement costs for national public authorities 

Options related to enforcement (problem area 1). PO 1.1 and PO 1.2 are expected to lead to 
enforcement  costs  for  national  public  authorities.  The  recurrent  costs  for  monitoring  the 
implementation of the quality standards (PM A.2), which will consist in reviewing the reports 
of  carriers  and  the  information  provided  by  terminal  operators,  are  estimated  at  EUR  5.2 
million expressed as present value over 2025-2050 relative to the baseline (EUR 281 thousand 
per year).  Total enforcement costs in PO 1.1 and PO 1.2 are estimated at EUR 7.2 million 
over 2025-2050 relative to the baseline (EUR 392 thousand per year).   

Options  related  to  multimodal  passenger  rights  (problem  area  2).  Enforcement  costs  are 
estimated overall at EUR 19.4 million for PO 2.1, expressed as present value for 2025-2050 
relative to the baseline, to monitor stakeholders’ activities. The enforcement costs are higher in 
PO  2.2  and  PO  2.3,  estimated  at  EUR  23.3  million  relative  to  the  baseline  for  all  national 
authorities.  The  additional  costs  relate  to  PM  B.2  to  monitor  the  real-time  information  to 
passengers  on  disruption,  and  PM  B.5  to  monitor  the  establishment  of  “Single  Points  of 
Contact” (SPC) for PRM (see Table 15). 

Options related to intermediaries (problem area 3). The enforcement costs for national public 
authorities of options PO 3.1, PO 3.2 and PO 3.3 are part of the enforcement costs of PM A.5 
(enforcement area). 

6.1.4.4  Enforcement costs savings for national public authorities 

Options related to enforcement (problem area 1). Some of the policy measures would ensure 
that NEBs could use their limited resources more efficiently for the enforcement of passenger 
rights. For PO 1.1 and PO 1.2, the implementation of quality standards (PM A.2) is estimated 
to result in recurrent enforcement costs savings of EUR 1.5 million, expressed as present value 
over 2025-2050 (EUR 82 thousand per year), by reducing the need to use other, more expensive 
monitoring tools (e.g. inspecting or auditing a larger number of stakeholders). Additionally, the 
adoption and use of standardised reimbursement and complaint forms (PM A.3) is estimated to 
result in 5% time savings of one full time equivalent per NEB, as it will help NEBs to more 
easily  monitor  compliance  with  reimbursement  and  complaint  handling  obligations  by  the 
industry. The costs savings due to PM A.3 are estimated at EUR 1.5 million over 2025-2050 
(EUR  82  thousand  per  year).  In  addition,  raising  the  awareness  of  passengers  about  the 
possibility of submitting reimbursement and compensation claims to an ADR body (PM A.6) 
is expected to save costs for courts, due to the expected decrease in the number of litigations 
cases. The costs savings due to PM A.6 relative to the baseline, are projected at EUR 2.9 million 
expressed as present value over 2025-2050 (EUR 155 thousand per year). 

There are no impacts on enforcement costs savings expected for national public authorities for 
policy options addressing problem area 2 and 3. 

Table 14: Recurrent and one-off costs and costs savings for national public authorities for policy options under 
problem area 1, expressed as present value over 2025-2050 relative to the baseline, in million EUR (2021 prices) 

144 For estimating the costs due to PM A.6, 174 NEBs are considered (31 for air, 32 for air PRM, 41 for waterborne 
and 70 for buses and coaches) and an hourly worker’s wage corresponding to ISCO 2 (professionals). 

46 

 
 
 
Adjustment costs 
PM A.6 
Administrative costs   
PM A.4 
Enforcement costs  
PM A.2 

Enforcement costs savings  
PM A.2 
PM A.3 
PM A.6 
Net costs 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

Difference to the Baseline 

PO 1.1 

PO 1.2 

0.02 
0.02 
0.00 

7.21 
5.17 

5.86 
1.50 
1.50 
2.86 
1.38 

0.02 
0.02 
1.40 
1.40 
7.21 
5.17 

5.86 
1.50 
1.50 
2.86 
2.77 

Table 15: Recurrent and one-off costs for national public authorities for policy options under problem area 2, 
expressed as present value over 2025-2050 relative to the baseline, in million EUR (2021 prices) 

Difference to the Baseline 
PO2.2 

PO2.1 

PO2.3 

19.42 

Enforcement costs  
PM B2 
PM B3a 
9.94 
PM B3b 
1.99 
PM B5 
5.29 
PM B7 
4.19 
PM B8 
71.42 
Hassle costs savings 
71.42 
PM B8* 
48.08 
Net benefits 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for the lower bound estimate. 

1.99 
5.29 
4.19 
71.42 
71.42 
48.08 

5.29 
4.19 
71.42 
71.42 
51.99 

23.34 
1.93 
9.94    

23.34 
1.93 

9.94 

6.1.4.5  Hassle costs savings for national public authorities 

There are no hassle costs savings expected for  national  public authorities for policy options 
addressing problem area 1. 

Options related to multimodal passenger rights (problem area 2). In PO 2.1, PO 2.2 and PO 
2.3, NEBs would benefit of hassle costs savings for processing the complaints from passengers 
concerning multimodal journeys (due to PM B.8). Drawing on a study by the World Bank145, 
under a  conservative approach, the hassle costs  savings are  estimated at  EUR 71.4 million, 
expressed as present value over 2025-2050 relative to the baseline146. 

Options related to intermediaries (problem area 3). During the Commission’s regular meetings 
with NEBs, many NEBs raised the issue of an increase in complaints by passengers due to the 
unclear  situation  of  which  body  (carrier  or  intermediary)  would  process  reimbursement 

145 Source:  https://thedocs.worldbank.org/en/doc/3ecf7262788a3ec69c8a45bbd3342a28-
0080022021/related/Spring2021-governance-talk-asli-0525.pdf. 
146 Each complaint handling would benefit of 15 minutes saved under a conservative approach (lower bound) and 
up to 60 minutes saved (upper bound). In order to calculate the hassle costs savings, an hourly worker’s wage 
corresponding to ISCO 2 (professionals) has been used. The hassle costs savings for national public authorities, 
expressed as present value over 2025-2050, are estimated at EUR 71.4 million (lower bound) to 285.7 million 
(upper bound) relative to the baseline. 

47 

 
 
 
  
 
 
 
 
  
  
  
  
 
requests. Whilst this administrative burden on NEBs is impossible to calculate due to lack of 
data, the clarity which all options would provide on this matter would alleviate the burden on 
NEBs in this regard. 

6.1.5 

Impacts on consumers 

Options related to enforcement (problem area 1). Both PO 1.1 and PO 1.2 will have a positive 
impact  on  consumers.  The  standardised  reimbursement  and  compensation  claim  forms  (PM 
A.3)  will  make  it  easier  to  submit  effective  claims  to  carriers,  terminal  operators  and 
intermediaries, and will ease a later enforcement process, should the claim be escalated to a 
complaint. Passengers will benefit from reduced hassle costs because submitting claims using 
such forms will require much less time (i.e. the standardised form will be easy to fill in, it will 
be available in all EU official languages, it will allow the passenger to submit a complete file 
so that the transport operators will not need to go back and ask for additional documents or 
information  and  it  will  be  accessible  for  persons  with  disabilities).  Under  a  conservative 
approach, the total benefits for passengers due to PM A.3 are estimated at EUR 147 million, 
expressed as present value over 2025-2050 relative to the baseline147 (see Table 16). 

The implementation of service quality standards (PM A.2) will lead to benefits for consumers 
relative to the baseline, as they will be able to make better choices when purchasing tickets, 
based on more information about the respective carriers and terminal operators. The increased 
awareness among consumers about the option to seek reimbursement and compensation trough 
an ADR body (PM A.6) will likewise serve as a benefit for consumers. More passengers may 
seek individual redress compared to the baseline, and more passengers may also use an ADR 
body to resolve their claim, instead of resorting to the more costly option of a court case. The 
costs savings associated  to  PM A.6 are estimated at  EUR 1.6 million, expressed  as present 
value over 2025-2050 relative to the baseline (see Table 16). The ongoing review of the ADR 
Directive will further increase the attractiveness of ADR and allow consumers to benefit from 
it.  In  addition,  under  PO  1.2,  the  better  information  of  passengers  by  carriers  and  terminal 
operators about rights when booking a ticket or in case of a transport disruption (PM A.5) will 
further help citizens to learn and understand their rights as passengers, which ultimately is a 
precondition to exercise and enjoy them. Although no reliable quantitative estimate is possible, 
PM A.5 is expected to benefit 95.9 million passengers in 2025 (including passengers from air 
transport, long-distance bus and coach transport, waterborne transport and rail transport), 109 
million passengers in 2030 and approximately 134 million passengers in 2050. 

As NEBs will have to be more transparent about their monitoring of compliance under PM A.4, 
this would contribute to the level playing field of passenger protection throughout the Union, 
as it will provide incentives for harmonized and higher enforcement standards across Member 
States. 

Table  16:  Benefits  for  consumers  for  policy  options  under  problem  area  1,  expressed  as  present  value  over 
2025-2050 relative to the baseline, in million EUR (2021 prices) 

147 With a more accessible claim form, that is developed with the passenger’s needs in mind, it is estimated that a 
passenger that files a claim would spend 10 to 30 minutes less for finding and filing in the claim. To calculate the 
hassle costs savings due to PM A.3, the baseline projections on the number of passengers travelling by air and 
long-distance bus and coach are used as a starting point. For passengers travelling by air, the share of passengers 
requesting reimbursements is assumed to be 3%, while for passengers travelling by long-distance bus and coach it 
is assumed to be 1.7%. In addition, under a conservative assumption, 5% of passengers that submit a claim are 
estimated to use the standardised form for reimbursement. Considering the consumer value of time estimated at 
EUR 22.7 per hour in 2021 prices, and the time saved of 10 minutes (lower bound estimate) to 30 minutes (upper 
bound estimate), the hassle costs savings are estimated at EUR 147 million (EUR 120.6 million for air passengers 
and EUR 26.4 million for bus and coach passengers) to EUR 441.1 million (EUR 361.7 million for air passengers 
and EUR 79.3 million for bus and coach passengers), expressed as present value over 2025-2050 relative to the 
baseline. 

48 

 
 
 
Benefits for consumers 
PM A.3 
PM A.6 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

Difference to the Baseline 
PO 1.2 
PO 1.1 

148.67 
147.02 
1.65 

148.67 
147.02 
1.65 

The stakeholder consultation did not result in any evidence that measures related to enforcement 
would lead to an increase in the ticket prices. In addition, the experience of the past ten to twenty 
years, which was overall a period of traffic growth for all modes of transport, indicates that the 
costs  of  implementing  the  passenger  rights  Regulations  for  operators  have  been  low  and 
sustainable for both passengers and operators (from a few cents per maritime and bus and coach 
passenger  to  a  few  euros  per  air  passenger)148.  As  the  costs  associated  with  the  measures 
included in this impact assessment are lower than those associated to the implementation of the 
entire passenger rights framework, the additional cost per passenger will be lower than these 
amounts. For these reasons cost pass-through to passengers is estimated not to be significant – 
or  could  be  absorbed  largely  by  the  carriers.  For  example,  regarding  enforcement,  some 
potential for cost pass-through has been identified with regard to the policy measure on the EU 
standardised claims form and the policy measure on ADR information. However, the potential 
increase in ticket prices is limited to the year of implementation and the cost per passenger is 
estimated at EUR 0.001. As such, the potential of cost pass-through is not an issue considering 
the very limited additional costs per passenger. 

Options  related  to  multimodal  passenger  rights  (problem  area  2).  All  policy  options 
addressing problem area 2 (PO 2.1, PO 2.2 and PO 2.3) would entail benefits for passengers 
planning or undertaking a journey with two or more transport modes. 

In particular, the quality of a multimodal journey offered as a single contract (category A) would 
increase under PM B.3a (included in PO 2.1 and PO 2.2), where passengers having concluded 
those contracts would enjoy a level of protection comparable to passengers travelling with 
a single mode of transport (right to reimbursement/rerouting and care). Under PM B.3b 
(included in PO 2.3), there would be an additional right for passengers having a category A 
ticket, to conclude an alternative transport contract in the event of a missed connection. The 
latter measure implies that any reasonable cost borne by the passenger to re-route in the event 
of a missed connection, in the absence of an offer by the carrier, would have to be borne by the 
carrier.  

The right to reimbursement/re-routing for passengers performing a multimodal journey under 
a category A ticket implies that passengers would avoid costs associated to re-routing in the 
event of a missed connection. The costs savings for reimbursement/re-routing are estimated at 
EUR 13.2 million for PM B3.a (in PO 2.1 and PO 2.2), expressed as present value over 2025-
2050  relative  to  the  baseline,  while  for  PM  B.3b,  which  includes  the  right  to  conclude  an 
alternative transport contract, at  EUR 15.7 million (in PO 2.3). Regarding the right to care, 
passengers  may  incur  costs  savings  related  to  expenses  on  refreshments,  meals,  and 
accommodation in the event of a missed connection. The costs savings for care are estimated 
at EUR 6.8 million for PM B3.a (in PO 2.1 and PO 2.2), expressed as present value over 2025-
2050 relative to the baseline, and at EUR 8.1 million for PM B.3b (in PO 2.3). The total costs 

148 The 2021 evaluation on bus and coach and waterborne transport showed that the additional cost for the entire 
passenger rights protection framework for these modes amounted to approximately 0.05 EUR per passenger (0.40 
for bus and coach if only bus and coach journeys over 250 km are counted). For the air PRM Regulation, each air 
passenger bears 0.55 to their fare (meaning EUR 75 per PRM in 2018). For air passenger rights, these are around 
6% of operating costs items in 2018 for low-cost carriers and around  3% of operating costs items in 2018 for 
network carriers (EUR 4.4). See fact-finding air passenger rights study 2019-20; evaluations studies of 2020-21 
for bus, ship and air PRM passenger rights Regulations. 

49 

 
 
  
 
savings for reimbursement/re-routing and care are estimated at EUR 20.1 million for PM B3.a 
(in PO 2.1 and PO 2.2), expressed as present value over 2025-2050 relative to the baseline, 
while for PM B.3b at EUR 23.8 million (in PO 2.3). 

Passengers would also benefit of more transparent and comprehensive travel information in the 
context  of  multimodal  journeys.  Improved  pre-purchase  information  on  multimodal  travel, 
including on the level of protection associated to particular transport ticket(s) (PM B.1), will 
allow  passengers  to  make  better-informed  decisions  about  their  travel  options,  and  may 
influence their purchasing behaviour of multimodal solutions. Thus, passengers may use more 
multimodal travel, due to increased confidence and less time spent on journey travel research 
(such  as  on  connecting  times  between  transport  services  or  the  access  of  certain  transport 
infrastructure).  This  may  also  indirectly  result  into  less  financially  uncertain  choices  or 
decisions to use single mode transport options, when informed of the risks. Providing real-time 
information to passengers, thereby providing transparency on possible delays, cancellations as 
well as on next connections (PM B.2) may also have a positive impact on consumer trust. 

In this context, it should be noted that it is not likely that extra costs for the implementation of 
information rights will be passed on to customers in the form of higher prices for multimodal 
tickets. In particular with regard to the implementation of pre-journey information to passengers 
on minimum connecting times and other useful information in the context of multimodal travel 
(PM B.1), the analysis shows that providing such information comes at a minimal cost for the 
undertakings concerned. Regarding the provision of real-time information on travel disruptions 
and next connections (PM B.2), the costs for the undertakings concerned are mitigated to a large 
extent  by  two  factors.  First,  large  airlines  already  provide  some  sort  of  information  to 
passengers on disruptions, and railway undertakings are assumed to have already implemented 
the  necessary  systems  to  provide  real-time  information  to  passengers  in  line  with  the  new 
Regulation  on  rail  passenger  rights.  Second,  SMEs  are  exempted  from  delivering  real-time 
information,  implying  that  only  a  handful  of  carriers  in  the  bus  and  coach  sector  and  the 
waterborne sector, as well as only a few ticket vendors would be affected by this measure149. 

PRMs would also benefit of hassle costs savings in POs 2.2 and PO 2.3 thanks to the Single 
Points of Contact (PM B.5). Considering that PRMs make on average 2 phone calls to request 
assistance and that each of these calls takes on average 30 minutes, PRMs may save 30 to 60 
minutes to request assistance in their multimodal journeys where they would only have to make 
one  such  call  to  the  Single  Point  of  Contact.  Under  a  conservative  approach  (lower  bound 
estimate), assuming 30 minutes saved to request assistance, the potential hassle cost savings for 
PRMs are estimated at EUR 277.3 million, expressed as present value over 2025-2050 relative 
to the baseline150 (see Table 17). This should also support an increase in PRM confidence to 
travel,  based  on  improved  expectation  of  being  granted  adequate  assistance  on  multimodal 
travels while reducing the number of requests made by the PRM for a given journey. 

Hassle costs savings for PRMs are also expected due to PM B.3a (in PO 2.1 and PO 2.2) and 
PM B.3b (in PO 2.3). In particular, PRMs having a single contract of carriage may save 40 to 
60  minutes  per  multimodal  journey  when  arranging  assistance.  Thus,  under  a  conservative 
approach (lower bound estimate), the hassle costs savings for PRMs are estimated at EUR 18.6 

149 See section 6.1.1 and Annex 4. 
150 Considering the total number of PRMs requests for long-distance bus and coach journeys and for rail and 
waterborne journeys and the share of multimodal market, the number of PRM requests affected is estimated at 
737,044 in 2025, 950,122 in 2030 and 2,176,299 in 2050 relative to the baseline. The time saved per PRM 
request is estimated at 30 (lower bound) to 60 (upper bound) minutes. Using the consumer value of time 
estimated at EUR 22.7 per hour in 2021 prices, the hassle costs savings per PRM request are estimated at EUR 
11.4 (lower bound) to 22.7 (upper bound). Expressed as present value over 2025-2050, total hassle costs savings 
for all PRMs due to PM B.5 are estimated at EUR 277.3 million (lower bound) to 554.6 million (upper bound) 
relative to the baseline. More details are provided in Annex 4 (section 3.2). 

50 

 
 
 
million in PM B.3a and PM B.3b, expressed as present value over 2025-2050 relative to the 
baseline151 (see Table 17). 

Moreover, PM B.7 (complaint-handling by industry stakeholders) and PM B.8 (enforcement by 
NEBs) would increase trust in redress mechanisms, which are key to ensuring that consumers 
fully benefit from the legal protections available. At the same time, hassle costs for passengers 
would be reduced. Under a conservative approach (lower bound estimate), assuming 15 minutes 
saved per complaint, total hassle costs savings are estimated at EUR 43.3 million relative to 
the baseline, expressed as present value over 2025-2050152. 

Table  17:  Benefits  for  consumers  for  policy  options  under  problem  area  2,  expressed  as  present  value  over 
2025-2050 relative to the baseline, in million EUR (2021 prices) 

Difference to the Baseline 
PO 2.2 

PO 2.1 

PO 2.3 

Benefits for consumers  
PM B.3a 
PM B.3b 
Hassle costs savings 
PM B.3a 
PM B.3b 
PM B.5 
PM B.7 
Total benefits 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

20.09 
20.09 

61.86 
18.57 

43.29 
81.95 

20.09 
20.09    

339.14 
18.57    

277.28 
43.29 
359.23 

23.81 

23.81 
339.14 

18.57 
277.28 
43.29 
362.95 

Options related to intermediaries (problem area 3). In PO 3.1, requesting reimbursement from 
air carriers (due to PM C.1a) is expected to lead to additional hassle costs for consumers, given 
the additional information that will need to be provided before requesting their reimbursement 
in case of tickets bought via intermediaries. This is because airlines do not often have all the 
necessary information from passengers to be able to issue the reimbursement. The additional 
time spent per reimbursement request to air carriers, for providing the information requested by 
them, is estimated at 20 minutes (lower bound) to 40 minutes (upper bound)153. Assuming 20 
additional minutes per reimbursement request, the total hassle costs due to PM C.1a in PO 3.1 
are estimated at EUR 1,044.9 million, expressed as present value over 2025-2050 relative to 
the baseline154. In PO 3.2 (due to PM C.1b) the number of requests for reimbursement to carriers 

151  Considering  the  total  number  of  PRMs  requests  for  long-distance  bus  and  coach  journeys  and  for  rail  and 
waterborne journeys, the share of multimodal market and the fact that 5% of multimodal passengers hold category 
A multimodal tickets, the number of PRM requests affected is estimated at 37,020 in 2025, 47,723 in 2030 and 
109,312 in 2050 relative to the baseline. The time saved per PRM request is estimated at 40 (lower bound) to 60 
(upper bound) minutes. Using  the consumer value of time estimated at EUR 22.7 per hour in 2021 prices,  the 
hassle costs savings per PRM request are estimated at EUR 15.1 (lower bound) to 22.7 (upper bound).  Expressed 
as present value over 2025-2050, total hassle costs savings for all PRMs are estimated at EUR 18.6 million (lower 
bound) to 27.9 million (upper bound) relative to the baseline. 
152 Under a conservative approach it is assumed that passengers would save at least 15 minutes per complaint 
handling (lower bound), drawing a parallel with a study by the World Bank (Source: 
https://thedocs.worldbank.org/en/doc/3ecf7262788a3ec69c8a45bbd3342a28-0080022021/related/Spring2021-
governance-talk-asli-0525.pdf). At an upper bound, time savings per complaint may amount to 60 minutes. 
Using the consumer value of time estimated at EUR 22.7 per hour in 2021 prices, the hassle costs savings per 
complaint are estimated at EUR 5.7 (lower bound) to 22.7 (upper bound). Expressed as present value over 2025-
2050, total hassle costs savings for passengers due to PM B.7 are estimated at EUR 43.3 million (lower bound) 
to 173.2 million (upper bound) relative to the baseline. 
153 This excludes the cases when an automatic verification system is used, in which case no additional time would 
be needed. 
154 The number of passengers’ requests affected by PM C.1a is estimated at 6.3 million in 2025, 6.9 million in 
2030 and 8.9 million in 2050. Considering the consumer value of time estimated at EUR 22.7 per hour in 2021 

51 

 
 
  
  
  
  
  
  
 
and intermediaries is expected to remain unchanged compared to the baseline. Therefore, no 
additional hassle costs for consumers are projected due to PM C.1b. In PO 3.3 (due to PM C.1c) 
passengers will have the choice to request reimbursement from the carrier or the intermediary 
in case of indirect ticket sales. Around 20% of passengers may request reimbursement from the 
carrier. Assuming 20 additional minutes per reimbursement request, the total hassle costs due 
to PM C.1c in PO 3.3 are estimated at EUR 301.8 million, expressed as present value over 
2025-2050 relative to the baseline155 (see Table 18). 

Passengers are usually unaware of how the reimbursement will be processed (i.e. whether the 
carrier will reimburse the passengers, by using their method of payment, as is the case with a 
pass-through agent intermediary or when an airline prefers to handle the reimbursement claim 
directly, or whether the intermediary will reimburse them), by when the Merchant of Record 
intermediary will reimburse them, and whether the intermediary charges a fee for this156. Under 
all options, passengers would benefit from hassle cost savings because of the clarity on the 
reimbursement procedure provided by PM C.1a, C.1b and C.1c. Passengers would no longer 
be sent around and could be sure that the body they would approach for their refund, in line 
with  the  information  provided,  would  indeed  process  the  refund.  Under  a  conservative 
approach, it is assumed that passengers may, on average, benefit from time savings of at least 
15 minutes when looking for information on the reimbursement conditions and process. Thus, 
the hassle costs savings due to PM C.1a (in PO 3.1), PM C.1b (in PO 3.2) and PM C.1c (in PO 
3.3) are estimated at EUR 1,679.1 million, expressed as present value over 2025-2050 relative 
to the baseline157 (see Table 18). 

Under the intermediary procedure, which is assumed to be most used in PO 3.2158, and a bit 
less under PO 3.3, the passenger will benefit from a guaranteed reimbursement deadline of 
7  days  for  the  (Merchant  of  Record)  intermediary’s  transaction  to  the  passenger.  The 
intermediary’s reimbursement deadline has so far been subject to the terms and conditions of 
the intermediary159 and often exceeds 7 days, or is not clear at all. According to the terms and 
conditions of a number of (Merchant of Record) intermediaries (see Annex 12), intermediaries 
may take between 7 to 60 days to reimburse passengers under the baseline. Passengers booking 
with intermediaries that take longer than 7 days to reimburse to the passenger would benefit 

prices, and the additional time spent per reimbursement request of 20 minutes (lower bound) to 40 minutes (upper 
bound),  the  hassle  costs  per  consumer  are  estimated  at  EUR  7.6  (lower  bound)  to  EUR  15.1  (upper  bound). 
Expressed as present value over 2025-2050, total hassle costs are estimated at EUR 1,044.9 million (lower bound) 
to EUR 2,089.8 million (upper bound). 
155 The number of passengers’ requests affected by PM C.1c is estimated at 1.3 million in 2025, 1.4 million in 
2030 and 1.8 million in 2050. Considering the consumer value of time estimated at EUR 22.7 per hour in 2021 
prices, and the additional time spent per reimbursement request of 20 minutes (lower bound) to 40 minutes (upper 
bound),  the  hassle  costs  per  consumer  are  estimated  at  EUR  7.6  (lower  bound)  to  EUR  15.1  (upper  bound). 
Expressed as present value over 2025-2050, total hassle costs are estimated at EUR 301.8 million (lower bound) 
to EUR 603.5 million (upper bound). 
156 Any potential fee will be contained in the intermediary’s terms and conditions, which passengers often do not 
read. 
157 On average, 3% of passengers booking via intermediaries request reimbursement, and around 46% of air 
passengers book their tickets via intermediaries. In the baseline scenario, the total number of air passengers 
booking via intermediaries who request reimbursement is projected at 13.5 million in 2025, 14.7 million in 2030 
and 19 million in 2050. Under PM C.1a, it is assessed that passengers would spent 15 minutes (lower bound) to 
30 minutes (upper bound) less when looking for information on their reimbursement process. Considering the 
consumer value of time estimated at EUR 22.7 per hour in 2021 prices, the hassle costs savings per consumer are 
estimated at EUR 5.7 (lower bound) to EUR 11.4 (upper bound). Expressed as present value over 2025-2050, 
total hassle costs savings are estimated at EUR 1,679.1 million (lower bound) to EUR 3,358.2 million (upper 
bound). More details are provided in Annex 4 (section 3.3). 
158 This is because it generates the least administrative burden to carriers and passengers, and because most are 
practicing this already. 
159 According to Commission online research, this transaction (from intermediary to passenger) may take longer 
than 7 days. See Annex 13. 

52 

 
 
 
from additional time savings. Furthermore, (Merchant of Record) intermediaries often do not 
inform  their  customers  at  all  about  the  maximum  time  it  takes  them  to  reimburse  to  the 
customer, once the intermediary has received the payment from the airline. PM C.3 will provide 
clarity  on  this,  and  save  the  passenger  the  hassle  of  contacting  the  intermediary  (possibly 
multiple times) to check when the reimbursement payment will be made. Under PO 3.2, where 
the intermediary is involved, passengers benefit by not having to pay fees to the intermediary 
for the reimbursement160.   

All options enable the passengers to approach the carrier for the reimbursement, with the 
data needed, if necessary. In PO 3.1 this is by default, while in PO 3.2 and PO 3.3 this is in 
the case where the intermediary has not paid the passenger within 14 days, as a ”plan B” for the 
passenger. This policy measure is important because many intermediaries generate their own 
ticket identification numbers or booking references, with the consequence that the passenger 
cannot provide the carrier with its own booking reference when requesting the reimbursement 
directly from it161. The benefit to passengers from this measure is a gain in time and less hassle 
from  calls  to  the  airline’s  call  centre.  It  is  assumed  that  passengers  booking  flights  via 
intermediaries with airlines with an indirect booking model will gain at least 10 minutes due to 
this measure in PO 3.1 and PO 3.3 in their reimbursement procedure. Thus, the hassle costs 
savings for consumers, expressed as present value over 2025-2050 relative to the baseline, are 
estimated at EUR 522.5 million in PO 3.1162 and EUR 104.5 million in PO 3.3163. The “plan 
B” under the intermediary procedure in PO 3.2 and 3.3 (PM C.4) lengthens the intermediary 
procedure by a maximum of 7 days. However, the main passenger and consumer associations 
consider that such a “plan B” is necessary, in case there is a problem with the intermediary.  

In terms of general length of the reimbursement procedure, PO 3.1 is the shortest: 7 days. PO 
3.2 and 3.3 (where the intermediary is chosen) would normally take a maximum of 14 days, 
but would save the passengers considerable hassle.  

Whilst it might appear at first sight that PO 3.3 is most beneficial for the passenger because the 
passenger  can  choose the procedure, this may not  be so in  reality.  The  passenger  cannot  be 
expected to know and to understand what kind of costs and benefits each procedure implies, 
such as the additional hassle inherent in the carrier-only procedure, as opposed to the one via 
the intermediary. The passenger is usually the least knowledgeable of the market and will not 
be aware of how well the individual intermediaries comply with the rules. It will in the end be 

160 Under PO 3.3 passengers might have to pay a fee to the intermediary, while under PO 3.1 and 3.2 they do not. 
161 We assume that this problem would normally cover all situations where the passenger had not yet received a 
boarding pass.  
162 The number of air passengers’ requests affected by PM C.3 in PO 3.1 is 6.3 million in 2025, 6.9 million in 2030 
and 8.9 million in 2050. These exclude the requests for which an automatic verification system is used. Considering 
the consumer value of time estimated at EUR 22.7 per hour in 2021 prices, and the time saved per reimbursement 
request  of  10  minutes  (lower  bound)  to  20  minutes  (upper  bound),  the  hassle  costs  savings  per  consumer  are 
estimated at EUR 3.8 (lower bound) to EUR 7.6 (upper bound). Expressed as present value over 2025-2050, total 
hassle costs savings are estimated at EUR 522.5 million (lower bound) to EUR 1,044.9 million (upper bound). 
163  In  PO  3.2,  including  PM  C.1b  together  with  PM  C.4,  it  is  expected  that  the  number  of  requests  for 
reimbursement to carriers and intermediaries remains unchanged compared to the baseline. Therefore, no hassle 
costs savings for consumers are estimated due to PM C.4. In PO 3.3, including PM C.1c together with PM C.4, 
the number of air passengers’ requests affected is estimated at 1.3 million in 2025, 1.4 million in 2030 and 1.8 
million in 2050. These exclude the requests for which an automatic verification system is used (large low cost 
carriers). Considering the consumer value of time estimated at EUR 22.7 per hour in 2021 prices, and the time 
saved  per  reimbursement  request  of  10  minutes  (lower  bound)  to  20  minutes  (upper  bound),  the  hassle  costs 
savings per consumer are estimated at EUR 3.8 (lower bound) to EUR 7.6 (upper bound). Expressed as present 
value over 2025-2050, total hassle costs savings are estimated at EUR 104.5 million (lower bound) to EUR 209 
million (upper bound). More details are provided in Annex 4 (section 3.3). 

53 

 
 
 
better for the passenger if the airline decides this, based on its market knowledge, as it is in the 
airline’s interest to only cooperate with reliable intermediaries164.  

In addition, under the carrier-only procedure (PO 3.1 fully, PO 3.2 and PO 3.3 partly) the carrier 
has no particular incentive, as it exists under the intermediary procedure of PO 3.2 and PO 3.3, 
to respect its payment deadline165, which might lead to delayed reimbursements to the passenger 
in practice. The respect of the payment deadline is an issue because on average, between 20-
30% of passengers booking via Merchant of Record intermediaries are currently not paid within 
7  days166  (based  on  pre-pandemic  data),  affecting  between  18.5  million  and  27.7  million 
passengers  in  2019.  Under  PO  3.2,  the  intermediaries  are  also  incentivised  to  respect  their 
payment  deadline,  as  otherwise,  the  carriers  may  no  longer  decide  to  involve  them  in  the 
reimbursement  process,  but  carry  it  out  by  themselves  (which  is  not  in  the  interest  of  the 
intermediaries).  

The  main  passenger  and  consumer  associations  are  not  advocating  PO  3.1  as  the  preferred 
option, which suggests that the slightly more lengthy procedure via the intermediary in PO 3.2 
and  3.3  is  not  a  key  factor  overall.  Intermediaries  have  reported  as  part  of  the  stakeholder 
consultation that carriers which do not want to cooperate with them are obstructing, delaying 
and refusing to provide refunds via the intermediaries - a situation which can be expected to 
also lengthen the time that the reimbursement arrives with the passenger. Leaving the choice to 
the airline under PO 3.2 (as opposed to  the passenger under PO 3.3) on how to  process  the 
reimbursement will best ensure that the passenger receives the reimbursement payment in time, 
and with the least hassle. 

Table 18: Hassle costs and costs savings for consumers for policy options under problem area 3, expressed as 
present value over 2025-2050 relative to the baseline, in million EUR (2021 prices) 

Difference to the Baseline 
PO 3.2 

PO 3.3 

PO 3.1 

Hassle costs  
PM C.1a 
PM C.1c 
Hassle costs savings 
PM C.1a 
PM C.1b 
PM C.1c 
PM C.3 
PM C.4 
Net benefits 

0.0 

301.8 

1,044.9 
1,044.9 

2,201.6 
1,679.1 

522.5 

1,679.1 

1,679.1 

1,156.7 

1,679.1 

301.8 
1,783.6 

1,679.1 

104.5 
1,481.8 

164 The carriers will be able to choose the carrier-only procedure for a particular intermediary when they, based 
on experience, deem it unlikely that the intermediary will respect the deadlines, or the payment obligation to the 
passenger. 
165 i.e. to pay within their deadline of 7 days in order to avoid the additional administrative costs that they would 
need to incur when the passenger contacts them directly for the reimbursement.  
166  Based  on  stakeholder  feedback  (intermediaries,  consumer  organisations).  In  addition,  80%  of  all 
reimbursements for bookings via Merchant of Record intermediaries are processed through IATA’s Billing and 
Settlement Plan (BSP). According to IATA information, 95% of these payments are made through the Global 
Distribution System (GDS). Although automated (pre-authorised by airlines), not all reimbursements made under 
the GDS are paid within 7 days. Payments via IATA’s BSP system (from the airline to the intermediary) follow a 
remittance payment period (i.e. the time span in respect of which a remittance is made to the Clearing Bank, which 
is when the agent receives the money). According to data received by IATA, 38% of payments are done within a 
period of 7 days (either on a daily basis or weekly basis), while the remaining 62% of payment flows under the 
GDS and via the BSP are either paid on a fortnightly basis, monthly basis or 3 times per month. The 5% of BSP 
payments outside the GDS are made through BSP Link, where airlines have not pre-authorised them and which 
therefore take (much) longer than 7 days. 

54 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

It should also be noted that it is not likely that extra costs for the implementation of information 
rights  will  be  passed  on  to  customers  in  the  form  of  higher  prices  for  tickets.  Regarding 
reimbursement of air tickets when intermediaries are involved, the one-off costs for airlines for 
informing the passenger about the reimbursement process are expected to lead to costs of EUR 
0.01, and of EUR 0.07 per passenger booking via intermediaries. As such, the potential of cost 
pass-through is not an issue considering the very limited additional costs per passenger. 

6.1.6 

Impacts on SMEs 

A significant part  of  carriers  and  intermediaries are SMEs.  Therefore, the initiative is  considered 
relevant for SMEs and the SME test has been performed (see Annex 8).  

While many carriers in the air and rail transport, and terminal operators, are medium and some even 
large companies, bus and coach carriers, waterborne carriers as well as intermediaries are often SMEs. 
Around 85%167 (3,211 out of 3,778) of bus and coach carriers and 99%168 (518 out of 523) of 
waterborne  carriers  are  SMEs.  Regarding  intermediaries,  ECTAA  estimates  that  there  are 
123,000 travel agents and tour operators across EU, of which 95% (116,850) are SMEs169. 

Detailed  tables  on  the  impacts  by  policy  option,  policy  measure  and  stakeholder  group  are 
provided  in  Annex  8.  An  overview  of  costs  and  costs  savings  by  policy  option  under  each 
problem area are also provided in Tables 19-24 below. 

Options related to enforcement (problem area 1). Both PO 1.1 and PO 1.2 lead to an increase 
of the administrative and adjustment costs for SME carriers and of the  adjustment costs for 
SME intermediaries, compared to the baseline. Administrative costs stem from policy measure 
PM A.2, while adjustment costs stem from policy measures PM A.2 and PM A.3 in PO 1.1 and 
PO 1.2. In addition, PM A.5 also results in adjustment costs for PO 1.2. 

For SME carriers, PO 1.2 shows higher costs than PO 1.1 in 2025 (EUR 17.8 million compared 
to EUR 13.5 million respectively), while in 2030 and 2050 the costs are similar for both options 
(EUR 4.4 million). This is because of PM A.5 (included only in PO 1.2) that requires carriers 
to better inform passengers about their rights, in particular when booking a journey or when a 
transport disruption occurs. In terms of present value over 2025-2050, total costs for carriers 
are estimated at EUR 89.3 million in PO 1.1 and EUR 93.6 million in PO 1.2. The intermediary 
ticket vendors and tour operators bear one-off adjustment costs of EUR 13.6 million in 2025 
(see Table 19-20).  

The  total  costs  per  SME  carrier  (for  bus  and  coach  operators  and  waterborne  transport 
operators) are estimated at EUR 3,618 in 2025 and EUR 1,167 per year from 2026 onwards, 
while for SME intermediaries at EUR 117 in 2025. Considering the annual average turnover 
per SME (EUR 2.1 million per bus and coach operator and EUR 13.7 million per waterborne 
transport operator170), the total cost per bus and coach operator is estimated at less than 0.2% 
of the turnover in 2025 (including also one-off costs) and less than 0.1% of the turnover post-

167 SMEs were estimated to account for around 85% of the occasional passenger transport, drawing on studies by 
International the Road Transport Union (IRU) and the European Transport Workers’ Federation (ETF).  TRT on 
behalf of IRU, 2015. A Pilot Study on Specific Driving and Rest Time Rules for Bus and Coach Drivers in the 
EU; ETF Report, 2018, Driven to distraction? Long-distance coach and bus drivers in the EU. 
168 According to Eurostat data, around 99% of water transport businesses were classified as SMEs. 
169 Figures based on Eurostat, confirmed by ECTAA. 
170 Eurostat. 

55 

 
 
 
2025, while the cost  per waterborne transport operator is  estimated  at  less than 0.1% of the 
turnover for all periods. 

Table  19:  Total  recurrent  and  one-off  costs  for  SMEs  in  the  POs  addressing  problem  area  1,  expressed  as 
present value over 2025-2050 relative to the baseline scenario, in million EUR (2021 prices) 

Carriers 
Administrative costs   
Adjustment costs   

Bus and coach operators  
Administrative costs   
Adjustment costs   
Waterborne transport operators 
Administrative costs   
Adjustment costs   

Intermediaries 
Adjustment costs   
Source: PWC, TIS and Steer (2023), Impact assessment support study 

Difference to the Baseline 
PO 1.2 
PO 1.1 

89.27 
80.14 
9.14 
76.9 
69.0 
7.9 
12.4 
11.1 
1.3 
13.6 
13.6 

93.63 
80.14 
13.49 
80.6 
69.0 
11.6 
13.0 
11.1 
1.9 
13.6 
13.6 

Table 20: Total recurrent and one-off costs for SMEs in the POs addressing problem area 1, in 2025, 2030 and 
2050 relative to the baseline scenario, in million EUR (2021 prices) 

Difference to the Baseline 

PO 1.1 
2030 

2025 

2050 

2025 

PO 1.2 
2030 

2050 

Carriers 
Administrative costs   
Adjustment costs   

Bus and coach operators  
Administrative costs   
Adjustment costs   
Waterborne transport operators 
Administrative costs   
Adjustment costs   

13.49 
4.35 
9.14 
11.62 
3.75 
7.87 
1.87 
0.60 
1.27 
13.64 
13.64 

4.35 
4.35 
0.00 
3.75 
3.75 
0.00 
0.60 
0.60 
0.00 
0.00 
0.00 

4.35 
4.35 
0.00 
3.75 
3.75 
0.00 
0.60 
0.60 
0.00 
0.00 
0.00 

17.84 
4.35 
13.49 
15.37 
3.75 
11.62 
2.48 
0.60 
1.87 
13.64 
13.64 

4.35 
4.35 
0.00 
3.75 
3.75 
0.00 
0.60 
0.60 
0.00 
0.00 
0.00 

4.35 
4.35 
0.00 
3.75 
3.75 
0.00 
0.60 
0.60 
0.00 
0.00 
0.00 

Intermediaries 
Adjustment costs   
Source: PWC, TIS and Steer (2023), Impact assessment support study 

Options related to multimodal passenger rights (problem area 2). All three policy options PO 
2.1, PO 2.2 and PO 2.3 result in an increase in adjustment costs for carriers and intermediaries 
SMEs, compared to the baseline. These costs stem from policy measures PM B.1 and PM B.7 
which are common to all policy options, and from PM B.3 (a or b) and PM B.4 (a or b). PM 
B.1 and PM B.7 are expected to have an impact on 270 SMEs, PM B.3a and PM B.3b on 128 
SMEs, and PM B.4a and PM B.4b on 263 SMEs. 

Carriers bear the largest share of the total costs. PO 2.3 shows the highest increase in costs for 
carriers relative to the baseline (EUR 11.25 million, of which EUR 11.23 million for bus and 
coach operators and EUR 0.02 million for waterborne transport operators), followed by PO 2.2 
(EUR 10.26 million, of which EUR 10.24 million for bus and coach operators and EUR 0.02 
million for waterborne transport operators) and PO 2.1 (EUR 10.2 million, of which EUR 10.18 
million for bus and coach operators and EUR 0.02 million for waterborne transport operators), 
expressed as present value over 2025-2050. The difference is due to PM B.3b included in PO 

56 

 
 
 
  
2.3, as opposed to PM B.3a included in PO 2.1 and PO 2.2. The reason is that under PM B.3b 
passengers  have  a  right  to  conclude  alternatives  contracts  where  a  carrier  does  not  make 
provision for the continuation of the journey, in addition to the more limited rights foreseen by 
PM B.3a. For intermediaries, PO 2.3 is also the most costly option relative to the baseline (EUR 
0.52 million), followed closely by PO 2.2 (EUR 0.36 million) and PO 2.1 (EUR 0.31 million), 
expressed as present value over 2025-2050.  

At the same time, SMEs would benefit of significant hassle costs savings that outweigh the 
costs. Hassle costs savings for carriers are estimated at EUR 29.9 million and for intermediaries 
at EUR 22.8 million in PO 2.1, PO 2.2 and PO 2.3. Thus, all policy options result in net benefits 
for SME carriers (EUR  19.7 million in  PO 2.1, EUR 19.6 million  in PO 2.2 and EUR 18.6 
million in PO 2.3) and intermediaries (around EUR 22.5 million in PO 2.1 and PO 2.2 and EUR 
22.3 million in PO 2.3), expressed as present value over 2025-2050 relative to the baseline.   

Table 21: Total costs and costs savings for SMEs in the POs addressing problem area 2, expressed as present 
value over 2025-2050 relative to the baseline scenario, in million EUR (2021 prices) 

Difference to the Baseline 
PO 2.2 

PO 2.3 

PO 2.1 

Carriers (net benefits) 
Adjustment costs   
Hassle costs savings* 

Bus and coach operators (net benefits) 
Adjustment costs   
Hassle costs savings* 
Waterborne transport operators (net benefits) 

19.67 
10.20 
29.87 
18.52 
10.18 
28.70 
1.15 

19.60 
10.26 
29.87 
18.45 
10.24 
28.70 
1.15 

18.62 
11.25 
29.87 
17.47 
11.23 
28.70 
1.15 

Adjustment costs   
Hassle costs savings* 

0.02 
1.17 
22.32 
Intermediaries (net benefits) 
0.52 
Adjustment costs   
Hassle costs savings* 
22.84 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for lower bound estimates. 

0.02 
1.17 
22.48 
0.36 
22.84 

0.02 
1.17 
22.53 
0.31 
22.84 

Table 22: Total costs and costs savings for SMEs in the POs addressing problem area 2, in 2025, 2030 and 2050 
relative to the baseline scenario, in million EUR (2021 prices) 

Carriers (net benefits) 
Adjustment costs   
Hassle costs savings* 

Bus and coach operators (net 
benefits) 
Adjustment costs   
Hassle costs savings* 
Waterborne transport 
operators (net benefits) 
Adjustment costs   
Hassle costs savings* 

Intermediaries (net benefits) 
Adjustment costs   

PO 2.1 

Difference to the Baseline 
PO 2.2 

PO 2.3 

2025 

0.73 
0.46 
1.19 
0.69 

0.45 
1.14 
0.04 

0.00 
0.05 
0.79 
0.12 

2030  2050 
0.95 
1.01 
0.74 
0.48 
1.69 
1.49 
0.89 
0.95 

0.48 
1.43 
0.06 

0.00 
0.06 
1.12 
0.01 

0.74 
1.62 
0.07 

0.00 
0.07 
1.28 
0.01 

2025 

0.66 
0.53 
1.19 
0.62 

0.52 
1.14 
0.04 

0.01 
0.05 
0.73 
0.18 

2030  2050 
0.95 
1.01 
0.74 
0.48 
1.69 
1.49 
0.89 
0.95 

0.48 
1.43 
0.06 

0.00 
0.06 
1.12 
0.01 

0.74 
1.62 
0.07 

0.00 
0.07 
1.28 
0.01 

2025 

0.62 
0.57 
1.19 
0.58 

0.56 
1.14 
0.04 

0.01 
0.05 
0.62 
0.29 

2030  2050 
0.88 
0.96 
0.81 
0.53 
1.69 
1.49 
0.82 
0.90 

0.53 
1.43 
0.06 

0.00 
0.06 
1.12 
0.01 

0.81 
1.62 
0.07 

0.00 
0.07 
1.28 
0.01 

57 

 
 
 
  
PO 2.1 

Difference to the Baseline 
PO 2.2 

PO 2.3 

2030  2050 
Hassle costs savings* 
1.29 
1.14 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for lower bound estimates. 

2030  2050 
1.29 
1.14 

2030  2050 
1.29 
1.14 

2025 

2025 

2025 

0.91 

0.91 

0.91 

Options  related  to  intermediaries  (problem  area  3).  SME  intermediaries  consist  mostly  of 
brick and mortar travel agents. All three policy options lead to identical one-off administrative 
costs for the 116,850 SME intermediary ticket vendors in 2025, amounting to EUR 54.6 million. 
These  costs  are  due  to  PM  C.1  (a,  b  or  c)  which  obliges  them  to  inform  passengers  on  the 
reimbursement  process.  Per  SME  intermediary,  the  administrative  costs  are  estimated  to  be 
limited, at EUR 467 in 2025. 

These costs are largely overcompensated by administrative costs savings in PO 3.3 (EUR 7.2 
million in 2025, EUR 7.8 million in 2030 and EUR 10.1 million in 2050) and especially in PO 
3.1  (EUR  36  million  in  2025,  EUR  39.2  million  in  2030  and  EUR  50.7  million  in  2050). 
Expressed as present value over 2025-2050, the total cost savings relative to the baseline are 
estimated at EUR 157.4 million in PO 3.3 and EUR 787 million in PO 3.1. The administrative 
cost  savings  are  explained  by  the  fact  that  intermediaries  would  no  longer  handle 
reimbursement requests to the same extent (PM C1.a under PO 3.1 and PM C1.c under PO 3.3).  

Table 23: Total costs and costs savings for SMEs in the POs addressing problem area 3, expressed as present 
value over 2025-2050 relative to the baseline scenario, in million EUR (2021 prices) 

Difference to the Baseline 
PO 3.2 

PO 3.1 

PO 3.3 

Intermediaries 
54.55 
Administrative costs   
157.41 
Administrative costs savings 
Net costs savings 
102.86 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: negative values stand for net costs. 

54.55 
787.04 
732.49 

54.55 
0.00 
-54.55 

Table 24: Total costs and costs savings for SMEs in the POs addressing problem area 3, in 2025, 2030 and 2050 
relative to the baseline scenario, in million EUR (2021 prices) 

PO 3.1 
2030 

2025 

Difference to the Baseline 
PO 3.2 

PO 3.3 

2050 

2025 

2030  2050 

2025 

2030  2050 

Intermediaries 
0.00 
0.00 
Administrative costs   
7.84  10.13 
Administrative costs savings 
Net costs savings 
7.84  10.13 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: negative values stand for net costs. 

54.55 
0.00 
0.00 
35.95  39.21  50.65 
-18.60  39.21  50.65 

54.55 
0.00 
-54.55 

54.55 
7.19 
-47.36 

0.00 
0.00 
0.00 

0.00 
0.00 
0.00 

6.1.7 

Impacts on the functioning of the internal market and on competition 

All  policy  options  are  expected  to  have  a  positive  impact  on  the  functioning  of  the  internal 
market,  by  removing  unnecessary  barriers  for  passengers  and  for  actors  in  the  passenger 
transport market. At the same time they ensure a level playing field for all stakeholders. 

Options related to enforcement (problem area 1). For PO 1.1 and PO 1.2 carriers and terminal 
operators will benefit from a bigger focus on enforcement. The obligation to publish reports on 
results of service quality standards for carriers and terminal operators will positively affect the 
competitiveness  of  compliant  carriers  and  operators,  as  ‘compliance’  will  become  more 
transparent  to  passengers,  and  a  factor  from  which  the  industry  can  get  a  competitive  edge. 
Additionally,  especially  PO  1.2  will  further  the  level  playing  field  between  industry 

58 

 
 
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
stakeholders  inside  the  Union,  as  NEBs  will  publish  risk  assessments,  ensuring  a  more 
harmonised  approach  for  enforcement  across  Member  States.  In  turn,  efforts  to  harmonise 
monitoring  and  enforcement  efforts,  will  facilitate  a  better-functioning  internal  market,  as 
consumers will be more willing to purchase services throughout the Union. 

Options related to multimodal passenger rights (problem area 2). PO 2.1, and in particular 
PO 2.2 and PO 2.3 are expected to have a positive impact on the functioning of the internal 
market  by  facilitating  the  free  movement  of  people,  where  the  introduction  of  multimodal 
passenger rights will encourage more long-distance travels which often entail a cross-border 
element, especially where they book a single contract of carriage (category A). This positive 
impact on the functioning of the internal market will also manifest itself across all options with 
the creation of a level playing field across the Union for carriers and intermediaries with regard 
to the provision of multimodal passenger rights. These policy options, and in particular PO 2.2 
and PO 2.3, will also increase the competitiveness of the market by improving the quality of 
passenger transport services for consumers, including for PRM with the introduction of a free 
right  to  assistance  under  single  contracts  of  carriage  (category  A)  and  the  establishment  of 
Single  Points  of  Contact  at  multimodal  hubs.  Especially  under  PO  2.2  and  PO  2.3,  this 
competitiveness  factor  is  reinforced  by  an  increased  level  of  information  to  passengers 
regarding the characteristics of the passenger transport service (in particular for separate tickets 
which are bundled and sold by intermediaries – category B), thereby allowing them to make a 
more informed decision before booking a multimodal journey. 

Options related to intermediaries (problem area 3). Many (online) air travel intermediaries, as 
well as carriers by definition, operate across borders within the EU. Under PO 3.2 and PO 3.3, 
for the intermediary procedure, intermediaries will benefit from an official role when it comes 
to  reimbursements,  which  will  strengthen  their  competitive  position.  They  will  most  likely 
invest in digital processes in order to be able to reimburse passengers quickly and to comply 
with their new 7-day deadline. Under PO 3.2, carriers will be encouraged to (further) invest in 
the reimbursement procedure which best suits them, leading to efficiency gains. Under PO 3.2 
and  PO  3.3,  for  the  intermediary  procedure,  air  passengers  will  benefit  from  a  harmonised 
intermediaries’ reimbursement period, which will contribute to their confidence in the air travel 
market.  This  provision  would  also  create  a  level-playing  field  for  air  travel  intermediaries 
involved in the reimbursement process in the EU. The information obligation on carriers and 
intermediaries  under  all  options  will  help  consumers  to  shop  effectively,  including  across 
borders.   

6.1.8 

Impacts on digitalisation (including Digital by Default) 

Options related to enforcement (problem area 1). Under both PO 1.1 and PO 1.2 there is a 
broad understanding of the need to use digital products and services. The proposed measures 
are shaped based on the assumption of a strong and agile digital framework, provided by PM 
A.5 on the improved information of passengers about their rights when booking a journey or 
when a transport disruption occurs and PM A.3 on the broad acceptance of a standardised claim 
form. Considerable economies of scale in the medium term can also be expected by data mining 
and other artificial intelligence tools to analyse the reports of carriers and terminal operators171.  

171 See the Commission’s strategy on data, information, and knowledge management.  See for example: DG JUST 
developed a user-friendly webcrawler in the context of the eSurveillance project. The crawler is used by both the 
Commission  and  Members  States  to  detect  unsafe  products  sold  online.  The  Commission’s  Information 
Management Steering Board invited in May 2022 DGs to investigate reusing the developed webcrawler solution. 
See  also  the  new  signposting  tool  for  reporting  of  the  European  Banking  Authority;  Both  tools  could  also  be 
adapted and offered to NEB delivered for monitoring of compliance and for reporting under this initiative. An 
assessment of the feasibility is under preparation. The Commission will support the development of a prototype 

59 

 
 
 
Options related to multimodal passenger rights (problem area 2). PO 2.1, PO 2.2 and PO 2.3 
recognise the important place that digital products and solutions take in today’s society. Many 
measures are based on the unstated assumption of a strong digital framework to facilitate the 
implementation. This is the case of PM B.2 (on real-time information), of PM B.3b and PM 
B.4b (on care and assistance, rerouting, etc.), of PM B.7 (on online complaint handling) and of 
PM B.5 (on Single Points of Contact).  

Options related to intermediaries (problem area 3). Under PO 3.2 and PO 3.3, intermediaries 
will  most  likely  be  incentivised  to  invest  in  digital  solutions  in  order  to  process  the 
reimbursement payments to their customers in a faster way. Many EU-based intermediaries are 
SMEs  and  would  most  likely  adapt  to  the  changes  under  consideration  through  increased 
reliance on digital solutions. Under PO 3.1, air carriers may decide to use possibly upcoming 
e-ID  solutions172  to  replace  their  existing  authentication  and  identification  systems,  such  as 
biometric checks of passengers. 

6.1.9  Territorial impacts 

The problems that this initiative aims to address and consequently the impacts of the policy 
options assessed are generally not concentrated in specific Member States, regions or transport 
hubs. No stakeholder raised this issue during the consultation process. For the problem areas 
on  multimodal  travel  and  reimbursement  of  air  tickets  booked  via  intermediaries,  the  even 
geographical  distribution  of  impacts  across  the  EU  is  straightforward,  with  the  notable 
exception of the establishment of multimodal hubs. For the problem area of enforcement there 
are  different  national  approaches  of  NEBs  but  the  measures  envisaged  apply  equally  to  all 
NEBs. 

All three options related to multimodal passenger rights (problem area 2) are expected to have 
positive effects on connectivity. This is because an increase in the protection of passengers on 
multimodal journeys will entice more passengers to use more than a single mode of transport 
for their journey. Therefore, they can maximise the convenience and benefits they derive from 
being able to use the most adapted transport offer to their needs, time and budget requirements. 
This  is  especially  important  for  users  living  in  remote  areas  (notably  rural  areas),  or  in 
segregated areas or in less developed regions as increased connectivity in their case affects all 
areas of life (employment opportunities, education and health care options, etc.). 

PM B.5 and PM B.6 (included in both PO 2.2 and PO 2.3) provide that terminal managers and 
carriers operating via multimodal passenger hubs have to cooperate to set up a Single Point of 
Contact. The methodology laid down in the proposal for the revision of the TEN-T Regulation 
provides that at least one multimodal passenger  hub has to be established for the 424 urban 
nodes of the TEN-T. According to the methodology, all cities with a population over 100,000 
inhabitants, as well NUTS2 capitals where there is no city of at least 100,000 inhabitants are 
TEN-T urban nodes. This leads to a total of 424 multimodal passenger hubs. The geographical 
distribution  is  also  illustrated  in  Figure  7.  This  map  demonstrates  that  the  presence  of 
multimodal  hubs,  which  correspond  to  these  urban  nodes,  reflects  the  actual  territorial 

of  a  WebCrawler,  which  could  automate  the  process  of  monitoring  the  industry’s  compliance  with  passenger 
rights, specifically for online information obligations. 
172 The possible use of European Digital Identity Wallets by private parties (foreseen in the provisional political 
agreement of the Council and European Parliament on the core elements of a new framework for a European digital 
https://www.consilium.europa.eu/en/press/press-
identity 
allow 
releases/2023/06/29/council-and-parliament-strike-a-deal-on-a-european-digital-identity-eid/)  would 
airlines to foresee in their contract with the  passenger the option for the passenger to identify himself through 
strong user authentication when requesting a reimbursement payment from the airline. As a condition for doing 
so, airlines would need to fulfil specific registration conditions that would be part of the wallet ecosystem. The 
passenger’s use of the eID would be voluntary in this case.  

29/6/2023172, 

available 

(eID) 

of 

at 

60 

 
 
 
 
distribution of the population – and hence potential passengers – as well as travelling patterns 
within the EU. 

Figure 7: Geographical distribution of the TEN-T urban nodes 

6.2  Social impacts 

PO 1.1 and PO 1.2 leads to a limited impact to employment, compared to the baseline. The 
proposed measures do not pose a risk of displacing less educated staff or lowering job standards. 
Employment  impacts  are  also  limited  under  PO  2.1,  PO  2.2  and  PO  2.3,  as  the  measures 
included do not require changes in competencies, the type of staff or type of job protection with 
regards to the services to be delivered. A slight increase in employment could be expected if 
the measures are correctly implemented. Employment impacts under PO 3.1, 3.2 and 3.3 are 
expected to be limited as well, as most changes are linked to increased use of technology by 
carriers and intermediaries. 

Improved rights associated to multimodal travel and increased information on those rights (PO 
2.1,  PO  2.2  and  PO  2.3)  will  provide  an  additional  incentive  for  youth  to  use  multimodal 
journeys, especially where those travels are associated with a lower cost and a comparatively 
lower environmental impact. As regards the elderly, who presumably are digitally less literate, 
it should be noted that the information to be provided by carriers, ticket vendors, tour operators 
and terminal operators under PM B.1 (on connecting times and other useful information when 
switching between modes), included in PO 2.1, PO 2.2 and PO 2.3, should be delivered in 
both  paper  and  electronic  format.  This  reflects  the  current  requirement  in  the  context  of 
Regulation (EU) 2021/782 on rail passengers’ rights and obligations. 

6.3 

Impacts on fundamental rights 

Article 38 of the Charter of Fundamental Rights of the European Union (the Charter) stipulates 
that Union policies shall ensure a high level of consumer protection.  

Both options related to enforcement (problem area 1) are expected to contribute to a high level 
of consumer protection, by making it easier for consumers to exercise their passenger rights, by 
introducing standardised forms for reimbursement and compensation claims and making them 
aware  of  the  possibility  to  use  ADR  bodies  to  settle  their  disputes  with  transport  operators. 
Additionally, the options introduce the obligation for industry operators to provide information 

61 

 
 
 
to NEBs upon request, as well as authorising the Commission to request NEBs to investigate 
issues,  both  of  which strengthen the enforcement  of passenger rights  at  Union and Member 
States level. 

All  three  options  related  to  multimodal  passenger  rights  (problem  area  2)  are  expected  to 
contribute  by  granting  a  higher  level  of  protection  to  passengers  undertaking  a  journey 
combining  at  least  two  modes  of  transport.  In  particular,  passengers  who  have  concluded  a 
single  contract  of  carriage  will  enjoy  a  level  of  protection  similar  to  the  one  enjoyed  by 
passengers  travelling  by  a  single  mode  (reimbursement/re-routing,  care).  In  addition, 
passengers  would  be  better  informed,  both  on  their  rights  before  booking  (under  all  policy 
options) as well as in real-time on any possible travel disruptions occurring during the journey 
(PO 2.2 and PO 2.3). Moreover, a high level of consumer protection would be further enabled 
by redress mechanisms, both at the level of operators and national authorities (all options) 

All three options related to intermediaries (problem area 3) are expected to contribute to a 
high  level  of  consumer  protection.  PO  3.1,  3.2  and  3.3  foresee  a  high  level  of  consumer 
protection,  because  the  passenger  who  booked  via  an  intermediary  will  always  be  able  to 
request the reimbursement from the carrier (as a default option under PO 3.1 and as a last resort 
in the intermediary procedure under PO 3.2 and 3.3). Intermediary and carrier are obliged, under 
all options, to inform the consumer. The enforcement of the reimbursement procedure will be 
strengthened through PM A.4. 

Furthermore, it follows from Article 21(1) of the Charter that any discrimination based on 
grounds of disability shall be prohibited, while Article 26 of the Charter states that the Union 
recognises and respects the right of persons with disabilities to benefit from measures designed 
to ensure their independence, social and occupational integration and participation in the life 
of the community. 

Both options related to enforcement (problem area 1) introduce standardised complaint and 
reimbursement forms that would be fully accessible for persons with disabilities and reduced 
mobility.  

All three options related to multimodal passenger rights (problem area 2) grant a right to non-
discrimination and a right to free assistance with regard to single contracts of carriage for a 
multimodal journey, and furthermore in PO 2.3 also in cases when passengers bought separate 
tickets from a ticket vendor. In addition, industry actors would have to provide information to 
passengers on the accessibility of transport infrastructure (all policy options). Moreover,  PO 
2.1 and PO 2.2 foresee the establishment of Single Points of Contact at multimodal hubs to 
cater for the assistance of PRM travelling between modes. 

All  three  options  related  to  intermediaries  (problem  area  3)  are  expected  to  contribute  to 
support PRM, because all information and procedures to be provided to passengers have to be 
offered in an accessible way. 

6.4  Environmental impacts 

All  policy  options  considered  are  expected  to  have  some  positive  environmental  impacts 
compared to the baseline, mainly on climate and air quality, although it is not possible to assess 
the impact quantitatively. As all policy options will enhance passenger rights, they will make 
mobility  with  collective  transport  solutions  more  attractive  and  may  contribute  to  people 
choosing to use less their individual cars. This is expected to have a positive impact in terms of 
reducing CO2 and other pollutant emissions per passenger, as well as on congestion. In addition, 
all policy options will result in increased confidence of passengers in enforcement of passenger 
rights, including when travelling multimodal or when buying air tickets via an intermediary, 

62 

 
 
and can therefore support the shift towards more sustainable transport choices by consumers on 
a  given  journey,  in  particular  where  this  is  combined  with  both  an  increased  ability  for 
passengers to find, compare, and book tickets across modes.  

All policy options are consistent with the environmental objectives of the European Green Deal and 
the European Climate Law173. All policy options contribute towards Sustainable Development Goal 
13 (Take urgent action to combat climate change and its impacts). No significant harm is expected 
on the environment in any of the policy options. 

7  HOW DO THE OPTIONS COMPARE?  

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 25 provides the link between 
policy objectives and assessment criteria. 

Table 25: Link between objectives and assessment criteria 

General objectives 
The general objectives 
are:  
-the proper functioning 
of the internal market 
for passenger transport, 
and; 
- the achievement of a 
high level of consumer 
protection for 
passengers when 
travelling within one 
mode or when 
switching modes 
during their journey 

Specific objective 
SO1 - Ensure effective and 
efficient enforcement across all 
Member States 
SO2 - Ensure effective complaint 
handling for passengers 
SO3 - Increase protection of 
passengers facing travel 
disruptions in the context of 
multimodal journeys 

SO4 - Increase information for 
and assistance of persons with 
disabilities or reduced mobility 
when switching between transport 
modes 

SO5 - Ensure a clear 
reimbursement process when air 
passengers booked via an 
intermediary 

industry 
stakeholders 
implemented  passenger 

Assessment criteria  
Passengers 
and 
experience  better 
rights across modes and Member States 
Passengers  can  easily  find  out  how  and  to 
whom they can submit complaints 
Passengers  performing  a  multimodal  journey 
are  better  informed,  both  before  and  during 
their journey 

Passengers are assisted and cared for in case of 
a  travel  disruption  during  their  multimodal 
journey 
Persons  with  disabilities  or  reduced  mobility 
are better informed when planning to undertake 
a multimodal journey 

Persons  with  disabilities  or  reduced  mobility 
are assisted when switching between transport 
modes 
The  reimbursement  process  is  clear  for  all: 
passengers, air carriers and intermediaries 

All options contribute to the general objectives by contributing to the proper functioning of the 
internal market via measures on effective and efficient enforcement and complaint handling as 
well as ensuring a high level of consumer protection for passengers when travelling within one 
mode  or  when  switching  modes  during  their  journey  by  addressing  problems  detected  with 
reimbursements through intermediaries and the new multimodal market, which is currently not 
covered by any rights.  

Concerning SO1, both PO 1.1 and PO 1.2 are expected to further effectiveness and efficiency 
of enforcement across all Member States. Both options will facilitate increased efficiency in 
the  NEBs  enforcement  efforts  as  it  exists  today,  and  expand  upon  it,  by  enabling  the 
Commission to  require NEBs to  investigate specific suspected breaches  of passenger  rights. 
This  helps  to  ensure  effective  enforcement  across  all  Member  States.  Both  options  also 
introduce new reporting obligations for the industry, which will provide vital information for 

173 Regulation (EU) 2021/1119. 

63 

 
 
 
 
 
NEBs. The need for NEBs to have a clear overview on what is happening on the ground has 
been evidenced already before the COVID-19 pandemic but became most apparent during and 
after the COVID-19 pandemic, as also highlighted by the 2021 ECA report. 

PO  1.2  also  introduces  the  outlining  and  publishing  of  risk  assessments  by  NEBs.  The 
publishing of risk assessments will facilitate cross-border co-operation between NEBs, in the 
sense that NEBs will be able to gather insight, in a more efficient way, on monitoring practises 
from other Member States. This takes sight on SO1 in two ways. Firstly, it incentivises better 
enforcement  efforts  among  all  NEBs,  as  the  methodology  behind  their  monitoring  will  be 
publicised, enabling comparison between their targeted and actual monitoring efforts as well as 
comparisons  between  NEBs  across  Member  States.  Secondly,  the  publication  of  risk 
assessments from well performing and active NEBs, will serve as valuable material and insight 
for  less  active  NEBs,  to  bolster  their  own  enforcement  efforts,  effectively  creating  a  higher 
standard for passenger rights  enforcement across Member States.  While not  quantifiable, an 
improvement  in  the  standard  of  enforcement  across  Member  States,  will  also  encourage 
passengers to choose the most virtuous operators for compliance against passenger rights. This 
will  also  level  the  playing  field  for  industry  as  well  as  ensure  more  equal  protection  of 
passengers  across  the  Union.  The  option  introduces  the  obligation  for  carriers  and  terminal 
operators to better inform passengers about their rights, notably when booking a ticket or in 
case  of  a  transport  disruption,  which  will  also  further  the  effectiveness  and  efficiency  of 
enforcement, as passengers will become knowledgeable about their rights and when and how 
to make claims and complaints. As such, PO 1.2 is much more effective in addressing SO1 than 
PO 1.1. 

Concerning SO2, both PO 1.1 and PO 1.2 will further ensure effective complaint handling for 
passengers  by  obliging  carriers,  ticket  vendors  and  tour  operators  to  accept  an  EU-wide 
standardised  form  for  requesting  reimbursements  and  compensations  (which  will  be  fully 
accessible for persons with disabilities) and by informing passengers about the possibility to 
address  themselves  to  ADRs.  PO  1.2  goes  further  than  PO  1.1,  as  it  also  introduces  the 
obligation  for  carriers  and  terminal  operators  to  better  inform  passengers  about  their  rights, 
notably when booking a ticket or in case of a transport disruption including how to complain. 
The more knowledgeable passengers are on their rights, the more passengers will succeed in 
making informed complaints, with sufficient information and documentation, which in turn will 
facilitate  effective  complaint  handling.  As  such  PO  1.2  is  also  much  more  effective  in 
addressing SO2 than PO 1.1. 

Concerning SO3, while each of the policy options PO 2.1, PO 2.2 and PO 2.3 would see the 
improvement of information to all multimodal passengers prior to their journey, PO 2.2 and PO 
2.3  would  also  imply  that  passengers  having  a  category  A  or  B  ticket  would  receive  better 
information during their journey with the introduction of an obligation for carriers and ticket 
vendors/tour operators to provide real-time information.  

In addition, each of the policy options PO 2.1, PO 2.2 and PO 2.3 is expected to improve the 
assistance to passengers in case of a travel disruption during multimodal journeys, notably of 
those passengers acquiring a category A-ticket, with the introduction in PO 2.1 and PO 2.2 of 
a  basic  set  of  rights.  These  rights  include  a  right  to  pre-purchase  information,  a  right  to 
reimbursement  or  re-routing,  and  the  right  to  care  (meals,  refreshments,  accommodation), 
which is complemented with a right to conclude an alternative contract in PO 2.3.  

PO 2.3 would be the most effective in addressing SO4 for passengers with a category B-ticket 
due to the additional incentive for ticket vendors and tour operators to inform passengers with 
separate tickets compared to PO 2.2 (i.e. liability in the form of the same enhanced rights as 
passengers with a category A-ticket, compared to a right to reimbursement combined with a 

64 

 
 
75%  penalty).  PO  2.1  would  not  bring  any  particular  contribution  to  passengers  having  a 
category B ticket. 

Concerning SO4, the effects of PO 2.1 are expected to be rather limited where PRM would be 
informed  on  the  accessibility  of  transport  infrastructure  where  they  intend  to  undertake  a 
multimodal journey (PM B.1) and would receive assistance where they acquired a category A-
ticket  (PM  B.3a).  PO  2.2  and  PO  2.3  are  however  expected  to  significantly  contribute  to 
increasing  the  assistance  of  all  PRM  performing  a  multimodal  journey  (i.e.  not  only  those 
having a category A ticket) by the establishment of Single Points of Contact at multimodal hubs 
where PRM will be able to pre-notify their special needs only once for every segment of the 
journey.  

Concerning  SO5,  all  options  ensure  clarity  on  the  reimbursement  process  through  the 
information that carriers and intermediaries have to provide to passengers, but also the rules on 
the reimbursement procedure and the B2B rules under PO 3.2 and PO 3.3.  PO 3.3 will be the 
least effective, as the passenger will have to deal with the burden and hassle of communicating 
to  both  the  carrier  and  the  intermediary.  On  the  other  hand,  under  PO  3.1  and  PO  3.2,  the 
procedure would be clarified upfront, prior to booking. Intermediaries (under PO 3.2 and PO 
3.3) will no longer be able to foresee in their terms and conditions reimbursement periods to 
their customers where the maximum length of the reimbursement to the customer (after having 
received the payment from the carrier) is left open174.  

7.2  Efficiency 

Efficiency  concerns  “the  extent  to  which  objectives  can  be  achieved  for  a  given  level  of 
resource/at least cost”. 

7.2.1  Assessment of efficiency for policy options under problem area 1 (Passengers do not 
fully benefit from their rights due to shortcomings in implementation and enforcement) 

For PO 1.1, total costs and loss of revenues are estimated at EUR 130.7 million, expressed as 
present value over 2025-2050 relative to the baseline (see Table 26). The main part of these 
costs is expected to be incurred by carriers (EUR 103.8 million), of which EUR 90.4 million 
by  bus  and  coach  operators,  EUR  12.5  million  by  waterborne  operators  and  EUR  832 
thousand by air carriers. Intermediaries are expected to incur costs of approximately EUR 14.4 
million and terminal operators EUR 3.6 million. The loss of revenues for the claim agencies 
are  estimated  at  EUR  1.7  million.  For  national  public  authorities,  total  costs  amount  to 
approximately EUR 7.2 million. 

For PO 1.2, total costs and loss of revenues are estimated at approximately EUR 138 million, 
expressed as present value over 2025-2050 (of which EUR 109.1 million for carriers, EUR 
14.4 million for intermediaries, EUR 4.3 million for terminal operators, EUR 1.7 million for 
claim agencies and EUR 8.6 million for national public authorities). As such, PO 1.2 adds EUR 
7.3  million  relative  to  PO  1.1,  which  is  mainly  attributed  to  NEBs,  carriers  and  terminal 
operators.  The  additional  cost  for  PO  1.2  are  due  to  PM  A.5  (outlining  and  publishing  risk 
assessments  for  NEBs)  and  PM  A.6  (on  the  obligation  of  carriers  and  terminal  operators  to 
better inform passengers about their rights). In terms of split by carrier PO 1.2 leads to costs of 
EUR 94.9 million for bus and coach operators, EUR 13.1 million for waterborne operators, 
EUR 1 million for air carriers and EUR 66 thousand for rail operators. 

174  Furthermore,  passengers  often  do  not  check  an  intermediary’s  terms  and  conditions,  so  having  this  right 
guaranteed by law is a clear advantage to the passenger.  

65 

 
 
 
 
For both PO 1.1 and PO 1.2, under a conservative approach, total cost savings are estimated 
at approximately EUR 154.5 million, expressed as present value over 2025-2050 relative to the 
baseline. Of these, EUR 148.7 million represent benefits for the consumers (in particular hassle 
costs  savings  due  to  PM  A.3)  and  EUR  5.9  million  enforcement  costs  savings  for  national 
public authorities.   

Both PO 1.1 and PO 1.2 result in net benefits, estimated at EUR 23.9 million and EUR 16.6 
million respectively, expressed as present value over 2025-2050 relative to the baseline. PO 1.1 
and PO 1.2 show similar benefits to costs ratio, estimated at 1.18 for PO 1.1 and 1.12 for PO 
1.2. 

Table 26: Summary of costs and benefits of policy options under the problem area 1 - expressed as present value 
over 2025-2050 relative to the baseline, in million EUR (2021 prices) 

Difference to the Baseline  
PO 1.2  
PO 1.1  

Carriers  
Administrative costs    
Adjustment costs    
Terminal operators  
Administrative costs    
Adjustment costs    
Intermediaries  
Adjustment costs    
Claim agencies  
Loss of revenues  
National public authorities  
Adjustment costs    
Administrative costs    
Enforcement costs   
Enforcement costs savings   
Consumers  
Hassle costs savings 
Other costs savings for consumers 
Total costs and loss of revenues  
Total costs savings  
Net benefits 
Benefits to costs ratio 
Source: PWC, TIS and Steer (2023), Impact assessment support study  

93.07  
10.73 

2.35 
1.27 

14.36 

1.65  

0.02 
0.00  
7.21 
5.86  

148.67 
1.65  
130.66 
154.53 
23.87 
1.18 

93.07  
15.99 

2.35 
1.91 

14.36 

1.65  

0.02 
1.40  
7.21 
5.86  

148.67 
1.65  
137.95 
154.53 
16.57 
1.12 

It should be noted that there is high uncertainty regarding the hassle costs savings estimated for 
the  consumers.  A  conservative  approach  (lower  bound  estimate)  has  been  used  for  the 
calculations above. When considering the higher bound estimate of the hassle costs savings, the 
net benefits of the policy options are estimated to be much higher (EUR 317.9 million in PO 
1.1 and EUR 310.6 million in PO 1.2). The benefits to costs ratio is also estimated to be higher 
although also very similar between PO 1.1 and PO 1.2. Thus, using the higher bound estimate 
for the hassle costs savings does not change the ranking of the options with regard to the benefits 
to costs ratio.  

7.2.2  Assessment of efficiency for policy options under problem area 2 (Insufficient protection 

of passengers during multimodal journeys) 

Total costs for PO 2.1 are estimated at EUR 41.5 million, expressed as present value over 
2025-2050 relative to the baseline, of which the costs for industry represent EUR 22.1 million. 
The largest share of costs for industry is provided by adjustment costs for carriers (EUR 20.6 

66 

 
 
   
   
   
   
   
   
   
   
   
   
   
   
   
 
million), followed by adjustment costs for multimodal terminal operators (EUR 1.1 million) 
and for intermediaries (EUR 0.38 million). Enforcement costs for national public authorities 
are estimated at EUR 19.4 million in PO 2.1. 

In PO 2.2, total costs are estimated to be higher than in PO 2.1, at EUR 379.8 million expressed 
as present value over 2025-2050 relative to the baseline. Of these, EUR 356.4 million represent 
costs for the industry and EUR 23.3 million enforcement costs for national public authorities. 
The  largest  share  of  costs  for  industry  are  represented  by  adjustment  costs  for  multimodal 
terminal operators (EUR 317.64 million), which are mostly linked to the obligation to set up 
Single Points of Contact (PM B.5). Costs for carriers are estimated at EUR 35.3 million (i.e. 
EUR 0.1 million administrative costs and EUR 35.2 million adjustment costs), while the costs 
for intermediaries (mostly adjustment costs) at EUR 3.5 million.   

Total  costs  in  PO  2.3  are  estimated  at  EUR  383.6  million  (i.e.  EUR  360.3  million  for  the 
industry  and  EUR  23.3  million  for  national  public  authorities).  The  costs  for  multimodal 
terminal operators are estimated to EUR 317.6 million (the same as in PO 2.2), the costs for 
carriers at EUR 39.1 million and those for intermediaries at EUR 3.6 million, expressed as 
present value over 2025-2050 relative to the baseline. The slightly higher costs for carriers and 
intermediaries relative to PO 2.2 are mainly due to PM B.3b, which additionally includes a right 
to conclude an alternative contract (compared to PM B.3a included in PO 2.2). 

Total  benefits,  expressed  as  present  value  over  2025-2050  relative  to  the  baseline,  are 
estimated to be the highest in PO 2.3 (EUR 493.7 million), followed by PO 2.2 (EUR 490 
million)  and  PO  2.1  (EUR  212.7  million).  Of  these,  the  largest  share  of  the  benefits  are 
expected for consumers (EUR 363 million in PO 2.3, EUR 359.2 million in PO 2.2 and EUR 
81.9 million in PO 2.1).  

As  explained  in  section  6.1.5,  the  benefits  for  consumers  are  reflected  through  hassle  costs 
savings for PRMs due to PM B.3a in PO 2.1 and PO 2.2 and PM B.3b in PO 2.3 (EUR 18.6 
million), due to the Single Point of Contact in PO 2.2 and PO 2.3 (EUR 277.3 million) and due 
to the complaint handling mechanism (EUR 43.3 million) in PO 2.1, PO 2.2 and PO 2.3. In 
addition,  the  right  to  reimbursement/re-routing  and  care  for  passengers  performing  a 
multimodal  journey  under  a  category  A  ticket  implies  that  passengers  would  avoid  costs 
associated  to  re-routing,  refreshments,  meals,  and  accommodation  in  the  event  of  a  missed 
connection. The costs savings for reimbursement/re-routing and care are estimated at EUR 20.1 
million  in  PO  2.1  and  PO  2.2,  expressed  as  present  value  over  2025-2050  relative  to  the 
baseline, while for PM PO 2.3, which includes the right to conclude an alternative transport 
contract, at EUR 23.8 million. 

All policy options are also expected to result in hassle costs savings for multimodal transport 
operators  (35.3  million)  and  intermediaries  (EUR  24  million)  due  to  less  time  spent  for 
handling complaints. NEBs would also benefit of hassle costs savings in all policy options (71.4 
million) for processing the complaints from passengers concerning multimodal journeys (see 
Table 27).  

PO 2.1 results in the highest net benefits, estimated at EUR 171.2 million expressed as present 
value over 2025-2050 relative to the baseline, followed by PO 2.2 (EUR 110.2 million) and 
PO 2.3 (EUR 110.1 million). PO 2.1 also results in the highest benefits to costs ratio, while 
PO 2.2 and PO 2.3 show similar benefits to costs ratios (see Table 27). Thus, the most efficient 
option is PO 2.1, followed by PO 2.2 and PO 2.3. 

67 

 
 
Table 27: Summary of costs and benefits of policy options under the problem area 2 - expressed as present value 
over 2025-2050 relative to the baseline, in million EUR (2021 prices) 

Difference to the Baseline 
PO 2.2 

PO 2.1 

PO 2.3 

Carriers 
Administrative costs  
Adjustment costs  
Hassle costs savings 
Terminal operators 
Adjustment costs  
Intermediaries 
Administrative costs  
Adjustment costs 
Hassle costs savings 
National public authorities 
Enforcement costs  
Hassle costs savings 
Consumers  
Benefits for consumers  
Hassle costs savings 
Total costs  
Total costs savings 
Net benefits 
Benefits to costs ratio 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

0.00 
20.60 
35.33 

0.12 
35.22 
35.33 

0.12 
38.95 
35.33 

1.11 

317.64 

317.64 

0.00 
0.38 
24.01 

19.42 
71.42 

20.09 
61.86 
41.51 
212.71 
171.20 
5.12 

0.03 
3.44 
24.01 

23.34 
71.42 

20.09 
339.14 
379.78 
489.99 
110.21 
1.29 

0.03 
3.55 
24.01 

23.34 
71.42 

23.81 
339.14 
383.63 
493.72 
110.09 
1.29 

It should be noted that there is high uncertainty regarding the hassle costs savings estimated for 
the  consumers,  carriers,  intermediaries  and  national  public  administrations.  A  conservative 
approach (lower bound estimate) has been used for the calculations above. When considering 
the higher bound estimate of the hassle costs savings, the net benefits are estimated at EUR 
702.6 million in PO 2.1, EUR 918.9 million in PO 2.2 and EUR 918.8 million in PO 2.3. In 
terms of benefits to costs ratio, the ranking of the policy options does not change. 

7.2.3  Assessment of efficiency for policy options under problem area 3 (Reimbursement rules 

are unclear when flights were booked via an intermediary) 

Total costs, expressed as present value over 2025-2050 relative to the baseline, are estimated 
to be the highest in PO 3.1 (EUR 2,719.6 million), followed by PO 3.3 (EUR 682.7 million) 
and  PO  3.2  (EUR  57.5  million).  The  largest  share  of  these  costs  in  PO  3.1  and  PO  3.3  is 
represented by administrative costs for air carriers (EUR 1,617.2 million in PO 3.1 and EUR 
323.5  million  in  PO  3.3)  for  processing  manual  reimbursements  (as  automatic  reversal  of 
payment is not possible), and hassle costs for consumers for requesting reimbursement from 
air carriers (EUR 1,044.9 million in PO 3.1 and EUR 301.8 million in PO 3.3), due to the 
additional information that they will need to provide before requesting their reimbursement in 
case of tickets bought via intermediaries. All options would lead to minor administrative costs 
for air carriers for the information obligation (EUR 0.07 million). Intermediaries would incur 
administrative  costs  (information  to  passengers)  of  EUR  57.4  million  in  all  policy  options. 
National public authorities are not expected to incur any additional cost under any option, as 
these are covered by PM A.5. 

Overall, for the industry, the option with  the lowest  costs is  PO 3.2 (the  carrier can choose 
whether the passenger has to request the reimbursement from the intermediary or the carrier), 
followed by PO 3.3 (the passenger can choose whether to request the reimbursement from the 

68 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
intermediary or the carrier). PO 3.1 (all reimbursement requests carried out by the air carrier) 
shows the highest costs.  

For the consumers, PO 3.2 contains no additional hassle costs relative to the baseline, and will 
only take 7 days longer than the procedure via the carrier only. In position papers submitted to 
the  Commission,  passenger  and  consumer  associations  have  not  advocated  the  carrier-only 
procedure under PO 3.1.  

Total  benefits,  expressed  as  present  value  over  2025-2050  relative  to  the  baseline,  are 
estimated at EUR 3,030 million in PO 3.1, followed by PO 3.3 (EUR 1,949.3 million) and 
PO 3.2 (EUR 1,679.1 million). The largest share of the total benefits is represented by hassle 
costs  savings  for  consumers.  Under  all  options,  passengers  would  benefit  from  hassle  cost 
savings of EUR 1,679.1 million because of the clarity on the reimbursement procedure. All 
options also enable the passengers to approach the carrier for the reimbursement, with 
the data needed, if necessary. This is expected to lead to hassle costs savings for consumers 
in particular in PO 3.1 and PO 3.3, estimated at EUR 522.5 million and EUR 104.5 million, 
respectively.  The  new  fixed  reimbursement  deadline  of  7  days  for  Merchant  of  Record 
intermediaries under PM C.3 (PO 3.2 and PO 3.3) will also lead to time savings for all cases 
where the intermediaries’ terms and conditions foresee a reimbursement deadline that is longer 
than 7 days. The new deadline will also provide clarity to consumers where the intermediary’s 
terms and conditions do not stipulate any clear maximum payment deadline.  

Intermediaries would benefit of administrative costs savings of EUR 828.5 million in PO 
3.1 for no longer carrying out the reimbursement requests. Under PO 3.3, the administrative 
costs savings (EUR 165.7 million) correspond to the share of passengers who choose to change 
the  processing  of  the  reimbursement  from  the  intermediary  to  the  air  carrier.  However, 
intermediaries may incur indirect costs, which cannot be quantified, as a result of no longer (or 
to a lesser degree) being able to offer the processing of reimbursements to their customers (and 
to airlines, as part of their agreements with them) as part of their service package. This would 
damage to a certain extent their business model of maintaining an exclusive relationship with 
their customers, which is why the intermediaries said in the stakeholder consultation that they 
are in favour of continuing to process reimbursement for their customers.  

Net benefits are estimated to be the highest in PO 3.2 (EUR 1,621.6 million), followed by PO 
3.3 (EUR 1,266.6 million) and PO 3.1 (EUR 310.5 million). PO 3.2 also shows the highest 
benefits to costs ratio (see Table 28). Thus, PO 3.2 is considered the most efficient option. 

Table 28: Summary of costs and benefits of policy options under the problem area 3 - expressed as present value 
over 2025-2050 relative to the baseline, in million EUR (2021 prices) 

Carriers 
Administrative costs  
Intermediaries 
Administrative costs  
Administrative costs savings 
Consumers 
Hassle costs 
Hassle costs savings 
Total costs  
Total benefits 
Net benefits 
Benefits to costs ratio 

Difference to the Baseline 

PO 3.1 

PO 3.2 

PO 3.3 

1,617.22 

0.07 

323.50 

57.42 
828.47 

57.42 
0.00 

57.42 
165.69 

1,044.90 
2,201.57 
2,719.55 
3,030.03 
310.48 
1.11 

0.00 
1,679.11 
57.49 
1,679.11 
1,621.62 
29.20 

301.76 
1,783.61 
682.69 
1,949.30 
1,266.61 
2.86 

69 

 
 
 
 
  
  
  
  
  
  
  
  
  
Source: PWC, TIS and Steer (2023), Impact assessment support study 

There is high uncertainty regarding the hassle costs and costs savings estimated for consumers. 
A  conservative  approach  (lower  bound  estimate)  has  been  used  for  the  calculations  above. 
When  considering  the  higher  bound  estimate  of  the  hassle  costs  and  costs  savings,  the  net 
benefits are estimated at EUR 1,467.1 million in PO 3.1, EUR 3,300.7 million in PO 3.2 and 
EUR 2,748.5 million in PO 3.3. In terms of benefits to costs ratio, the ranking of the policy 
options does not change. 

7.3  Coherence 

Internal coherence assesses how various elements of the initiative function together to achieve 
the objectives. The policy options are coherent across the three problem areas. Furthermore, the 
policy measures enhancing the enforcement are expected to contribute strongly to the success 
of the policy measures related to reimbursements and multimodal travel. PM A.4 included in 
PO  1.2,  under  which  NEBs  shall  perform  compliance  monitoring  activities  of  the  industry 
stakeholders  based  on  a  risk  assessment,  may  include  the  monitoring  of  the  respect  of  the 
reimbursement deadlines by carriers and intermediaries. 

External  coherence  concentrates  on  the  compliance  of  the  initiative  with  national  policies, 
other EU instruments and relevant EU policies, as well as international obligations. 

PO 1.1 and PO 1.2 are coherent with the existing EU legal framework on passenger rights. 
The policy measures common to both PO 1.1 and PO 1.2 intend to harmonise passenger rights 
across modes of transport. They would introduce certain passenger rights or NEB and industry 
obligations  already  existing  in  the  new  Rail  Passenger  Rights  Regulation  or  in  the  2013 
Commission proposal on air passenger rights to the other Regulations.  PO 1.1 and PO 1.2 are 
also  coherent  with  other  EU  instruments  aimed  to  enhance  enforcement  in  Member  States, 
especially concerning the ADR procedures and the CPC network which ensure strong powers 
for cross border enforcement. Under both policy options, the NEBs’ role will be strengthened, 
and  the  Commission  will  be  given  a  role  in  order  to  ensure  an  EU  wide  perspective  of 
enforcement, which will help the NEBs in the CPC network by ensuring that NEBs are aware 
of the situation in other Member States. Increased awareness of passengers about the possibility 
to address themselves to ADRs ensures cooperation between different instruments in place in a 
Member State, that passengers can use in cases where their rights have not been observed.  

PO  2.1,  PO  2.2  and  PO  2.3  are  all  coherent  with  the  existing  EU  legal  framework  on 
passenger  rights.  More  precisely,  the  proposed  intervention  aims  to  protect  passengers 
performing a multimodal journey in a way similar to those passengers undertaking a journey 
with one single mode of transport (e.g. information, reimbursement, re-routing, care, assistance 
to PRM) and builds on currently existing mechanisms to ensure the application of passengers’ 
rights  (Single  Point  of  Contact  for  PRM,  complaint-handling,  enforcement).  These  three 
options  also  show  strong  links  with  the  revision  of  Delegated  Regulation  2017/1926  on 
Multimodal  Travel  Information  Services  (MMTIS)  that  aims  to  improve  the  information 
service for passengers. 

Policy  options  PO  3.1,  PO  3.2  and  PO  3.3,  and  in  particular  the  latter  two,  build  on  the 
Commission’s proposal of 2013175 to amend Regulation (EC) No 261/2004 on air passenger 
rights and complement it. According to the proposal, for the purpose of informing passengers 
about  cancellations  or  delays  in  departure,  the  intermediary  through  whom  the  passenger 
acquired a ticket has two possibilities: it either provides the passenger’s contact details to the 
air carrier, on condition that the passenger has given his explicit and written authorisation, on 

175 COM(2013) 130 final. 

70 

 
 
 
an  ’opt-in’  basis,  or  it  proves  the  existence  of  an  alternative  system  that  ensures  that  the 
passenger is informed without the transmission of the relevant contact details. In addition, the 
(in total) 14-day reimbursement period from the passenger’s request and when an intermediary 
is involved (under PO 3.2 and PO 3.3) creates an alignment with the Package Travel Directive, 
which  already  includes  this  same  14-day  reimbursement  period  when  the  package  travel 
organiser needs to reimburse a package traveller. 

The currently ongoing review of the Package Travel Directive176 assesses as part of one option 
a 7-day deadline for the airline’s reimbursement of tickets as part of a package to the package 
travel organiser in case the airline cancels the flight. This aligns with the 7-day deadline that 
this  initiative’s  PO  3.2  (and  PO  3.3)  includes  for  reimbursements  of  single  tickets  from  the 
airline to the intermediary, where the intermediary processes the reimbursement.  

7.4  Subsidiarity and proportionality 

None of the options go beyond what is necessary to achieve the objectives of the initiative. 

Effective enforcement of rules (PO 1.1 and PO 1.2) rests on the cooperation between Member 
States. Therefore, intervention at EU level is needed to ensure that enforcement occurs in an 
aligned manner across Member States, so that all passengers effectively enjoy their passenger 
rights in a harmonised way, through a facilitation of efficient correspondence and knowledge 
sharing between Member States.  

The three options addressing problem 2 related to multimodal journeys (PO 2.1, PO 2.2 and 
PO 2.3) cover the same scope as the existing EU passenger rights framework (rail, bus and 
coach for long distance journeys, waterborne and air) and seek to address a gap in EU legislation 
which, if left at national level, would create the risk of distortions or potential negative spill-
over effects. 

Regarding  the  three  options  addressing  problem  3,  it  should  be  recalled  that  the  air  travel 
distribution  market  in  the  EU  is  essentially  cross-border,  with  some  of  the  largest 
intermediaries being international market players. Individual national action or action in only 
a limited number of Member States would not be beneficial to the EU consumer and would lead 
to distortions of the internal market. 

In  relation  to  proportionality,  each  of  the  policy  options  addressing  the  three  problems 
identified  contributes  to  achieving  the  general  objectives  and  the  measures  proposed  are 
proportionate in view of the specific objectives. 

On  enforcement,  both  PO  1.1  and  PO  1.2  address  SO1  (Ensure  effective  and  efficient 
enforcement  across  all  Member  States)  and  SO2  (Ensure  effective  complaint  handling  for 
passengers).  PO  1.1  introduces  measures  already  established  for  rail  and  proposed  for  air 
passenger  rights  (2013  proposal)  to  the  other  modes  of  transport.  In  PO  1.2,  two  additional 
policy measures (obligation to NEBs to carry out their monitoring activities following a risk 
assessment and obligation for carriers and terminal operators to better inform passengers about 
their rights, notably when booking a ticket or in case of a transport disruption) are included to 
address  more  effectively  the  issues  of  passengers’  low  awareness  of  their  rights  and  of  the 
diverging scope of NEBs’ actions. Both additional policy measures leave carriers and terminal 
operators,  as  well  as  NEBs,  flexibility  on  how  they  want  to  implement  them.  As  PO  1.2 
addresses two important aspects of the general objective that PO 1.1 does not address, but the 

176  See  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13117-Package-travel-review-of-
EU-rules_en. 

71 

 
 
 
additional  policy  measures  leave  flexibility  for  carriers,  terminal  operators  and  NEBs 
respectively to implement them, PO 1.2 is considered more proportionate than PO 1.1. 

Among the three options addressing problem 2, PO 2.2 is assessed to be more proportionate 
than  PO  2.1  and  PO  2.3.  This  option  is  highly effective  in  addressing  both  SO3  (Increase 
protection of passengers facing travel disruptions in the context of multimodal journeys) and 
SO4 (Increase information for and assistance of persons with disabilities or reduced mobility 
when switching between transport modes), while at the same time not going beyond what is 
necessary  for  achieving  the  objectives.  In  particular,  the  measures  in  PO  2.2  aim  at 
complementing  the  current  market  structure.  Single  contracts  of  carriage,  on  the  one  hand, 
imply  a  certain  degree  of  arrangements  and  cooperation  mechanisms  between  transport 
providers to ensure the passenger’s transfer from one transport mode to the other. The proposed 
measures would therefore aim to specify the level of service to be granted to passengers in a 
context  where  the  transport  operators  are  in  a  position  to  deliver  such  assistance.  Separate 
tickets,  on  the  other  hand,  suggest  the  absence  of  cooperation  between  transport  providers. 
Therefore, when these tickets are offered together, this lack of arrangements between transport 
operators should be made clear to passengers, while at the same time avoiding creating an undue 
burden on ticket vendors and tour operators who, as a general rule, do not operate transport 
services themselves. In the same vein, PO 2.2 is more proportionate than PO 2.3 in view of the 
sanction to be applied when ticket vendors and tour operators do not provide this information. 
Whereas in PO 2.2 this sanction consists of a reimbursement of the amount paid for the tickets 
by the passenger and an additional penalty of 75% of that amount, the sanction under PO 2.3 
would consist of ensuring rights to passengers as if the ticket vendors and tour operators would 
be  carriers  themselves  (i.e.  reimbursement,  re-routing,  care,  right  to  alternative  transport 
contract). PO 2.2 is also more proportionate than PO 2.1, where the latter does not foresee any 
sanction to incentivise ticket vendors and tour operators to provide such information. 

Both PO 3.1 and PO 3.3 (for the part that will be processed by carriers directly and which was 
formerly  processed by  intermediaries) are less proportionate than the baseline, because they 
deviate from established industry practice. PO 3.2. reflects the established industry practice, 
i.e. how the air travel and distribution industry operates, and is therefore the most proportionate 
option. Processing the reimbursement requests of their customers is part of the (full service) 
business model of intermediaries, and also what is expected under their current agreements with 
many airlines177. PO 3.2 is also the only option of the three which reflects the current air carrier 
distribution models, with airlines adopting different policies for the reimbursement of tickets 
booked by intermediaries, depending on their business model. Most carriers (network and small 
low-cost carriers) sell a large share of tickets via intermediaries and have agreements with these 
in  place  (including  for  reimbursements)178.  However,  currently,  at  least  one  large  low-cost 
carrier  allows  only  the  purchase  of  its  tickets,  if  done  online  via  its  website  directly  by  the 
passenger  and  does  not  use  intermediaries  (or  only  in  a  very  restricted  form).  Nevertheless, 
intermediaries  do  in  certain  instances  purchase  tickets  from  carriers  with  a  full  or  partial 
preference/model for direct distribution to the passenger, often without the knowledge of the 
carrier. This creates difficulties when it comes to reimbursements, as the carrier may refuse to 
perform reimbursements via the intermediaries in this context. However, only the intermediary 
may hold the key information necessary for the reimbursement such as the bank details and 
payment method for the reimbursement or the passenger’s contact details. Under PO 3.2, these 
carriers can continue their current practice of asking passengers to carry out the reimbursements 
directly with them. PO 3.2 is the least intrusive in terms of market practice.  

177 E.g. as part of the IATA rules. 
178 In  the  reference  year  2019,  network  carriers  in  the  EU  sold  about  53%  of  their  tickets  (about  269  million 
passengers in terms of tickets sold in 2019) through intermediaries, whereas this share is 15% for low-cost carriers 
(about 64 million passengers in 2019). 

72 

 
 
 
Table 29 provides a summary of the comparison of the options against the baseline scenario in 
terms of effectiveness, efficiency, coherence, subsidiarity and proportionality. The following 
ranking symbols have been used: from '+' (more effective/efficient/coherent/ proportionate than 
the baseline) to '+++' (much more effective/efficient/coherent/proportionate than the baseline); 
from  '-'  (less  effective/efficient/coherent/proportionate  than  the  baseline)  to  '---'  (much  less 
effective/efficient/coherent/ proportionate than the baseline).  

Table  29:  Comparison  of  options  in  terms  of  effectiveness,  efficiency,  coherence,  subsidiarity  and 
proportionality relative to the baseline 

Criteria 
Effectiveness 
Efficiency 
Coherence 
Subsidiarity and 
proportionality 

PO 1.1 
+ 
+ 
+++ 
+  

PO 1.2 
+++  
+ 
+++ 
+ + 

PO 2.1 
+ 
++ 
+++ 
+ 

PO 2.2 
+++ 
+ 
+++ 
+++ 

PO 2.3 
+++ 
+ 
+++ 
++ 

PO 3.1 
++ 
+ 
+ 
-- 

PO 3.2 
++ 
+++ 
++ 
++ 

PO 3.3 
+ 
++ 
++ 
- 

8  PREFERRED OPTIONS 

8.1 

Identification of the preferred policy options and stakeholder views 

8.1.1  Preferred policy option and stakeholder views for problem area 1 (Passengers do not 
fully benefit from their rights due to shortcomings in implementation and enforcement) 

The preferred policy option for problem area 1 is PO 1.2, which is the policy option that 
best ensures that carriers and terminal operators contribute to the effective complaint handling 
for passengers, and that NEBs further the effectiveness and efficiency of enforcement across 
all Member States.  

While the two policy options do not directly differ in the scope of passengers protected, the two 
options do differ in degree of protection, as PO 1.2 goes further to align enforcement efforts 
across Member States and to help ease the complaint handling for passengers. PO 1.2 targets 
the issue of lack of harmonisation of enforcement across Member States directly by obliging 
NEBs to have their enforcement efforts based on risk assessments and for these risk assessments 
to be published. PO 1.2 also directly targets the issue of lack of passenger’s awareness of their 
rights, by ensuring that passengers are provided with the information they need, when they need 
it, where they are. As such, to exclude these policy measures by choosing PO 1.1, would weaken 
the effectiveness significantly, as PO 1.1 exclusively aims at harmonisation between modes of 
transport, while PO 1.2 goes significantly further to accomplish the specific objectives. PO 1.2 
is thus assessed to be much more effective than PO 1.1 in achieving the objectives.  

In terms of efficiency, both PO 1.1 and PO 1.2 perform equally as they lead to similar benefits 
to costs ratios.  

In terms of coherence and subsidiarity both PO 1.1 and PO 1.2 perform similarly. However, 
as explained in section 7.4, PO 1.2 is assessed to be more proportionate than PO 1.1. Thus, 
the analysis points to PO 1.2 as the most balanced option in addressing both SO1 and SO2, and 
therefore as the preferred option. 

Many national enforcement bodies (NEBs), carriers and terminal operators support PO 1.1, as 
it  does  not  include  obligations  on  risk  assessments  and  an  additional  obligation  to  inform 
passengers about their rights when buying a ticket or in case of a transport disruption for these 
stakeholders.  PO  1.2  is  supported  by  consumer  organisations  as  the  option  goes  further  on 
obligations for carriers and terminal operators to provide passengers with information on their 
rights. Well performing NEBs, carriers, terminal operators and intermediaries also support PO 

73 

 
 
1.2, as it ensures that the NEBs monitoring, and enforcement activities are more transparent 
and predictable. 

8.1.2  Preferred  policy  option  and  stakeholder  views  for  problem  area  2  (Insufficient 

protection of passengers during multimodal journeys) 

The  preferred  policy  option  for  problem  area  2  is  PO  2.2,  which   ensures  a  fair  balance 
between  the  effectiveness  of  the  intervention  in  addressing  SO3  and  SO4  for  multimodal 
passengers, including PRM, and efficiency in terms of benefits to costs ratio, given that this 
market is under development (see section 2.2.4). PO 2.2 is also the most proportionate option 
and performs the same as PO 2.1 and PO 2.3 in terms of coherence and subsidiarity.  

With  regard  to  effectiveness,  PO  2.2  not  only  ensures  that  all  passengers  performing 
multimodal travel are well informed before and during their journey, but also provides for a 
basic  set  of  rights  for  multimodal  passengers  having  a  single  contract  as  well  as  improved 
information on the separate nature of the tickets to passengers having acquired such tickets for 
a multimodal journey from a ticket vendor or tour operator. The measures would therefore cover 
the entire multimodal passenger market (estimated at 91 million passengers in 2019) as regards 
the provision of pre-journey information and contains additional measures for both main sub 
segments of this market (single contracts (5%) and separate tickets (95%)), meaning that this 
option would be highly effective in achieving SO3. At the same time, the measures covered by 
this option would be very effective in addressing SO4, where PRM would not only be entitled 
to the right to non-discrimination and free assistance when travelling with a single contract of 
carriage, but  also  by the establishment of Single Points of Contact  at  multimodal  hubs (and 
possibly beyond), thereby potentially covering the entire multimodal passenger market. 

Even  though  PO  2.1  is  more  efficient  than  PO  2.2  in  terms  of  benefits  to  costs  ratio,  the 
measures envisaged therein would only partially cover the multimodal market and therefore be 
less  effective  in  achieving  SO3,  where  it  only  provides  for  basic  information  rights  for  all 
multimodal passengers (e.g. on the type of multimodal ticket) as well as basic rights for single 
contracts of carriage for multimodal journeys (category A). As mentioned above, such single 
contracts only represent a small fraction (circa 5%) of the entire multimodal market. In addition, 
the measures in PO 2.1 would concern those single contracts of carriage that do not include an 
air leg, whereas nearly all multimodal products concern an air leg (see sections 2.2.4 and 5.2.2). 
No particular measures would be foreseen in addition for passengers having separate contracts 
(category B). Moreover, this policy option would only marginally consider the protection of 
PRMs who are not travelling on such single contracts, where they would only be entitled to pre-
journey  information  on  the  accessibility  of  transport  infrastructure  when  switching  between 
modes.  PO  2.1  would  therefore  be  significantly  less  effective  than  PO  2.2  and  PO  2.3  in 
achieving SO 3 and SO4. On the other hand, PO 2.3 is equally efficient to PO 2.2 in terms of 
benefits  to  costs  ratio,  whereas  it  only  provides  for  a  marginal  increase  in  effectiveness  in 
addressing  SO3  (by  introducing  a  full  set  of  rights  for  both  passengers  travelling  on  single 
contracts (category A) and those travelling on separate tickets (category B)) and no additional 
benefits with regard to effectiveness in addressing SO4.  

In terms of coherence and subsidiarity, all options perform equally. However, as explained in 
section 7.4, PO 2.2 is more proportionate than both PO 2.3 and PO 2.1. Thus, the analysis 
points to PO 2.2 as the most balanced option in addressing both SO3 and SO4, and therefore 
as the preferred option. 

Consumer  associations  support  PO  2.3,  as  it  would  entail  a  high  protection  of  consumers. 
Carriers and intermediaries rather support PO 2.1 in view of the current level of development 
of the multimodal ticketing market. NEBs are more favourable to PO 2.2. 

74 

 
 
8.1.3  Preferred policy option and stakeholder views for problem area 3 (Reimbursement rules 

are unclear when flights were booked via an intermediary) 

The  preferred  option  for  problem  area  3  is  PO  3.2,  which  is  the  most  efficient  and 
proportionate option of the three. Together with PO 3.1, it is also the most effective one.  

Both PO 3.1 and PO 3.2 are equally effective in providing clarity on the reimbursement process; 
PO 3.3 slightly less so because the passenger will need to inform the carrier and the intermediary 
simultaneously of their choice.  

In terms of efficiency, PO 3.2 is much more efficient than both PO 3.3 and PO 3.1, with a much 
higher benefits to costs ratio (29.2 in PO 3.2 relative to 2.9 in PO 3.3 and 1.1 in PO 3.1). It is 
also  by  far  the  cheapest  option  as  the  most  expensive  element  -  the  carrier’s  (mostly  non-
automated) processing of the reimbursement - is limited under this option.  

PO  3.2  is  coherent  with  the  Commission’s  2013  proposal  to  amend  Regulation  (EC)  No 
261/2004 on air passenger rights and complements it. The 14-day reimbursement period when 
the intermediary is involved also creates an alignment with the Package Travel Directive, where 
the  package  travel  organiser  also  needs  to  reimburse  the  traveller  within  14  days.  PO  3.2 
performs the same as PO 3.3 in terms of coherence and better than PO 3.1. 

In terms of subsidiarity, all three policy options perform the same. However, PO 3.2 is the 
most proportionate of the three options because it interferes the least in the current market 
practice,  where  intermediaries  process  reimbursements  for  their  customers  as  part  of  their 
business  model,  and  carriers  are  paying  for  systems  like  the  BSP179,  which  facilitates  the 
financial flows  between  airlines and intermediaries.  PO 3.2 also  follows best  the current  air 
carrier distribution model, with about 92% of tickets being processed through the “reversal of 
the  payment  flow”  model.  It  will  allow  those  air  carriers  that  do  not  want  to  involve 
intermediaries for reimbursements to do so. Generally speaking, it will enable air carriers to 
follow a “pick and choose” approach with regard to intermediaries: cooperating with those they 
trust, and not to cooperate with those they don’t trust. This will also benefit the passenger, as 
the passenger cannot be expected to have the market knowledge of which intermediary may 
abide by the rules, and which may not.  

Most intermediaries and air carriers that took part in the stakeholder consultation favoured the 
option  where  the  intermediary  would  be  involved  in  the  reimbursement  process.  For 
intermediaries,  it  was  important  that  they  would  receive  the  money  from  the  carrier  first, 
without the need to pre-finance a reimbursement to the passenger, which PO 3.2 foresees. Even 
though PO 3.2 is not the cheapest option for intermediaries, because they would carry out the 
reimbursements, and do so free of charge, it is important to note that the stakeholder feedback 
has  shown  that  the  processing  of  reimbursements  is  part  of  the  business  model  of  the 
intermediaries. An EU association of intermediaries expressed the view that the intermediaries 
should be allowed to charge a fee for processing the reimbursement, but that, if passengers did 
not wish to pay the fee, the passengers should be allowed to submit their reimbursement request 
to  airlines  directly.  PO  3.2  and  3.3  reflect  this:  under  PO  3.3,  the  passenger  can  take  this 
decision, and under PO 3.2, the intermediary can decide not to process the reimbursements.  

For  the  passenger  and  consumer  stakeholders  and  national  authorities,  it was  important  that 
passengers could still turn to the carrier if the intermediary does not reimburse the passengers 
in time, which PO 3.2 foresees. In the stakeholder consultation, airlines and intermediaries had 
rejected  this  measure.  An  EU  association  of  intermediaries  supported  the  possibility  for  the 

179 IATA’s Billing and Settlement Plan (BSP) is a system designed to facilitate and simplify the selling, reporting 
and remitting procedures of IATA Accredited Passenger Sales Agents, as well as improve financial control and 
cash flow for BSP Airlines. 

75 

 
 
 
passenger to be able to turn to the airline if the intermediary had not received the payment from 
the airline in time, which PO 3.2 and 3.3 foresee for the intermediary procedure. Intermediaries 
and their associations and an association of airlines are also supportive of an additional 7-day 
payment deadline for intermediaries, which PO 3.2 includes. 

8.1.4  Costs and benefits of the preferred package of policy options 

Table  30  provides  a  summary  of  the  costs  and  benefits  of  the  preferred  package  of  policy 
options, expressed as present value over 2025-2050 relative to the baseline.  

Table 30: Summary of costs and benefits of the preferred package of policy options - expressed as present value 
over 2025-2050 relative to the baseline, in million EUR (2021 prices) 

Preferred package of options (difference to the 
baseline) 

Carriers 
Administrative costs   
Adjustment costs   
Hassle costs savings 
Terminal operators 
Administrative costs   
Adjustment costs   
Intermediaries 
Administrative costs  
Adjustment costs   
Hassle costs savings 
Claim agencies 
Loss of revenues 
National public authorities 
Adjustment costs   
Administrative costs   
Enforcement costs  
Enforcement costs savings  
Hassle costs savings 
Consumers 
Benefits for consumers  
Total costs  
Total costs and loss of revenues 
Total benefits 
Net benefits 
Benefits to costs ratio 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

93.3 
51.2 
35.3 

2.3 
319.5 

57.5 
17.8 
24.0 

1.6 

0.02 
1.4 
30.6 
5.9 
71.4 

2,187.0 
573.6 
575.2 
2,323.6 
1,748.4 
4.0 

The total costs (and loss of revenues for the claim agencies) of the preferred policy package 
are estimated at EUR 575.2 million in addition to the baseline over the period 2025 to 2050. 
For carriers, total costs are estimated at EUR 144.5 million expressed as present value over 
2025-2050 relative to the baseline, of which EUR 51.2 million adjustment costs and EUR 93.3 
million  administrative  costs.  The  largest  share  of  adjustment  costs  is  driven  by  the  right  to 
reimbursement or re-routing, the right to care and the right to PRM assistance for passengers 
having a single contract of carriage (category A), and by the need to put in place the system for 
providing  real-time  information  to  passengers  for  multimodal  ticket  categories  A  and  B 
(separate tickets bundled by intermediaries). The administrative costs are largely driven by the 
requirement  to  report,  following  the  setting  up  of  service  quality  standards  and  a  quality 
management system. For terminal operators, total costs are estimated at EUR 321.9 million 

76 

 
 
  
  
  
  
  
  
  
expressed as present value over 2025-2050 relative to the baseline, of which EUR 319.5 million 
adjustment  costs  and  EUR  2.3  million  administrative  costs.  The  requirement  to  establish  a 
“Single Points of Contact” (SPC) for PRM at multimodal hubs makes up a large part of the 
adjustment  costs  (EUR  316.5  million),  while  the  administrative  costs  are  driven  by  the 
requirement  to  report  on  results,  following  the  setting  up  of  service  quality  standards  and  a 
quality management system. For intermediaries, total costs are estimated at EUR 75.2 million, 
of which EUR 17.8 million adjustment costs and EUR 57.5 million administrative costs. The 
administrative costs are mainly driven by the need to change the information systems, to inform 
passengers on the reimbursement process. Claim agencies may experience losses, estimated at 
EUR 1.6 million, due to  the use of the cheaper  option of an Alternative Dispute Resolution 
(ADR) body. For national public authorities, total costs are estimated at EUR 32 million, of 
which EUR 30.6 million enforcement  costs, EUR 1.4 million  administrative costs and EUR 
0.02 million adjustment costs.  

Total benefits are estimated at EUR 2,323.6 million expressed as present value over 2025-
2050 relative to  the baseline.  The ultimate beneficiaries of this initiative  are the  passengers 
whose awareness about their rights is expected to increase because of the action of carriers, 
intermediaries,  terminal  managers,  and  enforcement  authorities.  In  addition,  passengers 
(including PRM) would enjoy more rights to information and assistance when performing a 
multimodal journey.  

Total benefits for passengers are estimated at EUR 2,187 million, of which EUR 2,165.3 million 
correspond to hassle costs savings. Hassle costs savings are driven by the time saved thanks to: 
the higher clarity on the reimbursement procedure (EUR 1,679.1 million), the Single Point of 
Contact  for  PRMs  (EUR  277.3  million),  the  use  of  a  EU-wide  standardised  form  for 
reimbursements  and  compensation  requests  (EUR  147  million),  the  complaint-handling 
mechanism  for  multimodal  passengers  (EUR  43.3  million)  and  the  assistance  for  PRM 
passengers  travelling  under  category  A  multimodal  tickets  (EUR  18.6  million).  In  addition, 
passengers benefit of assistance rights in the event of a missed connection during a multimodal 
journey (in particular the right to reimbursement and re-routing as well as a right to care in the 
form of e.g. refreshments, meals and accommodation), estimated at EUR 20.1 million, and of 
the use of the cheaper option of an Alternative Dispute Resolution (ADR) body, estimated at 
EUR 1.6 million.  

Carriers and intermediaries also benefit of hassle costs savings due to the complaint-handling 
mechanism for multimodal passengers, estimated at EUR 35.3 million and EUR 24 million, 
respectively, expressed as present value over 2025-2050 relative to the baseline.   

For national public authorities, the enforcement costs savings are estimated at EUR 5.9 million, 
expressed as present value over 2025-2050 relative to the baseline. Costs savings are due to an 
easier  way  to  evaluate  compliance  for  carriers  and  terminal  operators,  without  having  to  do 
more  in  depth  and  costly  monitoring  activities,  the  use  of  standard  claim  forms  which  easy 
monitoring activities and the expected decrease in the number of court cases. In addition, they 
are expected to experience hassle costs saving due to the complaint-handling mechanism for 
multimodal passengers (EUR 71.4 million). 

The preferred policy package is estimated to result in  net benefits of EUR 1,748.4 million, 
expressed as present value over 2025-2050 relative to the baseline. The benefits to costs ratio 
is estimated at 4. 

It should be noted that there is high uncertainty regarding the hassle costs savings estimated for 
the  consumers,  carriers,  intermediaries  and  national  public  administrations.  A  conservative 
approach (lower bound estimate) has been used for the calculations above. When considering 

77 

 
 
the higher bound estimate of the hassle costs savings, the net benefits are estimated at EUR 
4,530.3 million and the benefits to costs ratio at 8.9. 

It should be stressed that only passengers who are aware of their rights, and are convinced that 
they can make use of them and enforce them if needed, will have sufficient trust in the common 
transport system. This trust is the precondition to convince people to use more common instead 
of individual transport. This again is a precondition for a more sustainable transport system. 
The European Parliament,  the Council as well as the European Court of  Auditors have also 
underlined the importance of the protection of passengers (see above section 1).  

8.2  REFIT (simplification and improved efficiency) 

This  initiative  is  part  of  the  Commission  Work  Programme  2023  under  Annex  II  (REFIT 
initiatives), under the heading An Economy that Works for People180. It has an important REFIT 
dimension in  terms  of harmonisation  of rights  across modes as well as simplification of the 
rules  for  passengers  travelling  in  a  multimodal  context.  It  also  presents  simplifications  for 
passengers who use intermediaries to buy their air tickets, as it becomes clear how they will be 
reimbursed (most importantly: by whom and when). 

Table 31: REFIT potential 

Problem 

Simplification potential 

Efficiency potential 

Reduction of regulatory costs 

1 

For passengers and NEBs, 
PO 1.2 has great 
simplification potential, as 
it introduces an EU-wide 
standardised claim form 
that passengers can 
always resort to, instead 
of using claim tools that 
vary between service 
providers. 
In turn, these forms can 
also serve as a 
standardised model to 
which operators may align 
their own systems, which 
would facilitate 
themselves as well as 
NEBs to review a case’s 
factual circumstances, 
should the claim be 
escalated to a complaint.  

For transport operators it will 
be clearer how to comply with 
the existing rights, making the 
implementation more efficient. 
For NEBs it will be easier to 
enforce the EU passenger rights 
acquis, because transport 
operators will have to share 
more data with them about their 
compliance with the rules. 
For passengers it will ease the 
process of submitting a request 
for a reimbursement or a 
compensation and passengers 
will be able to make more 
informed decisions about which 
carrier to choose based on their 
compliance with passenger 
rights. 

For national public authorities, 
the enforcement costs savings 
are estimated at EUR 5.9 
million, expressed as present 
value over 2025-2050 relative 
to the baseline. These costs 
savings are due to an easier way 
to evaluate compliance for 
carriers and terminal operators, 
the use of standard claim forms, 
and the expected decrease in the 
number of court cases.  
For consumers, the use of the 
cheaper option of an Alternative 
Dispute Resolution (ADR) 
body, is estimated to lead to 
costs savings of EUR 1.6 
million, expressed as present 
value over 2025-2050 relative 
to the baseline. In addition, the 
use of the EU-wide 
standardised claim form could 
lead to hassle costs savings 
estimated at EUR 147 million, 
expressed as present value over 
2025-2050 relative to the 
baseline.  
Regarding the trend to use 
increasingly more IT tools for 
reporting and analysis, costs 
may decrease in the medium to 
long term. 
Common rules on enforcement 
across all modes and including 
multimodal journeys facilitates 
a common approach across 

180 COM(2022) 548 final.  

78 

 
 
 
Problem 

Simplification potential 

Efficiency potential 

Reduction of regulatory costs 

modes, which offers synergies 
regarding interpretation of the 
rules, information of 
passengers, and enforcement. 

Given that there are currently 
no rules protecting passengers 
undertaking multimodal 
journeys, the preferred option 
would necessarily imply an 
increase in regulatory burden. 
However, there is a significant 
mitigating factor in this context, 
especially for transport 
operators, where they already 
apply most measures in the 
context of travels within a 
single mode of transport (e.g. 
reimbursement or re-routing, 
care, PRM assistance) – only 
the part of the journey when the 
passenger is switching between 
transport modes was not taken 
into consideration until now. In 
addition, significant hassle costs 
savings are estimated for 
consumers (EUR 339.1 
million), carriers (EUR 35.3 
million), intermediaries (EUR 
24 million) and national public 
authorities (EUR 71.4 million), 
expressed as present value over 
2025-2050 relative to the 
baseline. 

As this option introduces a new 
role for intermediaries, no 
reduction in the regulatory costs 
is expected. However, 
significant hassle costs savings 
are expected for consumers, 
estimated at EUR 1,679.1 
million, expressed as present 
value over 2025-2050 relative 
to the baseline.  

2 

3 

For passengers, PO 2.2 
has a strong simplification 
potential as it improves 
their information on the 
type of ticket they are 
travelling with during a 
multimodal journey, 
where they currently 
would not have easy 
access to such 
information, if at all 
available. Multimodal 
passengers would also 
have improved redress 
tools under the preferred 
option by means of 
complaint-handling 
procedures on the level of 
both industry and national 
authorities, making it 
easier for them to assert 
their rights.  

For passengers, there is a 
potential for cost savings where 
they miss a connection. Costs 
savings due to the right to 
reimbursement/re-routing and 
care are estimated at EUR 20.1 
million, expressed as present 
value over 2025-2050 relative 
to the baseline. 
For PRM in particular, there is 
also an important efficiency 
potential where they would not 
only have a right to free 
assistance when travelling with 
a single multimodal contract but 
would also have the possibility 
to receive a coordinated 
assistance when transferring at 
multimodal hubs (Single Point 
of Contact). Such measures 
ensure that the burden on PRM 
to request such assistance when 
transferring between transport 
modes is reduced.  

For the carriers and the 
intermediaries there is a big 
efficiency potential as the 
reimbursement process and 
deadlines, and information 
channels, will be clear for all 
parties. 

For the passenger PO 3.2 
has a very clear 
simplification potential, as 
the passenger will know 
to which party to turn to 
receive reimbursement. 
Clear deadlines for 
intermediary payments 
are introduced, which 
saves the passenger the 
inconvenience to rely on 
different terms and 
conditions of 
intermediaries. 

8.3  Application of the ‘one in, one out’ approach 

The preferred package of options is  expected to  result in  additional recurrent  administrative 
costs for carriers, terminal operators and intermediaries, estimated at EUR 5.2 million per year, 
of which EUR 5.1 million for carriers181, EUR 0.1 million for terminal operators182 and EUR 

181 The number of carriers affected is 4,450 and the cost per carrier is estimated at EUR 1,137. 
182 The number of terminal operators affected is 546 and the cost per terminal operator is estimated at around EUR 
233.4. 

79 

 
 
 
 
1,401  for  intermediaries183.  These  costs  are  linked  to  the  reporting  on  results,  following  the 
establishment  of  service  quality  standards  and  the  implementation  of  a  quality  management 
system (EUR 5.18 million), and the need for carriers and ticket vendors/tour operators (except 
SMEs) to provide real-time information to passengers for category A and B tickets (EUR 0.01 
million)184.  In  addition,  one-off  administrative  costs  for  carriers  and  intermediaries  are 
estimated at EUR 57.5 million, of which EUR 57.4 million for intermediaries185 and EUR 0.1 
million  for  carriers186.  The  costs  for  intermediaries  are  for  informing  passengers  about  the 
reimbursement  process  and  the  costs  for  carriers  for  updating  the  information  disclosed  to 
passengers on their reimbursement process. 

9  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

The Commission services will monitor the implementation and effectiveness of this initiative 
through  a  number  of  actions  and  obligations  that  are  proposed  in  order  to  ensure  progress 
towards achieving the operational objectives. With a strong focus on enforcement and reporting 
obligations, it is ensured that the NEBs as well as the Commission have a solid base to monitor 
an effective implementation. The implementation of the initiative will therefore be monitored 
by  the  Commission  on  a  regular  basis  –  mainly  based  on  biennial  reports  from  the  NEBs 
containing  information  on  compliance  checks  and  their  results  in  terms  of  detected 
infringements.  In the future, this reporting and monitoring may be automated and digitalised187. 
Other  sources  of  information  to  monitor  the  implementation  of  this  initiative  are  carriers’ 
published  quality  standards  (PM  A.2),  citizen  complaints  and  queries  received  by  the 
Commission  services  directly,  as  well  as  regular  Eurobarometer  surveys  on  the  topic  of 
passenger  rights.  The  continuous  contacts  with  the  national  authorities  that  constitute  the 
membership of the Expert Group on passenger rights will also facilitate the monitoring of the 
implementation  of this initiative. For instance, the Expert  Group may  elaborate and suggest 
standardised procedures and guidelines for controlling compliance across Member States which 
can enhance consistency and comparability of data. In addition, such contacts may help to take 
mitigation measures in a timely manner.  

All of the above-mentioned data will constitute important input to the regular evaluation of the 
legislative instrument that will be the result of this initiative. Five years after the entry into force 
of this legislation, the Commission services should carry out an evaluation to verify to what 
extent the objectives of the initiative have been reached. 

The below table provides an overview of the operational  objectives for the preferred policy 
package and presents relevant indicators for monitoring the objectives. 

Table 32: Operational objectives per preferred option 

PO 

SO 

Specific objectives 

Operational 
objectives 

PO 
1.2 

SO1 
SO2 

Ensure effective 
and efficient 
enforcement across 
all Member States 

Strengthen and 
incentivise NEBs to 
enforce legislation 
within their powers 

Indicators 

Number, type and outcome of complaints 
received by NEBs/ADRs/ECCs 
Number/amounts of sanctions issued by NEBs 

183 The number of intermediaries affected is 6 and the cost per intermediary is estimated at around EUR 233.4. 
184  The  one-off  adjustment  costs  due  to  PM  B.2  serve  a  broader  scope  than  pure  information  reporting.  By 
implementing real-time information provisions and integrating communication systems to multimodal passengers, 
their aim is to enable better services for multimodal passengers in case of disruptions and delays. For this reason, 
the one-off costs have been classified as adjustment costs rather than administrative costs. 
185 The number of intermediaries affected is 123,000 and the cost per intermediary is estimated at EUR 467. 
186 The number of carriers affected is 149 and the cost per carrier is estimated at EUR 467. 
187 The Commission will support the development of a prototype of an e-surveillance tool (Web Crawler). The e-
surveillance  tool  could  automate  the  process  of  monitoring  the  industry’s  compliance  with  passenger  rights, 
specifically online information obligations. 

80 

 
 
 
PO 

SO 

Specific objectives 

Operational 
objectives 

Indicators 

Ensure effective 
complaint handling 
and reimbursement 
for passengers 

Ensure improvements 
in passenger rights 
outcomes 

- 

- 

SO3 

PO
2.2 

Increase protection 
of passengers 
facing travel 
disruption in the 
context of 
multimodal 
journeys 

Ensure delivery of 
passenger rights for all 
passengers travelling 
on multimodal 
journeys  

SO4 

Increase 
information for and 
assistance of PRM 
when switching 
between transport 
modes 

PO
3.2 

SO5  Ensure a clear 
reimbursement 
process when 
passengers booked 
via an intermediary 

Ensure PRM assistance 
switching between 
transport modes 

Ensure adequate 
reimbursement 
procedures (from 
airlines and 
intermediaries) and 
information provided 
to passengers 

81 

Number and outcomes of compliance checks 
done by NEBs 

From the NEBs’ biannual reports:  

- percentage of passengers using the EU-wide 
standardised form out of those who claim 
- 
infringements,  detection 
imposed, and compliance rates 

detected 
ratio,  penalties 

inspections, 

number 

of 

Reports  from  carriers  and  terminal  operators: 
degree of implementation of the obligation to 
better  inform  passengers  about  their  rights 
notably when booking a journey or in case of a 
disruption 
Results of future Eurobarometer surveys about 
the experience of citizens related to the 
application and enforcement of passenger 
rights 

Numbers of Member States that have 
established NEBs for multimodal rights 

Number of NEB enforcement actions in the 
context of multimodal journeys 

Number, type and outcome of complaints 
received from ticket categories a) and b) 
holders 

Number of ticket vendors and tour operators 
providing information to passengers having a 
category b)-ticket on the lack of rights in case 
of missed connections 

Number of passengers travelling multimodal 

Uptake of B2B agreements to offer single 
contracts of carriage for multimodal journeys 
(category A) 

Number of carriers, intermediaries and 
multimodal hubs providing real-time 
information to passengers 

Number of multimodal hubs that have a Single 
Point of Contact 

Number, type and outcome of PRM 
complaints received when switching between 
transport modes 

Number  of  passenger  enquiries  with  NEBs 
regarding 
between 
intermediaries  and  carriers  (NEBs’  biannual 
reports) 

ping-ponged 

being 

intermediaries 

Number of passengers’ complaints with NEBs 
regarding 
(as 
intermediaries  currently  have  no  statutory 
rights,  passengers  cannot  complain  to  NEBs 
today  as  far  as  intermediaries  are  concerned) 
(NEBs’ biennial reports) 

in  general 

 
 
  
  
  
 
 
 
 
82 

 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

1.  LEAD DG, DECIDE PLANNING/CWP REFERENCES 

DG  MOVE,  Unit  B5,  is  the  lead  Directorate  General  for  the  Impact  Assessment  on  Better 
protection for passengers and their rights. An impact assessment was validated in the Decide 
Planning under reference PLAN/2021/11684. 

The Call for Evidence was published in December 2021. 

This  initiative  is  part  of  the  Commission  Work  Programme  2023  under  Annex  II  (REFIT 
initiatives), under the heading ‘An Economy that Works for People’.  

2.  ORGANISATION AND TIMING 

The impact assessment on Better protection for passengers and their rights was coordinated by 
an Inter-Service Steering Group (ISSG) which was established in 2021 to oversee the impact 
assessment  process.  Representatives  from  Secretariat  General,  Legal  Service,  Directorate-
General for Mobility and Transport (MOVE), Directorate-General for Competition (COMP), 
Directorate-General  for  Employment,  Social  Affairs  and  Inclusion  (EMPL),  Directorate-
General  for  Justice  and  Consumers  (JUST),  Directorate-General  for  the  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs  (GROW),  Directorate-General  for  Communications 
Networks, Content and Technology (CNECT), the European External Action Service (EEAS), 
Directorate-General for Neighbourhood and Enlargement Negotiations (NEAR), Directorate-
General for Financial Stability, Financial Services and Capital Markets Union (FISMA) were 
appointed to the Steering Group. 

In  total,  4  meetings  of  the  ISSG  were  organised  to  discuss  this  impact  assessment  (on  9 
December 2021, 22 June 2022, 27 April 2023 and 1 June 2023. The ISSG has in addition been 
consulted  in  writing  on  intermediary  draft  documents  three  times  (August  2022,  September 
2022 and October 2022) 

3.  CONSULTATION OF THE RSB 

The  Impact  Assessment  received  a  positive  opinion  with  reservations  from  the  Regulatory 
Scrutiny  Board  on  7  July  2023.  The  following  table  describes  how  the  RSB’s  main 
recommendations for improvements were addressed: 

1 

 
 
 RSB Comment 

Modification of the IA report 

in  particular 

transport  modes 

(1) The  problem  analysis  should  be  strengthened  to 
present  better  the  scale  of  the  problem  across 
various 
the 
multimodal  travel.  It  should  demonstrate  with 
more  evidence  the  enforcement  problems related 
to the current passenger protection rules. It should 
clearly identify the market failure that the initiative 
tackles  and  explain  why  some  of  the  problems 
identified cannot be mitigated by other measures 
(e.g.  travel  insurance).  It  should  also  clearly 
explain the magnitude of the consequences of the 
problems for all the actors involved. 

The  problem  analysis  has  been  strengthened  for  all 
three problems in sections 2.1 and 2.2, better showing 
their magnitude. 
Further evidence from the 2020 Eurobarometer survey 
and  from  the  targeted  stakeholder  consultation  have 
been  added  to  better  demonstrate  the  enforcement 
problems.  These  problems  are  now  confirmed  and 
detailed  by  various  sources  in  section  2.1.1  (2020 
Eurobarometer  survey  on  passenger  rights,  four 
Commission evaluation studies, two ECA reports and 
the IA’s stakeholder consultation). 
A definition of the size of the multimodal market and 
of the scale of the related problem have been provided 
in  section  2.1.2.  The  same  section  now  includes  a 
reference to the lack of travel insurance. 
Data on the number of air passengers concerned by the 
problem of unclear reimbursement rules when flights 
were booked via an intermediary have been added to 
the problem definition in 2.1.3, along with the number 
of 
request  a 
reimbursement and the number of affected airlines and 
air travel intermediaries in the EU. In section 2.2.6 on 
problem  driver  6,  a  reference  to  Annex  13  has  been 
added,  which  includes  further  evidence  that  airlines 
with an indirect booking model generally do not offer 
on  their  websites  the  possibility  to  request  the 
reimbursement  with  them  directly,  and  instead  refer 
the customer to the intermediary. 

those  passengers  estimated 

to 

Regarding the magnitude of the consequences of the 
problems  for  all  the  actors  involved,  sections  2.1.2, 
2.3.1, 2.3.2 and 2.3.3 were strengthened.  
Section 2.1.2 and 2.3.2: reference is made to a number 
of  consequences  of  the  insufficient  protection  of 
passengers  during  multimodal  journeys,  such  as  the 
lack of information and the lack of assistance. 
Section 2.3.1 (enforcement) and 2.3.3 (reimbursement 
rules): the consumer hassle costs are referred to,  along 
with consumer personal welfare loss and risk of loss 
of consumer confidence in the transport sector. 

2 

 
 
 
 
 RSB Comment 

Modification of the IA report 

to  be  better  anchored 

(2) The  rationale  behind  the  choice  of  the  preferred 
option  needs 
in  a 
strengthened  analysis  of  benefits.  The  report 
should  make  the  benefits  of  this  initiative  more 
evident,  using  more  developed  qualitative 
argumentation  where  enhancing  quantitative 
analysis  is  not  possible.  The  analysis  should 
provide  the  evidence  of  consumer  detriment  and 
convincing arguments on how it would decrease as 
a  result  of  the  new  measures.  It  should  better 
explain  who  would  be  responsible  and  bear  the 
costs  of  providing  assistance  to  persons  with 
reduced  mobility  during  multimodal  travel,  in 
particular  regarding  the  establishment  of  Single 
Point  of  Contacts.  Based  on  a  strengthened 
analysis  of  benefits,  the  report  should  deliver  a 
more  developed  and  comprehensive  assessment 
and  comparison  of  the  options  in  terms  of 
effectiveness,  efficiency  and  coherence  better 
justifying  that  the  expected  benefits  of  the 
preferred package will outweigh its costs. It should 
also strengthen the proportionality assessment of 
the preferred combination of option. 

(3) The  report  should  clarify  and  adjust  the  One  In, 
One  Out  cost  calculations  so  that  all  the  costs 
related to providing information to passengers are 
accurately taken into account in the approach.   

(4) The  report  should  provide  a  more  detailed 
assessment  of  the  impacts  on  competitiveness  of 
the  most  affected  economic  actors.  The 
competitiveness  check  scoring  should  better 
reflect the analysis in the main report, in particular 
regarding 
international 
competitiveness.  The  analysis  of  capacity  to 
innovate  should  go  beyond  the  likely  take  up  of 
digital  solutions  and  expand 
the  data 
management potential. 

price 

into 

and 

the 

Options in the problem area of enforcement: Benefits 
for  consumers  in  terms  of  reduced  hassle  costs  are 
included  in  section  6.1.5  and  explained  in  detail  in 
Annex 4 (section 3.1). 

Options  in  the  problem  area  of  multimodal  rights: 
Benefits for consumers in terms of hassle costs savings 
are included in section 6.1.5 and explained in detail in 
Annex  4  (section  3.2).  Further  explanations  on  the 
functioning  of  Single  Points  of  Contact  were 
introduced  in  sections  5.2.2,  6.1.2  and  in  Annex  4 
(section 3.2). Benefits in terms of reduced hassle costs 
savings have been also  included for carriers (section 
6.1.1),  intermediaries  (section  6.1.3)  and  national 
public authorities (section 6.1.4). Their quantification 
is explained in detail in Annex 4 (section 3.2). 

Options in the problem area of reimbursements when 
tickets  were  booked  via  intermediaries:  Hassle  costs 
and costs savings for consumers have been quantified 
and included in section 6.1.5 and explained in detail in 
Annex 4 (section 3.3). 

The section on the comparison of options (section 7.1) 
has  been  strengthened,  in  particular  by  adding  the 
benefits of the policy options. All policy options result 
in net benefits. 

Section  8.3  has  been  amended  to  reflect  the  one-off 
administrative  costs  for  intermediaries  for  informing 
passengers  about  the  reimbursement  process  and  for 
carriers  for  updating  the  information  disclosed  to 
passengers  on  their  reimbursement  process.  These 
costs have been reclassified from adjustment costs to 
administrative  costs  and  thus  sections  6.1.1,  6.1.3, 
Annex 3 and Annex 4 were also amended to reflect the 
changes. In addition, an explanation was added on the 
reason for classifying one-off costs for implementing 
real-time 
integrating 
information  provisions  and 
communication systems to multimodal passengers as 
adjustment costs rather than administrative costs. 

Annex 5 now contains references to where in the main 
text  the  impacts  on  competitiveness  of  the  most 
affected economic actors were included. The scoring 
has been amended in annex 5. This Annex now also 
expands into the data management potential due to the 
sharing  of  real-time  information  in  the  context  of 
multimodal travel. 

4.  EVIDENCE, SOURCES AND QUALITY 

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

•  contracted  impact  assessment  support  study  carried  out  by  an  external,  independent 

consultant 

3 

 
 
 
 
 
 
 
 
•  Stakeholder consultation activities (see Annex 2) 
•  The Commission’s experience in monitoring and implementing the respective passenger 

rights Regulations 

•  European Court of Auditors Special Report 15/2021: Air passenger rights during the 
COVID-19 pandemic: key rights not protected despite Commission efforts188, Special 
Report no 30/2018: EU passenger rights are comprehensive, but passengers still need to 
fight for them 

•  Evaluations on Regulation (EC) No 1107/2006 concerning the rights of disabled persons 
and  persons  with  reduced  mobility  when  travelling  by  air,  Regulation  (EU) 
No 1177/2010 concerning the rights of passengers when travelling by sea and inland 
waterway and Regulation (EU) concerning the rights of passengers in bus and coach 
transport, published in 2021 (SWD(2021)417, SWD(2021)413 and SWD(2021)415)189 

•  Study on the current level of protection of air passenger rights in the EU190 
•  2020 Eurobarometer survey on EU passenger rights, 2020191 
•  Study on passenger rights in multimodal transport, 2019192 

188 Special Report 15/2021: Air passenger rights during the COVID-19 pandemic: Key rights not protected despite 
Commission efforts. 
189  Published  here:  https://transport.ec.europa.eu/news-events/news/evaluation-confirms-better-protection-air-
ship-and-bus-passengers-thanks-eu-law-2021-12-15_en. 
190  Study  on  the  current  level  of  protection  of  air  passenger  rights  in  the  EU  -  Publications  Office  of  the  EU 
(europa.eu). 
191 https://ec.europa.eu/commission/presscorner/detail/en/ip_19_6814.  
192 https://op.europa.eu/en/publication-detail/-/publication/f176da6f-d9ca-11e9-9c4e-01aa75ed71a1. 

4 

 
 
 
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) 

This annex summarizes the outcome of the consultation activities performed in the context of 
the impact assessment on new rules for making the passenger rights framework resilient and 
future proof. It describes the range of stakeholders consulted, the main consultation activities, 
and provides a succinct analysis of their views and the main issues raised. 

The consultation activities aimed to: 

- 

collect  evidence  and  stakeholders’  views  on  identified  problems,  problem  drivers, 
policy  objectives,  and  draft  policy  measures  and  options  considered  in  the  impact 
assessment; 

-  gather information and opinions on the likely impacts of policy measures and options. 

1.  CONSULTATION METHODS AND STAKEHOLDERS INVOLVED 

Consultation activities took place between December 2021 and January 2023. The following 
table summarises the types of consultation activities, their timing, and their objectives. 

Table 33: Consultation activities conducted  
#  
1   Call for 

Means  

Evidence  

Objective  

2   Public 

Consultation  

3   Targeted 

questionnaire  

4   Targeted 

interviews  

5   Online 

workshops  

the  Commission’s 

Collect  stakeholders’  feedback  on 
understanding of the problem and possible solutions.  
Allow the general public to provide their views on the current 
state  of  play  and  needs  for  additional  policy  action  at 
European level.  
Collect  specific  stakeholders’  views  on  problems,  policy 
objectives  and policy  measures  as  well  as  to  gather 
quantitative  data  on  the  costs  and  benefits  of  the  policy 
measures.  
Explore  stakeholders’  views  on  problems,  objectives  and 
measures,  as  well  as  to  collect  quantitative  estimates  and 
filling  gaps  from  desk  research  and  the  targeted  online 
questionnaire.  
Fill  in  the  gaps  from  the  OPC,  the  targeted  online 
questionnaire and interviews, validate the results and to spur 
a dialogue between relevant stakeholders on selected topics.  

Timing  
20/12/2021 – 
17/01/2022  

14/09/2022 – 
07/12/2022  

18/10/2022 – 
09/12/2022  

14/11/2022 – 
10/01/2023  

13/12/2022 – 
26/01/2023  

6   Modal NEB 
meetings  

Gather  specialised  input  in  relation  to  the  issue  of 
enforcement.  

4 meetings between 
13/10/2022 and 
12/12/2022  

Participants  

58  

173  

185  

40  

93  

128  

Ten  categories  of  stakeholders’  groups  were  targeted  through  these  activities,  ensuring  a 
representation  of  various  interests.  The  table  below  summarises  the  participation  of  these 
groups in the consultation activities. 

Call for 
evidence 

OPC 

Targeted 
questionnaire 

Targeted 
interviews 

Online 
workshops 

Modal 
NEB 
meetings 

for  air  and 

Stakeholder coverage 
Passengers 
consumers 
and 
organisations and representative 
organisations of passengers with 
disabilities (PRM) 
Carriers 
umbrella organisations 
Carriers for waterborne, bus and 
coach,  and 
their 
representative organisations 
ticket  vendors, 
Intermediary 
online travel agencies and travel 
package organisers 

rail  and 

their 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

✓ 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
and 

other 

Stations,  terminal  or  (air)port 
infrastructure 
terminal 
manager 
National  Enforcement  Bodies 
(NEBs)  & 
public 
authorities  at  national  and local 
level 
Alternative  Dispute  Resolution 
bodies (ADRs) 
Insurance 
insolvency protection funds 
Credit card companies 
Claim agencies 
Geographical coverage 
EU 

companies 

& 

✓ 

16  MS: 
AT,  BE, 
BG,  CZ, 
DE,  DK, 
ES, 
FI, 
FR,  HU, 
IE, IT, LT, 
NL, PT 

Non-EU 

US,  UK, 
Canada 

✓ 

✓ 

✓ 

✓ 

✓ 
✓ 

25  MS: 
AT,  BE, 
BG, 
CY,  CZ, 
DE,  DK, 
EE,  EL, 
ES, 
FI, 
FR,  HU, 
IT, 
LT, 
LU,  LV, 
MT,  NL, 
PL, 
PT, 
RO,  SE, 
SI, SK 
Serbia, 
UK,  US, 
Trininad 
and 
Tobago, 

✓ 

✓ 

✓ 

✓ 

✓ 
✓ 

✓ 

✓ 

✓ 

✓ 

✓ 
✓ 

✓ 

✓ 

✓ 
✓ 

All 27 MS 

10 MS : AT, 
CZ, 
DE, 
DK, ES, FR, 
IE,  IT,  NL, 
SE  

16  MS:  AT, 
BE, CZ, DE, 
DK,  ES,  FI, 
FR,  HU,  IE, 
IT,  LU,  NL, 
PT, SE, SK 

✓ 

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

Canada, 
Iceland, 
Switzerland, 
UK, US 

UK, US, IS  Norway, 
UK, US 

IS, 

CH, 
NO, UK 

1.1. Call for Evidence   

Of the 58 stakeholders who answered to the call for evidence, 13 provided in depth position 
papers,  while  45  provided  their  feedback  directly  on  the  Commission’s  website.  Consumer 
organisations,  EU  citizens,  public  authorities,  NGOs  and  environmental  organisations 
responded  to  the  call  for  evidence.  Most  of  the  feedback  was  submitted  by  companies  and 
business  associations  (24  out  of  58),  including  operators  from  all  transport  modes  and 
intermediary ticket vendors, travel agencies, package travel organisers and their representative 
organisations.  Respondents  could  not  find  common  grounds  on  the  issues  related  to 
reimbursements  when  intermediaries  are  involved  (Topic  C),  and  self-cancellation  in 
major crises (Topic D). On the other hand, some respondents agreed on the need for a clearer 
regulatory  framework  on  multimodal  travel  (Topic  B)  and  on  the  need  to  harmonise 
passenger rights across modes (Topic A). Nevertheless, there was a general consensus on the 
need for an update of the passenger rights legislative framework. 

1.2. Open Public Consultation 

The open public consultation (also referred as “OPC”) sought to capture stakeholders’ views 
on  the  magnitude  of  the  problems  and  possible  solutions.  173  stakeholders,  covering  11 
stakeholder groups and 31 countries, responded to the OPC. 

2 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
Figure 8: Participants in the Open Public Consultation 

1.3. Targeted Online Questionnaire   

Figure 9: Participants in the Targeted Online Questionnaire 

1.4.Targeted interviews   

Overall, 40 stakeholders, from 10 EU Member States168 and 3 non-EU countries169, as well as 15 
pan-European  organisations  and  1  international  organisation,  participated  in  the  targeted 
interviews. The selection of the stakeholders aimed to ensure a balance in terms of geographical 
coverage and in terms of organisational characteristics - i.e. big and small carriers and terminals, 
low-cost  and  network  carriers,  international  and  regional  operators),  which  led  also  to  the 
involvement of extra-EU actors (i.e. major credit card companies active in Europe) and one 
international organisation170. Additionally, two stakeholders based in the United Kingdom and 
in Iceland were included due to their relevance to the study as their services are widely used by 
European passengers (e.g. credit card and travel planning services)). These two stakeholders 
have provided precious insights, clarifying the role of the intermediaries if the proposed policy 
measures  would  apply,  as  well  as  detailing  potential  challenges  deriving  from  their 
implementation. To be noted that all the extra-EU actors also have businesses in the EU.   

1.5. Online workshops  

During  the  consultation  process  three  online  workshops  were  organised:  the  first  two 
workshops were structured as a plenary session to present the preliminary results of the work, 
followed by a break-out rooms session to spur a dialogue amongst stakeholders on the proposed 
policy  measures.  The  third  workshop  was  structured  as  a  plenary  session,  providing  for 
opportunity  for  interaction  amongst  participants  in  the  form  of  a  poll  and  Q&A  sessions. 
Overall, 51 stakeholders, covering 8 stakeholder groups171, 16 Member States172 and 3 non-EU 
countries173,  as  well  as  12  pan-European  organisations  and  3  international  organisations174 

3 

 
 
 
 
 
 
 
attended the three online workshops. The same considerations regarding representativeness as 
for the targeted interviews presented above apply.  

Table 34: Workshop participation  
#   

Topic  

Date  

Organisations  

1   Reimbursement of air passengers in case of booking with an intermediary ticket vendor.  
2   Insufficient protection for passengers making multi-modal journeys.  
3   Revised and preliminary policy measures suggested by stakeholders during the consultation 

process and preliminary policy options.  

13/12/2022  
15/12/2022  
26/01/2023  

24  
22  

45 

1.6. Meetings with National Enforcement Bodies  

As  part  of  the  consultation  strategy,  several  modal  expert  group  meetings  of  NEB 
representatives were held which allowed to gather specialised input in relation to the issues 
of  enforcement  and  multimodality.  The  meetings  were  organised  through  both  an  initial 
plenary session to illustrate the findings and consequent breakout rooms to discuss with NEBs 
and  gather  their  feedback  on  the  proposed  measures.  The  outcome  of  these  meetings  was 
information on the NEBs’ views on the proposed policy measures, which have been analysed 
together with all the data collected though the other consultation activities.   
The  NEBs  meetings  have  been  organised  per  mode  of  transport,  as  illustrated  in  the  table 
below.   

Table 35: Meetings with National Enforcement Bodies  
#  
Topic  
1   Informative session on the project  

Date  
13/10/2022  

# of NEB 
participants  
27  

2   Meeting  of  NEBs  under  Regulation  (EC)  No  1371/2007 
concerning the rights of passengers travelling by train  

28/10/2022  

3   Meeting  of  NEBs  under  Regulation  (EU)  No  1177/2010 

concerning the rights of passengers travelling by sea  
Meeting of NEBs on the application of Regulations (EC) No 
261/2004 on air passenger rights and (EC) No 1107/2006 on 
rights of persons with disabilities or reduced mobility when 
travelling by air  
Meeting  of  NEBs  under  Regulation  (EU)  No  181/2011 
concerning  the  rights  of  passengers  travelling  by  bus  and 
coach  

4  

5  

24/11/2022  

06/12/2022  

12/12/2022  

21  

27  

28  

21  

Countries  
BE, DE, DK, ES, FR, IT, UK  

AT, BE, CZ, DK, DE, IE, EL, ES, HR, 
IT, LV, LU, HU, NL, PL, PT, SI, SK, 
FI, SE, CH  
AT, BE, BG, DK, DE, EE, IE, EL, FR, 
HR, IT, CY, LV, LT, LU, MT, NL, PO, 
PT, RO, SI, FI, SE, NO  
AT, BE, BG, CZ, DK, DE, EE, IE, EL, 
ES, FR, HR, IT, CY, LV, LU, HU, MT, 
NL, PL, PT, SI, SK, FI, SE, IS, NO, CH  
AT, BE, CZ, DK, DE, EE, IE, EL, ES, 
FR, HR, IT, CY, LT, LU, NL, PT, RO, 
SK, FI, SE  

2.  Analysis of the results of the stakeholder consultation  

An overview of the main results of the stakeholder consultation is provided in the next sections, 
highlighting  the  agreements  and  disagreements  amongst  respondents.  As  the  problems  and 
objectives have developed during the IA process, the wording presented below may not mirror 
completely the problems presented in the main body of the SWD. 
Unless  specified  otherwise,  figures  and  percentages  refer  to  replies  to  the  targeted 
questionnaire. 

2.1. Problem 1: Insufficient enforcement of passenger rights in all modes 

2.1.1. Problem aspects and policy objective 

-  “Carriers,  terminal  operators,  and  NEBs  apply  EU  passenger  rights  legislation  in 
different ways”: 71% (105 out of 149) of respondents to the targeted questionnaire strongly or 
somewhat  agree  that  this  is  an  important  problem,  while  10%  (15  out  of  149)  strongly  or 
somewhat disagree. 
- “The enforcement of EU passenger rights legislation by NEBs is neither harmonised nor 
consistent”: 67% (99 out of 148) of respondents agree that the problem is important, while 
16% (23 out of 148) disagree. Similarly, 70% of respondents to the OPC (117 out of 169) agree 
with the statement that the enforcement of passenger rights varies greatly across the EU. 

4 

 
 
 
 
  
 
  
 
 
 
- The detail by stakeholders’ groups is presented in the graphs below. 

Figure 3 - Level of agreement with problem aspect 1: carriers, terminal operators, and NEBs apply EU passenger rights 
legislation in different ways (Targeted stakeholder questionnaire) 

Figure 4 - Level of agreement with problem aspect 2: the enforcement of EU passenger rights legislation by NEBs is neither 
harmonised nor consistent (Targeted stakeholder questionnaire)  

93% (140 out of 151) of respondents to the targeted questionnaire expressed their agreement 
with the objective of ensuring that passengers fully enjoy their rights. 

Figure 5 - Level of agreement with the objective: improving enforcement of passenger rights in all transport modes (Targeted 
stakeholder questionnaire) 

63%  (106  out  of  166)  of  respondents  to  the  OPC  considered  the  objective  of  improving 
enforcement of passenger rights in all transport modes as of high/medium-high relevance. 

2.1.2. Policy Measures 

5 

 
 
 
 
 
 
 
 
  
 
 
 
 
 
“Obliging  carriers,  terminal  managers,  ticket  vendors  and  tour  operators  to  provide 
NEBs with relevant documents and information at the NEBs request”: 

-  Half of the 16 passenger organisations replying to the targeted questionnaire declared 

that this legislative measure would bring a strong or very strong contribution. 

-  Carriers, ticket vendors and infrastructure managers were more sceptical. Indeed, 14 out 
of 17 airlines and 7 out of 20 carriers for rail, waterborne, bus and coach think that this 
measure would bring only  a slight  contribution or no contribution  at  all. 9 out  of 13 
ticket  vendors, and 9 out  of 14 infrastructure managers, believe that it would have a 
moderate contribution. 

-  During the NEB meeting on Air and Air PRM, it appeared that some Member States 
already have regulation in place to help NEBs gather information. However, other NEBs 
explained that the measure would be useful since the possibility for NEBs to request 
information is currently restricted to carriers, leaving out terminal managers and ticket 
vendors. Moreover, during the meeting on bus and coach, NEBs claimed that having a 
legal obligation at EU level could foster the sharing of information in those cases where 
national legislation is absent or unenforced. The results are confirmed in the targeted 
online questionnaire, where 29 out of 44 NEBs reported that the policy measure would 
bring a very strong or strong contribution. 

“Obliging  carriers  to  establish  a  quality  management  system,  monitor  and  publish  the 
related performance”: 

-  Half of the 16 consumer organisations replying to the targeted questionnaire declared 
that the establishment of a quality management system would (strongly) contribute to 
solving the problem. Half of them as well declared that gathering and publishing the 
data would have a slight contribution. In the OPC, 17 out of 19 consumer organisations, 
5 out of 7 PRM organisations and 34 out of 50 EU citizens assigned high or medium-
high relevance to the measure ensuring that carriers and terminal operators publish data 
on their compliance with EU passenger rights. 

-  Air carriers  and their umbrella organisations believe this policy measure would only 
have a slight or no contribution (15 out of 17 air carriers for the measure on establishing 
a quality management system, and 16 out of them for monitoring and publishing the 
data).  12  out  of  20  carriers  for  waterborne,  rail  and  bus  and  coach  had  no  opinion 
regarding the idea of a quality management system, and 4 of them reported it would 
have a slight or no contribution. Out of those same 20 carriers, 10 had no opinion on 
gathering  and  publishing  the  data  and  6  reported  it  would  have  a  slight  or  no 
contribution. One interviewed waterborne carrier expressed concerns regarding the risk 
of customers misunderstanding and misinterpreting the published data. 

“Introduction of a service quality standard for terminal operators”: 

-  7 out of 16 passenger organisations stated in the targeted questionnaire that the measure 
would only be slightly effective. One interviewed consumer organisation supporting the 
measure  suggested  that  this  should  apply  to  intermediaries  too,  and  pointed  out  that 
these requirements may take inspiration from the Rail Passenger Rights Regulation. 
-  8  out  of  14  terminal  operators  claim  that  this  measure  would  have  a  (very)  strong 
contribution  although,  in  a  written  contribution,  one  terminal  operator  noted  that  it 
might require additional investments in staffing and IT systems for its implementation. 

“Implementation  of  a  standardised  EU-wide  form  for  complaints”  (proposed  both  as 
voluntary and legislative measure): 

-  9 out of 16 responding passenger organisations supported it as a legislative measure and 
8 out of 16 as a soft policy measure. The only PRM organisation contributing expressed 
that an EU-wide form would bring a very strong contribution. 

-  13 out of 19 air carriers believe the soft policy measure would have a strong or very 

strong contribution. The support was lower for a legislative measure. 

6 

 
 
 
 
 
-  Carriers for rail, waterborne and bus and coach were more sceptical with respect to both 
the soft policy measure (10 out of 21 expressed no opinion, 5 claimed the contribution 
would be slight or null, another 5 claimed it would be moderate) and legislative measure 
(10 out of 20 expressed no opinion, 9 claimed the contribution would be slight or null). 
-  25 out of 44 NEBs expressed a favourable view towards this policy measure by claiming 

it would have a strong or very strong contribution. 

“Improving the enforcement with enhanced cooperation between ADRs and NEBs”: 

-  3 out of 4 ADRs agreed that it would strongly contribute to solving the problem. They 
suggested the inclusion  of an obligation for transport operators to  inform  passengers 
about the relevant ADRs. One ADR stated that the role of NEBs in enforcing passenger 
rights  is  often  overestimated,  as,  in  many  Member  States,  NEBs  do  not  deal  with 
individual passengers’ complaints, while ADRs have more experience on the matter. 
-  12 out of 19 airlines claim that the measure would bring no contribution, while 8 out of 
13 ticket vendors and 8 out of 16 passenger organisations believe the measure would 
bring a moderate contribution. 

-  9 out of 14 infrastructure managers replying to the targeted consultation consider the 
measure to have a very strong or strong contribution and 22 out of 46 NEBs claimed 
that it would have a strong or very strong contribution. 

Two policy measures emerged during the targeted stakeholder consultation.  

-  The policy measure requiring NEBs to make a risk assessment and implement their 
monitoring activities according to this risk assessment was inspired by the ECA’s 
recommendation “to  give the Commission  mandate to  perform quality  control of the 
enforcement  practices  of  NEBs”.  Stakeholders  were  divided  regarding  the  ECA’s 
recommendation: 41 out of 146 of the stakeholders (strongly) supported it (including 7 
out  of  8  consumer  and  passenger  organisations  that  expressed  an  opinion)  while  39 
stakeholders  (almost  all  carriers,  and  34%  of  the  NEBs)  (strongly)  opposed  it. 
Accordingly, it was decided to assess the impacts of a slightly different policy measure 
which would require NEBs to make a risk assessment and allow the Commission to 
assess such risk assessments and whether the monitoring activities implemented 
by the NEBs are appropriate to the risks they identified.   

-  Both the European Passenger Federation and BEUC, the two EU-level consumer and 
passenger representative organisations highlighted the need to improve the awareness 
of  passengers  about  their  rights,  by  promoting  accurate  information  sharing  from 
transport  operators  during  booking,  when  a  disruption  occurs,  and  on  the  complaint 
handling mechanisms. Their view was supported by the latest Eurobarometer report on 
passenger rights, showing very low citizens’ awareness of their rights. Consequently, it 
was  decided  to  add  a  policy  measure  obliging  operators  to  require  carriers  and 
terminal  operators  to  better  inform  passengers  about  their  rights  in  particular 
when booking a journey or in case of a transport disruption with the view to raise 
their awareness about passenger rights. 

2.2. Problem 2: Insufficient protection for passengers making multimodal journeys 

2.2.1. Problem aspects and policy objective 

-  “Passengers are not protected by existing rights when switching between transport 
modes”: 89 out of 145 respondents to the targeted questionnaire strongly or somewhat 
agree that the problem is important, while 26 respondents fully or somewhat disagree. 
The  latter  are  mainly  carriers  (for  all  modes)  and  their  umbrella  organisations,  who 
during the interviews and the dedicated workshop argued that it is too early to regulate 
the sector, as a legislative framework might disrupt an underdeveloped but emerging 
industry. In the OPC, 70% (117 out of 166) of respondents agreed somewhat/fully that 

7 

 
 
 
 
 
 
 
the problem is important. In reply to the call for evidence, one passenger organisation 
claimed that the certainty of reaching the destination must be always guaranteed, even 
in the case of serious delays and independently from the travel mode(s) used. 

-  “Persons  with  disabilities  or  reduced  mobility  (PRM)  are  not  provided  with 
assistance  when  switching  between  transport  modes”:  50%  (69  out  of  138)  of 
respondents agree that this is an important problem, while 16% (22 out of 138) strongly 
or  somewhat  disagree,  14%  (19  out  of  138)  are  neutral  and  20%  (28  out  of  138) 
expressed no opinion. In the OPC, 57% (95 out of 167) of respondents consider this to 
be an important problem. 

-  The detail by stakeholders’ groups is presented in the graphs below. 

Figure 6 - Level of agreement with problem aspect 1: passengers are not protected by existing rights when switching 
between transport modes ((Targeted stakeholder questionnaire)  

Figure 7 - Level of agreement with problem aspect 2: persons with disabilities or reduced mobility are not provided 
with assistance when switching between transport modes (Targeted stakeholder questionnaire) 

71% (101 out of 143) of respondents to the targeted questionnaire agree with the objective of 
proposing  an  adequate  framework  of  rules  for  the  protection  of  passengers  who 
experience travel disruptions when changing from one transport mode to another, while 
11% (16 out of 143) disagree with this objective. 
In the OPC, 63% (104 out of 165) of respondents assess the objective’s relevance as high or 
medium-high, while 16% (26 out of 165) believe it is of low/medium-low relevance. 

8 

 
 
 
  
 
 
 
 
Figure 8 - Level of agreement with the policy objective of proposing an adequate framework of rules for the protection of 
passengers who experience travel disruptions when changing from one transport mode to another (Targeted stakeholder 
questionnaire) 

2.2.2. Policy Measures  

“Encouraging  carriers  and  ticket  vendors  to  provide  additional  information  to 
multimodal passengers” (measure proposed both as voluntary and obligatory): 

-  11 out of 16 consumer organisations replying to the targeted questionnaire expressed 
support  for  the  legislative  measure,  claiming  it  would  have  a  strong  or  very  strong 
contribution.  One  consumer  organisation  argued,  in  a  written  contribution,  that 
passenger  protection  for  ticket  category  B  should  not  be  conditioned  to  the  pre-
contractual  lack  of  information  [under  the  current  policy  measures  for  category  B, 
passengers are protected except if informed otherwise] as it would mean that passengers 
would  in  practice  remain  unprotected;  and  that  in  case  of  travel  disruptions, 
intermediaries should be held liable to inform consumers in real-time, to inform them 
on the re-routing options, as well as on their rights and how to exercise them. 

-  Airlines  and their representative organisations stated, during the workshop, that they 
could  not  be  legally  bound  to  provide  information  that  they  often  do  not  have 
(connecting times and connecting journeys). In the OPC, they pointed out that providing 
real-time  information  on  journey  disruption  is  unfeasible  if  passengers  booked  via  a 
ticket  vendor.  Umbrella  organisations  explained  that  this  measure  would  increase 
operational  costs  mainly  due  to  the  necessary  updates  of  the  IT  systems  supporting 
booking  arrangements  and  to  additional  resources  needed  to  identify  the  relevant 
information.  In  the  targeted  consultation,  one  rail  carrier  reported  that  the  current 
technical limitations make real-time information impossible to implement. 

-  On the other hand, ticket vendors were generally supportive of the introduction of a soft 
policy measure encouraging carriers and ticket vendors to provide passengers with 
information such as time schedules on every part of their multimodal trip. They 
were less supportive of the provision of real-time information and claimed that such a 
solution would only be feasible if carriers were obliged to share information with 
intermediaries. One intermediary (extra-EU actor) argued that it would not be feasible 
for ticket vendors to grant “full passenger rights” for ticket category B for the following 
reasons: (i) disruptions are outside of the intermediary’s control; (ii) operators would 
have to cooperate with ticket vendors to make this work, but do not appear to be willing 
to do so if they did not make the travel connection themselves; (iii) when tickets are 
bought, intermediaries pass the money on to operators, hence they wouldn’t have the 
financial capacity to reimburse or compensate. 

-  6 out of 11 intermediaries replying to the targeted questionnaire claimed the legislative 
measure would only have a slight contribution; 4 of them think it would be moderate. 

9 

 
 
 
 
 
 
 
- 

Infrastructure and terminal managers were more supportive of a legislative solution than 
a soft one. During the workshop, an airport representative, in  line with  the umbrella 
organisations for air carriers, stressed the importance of pre-notifying requests for PRM 
assistance for the proper functioning of other proposed measures. One organisation of 
airports  and  one  organisation  of  rail  stations  stressed  the  need  for  adequate 
communication channels to support information provision. 

“Introducing  a  multimodal  complaint  handling  system”  (measure  proposed  both  as 
voluntary and obligatory): 

-  Half of the 16 passenger organisations replying to the targeted questionnaire claimed 
that the soft policy measure would bring no contribution or only a slight contribution, 
whereas the majority (12 out of 16) believed that the legislative measure would have a 
strong contribution. 
In the same survey, airlines and their organisations expressed their concerns: 9 out of 
13 airlines stated that the legislative measure would bring no contribution (7 out of 17 
for the soft measure). In the dedicated workshop, they argued that this measure can only 
apply if there is a contract between carriers and intermediaries; if not, carriers cannot be 
held accountable for travel disruptions happening in other legs of the journey. 

- 

-  Carriers for waterborne, rail, bus and coach were more divided: 14 out of 25 replying to 
the  survey  believe  that  both  the  soft  and  legislative  measure  would  have  a  slight  or 
moderate  contribution.  In  an  interview,  one  umbrella  organisation  for  these  modes 
stressed that multimodal complaints are very rare, hence these measures would imply a 
cost that is not outweighed by a clear benefit. 

-  10 out of 11 ticket vendors claimed that the voluntary and obligatory measures would 
have  a  slight  or  moderate  contribution  (6  out  of  11  for  the  soft  measure).  In  the 
workshop,  ticket  vendors  argued  that  it  would  increase  the  cost  of  tickets,  making 
multimodal journeys an economically unsustainable alternative. 

“Introducing  a  right  for  passengers  to  be  reimbursed  or  re-routed  in  case  of  a  travel 
disruption” (measure proposed both as voluntary and obligatory): 

-  13 out of the 16 passenger organisations replying to the targeted survey stated that the 
legislative measure would bring a very strong or strong contribution, while only 5 of 
them think the same of the soft policy measure. One consumer organisation suggested 
that,  in  case  passenger  opt  for  re-routing,  intermediaries  should  be  liable  to  re-route 
them at no extra cost. In case they fail to do so, any additional cost sustained by the 
passenger as a result (e.g., new tickets, taxi, etc.) should be refundable. 

-  11 out of 25 carriers for rail, waterborne, bus and coach, believe that the soft measure 
would bring no contribution or only a slight one, while 16 of them consider that the 
legislative measure would have a moderate or slight contribution. During the relevant 
workshop, one carrier for rail and an umbrella organisation for rail operators pointed 
out that the proposed measure does not clearly designate the party responsible for the 
reimbursement and re-routing in case of a missed connection, and that it would increase 
the ticket prices, making multimodal journeys less attractive. This view was supported 
by  one  rail  carrier  in  the  call  for  evidence  and  by  one  consumer  organisation  in  the 
targeted online questionnaire. 

-  Conversely, 9 out of the 11 intermediaries replying to the targeted survey agreed that 
the proposed measure would have a strong contribution, if implemented as a legislative 
measure, and provided that there are B2B agreements with respective liabilities. 

“Introduction of passenger rights (i.e. right to care, reimbursement, rerouting, alternative 
transport contract) for ticket category B, which will apply in case of disruptions during 
multimodal journeys comprised of separate tickets integrated by intermediaries, except 
where  the  intermediary  can  prove  that  the  passengers  were  properly  informed  by  the 

10 

 
 
  
 
 
intermediary, before purchase, that the integrated separate tickets do not entitle them to 
the full set of passenger rights”: 

-  Passenger and PRM organisations reported mixed views: 1 out of 3 PRM organisations 
and 5 out of 16 consumer organisations consider that the measure would bring a (very) 
strong  contribution,  while  1  out  of  3  PRM  organisations  and  6  out  of  16  consumer 
organisations believe it would bring no contribution. During the relevant workshop, one 
passenger organisation stressed the need to better clarify the role of intermediaries in 
case of journey disruptions. 

- 

-  11 out of 12 airlines responding to the targeted survey thought that this measure would 
not bring any contribution. Yet, the airlines attending the dedicated workshop confirmed 
that  intermediaries  should  be  responsible  for  the  protection  of  passengers  in  case  of 
separate  tickets  integrated  by  ticket  selling  entities.  8  out  of  25  carriers  for  rail, 
waterborne,  bus  and  coach  claimed  that  the  measure  would  have  a  moderate 
contribution,  while  9  of  them  believe  the  measure  would  have  only  a  slight  or  no 
contribution.  
In  the  workshop,  ticket  vendors  argued  that  providing  a  full  set  of  passenger  rights 
would not be financially viable as intermediaries do not have access to ticket money to 
provide protection to passengers. At the same time, in the targeted online questionnaire, 
with  10 out  of 11 ticket  vendors agreeing  with  the relevance of this policy measure, 
which might be due to the suggested possibility for them to be exempted where they 
inform passengers properly on the absence of the full set of passenger rights. In the OPC 
and in interviews, intermediary ticket vendor representatives argued that ticket vendors 
should not be held responsible for journey disruptions, as they are not involved in the 
operations. 

“Introduction of a single point of contact (SPC) for PRMs”: 

-  7 out of the 15 consumer organisations and 2 out of the 4 PRM organisations replying 
to the targeted questionnaire claimed the measure would have a strong or very strong 
contribution. During the dedicated workshop, one PRM representative underlined that, 
as PRMs require different types of assistance, there would be many issues to consider 
in defining the role/scope of the SPC and expressed concerns if the measure was soft 
law.  One  interviewed  PRM  organisation  remarked  that,  while  the  SPC  would  be  of 
considerable help to PRMs to obtain assistance and relevant information, it will only be 
effective if it is able to withstand the high demand for assistance. 

-  10 out of 17 airlines stated that the measure would bring a (very) strong contribution. 
During the workshop, airlines and their umbrella organisation expressed their support 
for it, while stressing the importance of establishing clear channels of communication 
and defining the scope of the services to be provided. One interviewed organisation of 
airlines  argued  that  the  SPC  should  be  the  terminal  operator,  as  in  the  case  of  air 
transport. 15 out of 25 carriers for rail, waterborne, bus and coach responding to the 
targeted survey stated that it would only bring a moderate or slight contribution. One 
interviewed  umbrella  organisation  for  rail  operators  pointed  out  that  the  cost  of 
establishing an SPC would be significant on smaller operators. One organisation for rail, 
waterborne, bus and coach stated that carriers should be free to organise this service in 
the most convenient way for them. And an interviewed bus carrier reported that the SPC 
would also  be useful in  mapping the demand for PRM assistance or the (un)suitable 
infrastructure, to encourage local communities to improve the situation. 

-  One intermediary (extra-EU actor) supported the measure and stated that intermediaries 
could direct passengers to those SPCs when they book their tickets, although it should 
be clarified that intermediaries cannot have control over the SPCs’ process or operation. 
-  6  out  of  the  11  infrastructure  and  terminal  managers  replying  to  the  targeted  survey 
believe that the measure would (very) strongly contribute towards the policy objective. 

11 

 
 
 
 
Overall, consumer organisations and PRM representatives expressed a general preference for 
the implementation of legislative policy measures addressing the right to rerouting, care and 
information in case of disruptions, as opposed to soft measures and market-based solutions (i.e. 
insurance). In the public consultation, some PRM representatives suggested the introduction of 
a compensation to PRMs in case of lack of assistance during multi-modal journeys.  

The following views have been reported by  NEBs and national, regional and local public 
authorities in relation to the proposed policy measures for problem area 2:  

- 

- 

In the public consultation, 4 public authorities stressed the need to provide additional 
information to passengers regarding ticket categories and alternative connections. 
In the targeted questionnaire and the interviews, NEBs pointed out that the measures 
providing for the introduction of a voluntary agreement between NEBs, or any other 
designated body or authority, enabling passengers to direct complaints to any NEB in a 
Member  State,  would  entail  significant  bureaucratic  costs,  especially  for  smaller 
regional/local  NEBs,  to  run  the  communication  channels  and  to  provide  for  internal 
coordination.  Conversely,  another  interviewed  NEB  highlighted  the  usefulness  of 
establishing  a  framework  of  communication  between  NEBs  for  cross  border  cases. 
Moreover,  some  NEBs  attending  the  meeting  on  bus  and  coach  pointed  out  that  the 
measure would be beneficial, but it could only be effective if a multimodal passenger 
rights  framework  is  to  be  established,  as  NEBs  can  only  act  within  the  existing 
regulation. 

Problem  3:  Reimbursement  rules  are  unclear  when  flights  were  booked  via  an 
intermediary 

2.3.1 Problem aspects and policy objective  

-  “Passengers do not always enjoy the right to reimbursement within seven days of 
a  flight  cancellation  when  booking  via  an  intermediary  ticket  vendor  due  to 
insufficient  awareness  from  the  passenger  on  the  respective  roles  and 
responsibilities of such vendors and carriers”: 77% of respondents (72 out of 93) to 
the targeted survey strongly or somewhat agree that this problem is important, while 
11% (10 out of 93) fully or somewhat disagree. Similarly, in the OPC, 70% (110 out of 
157) of respondents agree somewhat/fully that the problem is important. 

-  “Carriers cannot always meet the obligation to reimburse passengers within seven 
days  following  the  cancellation  of  a  flight  booked  via  an  intermediary  ticket 
vendor”: 89% of respondents (83 out of 93) to the targeted questionnaire strongly or 
somewhat  agree  this  problem  is  important.  In  the  OPC,  64%  (101  out  of  157)  of 
respondents consider it as important. 

-  “Intermediary  ticket  vendors  sometimes  have  no  statutory  rights  or  obligations 
with respect to carriers and passengers in cases involving reimbursement”: 75% 
(70 out of 93) of respondents to the targeted survey strongly or somewhat agree that the 
problem is important, while 15% (14 out of 93) had no opinion. However, in the OPC, 
45% (54 out of 156) of respondents fully/somewhat found it important, while 32% (50 
out of 156) fully/somewhat disagreed, and 18% (28 out of 156) do not have an opinion 
and  5%  are  neutral.  On  the  latter  two  problem  aspects,  interviewed  tickets  vendors 
claimed that the main obstacle to reimbursement is the absence of obligation for carriers 
to provide refunds to the intermediaries in a reasonable timeframe. On the other hand, 
airlines argued, in interviews and in the workshop, that intermediaries should be obliged 
to either share passenger data (contact details) with the operating airline or be liable for 
eventual reimbursements. 

12 

 
 
 
   
 
 
  
Figure 9 - Level of agreement with problem aspect 1: passengers do not always enjoy the right to reimbursement within 
seven days of a flight cancellation when booking via an intermediary ticket vendor (Targeted Stakeholder Questionnaire)  

Figure 10 - Level of agreement with problem aspect 2: carriers cannot always meet the obligation to reimburse passengers 
within seven days following the cancellation of a flight booked via an intermediary (Targeted Stakeholder Questionnaire)  

Figure 11 - Level of agreement with problem aspect 3: intermediary ticket vendors sometimes have no statutory rights or 
obligations  with  respect  to  carriers  and  passengers  in  cases  involving  reimbursement  (Targeted  Stakeholder 
Questionnaire)  

There was strong support from most stakeholders for the policy objective of ensuring the 
swift reimbursement of air passengers booking via an intermediary, with 72% (67 out 
of 93) of respondents to the targeted online questionnaire agreeing with it, and 17% (16 out 
of 93) disagreeing. Similarly, 67% (106 out of 158) of respondents to the OPC consider the 
objective relevant, whereas 11% (18 out of 158) consider it to be of medium relevance. 

Figure  16  -  Level  of  agreement  with  the  policy  objective:  policy  objective  of  ensuring  the  swift  reimbursement  of  air 
passengers booking via an intermediary (Targeted Stakeholder Questionnaire)  

13 

 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
Overall, a consensus was reached across stakeholder groups during the workshop on the need 
to  clearly  define  the  liability  and  responsibilities  regarding  the  provision  of  information  to 
passengers and the processing of refunds. This view was stressed by passenger organisations in 
the call for evidence and by business organisations and associations through the OPC. 

2.3.2. Policy Measures 

3 options to ensure the swift reimbursement of air passengers booking via an intermediary were 
identified and assessed. 

Option A: passengers having intermediaries as the first point of contact, which receive the 
payments from the airlines first, and with the possibility for passengers of going to the 
airline in case they do not receive their reimbursement within 7 days. 

-  One  passenger  organisation  attending  the  workshop  claimed  that  refunds  should  be 
handled by the vendor, using the same payment channel applied by the passenger during 
the  purchase  of  the  ticket  and  providing  for  the  full  amount  of  the  ticket.  Another 
passenger  organisation  expressed  support  for  option  A  if  paired  with  a  mutual 
enforceable right of redress, refund money following the original money flow and a 14 
days deadline. 

-  Airlines  and  their  representative  organisations  claimed  (in  the  call  for  evidence,  the 
OPC,  interviews  and  the  workshop)  that  this  option  would  only  be  effective  if 
intermediaries were obliged to provide airlines with relevant passenger data. One 
air carrier explained in the targeted questionnaire that, since some ticket vendors operate 
without a contract with the carrier, the carrier does not have sufficient information to 
process reimbursements. 

-  On the other hand, ticket vendors and travel agencies noted that this option does not 
provide additional clarity nor certainty on the party responsible for the reimbursement.  
-  13 out of 17 passenger organisations claimed that allowing the passenger to claim the 
reimbursement from the carrier in case reimbursement is not received from the 
ticket vendor within 7 days would have a strong or very strong contribution towards 
the solution of the problem. However, ticket vendors (9 out of 13) and airlines and their 
representative  organisations  (17  out  of  20)  expressed  their  disagreement  with  the 
measure. 

-  Similarly, 11 out of 17 consumer organisations stated that ensuring that air carriers 
implement  an  accessible  procedure  to  allow  passengers  to  easily  identify 
themselves and provide payment details to the airline would bring a very strong or 
strong contribution. Ticket vendors (9 out of 13) and airlines (11 out of 19), on the other 
hand, claimed that the policy measure would bring no contribution at all. In a written 
follow-up to the workshop, an umbrella organisation of ticket vendors emphasised that 
the  right  to  seek  a  refund  from  the  intermediary  should  only  be  applicable  if  the 
intermediary had received the refund from the airline but had not refunded the customer. 
On the other hand, the right to redress from the intermediary does not apply if the airline 
did  not  refund the intermediary within 7 days,  and the customer received the refund 
from  the  airline.  Additionally,  as  a  further  feedback,  an  umbrella  organisation  of 
intermediary ticket vendors expressed their support for option A, only if the following 
changes apply: (i) a mutual enforceable right to redress; (ii) the money flow of refund 
follows the same purchase flow of tickets; (iii) a deadline of 14 days for tickets booked 
through an intermediary ticket vendor while the deadline for a carrier to refund to the 
intermediary ticket vendor remains at 7 days; (iv) if the airline does not fulfil its refund 
obligation within the deadline, the ticket intermediary decides whether to pre-finance 
the refund or refers the customer to the airline for a refund, providing passenger contact 

14 

 
 
 
  
 
 
details.  During  the  workshop  on  policy  measures  and  options,  intermediary  ticket 
vendors stressed the importance of ensuring that the right to redress is mutual and easily 
enforceable between airlines and intermediaries. There was also a consensus between 
the  different  stakeholder  groups  that  the  introduction  of  the  reimbursement  process 
under option A is expected to increase costs for the activities related to fostering airline 
-  intermediary  ticket  vendor  communications,  providing  additional  information  to 
consumers  and  implementing  accessible  procedures  to  allow  passengers  to  easily 
identify themselves and provide their payment details to the airlines. 

A European Passengers’ association stated in a position paper of 22 April 2023 that “the most 
logical solution would be that passengers first address the party they bought their ticket from”.  

Option B: giving intermediaries the ultimate responsibility for reimbursements 

-  7 out of 17 passenger organisations claimed that the measure ensuring that passengers 
can only request reimbursement from the ticket vendor, which then immediately 
requests the reimbursement from the carrier, and the intermediary reimburses the 
passenger within 7 days following the latter’s reimbursement request, and receives 
the  reimbursement  from  the  carrier  within  7  days  following  its  reimbursement 
request to the carrier would bring no contribution at all. 

-  On  the  other  hand,  16  out  of  19  of  airlines  and  their  representative  organisations 
expressed that the measure would bring a very strong or strong contribution. Similarly, 
9  out  of  13  intermediary  ticket  vendors  and  the  only  credit  card  company  who 
contributed  considered  that  the  measure  would  bring  a  very  strong  or  strong 
contribution.  During  the  dedicated  workshop,  airlines  and  their  representative 
organisations  remarked  that  intermediaries  should  be  the  single  point  of  contact  for 
consumers and ultimately be liable for the reimbursement of passengers within the set 
timeframe, as they have the information regarding the price charged (including mark-
ups)  and  relevant  passenger  data.  An  umbrella  organisation  of  airlines  argued  that, 
because  some  intermediaries  combine  tickets  from  various  airlines  into  a  single 
reservation, if any other option than option B was chosen, it would make the refunding 
process very cumbersome for these passengers. On the other hand, during the workshop, 
intermediaries  and  credit  card  companies  claimed  that  this  proposal  could  only  be 
effective  if  accompanied  by  a  legislative  measure  obliging  carriers  to  refund 
intermediaries within 7 days. 

-  On  the  measure  ensuring  that  passengers  receive  the  reimbursement  from  the 
carrier if the intermediary ticket vendor is engaged in insolvency proceedings, 10 
out of 17 consumer organisations expressed their agreement with the measure, claiming 
it would have a strong or very strong contribution. 10 out of 19 airlines disagreed with 
the measure, claiming it would bring no contribution at all, whereas intermediary ticket 
vendors (11 out of 13) and claim agencies (2 out of 3) claimed that the policy measure 
would have a strong or very strong contribution. 

Option C: obliging the passenger to request and receive the reimbursement only from the 
carrier 

-  Passenger organisations had mixed views. Most air carriers and their organisations were 
sceptical  as  option  C  would  mean  airlines  would  be  responsible  for  the  refund  of 
costumers  for  whom  they  potentially  lack  the  essential  data.  During  the  workshop, 
airlines  highlighted  the  challenges  related  to  the  reimbursement  of  the  total  cost  of 
tickets to the passenger, including possible mark-ups by intermediaries, and then having 
to turn to intermediaries for their share, making the process unnecessarily complex and 
expensive (administrative costs and legal costs). 

-  This  proposal  is  also  not  supported  by  intermediary  ticket  vendors,  whereas  it  is 
supported  by  claim  agencies,  who  agree  that  the  responsibility  to  reimburse 

15 

 
 
 
 
 
passengers  should  lie  directly  with  the  airline  regardless  of  how  the  ticket  was 
purchased. 

-  9 out of 17 consumer organisations consider that this option would bring a strong or 
very  strong  contribution.  On  the  other  hand,  17  out  of  18  airlines  and  7  out  of  14 
intermediaries claimed that this option would not bring any contribution (while 5 out of 
14 ticket vendors consider that it would have a strong or very strong contribution). 

One  consumer  organisation  proposed  another  reimbursement  process  in  the  OPC  and  the 
dedicated workshop: a system of joint and several liability between intermediaries and air 
carriers, providing for a  mutual B2B right to redress, in which passengers can request the 
reimbursement to either the carrier or the intermediary. 
Consumer organisations, ticket vendors and claim agencies reported, in the targeted survey, that 
companies  should agree on commercial terms  to make the reimbursement process  swift and 
easier, considering that the reimbursement process usually takes more than 7 days. Consumer 
organisations stated at the final workshop that the 7-day deadline is never matched in practice. 
On this matter, the credit card companies involved in the dedicated workshop and interviews 
stressed the importance to hold the “Merchant of Record” (actor responsible for the processing 
of  the  payment)  liable  for  the  reimbursement,  using  the  same  channel  as  used  during  the 
purchase  of  the  ticket,  in  line  with  the  principle  of  “follow  the  money”,  and  this  view  was 
echoed by intermediary ticket vendors during the final workshop. 

In the OPC, EU citizens complained about the lack of accountability of both the airline and the 
intermediary ticket vendor regarding the reimbursement of tickets. Several solutions have been 
identified by the responding EU citizens, including: i) to oblige the vendors to provide airlines, 
within  a  reasonable  timeframe,  with  the  payment  information  and  place  the  reimbursement 
burden only on airlines;  ii) put the reimbursement burden on the actual seller of the tickets, 
while  the  carrier  should  be  obliged  to  transfer  money  within  the  7-day  deadline;  iii)  clearly 
define relations and responsibilities between intermediaries and airlines; iv) allow citizens to 
contact the intermediary ticket vendor in relation to journey cancellations by the carrier. 

In  the  targeted  stakeholder  consultation,  several  intermediary  stakeholders  and  their 
associations highlighted the importance of the airline including all relevant information with 
the reimbursement payment, to allow them to easily identify the relevant booking. 

A European consumer umbrella organisation submitted evidence to the Commission from its 
national member associations on passengers’ restricted possibilities to contact airlines, and 
passengers’ emails to airlines remaining unanswered, during 2022. The same organisation, as 
well as a major European airline, referred to the problem of intermediaries not providing certain 
data which are only available to them, which restricts the possibility to identify passengers. 

A  major  European  airline  drew  the  Commission’s  attention  to  the  problem  of  it  having 
reimbursed  the  intermediary,  and  the  intermediary  not  having  reimbursed  the  passengers 
because  the  intermediary  went  bankrupt.  Passengers  then  contacted  the  airline  for  the 
reimbursement  payment,  which  would  mean  that  the  airline  would  pay  twice  (to  the 
intermediary  and  the  airline).  A  national  court  had  stated  that  it  had  not  been  clear  that  the 
passenger had mandated the intermediary to receive the payment on his or her behalf. 

The  following  views  have  been  reported  by  NEBs  and  national,  regional  and  local  public 
authorities in relation to the proposed policy measures for this problem area:   

-  Regarding  the  proposed  preliminary  policy  options,  NEB  and  national  public 
authorities,  within  the  online  questionnaire,  were  generally  in  favour  of  Option  A 
(Passengers having intermediaries as the first point of contact, with the possibility 
of going to the airline in case they do not receive their reimbursement). Indeed, 14 

16 

 
 
 
 
 
 
 
 
 
out of 30 NEBs and 4 out of 6 national public authorities responding to  the targeted 
survey  stated  that  measure  PM  2.2.  (“in  case  the  passenger  does  not  receive  the 
reimbursement from the ticket vendor within 7 days, then the passenger can claim 
reimbursement from the carrier”) would have a strong or very strong contribution. 
20  out  of  30  NEBs  and  national  public  authorities  and  4  out  of  6  national  public 
authorities also thought that measure PM 2.2.3 (ensuring that air carriers implement 
an  accessible  procedure  to  allow  passengers  to  easily  identify  themselves  and 
provide payment details to the airline) would bring a (very) strong contribution.  
-  NEBs and national public authorities were more sceptical regarding Option B (Giving 
intermediaries the ultimate responsibility for reimbursements). Indeed, 13 out of 
29  NEBs and 2 out of 6 national public authorities replying believe that measure PM 
2.2.5 (ensuring that passengers can only  request reimbursement from the ticket 
vendor, which then immediately requests the reimbursement from the carrier, and 
the  intermediary  reimburses  the  passenger  within  7  days  following  the  latter’s 
reimbursement request, and receives the reimbursement from the carrier within 7 
days  following  its  reimbursement  request  to  the  carrier)  would  bring  a  strong  or 
very  strong  contribution,  while  3  out  of  29  NEBs  and  3  out  of  6  national  public 
authorities think that the measure would have a moderate contribution. 7 out of the 29 
NEBs believe that the measure would bring a slight contribution to solving the problem.  
-  NEBs and national public authorities have expressed support about Option C (Giving 
airlines the ultimate responsibility for reimbursements), both in the interviews and 
the  targeted  questionnaire,  claiming  that  the  responsibility  to  reimburse  passengers 
should lie directly with the airline regardless of the modality of purchase of the tickets. 
In the call for evidence and the targeted questionnaire, they claimed that there are many 
cases in which intermediaries receive a reimbursement from the carrier but then do not 
transfer it to the customer, causing delays in the refund process and the risk of “double 
reimbursement” for air carriers. This option was deemed to have a very strong or strong 
contribution by 17 out of 30 NEBs and 3 out of 6 national public authorities replying to 
the question. 

During  the  analysis  of  information  gathered  throughout  the  stakeholder  consultation,  two 
possible coordinated answers have been identified: one from waterborne carriers and their 
umbrella  organisation  within  the  context  of  the  call  for  evidence,  and  one  from 
intermediary  ticket  vendors,  travel  agencies  and  travel  package  organisers  within  the 
targeted online questionnaire. These responses have been treated separately in the analysis of 
the consultation results. 

In  the  call  for  evidence,  waterborne  carriers  and  one  umbrella  organisation  raised  the 
following points: improved clarity and consistency of Regulation 1177/2010 is needed, since it 
does not currently allow carriers to engage with  passengers to choose a preferred re-routing 
option. Moreover, they pointed out the unique circumstance of some waterborne routes which 
represent the only connection available for some geographical areas. If these routes were to be 
disrupted by excessive regulation, it might have rippling effects on the economy of the area. In 
reply to the targeted survey, intermediary ticket vendors expressed the following points: there 
should be no restrictions on B2B reimbursements; transport services which require the traveller 
to  pay  in  advance  should  be  protected  against  the  operators’  insolvency;  service  suppliers 
holding the prepayments must refund the intermediaries on time; in the event of major crises, a 
rapid  refund  system,  either  set  up  at  EU  level  or  coordinated  at  national  level,  should  be 
mobilised; an harmonisation of the PTD and passenger rights Regulations is needed. 

17 

 
 
  
 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

1.  PRACTICAL IMPLICATIONS OF THE INITIATIVE 
This initiative aims at ensuring better financial and personal welfare protection of passengers 
as well as a higher level of protection through better compliance and stronger enforcement of 
rights. This objective is intended to ensure a transport sector fit for the future, promoting more 
sustainable travel and travel across modes. 

The impacts of the measures included in the preferred policy package are expected to fall on 
different stakeholder groups, namely: carriers, intermediary ticket vendors, terminal operators, 
NEBs and passengers. 

Passengers 

The ultimate beneficiaries of this initiative are the passengers: they will be more aware of their 
rights which will be better applied and enforced as a result of the action of carriers, terminal 
managers, intermediaries and enforcement authorities. They will be much more aware of the 
possibility to submit their case to ADRs which are in many cases the most efficient bodies to 
enforce  passenger  rights.  The  use  of  standard  claim  forms  will  make  reimbursement  and 
compensation  claims  easier  to  submit.  These  claim  forms  will  also  be  fully  accessible  for 
persons with disabilities. The fact that carriers will have to publish reports regularly on their 
key performance indicators related to passenger rights (e.g., cancellations, delays, number of 
complaints,  results  of  passenger  surveys)  will  allow  passengers  to  make  informed  decisions 
about which carrier to choose. More transparency about their performance will also encourage 
carriers to improve the quality of their services. 

In addition, for the first time, passengers will have rights towards carriers, intermediary ticket 
vendors and terminal operators when performing a multimodal journey, in addition to the rights 
they currently enjoy  when travelling  within a single mode of transport. On top  of improved 
information  rights,  they will also  be better protected when travelling  on a single contract  of 
carriage for a multimodal journey (reimbursement/re-routing, care, PRM assistance), leading 
to substantial cost savings in the event of a travel disruption. Passengers having bought separate 
tickets from ticket vendors or tour operators will also have a right to reimbursement from the 
latter in the event of a missed connection, together with a penalty of 75%, in case they were not 
properly informed of the separate nature of the tickets. The assistance of PRM when switching 
between modes will also be ensured at multimodal hubs, thanks to the establishment of Single 
Points of Contact, thereby significantly reducing not only the number of assistance requests to 
be made by PRM, but also their waiting time before being assisted according to their needs. 
Finally, passengers will also be able to address complaints to both the industry and national 
authorities, thereby greatly reducing the hassle costs associated to complaint filing. 

Passengers will benefit from full clarity on whom to contact for the reimbursement when they 
booked through intermediaries, and clear upfront information by both carrier and intermediary 
on how the reimbursement procedure will be carried out, free of charge to the passenger. The 
procedure  likely  to  be  chosen  by  most  carriers  will  be  via  the  intermediary.  This  procedure 
contains the least ‘hassle’ for the passenger, as the reimbursement can be processed by reversing 
the original money flow, i.e. without the passenger having to go through proof of identification, 
having to submit bank details, proof that the ticket was not paid by a corporate third party, and 
that he did not launch a credit card chargeback (which is assumed to take at least an additional 
20  minutes).  Furthermore,  both  carrier  and  intermediary  are  incentivised  to  respect  their 
payment  deadlines.  The  new  payment  deadline  for  the  intermediary  ensures  that  the 
intermediary cannot take longer than 7 days, or leave its payment period open, when making 
the final payment to the customer. 

18 

 
 
Carriers 

The main change for carriers related to enforcement will be that they will have to collect and 
publish information about the implementation of the already existing rules (establishment of 
service  quality  standards).  In  addition,  they  will  have  to  take  additional  measures  to  inform 
passengers about their rights and make it easier to exercise them (obligation to better inform 
passenger  about  their  rights  in  particular  when  booking  a  ticket  or  in  case  of  transport 
disruptions  and  standardised  compensation  and  reimbursement  claim  forms).  Compliant 
carriers may have a competitive advantage, because carriers have to be transparent about how 
they comply with their obligations stemming from the EU passenger rights legislation. Given 
that NEBs have to be more transparent about their way of monitoring passenger rights (based 
on a transparent risk analysis), carriers may also  have a better level playing field within the 
Single Market.  

Regarding passenger rights for multimodal journeys, carriers will have some costs related to 
information as they will be obliged to provide guidance to passengers on minimum connecting 
times and other useful information when switching between modes. In addition, they would 
have  to  provide  real-time  information  to  passengers  on  cancellations,  delays  and  next 
connections  (SMEs  are  exempted).  Furthermore,  they  will  have  to  ensure  the  protection  of 
passengers having a single contract of carriage by means of reimbursement/re-routing, care and 
PRM assistance. Carriers will also be connected to the Single Points of Contact on multimodal 
hubs in view of the assistance to PRMs at these hubs when switching between modes. Carriers 
would also have to set up an online and offline complaint-handling mechanisms for passengers.   

The new reimbursement process builds on the current industry system that is being practiced 
by airlines, whereby large low-cost carriers with an exclusive direct (online) distribution model 
prefer passengers who booked via an intermediary to request reimbursements directly to the 
airline, and network carriers and small low-cost carriers reverse the original payment flow via 
the intermediary, and often have agreements for this in place. If carriers choose the intermediary 
procedure, they will be able to refuse to process direct requests by passengers and benefit from 
the  easier  and  cheaper  ‘reversal  of  the  payment  flow’,  as  long  as  they  pay  the  intermediary 
within the deadline, and the intermediary pays within its deadline. If they choose the carrier-
only  procedure,  they  will  be  able  to  refuse  to  cooperate  with  intermediaries  for  the 
reimbursement,  which  is  particularly  relevant  for  airlines  which  do  not  authorise  or  do  not 
prefer  intermediaries  to  purchase  their  tickets  (and  some  intermediaries  purchase  them 
nevertheless, on behalf of the passenger).  

Terminal operators 

The main changes for terminal operators related to enforcement will be that they will have to 
collect  and  report  information  at  the  NEBs  request  about  the  implementation  of  the  already 
existing rules (establishment of service quality standards). In addition, they will have to take 
additional measures to inform passengers about their rights and make it easier to exercise them 
(obligation to better inform passenger about their rights in particular when booking a ticket or 
in  case  of  transport  disruptions  and  standardised  compensation  and  reimbursement  claim 
forms). 

Concerning passenger rights for multimodal journeys, terminal operators will have some costs 
related  to  information  as  they  will  be  obliged  to  provide  guidance  on  minimum  connecting 
times and other useful information when switching between modes. In addition, they will have 
to ensure that a Single Point of Contact is established for PRMs at multimodal hubs. Terminal 
operators will also have to set up an online and offline complaint-handling mechanism. 

Intermediaries 

19 

 
 
Related to  enforcement,  intermediaries,  alongside carriers, will be obliged to  accept  an  EU-
wide  standard  form  for  claim-requests,  which  may  necessitate  some  changes  to  their  claim 
handling procedures (e.g. possibly impacting their IT systems).  

With regard to passenger rights for multimodal journeys, intermediaries will have some costs 
related  to  information  as  they  will  be  obliged  to  provide  guidance  on  minimum  connecting 
times and other useful information when switching between modes. In addition, they will have 
to provide real-time information to passengers on cancellations, delays and next connections, 
where possible. Furthermore, they will have to ensure that they inform passengers correctly in 
case they sell them separate tickets in a single commercial transaction for a multimodal journey 
– otherwise they will be liable for the reimbursement (+ a penalty of 75%). This will on the 
other  hand  help  them  to  manage  expectations  of  passengers  regarding  their  protection  for 
journeys with separate tickets. In addition, they will have to ensure that PRM can connect to 
the Single Point of Contact at multimodal hubs. Intermediaries will also have to set up an online 
and offline complaint-handling mechanism. 

Intermediary ticket vendors will receive an official role in the reimbursement process, where 
the airline so decides  and the intermediary  agrees as well.  Intermediaries are not  obliged to 
advance any payments if they do not want to. 

National public authorities  

NEBs will be provided with better information to carry out their monitoring and enforcement 
activities. They will be empowered to request information and documents from operators, and 
operators would have to provide the information and document requested to NEBs within one-
month.  The  obligation  of  carriers  to  publish  reports  about  their  key  performance  indicators 
related to passenger rights and terminal operators’ obligation to submit similar reports to NEBs 
at the NEBs’ request will provide NEBs with valuable information which will also make their 
enforcement  efforts  more  effective.  The  obligation  of  carriers  to  provide  information  to 
passengers about the relevant ADR bodies will ensure that they will receive less complaints in 
cases where they cannot act upon individual complaints or they cannot take a binding decision, 
thus they could concentrate their efforts on monitoring and enforcement tasks where they can 
make real difference.  

Concerning  multimodal  passenger  rights,  Member  States  will  have  to  designate  a  national 
authority to deal with passenger complaints. This authority could be a body which is already 
competent for dealing with such complaints for at least one of the individual Regulations for 
passenger rights.  

20 

 
 
 
 
 
 
2.  SUMMARY OF COSTS AND BENEFITS 

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

Description 

Amount 

Comments 

Direct benefits 

Benefits to passengers (in million 
EUR, expressed as present value 
over 2025-2050 relative to the 
baseline) 

EUR 21.7 
million 

Hassle costs savings for 
passengers (in million EUR, 
expressed as present value over 
2025-2050 relative to the 
baseline)  

EUR 2,165.3 
million 

Passengers will benefit much 
more from their rights, and they 
have new rights for travelling 
multimodal.  

Assessed 
qualitatively 

Clarity on the reimbursement 
procedure and likely speed of 
reimbursement payment for the 
passenger 

Assessed 
qualitatively 

Benefits to consumers due to certain assistance rights 
in  the  event  of  a  missed  connection  during  a 
multimodal 
to 
journey  (in  particular 
reimbursement and re-routing as well as a right to care 
in 
the  form  of  e.g.  refreshments,  meals  and 
accommodation) and due to the increased  use of the 
cheaper option of an ADR body, rather than seeking 
individual redress. 

the  right 

Hassle costs savings for passengers are driven by the 
time  saved  thanks  to:  the  higher  clarity  on  the 
reimbursement procedure (EUR 1,679.1 million), the 
Single  Point  of  Contact  for  PRMs  (EUR  277.3 
million), the use of a EU-wide standardised form for 
reimbursements and compensation requests (EUR 147 
million), 
the  complaint-handling  mechanism  for 
multimodal  passengers  (EUR  43.3  million)  and  the 
assistance  for  PRM  passengers  travelling  under 
category A multimodal tickets (EUR 18.6 million). 

The initiative deals with many recurrent issues which 
make it difficult for passengers to exercise their rights. 
They will be made much more aware about them, and 
will  have  standardised  claim  forms  at  their  disposal 
which  carriers  cannot  refuse  to  deal  with.  They  can 
inform  themselves  easily  about  the  service  quality 
standards of a carrier. They are now for the first time 
protected when switching modes during a multimodal 
journey,  and  they  can  receive  their  reimbursements 
without  worrying  to  whom  to  turn  to  and  when  the 
money  has  to  be  in  their  account  in  case  an 
intermediary  is  involved  in  this  process.  Their 
complaints can be taken care of much faster, because 
the NEBs can request supporting documents within a 
certain deadline, and passengers have to be informed 
about  ADR  bodies  –  a  cheap  and  efficient  way  of 
solving  disputes  with 
transport  operators  or 
intermediaries. 

Benefit for passengers to have full clarity on whom 
to contact, and the procedure, with deadlines and 
including what to do when the intermediary does not 
pay within 14 days, which should be rare due to 
incentives for the carrier and the intermediary to 
comply. Benefit of new 7-day payment deadline for 
the transaction from the intermediary to the 
passenger, and the clarity of information on this. 
Benefit for passengers of the enforcement of the 
speed of reimbursement through the enforcement 
measure PM A5. 

Enforcement costs savings for 
national public authorities (NEBs) 
(in million EUR, expressed as 
present value over 2025-2050 
relative to the baseline) 

EUR 5.9 million  Costs savings for national public authorities due to: an 
easier  way  to  evaluate  compliance  of  carriers  and 
terminal operators due to service quality standards and 
reporting  of  carriers  and  terminal  operators,  without 
having  to  do  more  in  depth  and  costly  monitoring 
activities, the use of standard claim forms which ease 
monitoring activities and the expected decrease in the 
number of court cases. 

21 

 
 
 
Hassle costs savings for national 
public authorities (in million 
EUR, expressed as present value 
over 2025-2050 relative to the 
baseline) 

EUR 71.4 
million 

Hassle costs saving for national public authorities 
due to the complaint-handling mechanism for 
multimodal passengers. 

NEBs will be much better 
equipped to deal with their tasks  

Assessed 
qualitatively 

NEBs will be able to request information vital to the 
monitoring and enforcement effort, making it more 
efficient and less time consuming. It remains their 
decision how NEBs organise their monitoring and 
enforcement activities, more transparency about the 
approach taken may lead to the exchange of good 
practices and enhance the cooperation between them.  

Hassle  costs  savings  for  carriers 
(in  million  EUR,  expressed  as 
present  value  over  2025-2050 
relative to the baseline) 

EUR 35.3 
million 

Hassle costs saving for carriers due to the complaint-
handling mechanism for multimodal passengers. 

Carriers  and  terminal  operators 
have a better level playing field 

Assessed 
qualitatively 

Transparency about the risk evaluation of NEBs and 
the  monitoring  based  on  it,  the  possibility  that  the 
Commission  can  ask  NEBs  to  investigate,  that  all 
carriers  have  to  be  transparent  about  their  service 
quality  standards,  giving  compliant  carriers  a 
competitive advantage, that the B2B relationship with 
intermediaries is clarified on EU level, all this leads to 
an improved business environment for carriers. 

costs 

savings 

Hassle 
for 
intermediaries  (in  million  EUR, 
expressed  as  present  value  over 
2025-2050 relative to the baseline) 

EUR 24 million  Hassle  costs  saving  for  intermediaries  due  to  the 
complaint-handling  mechanism 
for  multimodal 
passengers. 

Intermediaries  

Assessed 
qualitatively 

Positive  impact  on  compliance 
with the rules 

Assessed 
qualitatively 

Their  role  in  the  reimbursement  process  is  clarified 
which  may  enhance  the  trust  of  passengers  in  them. 
Intermediaries have if need be also a right to redress if 
they pre-finance reimbursements. Intermediaries may 
also indirectly benefit from clearer liability rules in the 
context of multimodal travel, in particular where they 
properly inform passengers on the separate nature of 
the  transport  tickets  that  these  intermediaries  have 
combined and sold for a given multimodal journey. 

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. 

Functioning of the internal market 

Improving the monitoring and enforcement by NEBs 
is expected to contribute to a level playing field. 

Indirect benefits 

Technological development  

Accelerated deployment of innovative technologies is 
expected  due  to  the  requirements,  specifically  on 
collecting  and  publishing  data  on  service  quality 
standards, obligations for reporting and to respect the 
deadlines  for  reimbursements  if  an  intermediary  is 
involved. 

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

22 

 
 
 
 
 
 
 
- 

- 

- 

II. Overview of costs – Preferred package of policy options 

Citizens/Consumers 

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

For national 
public 
authorities: 
0.02 million 

For national 
public 
authorities: 
1.4 million 

For national 
public 
authorities: 
30.6 million 

Direct adjustment costs (in 
million EUR, expressed as 
present value over 2025-2050 
relative to the baseline) 

Direct administrative costs (in 
million EUR, expressed as 
present value over 2025-2050 
relative to the baseline) 

- 

- 

- 

- 

For carriers: 
30.7 million 

For carriers: 
20.5 million 

For terminal 
operators: 6.3 
million 

For terminal 
operators: 
313.2 million 

For 
intermediaries: 
17.5 million 

For 
intermediaries: 
0.3 million 

- 

- 

For carriers: 
0.1 million 

For carriers: 
93.2 million 

For terminal 
operators: 2.3 
million 

For 
intermediaries: 
57.4 million 

For 
intermediaries: 
0.03 million 

Direct enforcement costs (in 
million EUR, expressed as 
present value over 2025-2050 
relative to the baseline) 

Direct adjustment 
costs (in million 
EUR, expressed 
as present value 
over 2025-2050 
relative to the 
baseline) 

Total   

Indirect 
adjustment costs 

Administrative 
costs (for 
offsetting) – costs 
per year relative 
to the baseline 

- 

- 

- 

- 

- 

- 

- 

- 

Costs related to the ‘one in, one out’ approach 

- 

- 

- 

For carriers: 
30.7 million 

For carriers: 
20.5 million 

For terminal 
operators: 6.3 
million 

For terminal 
operators: 
313.2 million 

For 
intermediaries: 
17.5 million 

For 
intermediaries: 
0.3 million 

- 

- 

- 

Recurrent 
administrative 
costs for 
carriers, 
terminal 
operators and 
intermediaries: 
5.2 million per 
year (of which, 
EUR 5.1 
million for 
carriers, EUR 

23 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
II. Overview of costs – Preferred package of policy options 

Citizens/Consumers 

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

0.1 million for 
terminal 
operators and 
EUR 1,401 for 
intermediaries). 

One-off 
administrative 
costs for 
carriers and 
intermediaries: 
EUR 57.5 
million (of 
which, EUR 
57.4 million for 
intermediaries 
and EUR 0.1 
million for 
carriers).   

3.  RELEVANT SUSTAINABLE DEVELOPMENT GOALS 

III. Overview of relevant Sustainable Development Goals – Preferred Option(s) 
Relevant SDG 

Expected progress towards the Goal 

Comments 

SDG  no.  10  – 
  Reduce 
inequality within and among 
countries  

More  PRM  passengers  would  enjoy  travels  that 
include several modes of transport and they would 
more easily file a complaint if they wish to do so. 

SDG no. 13 – Climate action  Citizens  will  be  incentivised  to  travel  long 

distances using multimodal transport. 

The  current  contribution  of  the  passenger 
rights framework to the better protection of 
passengers  with  disabilities  and  reduced 
mobility  is  essential.  All  passenger  rights 
Regulations  already  address  PRM  related 
needs.  This  initiative  will  make  a  step 
inequality  between 
further 
passengers.     

reduce 

to 

Providing  information  to  passengers  prior 
to  the  journey  on  multimodal  travel  will 
support the use of more sustainable modes 
for  each 
thus 
leg  of 
contributing to climate objectives.  

journey, 

the 

SDG  no.  16  -  Access  to 
justice  for  all  and  build 
effective,  accountable  and 
inclusive institutions   

Passengers can more easily enforce their rights by 
an easy filing of complaints or by using the means 
of redress available such as ADR procedures. 

The initiative, which relates to the right to 
full  application  and  effective  enforcement 
of EU law, will contribute to enhance and 
make easier the access to justice, means of 
redress and tools for enforcement. 

24 

 
 
 
 
 
 
 
 
  
 
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” 
package193, the impact assessments accompanying the 2030 Climate Target Plan194 and the Staff 
Working  Document  accompanying  the  Sustainable  and  Smart  Mobility  Strategy195,  the 
Commission’s proposal for a Long Term Strategy196 as well as for the 2020 and 2030 EU’s climate 
and energy policy framework.  

For the assessment of the impacts of the policy options, an Excel-based tool has been developed by 
PWC, TIS and Steer in the context of the impact assessment suport study, drawing on the standard 
cost model. The proposed measures 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 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 TREMOVE197 modelling 

193 Delivering the European Green Deal | European Commission (europa.eu). 
194 SWD(2020)176 final. 
195 EUR-Lex – 52020SC0331 – EN – EUR-Lex (europa.eu).  
196 Source: 2050 long-term strategy (europa.eu).   
197 Source: https ://www.tmleuven.be/en/navigation/TREMOVE.  

25 

 
 
community.  Part  of  the  model  (e.g.  the  utility  nested  tree)  was  built  following  the  TREMOVE 
model.198 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 figures199. Excise taxes are derived from DG TAXUD excise duty tables. Other data comes from 
different sources such as research projects (e.g. TRACCS and New Mobility Pattern projects) 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. 

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)200. The same assumptions have been used in the policy scenarios underpinning the 
impact assessments accompanying the “Fit for 55” package201. 

2.1.  Main assumptions of the baseline scenario 

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

2.1.1.  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  Eurostat202  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 

198 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. 
199 Source: https://ec.europa.eu/transport/facts-fundings/statistics_en.  
200 EU Reference Scenario 2020 (europa.eu). 
201 Policy scenarios for delivering the European Green Deal (europa.eu). 
202 EUROPOP2019 population projections: Eurostat - Data Explorer (europa.eu).   

26 

 
 
growth  projections  are  from  the  Ageing  Report  2021203  by  the  Directorate  General  for 
Economic and Financial Affairs, which are based on the same population growth assumptions. 

Table 36: Projected population and GDP growth per Member State 

Population 

GDP growth 

EU27 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czechia 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

2020 

447.7 

8.90 

11.51 

6.95 

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 

449.3 

9.03 

11.66 

6.69 

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 

449.1 

9.15 

11.76 

6.45 

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 

2026-‘30 

0.9% 

0.9% 

0.8% 

0.7% 

0.2% 

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% 

1.1% 

1.2% 

0.8% 

1.3% 

0.6% 

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. 

2.1.2. 

International energy prices assumptions  

Alongside  socio-economic  projections, 
requires  projections  of 
international fuel prices. The table below shows the oil prices assumptions of the baseline and 

transport  modelling 

203 The 2021 Ageing Report : Underlying assumptions and projection methodologies  The 2021 Ageing Report: 
Underlying Assumptions and Projection Methodologies | European Commission (europa.eu).  

27 

 
 
  
 
policy  options  of  this  impact  assessment,  that  draw  on  the  modelling  underpinning  the 
REPowerEU package204.  

Table 37: Oil prices assumptions  
Oil 

2015 

in $'15 per boe 

in €'15 per boe 

2020 

2030 

2040 

2050 

52.3 

47.2 

39.8 

35.8 

92.1 

83.0 

97.4 

87.8 

117.9 

106.3 

2.1.3.  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 JRC. 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 2020205. The 
same assumptions have been used in the context of this impact assessment. 

2.1.4.  Policies in the Baseline scenario  

Building on REF2020, the baseline has been designed to include the initiatives of the ‘Fit for 
55’  package  proposed  by  the  Commission  on  14 July  2021206  and  the  initiatives  of  the 
RePowerEU package proposed by the Commission on 18 May 2022207. In terms of passenger 
rights,  the  baseline  scenario  assumes  no  further  EU  level  intervention  beyond  the  current 
Regulations  in  place208  and  the  proposal  to  amend  Regulation  (EC)  No  261/2004  on  air 
passenger rights209, currently under discussion by the co-legislators. 

As  regards  the  reimbursement  of  air  tickets  when  booked  via  intermediaries,  the  baseline 
scenario includes: 

-  The possible use of European Digital Identity Wallets by private parties (provided for in the 
provisional political agreement of the Council and European Parliament on the core elements 
of  a  new  framework  for  a  European  digital  identity  (eID)  of  29/6/2023210)  that  could 
potentially  lead  to  future  uptake  of  eIDs  by  the  airline  industry.  This  would  most  likely 
facilitate  the  airline’s  check  of  the  identity  of  the  passenger.  It  is  currently  part  of  the 
additional information required by airlines when the ticket was paid by an intermediary on 
behalf of a passenger, and the passenger approaches the airline directly for a reimbursement. 

204 SWD(2022)230 final. 
205 EU Reference Scenario 2020 (europa.eu). 
206 https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal/delivering-european-green-
deal_en. 
207 https://ec.europa.eu/commission/presscorner/detail/en/IP_22_3131. 
208 Regulations (EC) No 261/2004 (air), (EC) No 1107/2006 (air PRM), (EU) No 1177/2010 (sea and inland 
waterways), (EU) No 181/2011 (bus and coach), (EU 2021/782 (rail). 
209 EUR-Lex - 52013PC0130 - EN - EUR-Lex (europa.eu), COM(2013)130 final. 
210 Available at: https://www.consilium.europa.eu/en/press/press-releases/2023/06/29/council-and-parliament-
strike-a-deal-on-a-european-digital-identity-eid/. 

28 

 
 
-  In case of insolvency of the entity which sold the passenger the air ticket, Regulation (EU) 
261/2004 applies. The transport contract is always concluded between the passenger and the 
airline. The onus for the passenger’s reimbursement  lies with  the  airline, except  where it 
already  transferred  the  reimbursement  money  to  an  intermediary  which  holds  a  valid 
mandate from the passenger to receive the airline’s reimbursement payment on his or her 
behalf.  Such a mandate depends on national law and the terms and conditions of the contract 
between passenger and intermediary. If the airline goes bankrupt and did not yet pay out to 
the intermediary (with a valid mandate), the passenger becomes the creditor of the airline. If 
the  intermediary  goes  bankrupt  without  having  received  the  carrier’s  reimbursement 
payment, the passenger can request it from the carrier directly. 

-  The Digital Services Act (DSA)211, that sets up a single point of contact for intermediaries212.  
-  The  Consumer  Rights  Directive  2011/83/EU,  Art.  6(1)c,  stipulates  that  the  trader  is  to 
provide the consumer with its telephone, fax and email address. The E-Commerce Directive, 
Art. 5(1)c, stipulates that the service provider is to provide the recipient of the service with 
an email address. However, these two articles do not apply to air carriers. 

The baseline also incorporates foresight megatrends213 and developments captured in the 2022 
Strategic Foresight Report214. More specifically, it captures the trend of increasing demand for 
transport as population and living standards grow. The projected transport activity draws on the 
long-term  population  projections  from  Eurostat  and  GDP  growth  from  the  Ageing  Report 
2021215 by the Directorate General for Economic and Financial Affairs. 

2.2.  Baseline scenario results 

Number  of  passengers  and  passenger  services.  The  total  number  of  passengers  in  the  EU 
travelling by air, bus and coach, rail and waterborne transport is projected to grow from 13.4 
billion in 2019 to 15.4 billion in 2030 and 19.8 billion in 2050 (15% increase for 2019-2030 
and 48% increase for 2019-2050), following the recovery from the COVID pandemic216. The 
number of passengers travelling by air would increase from 970 million in 2019 to 1.1 billion 
in  2030  and  1.4  billion  in  2050  (9%  growth  for  2019-2030  and  41%  for  2019-2050), 
maintaining a relatively stable share in the total number of passengers between 2019 and 2050. 
The number of passengers travelling by rail is projected to increase faster than for air (from 8.7 
billion  in  2019  to  9.7  billion  in  2030  and  13.3  billion  by  2050),  driven  in  particular  by  the 
completion of the TEN-T core network by 2030 and of the comprehensive network by 2050, 
supported by the CEF, Cohesion Fund and ERDF funding, but also by measures of the ‘Fit for 
55’ package that increase to  some extent the competitiveness  of rail relative to  road and air 
transport. The number of passengers travelling by bus and coach is projected to increase from 
3.3 billion in 2019 to 4.1 billion in 2030 and 4.6 billion by 2050, with the share of passengers 
travelling above 250 km representing around 11% of the total number of passengers travelling 
by bus and coach217. The number of passengers travelling by waterborne transport would also 

211 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022R2065. 
212 The assessment of which intermediary is covered by the DSA needs to be done on an individual basis. 
213 https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en#explore.  
214 COM(2022) 289 final of 29 June 2022. 
215The  2021  Ageing  Report :  Underlying  assumptions  and  projection  methodologies  The  2021  Ageing  Report: 
Underlying Assumptions and Projection Methodologies | European Commission (europa.eu).   
216 The projections for the number of passengers by transport mode are derived based on the number of passengers 
for  the  historical  period  from  Eurostat  and  the  projected  growth  in  passenger-kilometres  from  the  PRIMES-
TREMOVE model.  
217 The share of bus and coach passengers travelling above 250 km is derived based on Steer (2021), Study on the 
EU Regulatory Framework for Passenger Rights. Part B, Evaluation of Regulation (EU) No 181/2011 on the rights 
of passengers travelling by bus and coach: final report, https://data.europa.eu/doi/10.2832/486038. In the baseline 
scenario, this share is assumed to remain stable over time.  
29 

 
 
increase in  the baseline  scenario, from  418 million  in  2019 to  459 million  in  2030 and 569 
million in 2050. Drawing on the projected number of passengers, seat capacity and occupancy 
rates, the total number of passenger services by air transport, rail, bus and coach and waterborne 
transport is estimated to increase from 107 million in 2019 to 109.1 million in 2030 and 133.8 
million in 2050. The projected number of passengers and passenger services by mode in the 
baseline scenario are provided in Table 27. 

Table 38: Passenger services and number of passengers in the baseline, by mode 

2019 

2020 

2030 

2040 

2050 

Total air, bus and coach, rail and 
waterborne passenger transport 
Total number of passenger services (million) 

107.0 

Growth rate relative to 2019 

Total number of passengers (million) 

13,402  

Growth rate relative to 2019 

Air transport 
Air services (million) 
Passengers travelling by air (million) 

Bus and coach 
Bus and coach services (million) 

of which, services above 250 km 
Passengers travelling by bus and coach 
(million) 

7.5 
970  

66.4 
7.3 
3,345  

56.8 

-47% 
7,400  
-45% 

2.7 
210  

36.5 
2.6 
2,390  

109.1 

120.7 

133.8 

2% 
15,391  
15% 

13% 
17,863  
33% 

25% 
19,846  
48% 

8.6 
1,058  

63.2 
7.4 
4,137  

10.3 
1,231  

64.9 
6.8 
4,246  

12.0 
1,367  

71.0 
7.0 
4,645  

of which, passengers travelling above 250 

369  

259  

449  

460  

504  

km 
Rail transport 
Rail services (million) 
Passengers travelling by rail (million) 
Waterborne transport 
Passengers travelling by waterborne transport 
(million) 
Source:  PWC,  TIS  and  Steer  (2023),  Impact  assessment  support  study;  Note:  the  total  number  of  passenger 
services does not include the services by waterborne transport, for which data is not available.  

50.8 
13,264  

45.4 
11,872  

37.3 
9,737  

33.2 
8,668  

17.5 
4,570  

569  

418  

514  

230  

459  

Multimodal passengers. Drawing on data for the historical period collected in the context of the 
exploratory study on passenger rights in the multimodal context218, the number of multimodal 
passengers is projected to increase from 91 million in 2019 to 103.6 million in 2030 and 150.9 
million in 2050 in the baseline scenario. The air-rail passengers represent over 60% of the total 
multimodal  passengers,  air-coach  passengers  above  30%,  while  the  share  of  rail-coach 
passengers is limited to around 1% of the total number of multimodal passengers. In terms of 
market  size,  the  air-rail  passengers  represented  6.3%  of  the  total  number  of  passengers 
travelling by air in 2019 and their share is projected at 6.3% in 2030, following the recovery 
from  the  COVID-19  pandemic,  going  up  to  6.9%  by  2050.  The  air-coach  passengers 
represented around 0.9% of the total number of bus and coach passengers in 2019, going up to 
1.2% by 2050 in the baseline scenario, while the rail-coach passengers represent below 0.05% 
of the bus and coach passengers over the whole time horizon. Expressed as share of the total 
number of passengers, multimodal passengers are estimated to increase from 0.7% in 2019 to 
0.8% by 2050.     

Table 39: Number of multimodal passengers and the market share in the baseline 

Number of multimodal passengers (million) 

2019 
91.0 

2020 
30.4 

2030 
103.6 

2040 
126.0 

2050 
150.9 

218  EY  (2019),  Exploratory  study  on  passenger  rights 
https://data.europa.eu/doi/10.2832/72925.  

in 

the  multimodal  context:  final  report, 

30 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
Air-rail passengers  
Air-coach passengers  
Rail-coach passengers  

Market size 

2019 
60.8 
29.2 
1.0 

2020 
12.4 
17.3 
0.7 

2030 
66.3 
36.1 
1.3 

2040 
81.3 
43.3 
1.4 

2050 
95.0 
54.2 
1.7 

Air-Rail (% of air market size) 
Air-Coach (% of bus and coach market size) 
Rail-Coach (% of bus and coach market size) 

6.3% 
0.9% 
0.03% 

5.9% 
0.7% 
0.03% 

6.3% 
0.9% 
0.03% 

6.6% 
1.0% 
0.03% 

6.9% 
1.2% 
0.04% 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Costs for the provision of passenger rights per mode 

For air transport, the costs for the provision of passenger rights are the costs to comply with 
assistance  to  passengers,  in  accordance  with  Regulation  261/2004219.  The  costs  are  derived 
based on the Study on the current level of protection of air passenger rights in the EU220, and 
taking into account the number of services and passengers projected in the baseline scenario. 
For  air  passengers,  the  composition  of  cancellations  and  delay  costs  are  divided  into  three 
categories:  “compensation”,  “care  and  assistance”  and  “reimbursement  and  re-routing”. 
Drawing  on  the  costs  by  distance  to  destination  and  hours  of  delays,  and  the  number  of 
passengers, the projected costs for airlines for the provision of passenger rights due to delays 
and cancellations in  the  baseline scenario  are projected to  increase from  EUR 8.1 billion in 
2019 to EUR 9.2 billion in 2030 and EUR 13 billion in 2050 (see Table 33). 

Table 40: Costs for airlines in the baseline scenario due to cancelations and delays, including compensation, 
care and assistance, and reimbursement and re-routing (EUR million, in 2021 prices) 
2030 
      6,490  

2020 
      2,075  

2050 
      9,119  

2040 
      7,826  

2019 
      5,681  

2025 
      5,681  

      2,386  

         872  

      2,386  

      2,726  

      3,288  

      3,831  

      8,067  

      2,947  

      8,067  

      9,216  

    11,114  

    12,950  

Costs for airlines related to 
cancelations 
Costs for airlines related to delays 

Total costs related to cancelations 
and delays (EUR million) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

For bus and coaches, the costs for bus and coach operators for the provision of passenger rights 
due to delays (i.e. refreshments) is derived based on the number of passengers travelling by bus 
and  coach  using  passenger  services  above  250  km  from  the  baseline  scenario,  the  share  of 
passengers delayed by more than 90 minutes, the share of passengers that started their journey 
at a bus terminal and the average cost per passenger to cover the refreshments. The share of 
delays of over one hour and a half in long-distance bus and coach passenger services, the share 
of passengers that started their journey at a bus terminal, and the average cost per passenger to 
cover the refreshments  for 2019 were  retrieved from the evaluation study221. In the baseline 
scenario, the share of delays is assumed to decrease from 6% in 2019 to 4.4% in 2025 and to 
remain stable till 2050, while the share of passengers that started their journey at a bus terminal 
is assumed to remain constant over time to its 2019 levels. The average cost per passenger to 
cover the refreshments is assumed to remain stable over time in constant prices (2021 prices). 
The total costs for bus and coach operators for the provision of passenger rights due to delays 

219 The costs borne by airlines in instances of disruption, as stipulated within Regulation 261/2004, that we have 
included in our estimation of the total costs currently borne by airlines are as follows: compensation, care and 
assistance, reimbursement and re-routing. 
220 Steer (2020), Study on the current level of protection of air passenger rights in the EU: final report, available 
at: https://data.europa.eu/doi/10.2832/529370.  
221 Steer (2021), Part B - Evaluation of Regulation (EU) No 181/2011 on the rights of passengers travelling by bus 
and coach.  

31 

 
  
 
 
 
 
 
  
 
(i.e. refreshments) are projected to decrease from EUR 4.7 million in 2019 to EUR 4.1 million 
in 2030, driven by the reduction in the share of delays, and to increase back to EUR 4.7 million 
in 2050, driven by the increase in the number of passengers.  

Table 41: Costs for bus and coach operators related to delays in the baseline scenario (EUR million, in 2021 
prices) 

Total (domestic and international) number of passengers 
using passenger services above 250km (million passengers) 

2019 

2025 

2030 

2040 

2050 

369 

381 

449 

460 

504 

Share of passengers delayed by more than 90 minutes (%) 

6% 

4.4% 

4.4% 

4.4% 

4.4% 

Share of passengers that started their journey at a bus 
terminal (%) 

10% 

10% 

10% 

10% 

10% 

Average cost per passenger to cover the delays (EUR) 

2.1 

Total costs related to delays (EUR million) 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

4.7 

2.1 

3.5 

2.1 

4.1 

2.1 

4.3 

2.1 

4.7 

The costs related to reimbursements and re-routing for bus and coach operators were further 
estimated based on the number passengers travelling by bus and coach using passenger services 
above 250 km, the share of delays of over one hour and a half in long-distance bus and coach 
passenger services, the share of passengers that claim reimbursement222 and the average fare 
per passenger223. The total costs for bus and coach operators related to reimbursements and re-
routing  are  estimated  at  EUR 323 million  in  2019, EUR 300 million  in  2030 and EUR 349 
million in 2050 (Table 35). 

Table 42: Costs for bus and coach operators in the baseline scenario due to reimbursement/ re-routing (EUR 
million, 2021 prices)  

Total (domestic and international) number of passengers 
using passenger services above 250km (million 
passengers) 

2019 

2025 

2030 

2040 

2050 

369 

381 

449 

460 

504 

Share of passengers that claim reimbursement (%) 

38% 

38% 

38% 

38% 

38% 

Share of passengers delayed by more than 90 minutes (%) 

6.0% 

4.4% 

4.4% 

4.4% 

4.4% 

Average fare per passenger (EUR) 

Total costs related to reimbursement/re-routing costs  
(EUR million) 

38 

323 

40 

257 

40 

300 

42 

322 

42 

349 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

The total costs for bus and coach operators for the provision of passenger rights related to delays 
(i.e. refreshments) and reimbursements and re-routing are estimated to go down from EUR 328 
million in 2019 to EUR 304 million in 2030, driven by the reduction in the share of delays, and 
to increase to EUR 354 million in 2050, driven by the increase in the number of passengers. 

222 The share of passengers that claim reimbursement is based on Steer (2021), Part B – Evaluation of Regulation 
(EU) No 181/2011 on the rights of passengers travelling by bus and coach, and it is assumed to remain constant 
over time in the baseline scenario.   
223 The average fare per passenger for 2019 is based on Steer (2021), Part B – Evaluation of Regulation (EU) No 
181/2011 on the rights of passengers travelling by bus and coach. Its evolution over time, expressed in constant 
prices of the  year 2021, follows the  projected developments in the costs for buses and coaches per passenger-
kilometre from the baseline scenario, developed with the PRIMES-TREMOVE model.   

32 

 
 
 
 
For the rail sector the costs related to reimbursement and re-routing were estimated based on 
the number of rail passengers in the baseline scenario, the share of delayed passengers224, the 
share of passengers that claim reimbursement225, and the average rail fare226. The total costs for 
the  rail  sector  related  to  reimbursements  and  re-routing  are  estimated  at  EUR  7.3  billion  in 
2019, EUR 7.3 billion in 2030 and EUR 6.7 billion in 2050, due to the expected reduction in 
the  share  of  delayed  passengers  over  time.  It  should  however  be  noted  that  these  should  be 
regarded as upper bound estimates as the share of passengers that claim reimbursement for rail 
is not known.  

Table 43: Rail reimbursement/ re-routing costs  

2019 

2025 

2030 

2040 

2050 

Number of passengers 

8,668 

9,067 

 9,737  

 11,872  

 13,264  

Share of passengers that claim reimbursement (%) 

38% 

38% 

38% 

38% 

38% 

Share of delayed passengers (%) 

10.5% 

8.8% 

8.8% 

7.6% 

6.3% 

Average fare per passenger (EUR) 

21 

22 

22 

22 

21 

Total costs related to reimbursement/re-routing costs  
(EUR million) 

7,330 

6,737 

7,251 

7,386 

6,732 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Overall, in the baseline  scenario, the costs for  airlines, bus and coach operators and the rail 
sector for the provision of passenger rights are projected to increase from EUR 15.7 billion in 
2019 to EUR 16.8 billion in 2030 and EUR 20 billion in 2050, driven by the increase in the 
number of passengers over time. 

PRM requests. The estimated number of PRM requests for the base year is based on the study 
on the current level of protection of air passenger rights in the EU227 and the study on the EU 
Framework for Passenger Rights228. The increase in PRM requests in the baseline scenario is 
driven  by  the  share  of  population  aged  65  years  or  more,  and  the  baseline  developments  in 
transport activity by transport mode. The total number of PRM requests for air, bus and coach, 
rail and waterborne transport is projected to increase from 82.7 million in 2019 to 115.6 million 
in 2030 and 199.7 million in 2050, driven by the ageing population. 

Table 44: PRM requests per mode of transport  

Air transport 
Number of PRM requests (million) 

Growth relative to 2019 

7.2 

Share of PRM requests in the number of passengers 

0.7% 

1.6 
-77% 
0.8% 

8.4 
18% 
0.9% 

10.3 
44% 
1.0% 

14.7 

18.7 
105%  161% 
1.4% 
1.2% 

2019  

2020  

2025  

2030  

2040  

2050  

224 For the share of delayed passengers over one hour in regional and long-distance rail passenger services, data 
for 2019-2022 was retrieved from the 10th Rail Market Monitoring Report (2022 – Market Monitoring – IRG Rail 
(irg-rail.eu)). For 2025, the assumptions draw on the evolution over the historical period. Post-2030, the reduction 
in the share of delayed journeys takes into account the improved infrastructure envisaged by the proposed revision 
of the TEN-T Regulation. 
225 For the share of passengers that claim reimbursement the same share as for buses and coaches has been used, 
in lack of specific data for rail.  
226 The average fare per passenger for 2019-2020 is derived based on 9th and 10th Rail Market Monitoring Report, 
taking  into  account  the  average  passenger  operators’  revenues  per  passenger-kilometre  from  fares  and 
compensation (considering long-distance passenger rail services). Its evolution over time, expressed in constant 
prices of the year 2021, follows the projected developments in the costs for rail per passenger-kilometre from the 
baseline scenario, developed with the PRIMES-TREMOVE model. 
227 Steer (2020), Study on the current level of protection of air passenger rights in the EU : final report, available 
at: https://data.europa.eu/doi/10.2832/529370.  
228 Steer (2021), Study on the EU Framework for Passenger Rights.  

33 

 
 
  
  
  
  
  
  
  
  
 
2019  

2020  

2025  

2030  

2040  

2050  

Bus and coach transport above 250 km 
Number of PRM requests (million) 

Growth relative to 2019 

Share of PRM requests in the number of passengers 
Rail transport 
Number of PRM requests (million) 

Growth relative to 2019 

Share of PRM requests in the number of passengers 
Waterborne transport 
Number of PRM requests (million) 

Growth relative to 2019 

Share of PRM requests in the number of passengers 
Total passenger transport 
Number of PRM requests (million) 

Growth relative to 2019 

3.1 

0.8% 

69.5 

0.8% 

2.9 

0.7% 

82.7 

Share of PRM requests in the number of passengers 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

0.8% 

2.2 
-28% 
0.9% 

37.4 
-46% 
0.8% 

1.6 
-43% 
0.7% 

42.9 
-48% 
0.8% 

3.6 
17% 
0.9% 

82.0 
18% 
0.9% 

3.4 
19% 
0.8% 

97.5 
18% 
0.9% 

4.7 
52% 
1.0% 

96.6 
39% 
1.0% 

4.0 
37% 
0.9% 

5.7 

6.9 
84%  123% 
1.4% 
1.2% 

137.3 
167.7 
97%  141% 
1.3% 
1.2% 

5.3 

6.4 
81%  122% 
1.1% 
1.0% 

115.6 
40% 
1.0% 

162.9 
199.7 
97%  142% 
1.3% 
1.2% 

Number of operators. The following table summarises the number of operators per transport 
mode used in the analysis. The sources used are discussed below. The number of operators by 
transport mode are assumed to remain stable over time in the baseline scenario.  

Table 45: Number of operators per transport mode 

Number of operators 

Air 

Rail 

Bus and coaches 

Waterborne 

Terminal operators, of which: 

Multimodal terminal operators 

Waterborne terminal operators 

149 

283 

3,778 

523 

546 

424 

122 

For air transport, the database of EU air carriers by country holding an active operating licence 
(the ACOL database) for air carriers providing passenger transport services at scale229 has been 
used. In total, there were 149 active category A passenger carriers in the EU-27 in 2021. 

For passenger rail operators, information from IRG-Rail230 on the number of active railway 
undertakings has been retrieved. In total, there were 283 passenger railway undertakings in the 
EU-27 in 2021.  

Regarding  bus  and  coach  operators,  no  statistics  are  available  at  EU  level.  Therefore,  the 
figures  are  based  on  estimations.  The  methodology  takes  into  account  the  number  of 
Community  licenses  which  any  road  passenger  operator  must  possess  in  order  to  have  free 

229  Considering  Category  A  active  operating  licences  (ACOL)  for  passenger  services.  Category  A  operating 
licences refer to operators of aircraft with 20 or more seats. This categorisation is in line with Regulation (EC) No 
1008/2008 on air services. 
230 Eleventh Annual Market Monitoring Working Document  (2023 – Market Monitoring – IRG Rail (irg-rail.eu)) 
34 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
access to the intra-EU road transport market231. In 2019, 34,324 carriers possessed community 
licences in the EU-27232. The share of passengers travelling by bus and coach for journeys over 
250 km is estimated at 11%233. In absence of reliable data, it has been assumed that the number 
of  bus  and  coach  operators  offering  long-distance  services  is  proportionate  to  this  share. 
Applying this share to the number of carriers possessing community licences, the number of 
operators offering long-distance bus and coach services is estimated at 3,778.  

For waterborne transport, data from Eurostat on the number of active waterborne passenger 
companies in the EU-27234 (including both inland passenger water transport and sea and coastal 
passenger transport) in 2019 has been retrieved. There are about 10,000 companies in the EU 
dealing with passenger water transport (both in inland passenger water transport and sea and 
coastal passenger transport), which employ about 124,000 persons. Of these, 80% are employed 
in  the  sea  and  coastal  passenger  transport  sector  and  approximately  523  operators  provide 
passenger services in the EU-27235. 

For terminal operators, to estimate the number of multimodal terminal operators affected, the 
methodology laid down in the proposal for the TEN-T Regulation236, which establishes that at 
least one multimodal passenger hub has to be established for the 424 urban nodes of the TEN-
T, has been used. This leads to a total of 424 multimodal terminals. In addition, based on the 
information collected via the main ferry routes, there are 122 waterborne terminals. Therefore, 
the total number of terminal operators is estimated at 546. 

3.  Assessment of the economic impacts by policy measure 
This section provides the assessment of the costs and costs savings by policy measure for each 
of the three problem areas, including the assumptions used for their estimation. The synergies 
between policy measures are also taken into account in the estimations. Section 3.1 provides 
the costs and costs savings for problem area 1 (Enforcement of EU passenger rights legislation), 
section 3.2 for problem area 2 (Protection of passengers performing multimodal journeys) and 
section 3.3 for problem area 3 (Reimbursement rules are unclear when flights were booked via 
an intermediary). At the end of each of the three sections summary tables of costs and costs 
savings by stakeholder group, policy option and policy measure are provided for each problem 
area. 

3.1.  Problem area 1 - Enforcement of EU passenger rights legislation 

PM A.1: Industry stakeholders to share relevant information with NEBs (all modes except 
rail) 

This measure seeks to ensure that carriers, terminal and infrastructure managers, ticket vendors 
and tour operators provide NEBs with the relevant documents and information according to 

231 In accordance with Article 28(4) of Regulation (EC) No 1073/2009.   
232 https://transport.ec.europa.eu/system/files/2022-10/community-licence-road-passenger-transport_2022-10.pdf  
233 The share of bus and coach passengers travelling above 250 km is derived based on Steer (2021), Study on the 
EU Regulatory Framework for Passenger Rights. Part B, Evaluation of Regulation (EU) No 181/2011 on the rights 
of passengers travelling by bus and coach: final report, https://data.europa.eu/doi/10.2832/486038. In the baseline 
scenario, this share is assumed to remain stable over time.  
234 Considering the scope of Regulation (EU) 1177/2010 concerning the rights of passengers when travelling by 
sea and inland waterway. 
235 Estimated based on figures from Eurostat, excluding micro companies and aligned with data from the European 
Community Shipowners’ Associations (ECSA). 
236 Proposal for a Regulation of the European Parliament and of the Council on Union guidelines for the 
development of the trans-European transport network, amending Regulation (EU) 2021/1153 and Regulation 
(EU) No 913/2010 and repealing Regulation (EU) 1315/2013, COM(2021) 812 final 2021/0420 (COD), 
December 2022. 

35 

 
 
their  request,  without  undue  delay  within  one  month  from  the  receipt  of  the  request.  MS 
authorities already have the resources and structures in place to comply with the requirements 
of PM A.1, as do many carriers, terminal and infrastructure managers, ticket vendors and tour 
operators. Thus, limited costs are expected due to PM A.1 and are not further assessed. 

PM  A.2:  Carriers  and  terminal  operators  to  establish  service  quality  standards, 
implement a quality management system and report on results (all modes except rail) 

Under  PM  A.2,  carriers  shall  establish  service  quality  standards,  implement  a  quality 
management system and publish biennial reports on the results. In addition, terminal operators 
shall establish service quality standards, implement a quality management system, and disclose 
results with NEBs if requested to do so. This measure is relevant for all modes, except rail as 
such a provision already exist in rail passenger rights237, which is thus part of the baseline. 

Adjustment costs for carriers and terminal operators  

PM A.2 entail one-off adjustment costs to establish and implement the service quality standards 
and quality management system relative to the baseline. Air carriers already publish reports and 
comply with normative standards that could be used to comply with this measure. Therefore, 
air carriers are expected to require 5 additional working days (on one-off basis) to comply with 
this measure. In turn, operators from other modes of transport (bus and coach and waterborne 
transport operators) and terminal operators are expected to require 10 working days (on one-off 
basis) to implement such quality management system. This assumption was based on evidence 
collected in the context of the targeted survey238, adapted to take into account the qualitative 
evidence gathered during the targeted consultation.  

Assuming  an  hourly  worker’s  wage  corresponding  to  ISCO  3  (technicians  and  associate 
professionals)239 and considering 5 additional working days on one-off basis for air carriers, 
and taking into account that 149 air carriers are affected by this measure, the one-off adjustment 
costs for air carriers are estimated at EUR 173,908 in 2025 relative to the baseline.  

Table 46: One-off adjustment costs for air carriers due to PM A.2 relative to the baseline 

ISCO 3 Technicians and associate professionals hourly wage (EUR 
per hour in 2021 prices) 

Working days to implement changes 

Workday (in hours) 

Number of air carriers 

One-off adjustment costs (EUR, in 2021 prices) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

31.1 

5 

7.5 

149 

173,908 

For  bus  and  coach  and  waterborne  transport  carriers,  10  working  days  are  assumed  to  be 
required to establish and implement the service quality standards and the quality management 
system. Assuming an hourly worker’s wage corresponding to ISCO 3 (technicians and associate 
professionals) and the 4,103 carriers operating in the bus and coach and waterborne transport 

237 In accordance with Article 29 of Regulation (EC) No 2021/782 of the European Parliament and of the 
Council of 29 April 2021 on rail passengers' rights and obligations. 
238 Based on evidence provided by travel agencies and tour operators. Although travel agents and tour operators 
are not affected by this measure, this assumption is also considered valid for transport operators. 
239 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs. 

36 

 
 
 
sectors, the one-off adjustment costs are estimated at EUR 10 million in 2025 relative to the 
baseline.  

Of the 4,103 carriers operating in the bus and coach and waterborne transport sectors, 3,729 
carriers are SMEs (3,211 in the bus and coach sector and 518 in the waterborne sector). Thus, 
out of EUR 10 million one-off adjustment costs for the bus and coach and waterborne transport 
sectors, EUR 8.7 million would be incurred by SMEs.  

Table 47: One-off adjustment costs for bus and coach, and waterborne transport carriers due to PM A.2 relative 
to the baseline 

ISCO 3 Technicians and associate professionals hourly wage (EUR 
per hour in 2021 prices) 

Working days to implement changes 

Workday (in hours) 

Number of bus and coach carriers (offering services above 250km) 

of which, SMEs 

Number of waterborne transport carriers 

of which, SMEs 

One-off adjustment costs (EUR, in 2021 prices) 

of which for SMEs (EUR) 

31.1 

10 

7.5 

3,778 

3,211 

523 

518 

10,039,092 

8,704,148 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

For terminal operators, 10 working days are assumed to be required to establish and implement 
the service quality standards and the quality management system. Assuming an hourly worker’s 
wage corresponding to ISCO 3 (technicians and associate professionals) and the 546 terminal 
operators  affected  by  the  measure,  the  one-off  adjustment  costs  are  estimated  at  EUR  1.3 
million in 2025 relative to the baseline.  

Table 48: One-off adjustment costs for terminal operators due to PM A.2 relative to the baseline 

ISCO 3 Technicians and associate professionals hourly wage (EUR 
per hour in 2021 prices) 

Working days to implement changes 

Workday (in hours) 

Number of terminal operators 

31.1 

10 

7.5 

546 

One-off adjustment costs (EUR, in 2021 prices) 

1,274,545 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Total one-off adjustment costs for carriers (air carriers, bus and coach and waterborne transport 
carriers) in 2025 are thus estimated at EUR 10.2 million in 2025, of which EUR 8.7 million for 
SMEs,  while  the  one-off  adjustment  costs  for  terminal  operators  are  estimated  at  EUR  1.3 
million.  

Administrative costs for carriers and terminal operators  

Recurrent  administrative  costs  are  expected  for  all  carriers  due  to  PM  A.2,  linked  to  the 
reporting obligations. It is however expected that air carriers will spend less time than other 
transport carriers to comply with the obligation. Air carriers already publish annual financial 

37 

 
 
 
reports,  which  include  details  on  their  operational  activities.  In  addition,  according  to  the 
evidence gathered in the context of the targeted stakeholder consultation, many airlines already 
have  key  performance  indicators  (KPIs)  regarding  complaint  handling,  refunds,  and 
compensation for non-compliance with service quality standards, as well as assistance provided 
to persons with disabilities and persons with reduced mobility. Hence, it is expected that this 
would require a smaller change in the baseline activities of air carriers in comparison to other 
modes, where this is not a common practice. Therefore, for air carriers it has been assumed that 
1 working day per year is required for the reporting obligation from 2025 onwards. Assuming 
an hourly worker’s wage corresponding to ISCO 3 (technicians and associate professionals), 
and considering the 149 air carriers operating in the sector, the recurrent administrative costs 
are estimated at EUR 34,782 per year from 2025 onwards, relative to the baseline. Expressed 
as present value over 2025-2050, the recurrent administrative costs for air carriers are estimated 
at EUR 640,438 relative to the baseline. 

Table 49: Recurrent administrative costs for air carries due to PM A.2 relative to the baseline 

ISCO 3 Technicians and associate professionals hourly wage (EUR per 
hour in 2021 prices) 

Working days per year for reporting obligations 

Workday (in hours) 

Number of air carriers 

Recurrent administrative costs per year, from 2025 onwards (EUR, 
in 2021 prices) 

Recurrent administrative costs, expressed as present value over 2025-
2050 (EUR, in 2021 prices) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

31.1 

1 

7.5 

149 

34,782 

640,438 

For  other  transport  carriers  (bus  and  coach  and  waterborne),  it  is  estimated  that  they  would 
require 5 working days per year in order to comply with the reporting obligations under PM 
A.2.  Considering  that  there  are  3,778  bus  and  coach  carriers  and  523  waterborne  transport 
carriers affected and assuming an hourly worker’s wage corresponding to ISCO 3 (technicians 
and associate professionals), the annual recurrent costs are estimated at EUR 5 million from 
2025 onwards relative to the baseline. Of this, EUR 4.4 million are estimated to be costs for 
SMEs. Expressed as present value over 2025-2050, the recurrent administrative costs for bus 
and coach and waterborne carriers are estimated at EUR 92.4 million relative to the baseline, 
of which EUR 80.1 million for SMEs.   

Table 50: Recurrent administrative costs for bus and coach and waterborne transport operators due to PM A.2 
relative to the baseline 

ISCO  3  Technicians  and  associate  professionals  hourly  wage 
(EUR per hour in 2021 prices) 

Working days per year for reporting obligations 

Workday (in hours) 

Number of bus and coach operators 

of which, SMEs 

Number of waterborne operators 

of which, SMEs 

38 

31.1 

5 

7.5 

3,778 

3,211 

523 

518 

 
 
 
Recurrent administrative costs per year, from 2025 onwards 
(EUR, in 2021 prices) 

of which for SMEs (EUR) 

Recurrent  administrative  costs,  expressed  as  present  value 
over 2025-2050 (EUR, in 2021 prices) 

of which for SMEs (EUR) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

5,019,546 

4,352,074 

92,425,640 

80,135,379 

For terminal operators, the effort required for disclosing results with NEBs is estimated at 1 
working day per year. Considering the 546 terminal operators affected and assuming an hourly 
worker’s wage corresponding to ISCO 3 (technicians and associate professionals), the annual 
recurrent administrative costs for terminal operators are estimated at EUR 127,455  from 2025 
onwards.  Expressed  as  present  value  over  2025-2050,  the  recurrent  administrative  costs  for 
terminal operators are estimated at EUR 2.3 million relative to the baseline. 

Table 51: Recurrent administrative costs for terminal operators due to PM A.2 relative to the baseline 

ISCO 3 Technicians and associate professionals hourly wage (EUR per hour in 
2021 prices) 

Working days per year for reporting obligations 

Workday (in hours) 

Number of terminal operators 

Recurrent  administrative  costs  per  year,  from  2025  onwards  (EUR,  in  2021 
prices) 

Recurrent administrative costs, expressed as present value over 2025-2050 
(EUR, in 2021 prices) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

31.1 

1 

7.5 

546 

127,455 

2,346,839 

Total recurrent administrative costs for carriers (air carriers, bus and coach and waterborne 
transport carriers) are thus estimated at EUR 5.1 million per year from 2025 onwards, of which 
EUR 4.4 million for SMEs, while for terminal operators they are estimated at EUR 127,455. 
Expressed as present value over 2025-2050, the recurrent administrative costs for carriers are 
estimated at EUR 93.1 million, of which EUR 80.1 million for SMEs, and those for terminal 
operators at EUR 2.3 million relative to the baseline.   

Enforcement costs for national public authorities  

PM A.2 is also expected to lead to recurrent enforcement costs for national public authorities 
for reviewing the results of terminal operators and the reports of passenger carriers considered 
(i.e. bus and coach carriers, waterborne transport carriers and air carriers). The effort per review 
is estimated at 2 working days. Assuming an hourly worker’s wage corresponding to ISCO 2 
(professionals), the cost per review is estimated at EUR 562.     

The  NEBs  are  not  expected  to  review  each  biennual  report  published  by  the  carriers  and 
terminal operators but rather to perform individual checks, based on their risk assessment. It is 
also  expected  that  reports  are  allocated  between  the  NEBs  (reports  allocated  to  the  NEBs 
responsible for issuing of the relevant license), so that each report is checked maximum once. 

39 

 
 
 
Therefore, it is assumed that authorities will have to review 20%240 of the reports each year. In 
addition, national public authorities will have to review the results of terminal operators.  

Total enforcement costs for national public authorities are thus estimated at EUR 280,663 per 
year from 2025 onwards, relative to the baseline. Expressed as present value over 2025-2050, 
this is equivalent to EUR 5.2 million relative to the baseline.  

Table 52: Recurrent enforcement costs for national public authorities due to PM A.2 relative to the baseline 

Cost per review (EUR) 

Number  of  reports  reviewed  per  year  (air  carriers,  bus  and  coach  and 
waterborne transport carriers) 

Number of reviews of terminal operators results per year 

Recurrent enforcement costs per year, from 2025 onwards (EUR, in 2021 
prices) 

Recurrent  enforcement  costs,  expressed  as  present  value  over  2025-
2050 (EUR, in 2021 prices)  

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Enforcement costs savings for national public authorities  

562 

445 

55 

280,663 

5,167,894 

The implementation of services quality standards, along with a quality management system, 
and the publication of carriers’ performance reports are expected to result in cost savings for 
national  public  authorities  by  reducing  the  need  for  monitoring  activities.  According  to  the 
evidence provided by the Danish public authority during the stakeholders’ consultation, such 
measure  could  result  in  costs  savings  of  5%  per  year  due  to  monitoring  activities.  Thus, 
considering 215 workdays per year, the savings due to this measure are estimated at 5% of one 
employee’s workload per year, for each of the 27 Member States. The total enforcement cost 
savings  are  estimated  at  EUR  81,534  per  year  from  2025  onwards,  relative  to  the  baseline. 
Expressed as present value over 2025-2050, they are estimated at EUR 1.5 million. 

Table 53: Enforcement costs savings for public authorities due to PM A.2 relative to the baseline 

ISCO 2 Professionals hourly wage (EUR per hour in 2021 prices) 

Workday (in hours) 

Workdays in a year 

Number of Member States 

Cost savings per year for one employee per Member State 

Recurrent  enforcement  costs  savings  per  year,  from 2025  onwards 
(EUR, in 2021 prices) 

Recurrent  enforcement  costs  savings,  expressed  as  present  value 
over 2025-2050 (EUR, in 2021 prices) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

37.5 

7.5 

215 

27 

5% 

81,534 

1,501,294 

240 This implies that each report would be reviewed at least every five years. 

40 

 
 
 
 
PM  A.3:  Adoption  of  an  EU-wide  standardised  form  for  reimbursements  and 
compensation requests (all modes except rail) 

In  PM  A.3,  the  Commission  adopts  an  EU-wide  standardised  form  for  reimbursements  and 
compensation requests via an implementing act - carriers, ticket vendors and tour operators are 
obliged to accept this form, but passengers are not forced to use it. This measure applies to all 
modes except rail as such a provision already exist in rail passenger rights. 

One-off adjustment costs for carriers and intermediaries   

PM A.3 is expected to lead to one-off adjustment costs for carriers (bus and coach, air carriers 
and waterborne transport carriers) and intermediaries to adopt an EU-wide standardised form 
for reimbursements and compensation requests. According to stakeholder evidence received in 
relation to similar measures for adjusting the information system241, it is assumed that half a 
working day on one-off basis would be needed to implement these changes. Considering the 
4,450 carriers (3,778 bus and coach carriers, 149 air carriers and 523 waterborne carriers) and 
123,000  intermediaries,  and  assuming  an  hourly  worker’s  wage  corresponding  to  ISCO  3 
(technicians and associate professionals), the total one-off adjustment costs due to PM A.3 are 
estimated at EUR 14.9 million, relative to the baseline, of which EUR 14.1 million are costs for 
SMEs. 

Table 54: One-off adjustment costs for carriers and intermediaries due to PM A.3 relative to the baseline 

ISCO 3 Technicians and associate professionals hourly wage  (EUR 
per hour in 2021 prices) 

Time to implement changes per carrier/intermediary (working days) 

Workday (in hours) 

Number of carriers affected (bus and coach, air and waterborne) 

Number of intermediaries affected 

One-off  adjustment  costs  for  carriers  in  2025  (EUR,  in  2021 
prices) 

of which for SMEs (EUR, in 2021 prices) 

One-off adjustment costs for intermediaries in 2025 (EUR, in 2021 
prices) 

of which for SMEs (EUR, in 2021 prices) 

Total one-off adjustment costs for carriers and intermediaries in 
2025 (EUR, in 2021 prices) 

of which for SMEs (EUR, in 2021 prices) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

EUR 31.1 

0.5 

7.5 

4,450 

123,000 

519,345 

435,207 

14,356,140 

13,638,333 

14,875,485 

14,073,540 

The  cost  per  stakeholder  is  estimated  at  around  EUR  117.  The  one-off  adjustment  costs  by 
stakeholder group are provided in the table below.   

Table 55: One-off adjustment costs due to PM A.3 for carriers and intermediaries, by stakeholder group  

Cost per stakeholder (EUR) 

Total costs for bus and coach carriers (EUR) 

117 

440,912 

241 According to the Dutch National Enforcement Body, it would be required 0.5 working days to implement such 
changes. 

41 

 
 
 
 
Total costs for air carriers (EUR) 

Total costs for waterborne transport carriers (EUR) 

Total costs for intermediaries (EUR) 

Total one-off adjustment costs in 2025 (EUR, in 2021 prices) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Benefits for consumers (hassle costs savings) 

17,391 

61,043 

14,356,140 

14,875,485 

It should be noted that the objective of this measure is to benefit the passengers. Passengers will 
be able to use this form in cases where the system of the carrier/intermediary does not easily 
allow  them  to  launch  a  request.  Therefore,  the  measure  is  expected  to  result  in  hassle  costs 
savings for the passengers. 

In  the  baseline  scenario  passengers  have  to  navigate  through  the  carriers’/intermediaries’ 
websites and complaint procedure, in order to find the right option to file a claim. This process 
can be very time consuming, as the navigation to the carriers’/ intermediaries’ claim form is 
often counterintuitive, leading to hassle costs for passengers. In the worst case scenario this 
cumbersome process completely deters some passengers from filing claims. 

With a more accessible claim form, that is developed with the passenger’s needs in mind, it is 
estimated that a passenger that files a claim would spend 10 to 30 minutes less for finding and 
filing in the claim. To calculate the hassle costs savings due to PM A.4, the baseline projections 
on the number of passengers travelling by air and long-distance bus and coach are used as a 
starting  point242.  For  passengers  travelling  by  air,  the  share  of  passengers  requesting 
reimbursements is assumed to be 3%243, while for passengers travelling by long-distance bus 
and coach it is  assumed to  be 1.7%244. In addition,  under a conservative assumption, 5% of 
passengers that submit a claim are estimated to use the standardised form for reimbursement. 
Considering the consumer value of time estimated at EUR 22.7 per hour245 in 2021 prices, and 
the time saved of 10 minutes (lower bound estimate) to 30 minutes (upper bound estimate), the 
hassle costs savings for 2025, 2030, 2040 and 2050 relative to the baseline are provided in the 
table below. Per consumer, they are estimated at EUR 3.8 to 11.4. Expressed as present value 
over 2025-2050, they are estimated at EUR 147 million (EUR 120.6 million for air passengers 
and EUR 26.4 million for bus and coach passengers) to EUR 441.1 million (EUR 361.7 million 
for air passengers and EUR 79.3 million for bus and coach passengers).  

Table 56: Hassle costs savings for consumers due to PM A.3 relative to the baseline 

Number of passengers affected 
Passengers travelling by air 

Passengers travelling by bus and coach 

Consumers value of time (EUR) 
Hassle costs savings (EUR) 

2025 
1,774,211 
1,455,642 
318,569 
22.7 

2030 
1,962,633 
1,587,638 
374,995 
22.7 

2040 
2,230,773 
1,845,865 
384,908 
22.7 

2050 
2,471,940 
2,050,860 
421,080 
22.7 

242 Due to lack of granular data on waterborne transport and the number of waterborne passengers affected, the 
benefits for the waterborne passengers have not been estimated. 
243  According  to  evidence  provided  by  one  airline  for  2019.  One  large  OTA  provided  a  similar  figure  for 
reimbursement requests in 2019 (3.2%).  
244 This is derived taking into account the share of passengers that claim reimbursement (38%) of the share of 
passengers delayed by more than 90 minutes (4.4%). 
245 Source: https://www.eurocontrol.int/sites/default/files/publication/files/standard-input-for-eurocontrol-cost-
benefit-analyses-2018-edition-8-version-2.6.pdf. 

42 

 
 
  
  
  
  
  
 
Lower bound estimate, of which: 
Passengers travelling by air 

Passengers travelling by bus and coach 

Upper bound estimate, of which: 
Passengers travelling by air 

Passengers travelling by bus and coach 

2025 
6,713,176 
5,507,788 
1,205,387 
20,139,527 
16,523,365 
3,616,161 

2030 
7,426,116 
6,007,228 
1,418,888 
22,278,348 
18,021,684 
4,256,664 

2040 
8,440,693 
6,984,298 
1,456,395 
25,322,079 
20,952,893 
4,369,186 

2050 
9,353,210 
7,759,947 
1,593,263 
28,059,631 
23,279,841 
4,779,790 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

It is important to note that passengers will use this form on a voluntary basis, opting either to 
request  reimbursement  using  the  carrier’s  online  reimbursement  form  or  using  the  EU-wide 
standardised form. Nonetheless, as carriers will be obliged to have a claim form available to 
passengers it is expected that they will be motivated by this measure to improve their own form. 
This is expected to bring additional benefits to passengers, due to more claims from passengers 
who would have otherwise not filed a claim. In addition, the form will be easily accessible to 
PRMs, bringing additional easiness to claim their reimbursement. 

Enforcement costs savings for national public authorities  

PM  A.3  is  expected  to  lead  to  enforcement  costs  savings  for  national  public  authorities.  A 
standardised form can facilitate the NEBs job in monitoring reimbursement and compensations 
requests, since they would spend less time analysing different forms from carriers. According 
to evidence provided by the Danish public authority during the stakeholders’ consultation, PM 
A.4 could lead to savings of 5% of the time of one employee performing monitoring activities, 
per year.  

Considering 215 workdays in a year and assuming an hourly worker’s wage corresponding to 
ISCO 2 (professionals), the savings from this measure are estimated to be 5% of one worker 
per year, for the 27 Member States involved. The total costs savings, expressed as present value 
over 2025-2050, are estimated at EUR 1,501,294. 

Table 57: Recurrent enforcement costs savings for national public authorities due to PM A.3 relative to the 
baseline 

ISCO 2 Professionals hourly wage (EUR per hour in 2021 prices) 

Workday (in hours) 

Workdays in a year 

Number of Member States 

Time saved per year for one employee per public authority 

Recurrent enforcement costs savings from 2025 onwards (EUR, in 
2021 prices) 

Recurrent  enforcement  costs  savings,  expressed  as  present  value 
over 2025-2050 (EUR, in 2021 prices) 

Source: PWC, TIS and Steer (2023), Impact assessment support study. 

37.5 

7.5 

215 

27 

5% 

81,534 

1,501,294 

PM  A.4:  NEB(s)  shall  perform  compliance  monitoring  activities  of  the  industry 
stakeholders based on a risk assessment    

Under PM A.4, each Member State shall require its NEB(s) to perform compliance monitoring 
activities of the carriers, terminal operators, ticket vendors and tour operators based on a risk 

43 

 
  
 
assessment. The outline of this risk assessment and an explanation in general terms on how it 
has been developed has to be published by the NEB(s) every two years. 

Administrative costs for public authorities  

No additional costs are expected due to the monitoring activities on carriers as these are part of 
the  baseline.  The  costs  of  additional  monitoring  activities  on  terminal  operators  and 
intermediaries are included in the costs of the risk assessment to be performed, presented below. 

To  produce  the  risk  assessment,  5  to  10  person  days  would  be  required,  according  to  the 
evidence  provided  during  the  stakeholders’  consultation.  This  includes  discussions  with 
stakeholders (namely industry/consumer-passengers’ representatives), with other NEBs, with 
the Commission and the review of monitoring activities. 

Regarding carriers, risk assessments are already performed and are thus part of the baseline. 
Under a conservative approach, 10 person days per year are assumed to be needed to produce 
the risk assessment, publish it and carry out monitoring activities on terminal operators, ticket 
vendors  and  tour  operators.  Assuming  an  hourly  worker’s  wage  corresponding  to  ISCO  2 
(professionals), working 7.5 hours per day which would amount to an estimated cost expressed 
as present value 2025-2050 of EUR 1,396,552. 

Table 58: Recurrent enforcement costs for national public authorities due to PM A.4 relative to the baseline 

ISCO 2 Professionals hourly wage (EUR per hour in 2021 prices) 

Annual working days for the risk assessment 

Workday (in hours) 

Number of Member States 

Recurrent  enforcement  costs  per  year  from  2025  onwards  (EUR,  in  2021 
prices) 

37.5 

10 

7.5 

27 

75,845 

Recurrent  enforcement  costs,  expressed  as  present  value  over  2025-2050 
(EUR, in 2021 prices) 

1,396,552 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

PM A.5: Carriers and terminal operators shall better inform passenger about their rights 
in particular when booking a ticket or in case of transport disruptions  

Under PM A.5, carriers and terminal operators shall better inform passengers on their rights 
when booking their journeys, when a disruption occurs, including on  the complaint handling 
mechanisms.  Information  to  passengers  on  their  rights  shall  be  succinct  and  made  easily, 
prominently and directly available. It shall be provided in a clear and comprehensible manner 
and not merely in the standard terms and conditions or similar contractual documents. It shall 
be provided by electronic means as far as possible. 

One-off adjustment costs for carriers and terminal operators 

For  implementing  this  measure,  carriers  and  terminal  operators  must  adjust  their  IT  and 
communications systems to improve the provision of information on passenger rights, notable 
at the time of booking and transport disruption. They shall be prepared to send such information 

44 

 
 
 
by electronic means to the passengers as far as possible (e.g. the passenger provided the contact 
details and authorised them to use to them to send such messages).  

Although  the  measure  is  foreseen  for  all  modes,  many  of  the  modes  already  present  some 
information to passengers (for rail - Article 30 and 33(1) of Regulation (EU) 2021/782, for bus 
and coach carriers and terminal operators - Article 25 of Regulation (EU) No 181/2011, for air 
-  Article  14  of  Regulation  (EC)  261/2004,  for  waterborne  carriers  and  terminal  operators  - 
Article  23  of  Regulation  (EU)  1177/2010).  However,  as  these  Articles  are  not  sufficiently 
descriptive about when and where passengers should be informed about their rights, it has been 
assumed that operators will incur additional costs due to PM A.5. This measure is expected to 
have varying impact on the different modes. The measure is expected to have the least impact 
on rail operators, and higher impact on air carriers, bus and coach operators, and waterborne 
carriers and their respective terminal operators.  

Regarding  multimodal  hubs,  for  passengers  on  multimodal  journeys,  the  legal  obligation  to 
inform passengers of their rights, is also needed. 

Hence, 5,319 carriers and terminal operators are expected to be affected by this measure. It is 
also assumed that a limited adjustment is needed to their website or booking process.  

Table 59: Number of stakeholders affected by PM A.5 

Stakeholders’ groups 

Number of carriers/terminals 

Number of bus and coach operators affected 

Number of rail operators affected 

Number of waterborne operators affected 

Number of air carriers affected 

Number of multimodal terminals affected 

Total 

3,778 

283 

523 

149 

546 

5,279 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Due  to  the  differences  among  the  articles  of  regulations,  the  additional  time  estimated  for 
implementing such changes differ between rail operators on the one hand, and bus and coach 
carriers, waterborne operators, air carriers and terminal operators on the other hand. 

Concerning  rail  operators,  assuming  an  hourly  worker’s  wage  corresponding  to  ISCO  3 
(technicians and associate professionals) and one additional working day per operator to update 
both their communication systems and websites to comply with PM A.5, the one-off adjustment 
are estimated at EUR 66,062 in 2025 relative to the baseline. 

Table 60: One-off adjustment cost for rail operators due to PM A.5 relative to the baseline 

ISCO 3 Technicians and associate professionals hourly wage (EUR 
per hour in 2021 prices) 

Workday (in hours) 

Working days to implement the changes per operator 

Number rail operators affected 

One-off adjustment costs in 2025 (EUR) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

31.1 

7.5 

1 

283 

66,062 

45 

 
 
Regarding  air  carriers,  waterborne  operators,  bus  and  coach  operators  and  terminal 
operators, it is estimated that 5 additional working days would be required to update both their 
communication  systems  and  websites  to  comply  with  PM  A.5.  As  mentioned  above,  these 
stakeholders’ groups have less legal information obligations than rail. Air carriers have even 
less  legal  information  obligations  than  the  rest,  but  air  carriers  already  partly  comply  on  a 
voluntary basis. For this reason, air carriers can be grouped together with waterborne operators, 
bus and coach operators and terminal operators. The one-off adjustment costs due to A.5 for air 
carriers, waterborne operators, bus and coach operators and terminal operators are estimated at 
EUR 5.8 million in 2025 relative to the baseline, of which EUR 4.4 million for SMEs. 

Table 61: One-off adjustment costs for operators (excluding rail) due to PM A.6 relative to the baseline 

ISCO 3 Technicians and associate professionals hourly wage (EUR 
per hour in 2021 prices) 

Workday (in hours) 

Working days to implement the changes per operator 

Number  of  bus  and  coach  operators,  air  carriers,  waterborne 
transport carriers and terminal operators affected 

of which SMEs (bus and coach and waterborne transport) 

One-off adjustment costs in 2025 (EUR) 

of which for SMEs (EUR) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

31.1 

7.5 

5 

4,996 

3,729 

5,830,726 

4,352,074 

Total  one-off  adjustment  costs  for  carriers  and  terminal  operators  are  estimated  at  EUR  5.8 
million in 2025 relative to the baseline, of which EUR 5.3 million for carriers. 

Enforcement costs for public authorities  

Considering the synergies with PM A.2  no additional costs are foreseen for public authorities 
in PM A.5 for monitoring activities.  

Benefits for consumers 

Under PM A.6, passengers are expected to benefit from greater transparency and clarity with 
regard to their rights, which may lead to hassle costs savings for bookings, in case of disruption 
during their journeys and in case of complaint-handling. 

Data from the Special Eurobarometer report on passenger rights (Eurobarometer 485)246 shows 
that 14% of passengers were aware of passenger rights in general terms. In turn, 14% of air 
passengers were aware of air passenger rights, 8% of rail passengers were aware of their rights, 
compared  to  5%  of  bus  and  coach  passengers  and  3%  of  waterborne  passengers.  The 
Eurobarometer report suggests a correlation between the use of air transport and awareness of 
air passenger rights. Indeed, this has been reflected in the Passenger Rights Evaluation support 

246 Special Eurobarometer 485, Passenger rights, January 2020, available at: 
https://europa.eu/eurobarometer/surveys/detail/2200https://europa.eu/eurobarometer/surveys/detail/2200.  

46 

 
 
 
studies247,248,249,250, which showed that passenger claim rates for compensation have increased 
significantly  between  2011  and  2018  in  air  transport.  Moreover,  the  Regulation  has  led  to 
improvements in the treatment of PRMs across Europe, primarily in terms of greater awareness 
of the needs of PRMs, and quality improvements to the PRM assistance service. 

In  this  regard,  better  information  of  passenger  about  their  notably  when  booking  a  ticket  is 
expected  to  lead  to  potential  hassle  costs  savings  for  all  passengers  due  to  the  greater 
transparency at the booking process. Although no reliable quantitative estimate is possible, PM 
A.6  is  expected  to  benefit  95.9  million  passengers  in  2025  (including  passengers  from  air 
transport, long-distance bus and coach transport, waterborne transport and rail transport), 109 
million  passengers  in  2030  and  approximately  134  million  passengers  in  2050.  The  better 
information  of  passenger  about  their  rights  is  also  expected  to  provide  greater  clarity  for 
passengers in case of disruption, which may provide even greater benefits for PRMs, in line 
with the findings of the Evaluation Support Study. Moreover, passengers may also benefit of 
time savings when handling their complaints and requesting compensation. 

PM  A.6:  NEBs  (all  modes  except  rail)  shall  provide  information  on  ADR  (Alternative 
Dispute Resolution) bodies to passengers  

In PM A.6, NEBs are obliged to inform the passengers about the right to complain to ADR 
bodies to seek individual redress where the NEB is not at the same time an alternative dispute 
resolution body. This mesure applies to all modes except rail. 

Adjustment costs for NEBs to inform about ADR body  

To implement PM A.6, NEBs would have to inform passengers about their option to use ADR 
bodies  to  seek  individual  redress  as  well  as  refer  them  to  the  ADR.  This  is  expected  to  be 
achieved by adding information on the ADR process and a reference to the EU ADR Database 
on their website. The effort required has been estimated at half a working day on one-off basis 
per NEB. For estimating the costs due to PM A.6, 174 NEBs are considered (31 for air, 32 for 
air PRM, 41 for waterborne and 70 for buses and coaches). Assuming an hourly worker’s wage 
corresponding  to  ISCO  2  (professionals)  and  7.5  working  hours  per  day,  the  total  one-off 
adjustment costs of PM A.6 are estimated at EUR 24,439 in 2025 relative to the baseline. 

Table 62: One-off adjustment costs for NEBs due to PM A.6 relative to the baseline 

ISCO 2 Professionals hourly wage (EUR per hour in 2021 prices) 

Working days to implement the changes  

Workday (in hours) 

Number of NEBs affected 

One-off adjustment costs in 2025 (EUR) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

37.5 

0.5 

7.5 

174 

24,439 

247 Steer (2021), PART A - Evaluation of Regulation (EC) No 1107/2006 on the rights of persons with 
disabilities and with reduced mobility when travelling by air - Study on the EU Framework for Passenger Rights. 
248 Steer (2021), Part B - Evaluation of Regulation (EU) No 181/2011 on the rights of passengers travelling by 
bus and coach - Study on the EU Framework for Passenger Rights. 
249 Steer (2021), Part C - Evaluation of Regulation (EU) No 1177/2010 on the rights of passengers travelling by 
sea and inland Waterways - Study on the EU Framework for Passenger Rights. 
250 Study on the current level of protection of air passenger rights in the EU, Steer (2020). 

47 

 
 
 
Loss of revenues for claim agencies 

Online claim agencies help handle air passengers’ claims to airlines on their behalf. They deal 
with the paperwork, the administrative details, representing passengers throughout the claims 
process  and  in  many  cases  representing  them  in  court.  Claim  agencies  may  incur  a  loss  of 
revenues due to PM A.6, due to the decrease in the number of litigation cases handled on behalf 
of passengers. Based on desk research carried out for the different court cases involving claims 
related to Regulation 261/2004, it is estimated that around 50% of the cases that are taken to 
court that relate to air passenger rights claims are currently done so through claim agencies. 
According to evidence provided by one claim agency in the stakeholders consultation, court 
cases may cost up to EUR 1,000, which encompasses costs from lawyers, court fees and official 
document translation.  

Evidence from online claim agencies’ websites251 shows that court fees may represent up to 
50% of the total amount the passenger is due in terms of compensation. It is estimated that, per 
year,  5,152  to  10,303  of  court  cases  are  taken  forward  by  claim  agencies  on  behalf  of  air 
passengers, considering that each court case involves on average 1 passenger (minimum) to 2 
passengers  (maximum),  although  there  may  be  court  cases  related  to  Regulation  261/2004 
representing up to 15 passengers according to the evidence gathered. For the assessment, it has 
been assumed that on average 7,728 court cases per year are taken forward by claim agencies 
on behalf of  air passengers (of around 15,456  cases in  total). Assuming that  the increase in 
passengers’ rights awareness may decrease the number of court cases by 10% relative to the 
baseline in line with evidence from the Steer study252, and the average reimbursement fee per 
case is EUR 231 per case, of which the court fees for claim agencies represent 50%, the loss of 
revenue for claim agencies is estimated at EUR 89,381 per year or EUR 1.6 million, expressed 
as present value over 2025-2050, relative to the baseline. 

Table 63: Loss of revenues for claim agencies due to PM A.6 relative to the baseline 

Number of court cases per year (average) 

Assumed reduction in the number of court cases due to 
the increase in passengers’ rights awareness 

Court fees for claim agencies 

Average reimbursement fee per case (EUR) 

Loss of revenues per year from 2025 onwards (EUR, 
in 2021 prices) 

Loss of revenues expressed as present value over 2025-
2050 (EUR, in 2021 prices) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Enforcement costs savings for national public authorites 

7,728 

10% 

50% 

231 

89,381 

1,645,793 

Authorities may incur enforcement costs savings due to the increased awareness by passengers 
of their rights. As passengers would be better informed about their rights to complain to ADR 
bodies  to  seek  individual  redress,  this  may  lead  to  a  decrease  in  the  litigation  cases  in 
courts, given that ADR bodies can take on a stronger mediation role in individual redress cases. 
This  would  result  in  costs  savings  for  consumers,  but  also  for  public  authorities,  due  to  a 
reduction in the number of hours spent resolving litigation disputes involving passenger rights.  

251 Information retrieved for AirHelp, euclaim, SkyRefund and Airclaim. 
252 Steer (2020), Study on the current level of protection of air passenger rights in the EU, European Commission. 
48 

 
 
 
The  scope  of  analysis  focuses  only  on  air  transport  since  most  of  the  available  information 
regards claims under Regulation 261/2004 on air passenger rights. However, PM A.7 could also 
result in costs savings for court cases related to other modes. So, the estimates here should be 
regarded as the lower bound.   

Based  on  desk  research,  on  average  litigation  hearings  take  2  hours.  Assuming  an  hourly 
worker’s  wage  corresponding  to  ISCO  1  (legislators,  senior  officials  and  managers)  for  the 
court staff, and considering according to evidence from the Steer study253, that the increase in 
passengers’  rights  awareness,  monitoring  and  enforcement  results  in  10%  decrease  in  the 
number of court cases relative to the baseline, the enforcement costs savings for national public 
authorities are estimated at EUR 155,177 per year from 2025 onwards relative to the baseline.  

Table  64: Recurrent enforcement costs savings for national public authorities due to PM A.6 relative to the 
baseline 

Number of court cases per year (average)  
ISCO1 Legislators, senior officials, and managers  hourly wage (EUR per hour in 
2021 prices) 
Average working hours per dispute (hours) 
Potential savings (%) 
Recurrent enforcement costs savings per year from 2025 onwards (EUR, in 2021 
prices) 
Recurrent enforcement costs savings, expressed as present value over 2025-2050 
(EUR, in 2021 prices) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

15,456 
50.2 

2 
10% 
155,177 

2,857,294 

Benefits for consumers 

The loss of revenues for claim agencies represent in practice costs savings for the consumers. 
Following  the  calculations  above,  the  cost  savings  for  the  consumers  are  estimated  at  EUR 
89,381 per year or EUR 1.6 million, expressed as present value over 2025-2050, relative to the 
baseline.  Beyond this, it was not possible to quantify the benefits for consumers related to PM 
A.6. Nevertheless, the increased level of information for passengers on their right to complain 
to  ADR,  may  result  in  passengers  seeking  more  individual  redress  when  compared  to  the 
baseline. Not only would they incur benefits by receiving reimbursements and compensation 
they would not otherwise, but it can also be less costly for them if they do not have to resort to 
claim agencies.   

Summary of costs and costs savings by option and by measure (problem area 1) 

The  summary  of  recurrent  and  one-off  costs  and  costs  savings  by  option  and  by  measure, 
expressed as present value over 2025-2050, and for 2025, 2030 and 2050 relative to the baseline 
are provided in the tables below.  

Table 65: Recurrent and one-off costs and costs savings in the POs, expressed as present value relative to the 
baseline, in million EUR (2021 prices) 

Carriers 
Administrative costs   
PM A.2 
Adjustment costs   

Difference to the Baseline 
PO 1.2 
PO 1.1 

93.07 
93.07 
10.73 

93.07 
93.07 
15.99 

253 Steer (2020), Study on the current level of protection of air passenger rights in the EU, European Commission. 
49 

 
  
  
  
 
 
PM A.2 
PM A.3 
PM A.5 
Terminal operators 
Administrative costs   
PM A.2 
Adjustment costs   
PM A.2 
PM A.5 
Intermediaries 
Adjustment costs   
PM A.3 
Claim agencies 
Loss of revenues 
PM A.6 
Public authorities 
Adjustment costs 
PM A.6 
Administrative costs   
PM A.4 
Enforcement costs  
PM A.2 

Difference to the Baseline 
PO 1.2 
PO 1.1 

10.21 
0.52 

2.35 
2.35 
1.27 
1.27 

14.36 
14.36 

1.65 
1.65 

0.02 
0.02 

0.00 

7.21 
5.17 

10.21 
0.52 
5.26 

2.35 
2.35 
1.91 
1.27 
0.64 

14.36 
14.36 

1.65 
1.65 

0.02 
0.02 

1.40 
1.40 

7.21 
5.17 

5.86 
1.50 
1.50 
2.86 

5.86 
1.50 
1.50 
2.86 

Enforcement costs savings  
PM A.2 
PM A.3 
PM A.6 
Consumers 
Hassle costs savings 
PM A.4* 
Benefits for consumers 
1.65 
PM A.7 
137.95 
Total costs and loss of revenues 
154.53 
Total costs savings 
16.57 
Net benefits 
Benefits to costs ratio 
1.12 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for the lower bound of the 
costs savings estimates for PM A.4. When considering the upper bound of the costs savings estimates for PM A.4, 
the net benefits of PO 1.1 are estimated at EUR 317.91 million and of PO 1.2 at EUR 310.61 million, and the 
benefits to costs ratio 3.43 and 3.25, respectively. 

1.65 
130.66 
154.53 
23.87 
1.18 

148.67 
147.02 

148.67 
147.02 

Table 66: One-off adjustment costs in the POs relative to the baseline scenario, in million EUR (2021 prices) 

Carriers 
One-off adjustment costs  
PM A.2 
PM A.4 

Difference to the Baseline 

PO 1.1 

PO 1.2 

10.73 
10.21 
0.52 

15.99 
10.21 
0.52 

50 

 
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
 
 
 
  
  
PM A.6 
Terminal operators 
One-off adjustment costs  
PM A.2 
PM A.6 
Intermediaries 
One-off adjustment costs  
PM A.4 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

1.27 
1.27 

14.36 
14.36 

5.26 

1.91 
1.27 
0.64 

14.36 
14.36 

Table 67: Recurrent and one-off costs for carriers in the POs, in 2025, 2030 and 2050 relative to the baseline 
scenario, in million EUR (2021 prices) 

Difference to the Baseline 

PO 1.1 
2030 

2025 

2050 

2025 

Administrative costs   
PM A.2 
Adjustment costs   
PM A.2 
PM A.4 
PM A.6 
Net costs 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

5.05 
5.05 
10.73 
10.21 
0.52 

5.05 
5.05 
0.00 

15.79 

5.05 

5.05 
5.05 
0.00 

5.05 

5.05 
5.05 
15.99 
10.21 
0.52 
5.26 
21.05 

PO 1.2 
2030 

5.05 
5.05 
0.00 

2050 

5.05 
5.05 
0.00 

5.05 

5.05 

Table 68: Recurrent and one-off costs for terminal operators in the POs, in 2025, 2030 and 2050 relative to the 
baseline scenario, in million EUR (2021 prices) 

Difference to the Baseline 

PO 1.1 
2030 

2025 

2050 

2025 

Administrative costs   
PM A.2 
Adjustment costs   
PM A.2 
PM A.6 
Net costs 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

0.13 
0.13 
1.27 
1.27 

0.13 
0.13 
0.00 

0.13 

1.40 

0.13 
0.13 
0.00 

0.13 

0.13 
0.13 
1.91 
1.27 
0.64 
2.04 

PO 1.2 
2030 

0.13 
0.13 
0.00 

2050 

0.13 
0.13 
0.00 

0.13 

0.13 

Table 69: Recurrent and one-off costs for intermediaries in the POs, in 2025, 2030 and 2050 relative to the 
baseline scenario, in million EUR (2021 prices) 

Difference to the Baseline 

PO 1.1 
2030 

2025 

2050 

2025 

PO 1.2 
2030 

2050 

Adjustment costs   
PM A.4 
0.00 
Net costs 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

14.36 
14.36 
14.36 

0.00 

0.00 

0.00 

14.36 
14.36 
14.36 

0.00 

0.00 

0.00 

0.00 

Table 70: Recurrent costs and costs savings for public authorities in the POs, in 2025, 2030 and 2050 relative 
to the baseline scenario, in million EUR (2021 prices) 

51 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Difference to the Baseline 

PO 1.1 
2030 

2025 

2050 

2025 

0.00 

0.00 

0.02 
0.02 
0.00 

Adjustment costs   
PM A.7 
Administrative costs   
PM A.5 
Enforcement costs  
PM A.2 
PM A.3 
Enforcement costs savings  
PM A.2 
PM A.4 
PM A.7 
Net costs 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

0.39 
0.28 
0.11 
0.32 
0.08 
0.08 
0.16 
0.07 

0.39 
0.28 
0.11 
0.32 
0.08 
0.08 
0.16 
0.07 

0.00 

0.00 

0.39 
0.28 
0.11 
0.32 
0.08 
0.08 
0.16 
0.07 

0.02 
0.02 
0.08 
0.08 
0.39 
0.28 
0.11 
0.32 
0.08 
0.08 
0.16 
0.15 

PO 1.2 
2030 

2050 

0.00 

0.00 

0.08 
0.08 
0.39 
0.28 
0.11 
0.32 
0.08 
0.08 
0.16 
0.15 

0.08 
0.08 
0.39 
0.28 
0.11 
0.32 
0.08 
0.08 
0.16 
0.15 

Table  71:  Loss  of  revenues  for  claim  agencies  in  the  POs,  in  2025,  2030  and  2050  relative  to  the  baseline 
scenario, in million EUR (2021 prices) 

Difference to the Baseline 

PO 1.1 
2030 

2025 

2050 

2025 

PO 1.2 
2030 

Loss of revenues 
PM A.7 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

0.09 
0.09 

0.09 
0.09 

0.09 
0.09 

0.09 
0.09 

0.09 
0.09 

2050 

0.09 
0.09 

Table 72: Benefits for consumers in the POs, in 2025, 2030 and 2050 relative to the baseline scenario, in million 
EUR (2021 prices) 

Difference to the Baseline 

PO 1.1 
2030 

2025 

2050 

2025 

PO 1.2 
2030 

2050 

Hassle costs savings 
PM A.4* 
Other benefits for consumers 
0.09 
PM A.7 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for the lower bound of the 
costs savings estimates. 

6.80 
6.71 

9.44 
9.35 

9.44 
9.35 

6.80 
6.71 

7.52 
7.43 

7.52 
7.43 

0.09 

0.09 

0.09 

0.09 

0.09 

3.2.  Problem area 2 - Protection of passengers performing multimodal journeys 
It  is  important  note  that  the  multimodal  sector  is  still  an  incipient  industry  with  only  few 
operators competing in the market. Although it is expected to grow in the next decades, the 
small scale of the multimodal market in relation to other well-established markets such as air, 
bus and coach and rail transport enhances the uncertainty of the projections. Moreover, ticket 
vendors act as third-party intermediaries that combine individual tickets from different transport 
modes into a single ticket, i.e. a multimodal ticket, allowing consumers to travel from one mode 
to another without purchasing separate tickets each time. However, it is worth noting that these 
ticket vendor intermediaries that sell the multimodal tickets are often not the actual carriers that 
will provide the service, even though all operators need to be informed or communicate about 
multimodal connections and repercussions on passenger rights. Thus, commercial agreements 
between  carriers  need  to  be  established.  In  order  to  establish  a  resilient  passenger  rights 
framework for multimodal market, investment needs to take place to inform the whole value 
chain. 

52 

 
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
PM  B.1:  Industry  stakeholders  shall  provide  guidance  to  passengers  on  minimum 
connecting  times  and  other  useful  information  when  switching  between  modes  of 
transport (category A+B+C) 

Under PM B.1 carriers, ticket vendors/tour operators and terminal operators have to  provide 
essential pre-purchase information to multimodal passengers on the type of multimodal tickets 
(single contract of carriage or integrated separate tickets), time schedules, available connections 
and tariffs, and the accessibility of services and terminals for PRM. This measure, which would 
apply to all multimodal passengers (category A+B+C) is similar to what  is already required 
under Article 9 and Annex II of Regulation (EU) 2021/782 on rail. 

Adjustment costs for carriers, terminal operators and intermediaries  

According to evidence from the targeted stakeholder consultation, carriers, ticket vendors/tour 
operators and terminal operators would incur one-off adjustment costs to provide information 
on minimum connecting times when switching between modes of transport, as they would have 
to adapt their websites and booking process systems in order to comply with PM B.1. Recurrent 
costs for periodically updating the relevant information are expected to be marginal and not 
further estimated. 

Stakeholders  provided  no  quantitative  estimates  regarding  the  economic  impacts  of  this 
measure  during  the  stakeholder  consultation,  but  it  was  stated  that  the  measure  would  have 
minimum impact on costs. Hence, it has been assumed that 2 working days would be necessary 
on one-off basis per stakeholder to update both their communication systems and websites to 
comply with PM B.1.  

To  estimate  the  number  of  bus  and  coach,  rail,  air  and  waterborne  carriers  affected  by  this 
measure, due to the lack of data, the share of multimodal passengers travelling by each transport 
mode has  been used. For air, it is  estimated that  90% of  air carriers already implement  this 
measure. It has been additionally assumed, that 0.1% of the total number of intermediaries254 
would be affected by the measure.  

Table 73: Number of carriers, terminal operators and intermediaries affected by PM B.1 

Multimodal Stakeholders 

Number of bus and coach carriers 
Number of rail carriers  
Number of air carriers  
Number of waterborne carriers  
Number of intermediaries  
Number of multimodal terminal operators  
Total, of which 
SMEs 

Total 

3,778 
283 
149 
523 
123,000 
424 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Share of 
Multimodal 
(%) 

Multimodal operators 
affected 

4.6% 
24.4% 
7.5% 
1.0% 
0.1% 
100% 

173 
69 
2255 
6 
123 
424 
797 
269 

Assuming  an  hourly  worker’s  wage  corresponding  to  ISCO  3  (technicians  and  associate 
professionals) and 7.5 working hours per day, the total one-off adjustment costs are estimated 
at EUR  372,092 in 2025, relative to the baseline, of which EUR 125,587 for SMEs.  

Table 74: One-off adjustment costs for carriers, terminal operators and intermediaries due to PM B.1  

254 https://www.ectaa.org/en/about-our-industry.  
255 It is estimated that 90% of air carriers already implement this measure. 

53 

 
 
 
 
 
 
ISCO 3 Technicians and associate professionals hourly wage (EUR 
per hour in 2021 prices) 

Working days to implement the changes 

Workday in hours 

Number of stakeholders affected 

31.1 

2 

7.5 

797 

One-off adjustment costs in 2025 (EUR, in 2021 prices), of which 

372,092 

of which, for:  

Carriers 

Multimodal terminal operators 

Intermediaries 

of which, for SMEs: 

Carriers 

Intermediaries 

116,717  

197,951   

57,425  

125,587 

70,964 

54,623 

Source: PWC, TIS and Steer (2023), Impact assessment support study. 

Benefits to consumers and passengers 

Policy  measure  B.1  seeks  to  provide  clear  guidance  to  passengers  on  minimum  connecting 
times and communicating information to passengers when switching between transport modes, 
for example on the accessibility of transport infrastructure. Improving the information available 
will allow consumers to make better informed decisions about their travel plans by enabling 
them  to  anticipate  the  connecting  time  between  transport  services  or  the  access  of  certain 
transport infrastructure. Additionally, by implementing guidance on minimum connection times 
and providing information when switching between modes of transport, PM B.1 would reduce 
the risk of missed connections, thereby benefiting consumers and passengers by minimising the 
need to purchase a second ticket. 

PM B.2: Carriers and ticket vendors/tour operators (except SMEs) to provide real-time 
information to passengers (category A+B) 

In PM B.2, carriers and ticket vendors/tour operators have to provide real-time information to 
passengers  on  disruptions,  possible  next  connections  and  security  alerts  during  the  journey, 
where technically feasible. This measure, which would apply to multimodal passengers having 
a single contact of carriage (category A), and those having separate tickets for a multimodal 
journey which are combined and sold in one commercial transaction by a ticket vendor/tour 
operator (category B), is similar to what is already required under Article 9, 10, 20(6), Annex 
II and Annex III of Regulation (EU) 2021/782. SMEs would be exempted from this measure. 

In order to provide real-time information to passengers, both transport carriers and intermediary 
ticket vendors who participated in the target survey pointed out that the data must be readily 
available.  In  addition,  intermediary  ticket  vendors  mentioned  that  a  widely  interoperable 
standardised  format  across  the  stakeholders  involved  is  necessary.  The  technology  is  not 
considered as barrier, as air carriers already provide some sort of information on disruptions of 
their services when they are in the same booking system256. 

256 According to desk research, large airlines already provide some sort of information to passengers on disruptions. 
This is also in line with the evidence provided by airlines as part of the CPC’s coordinated action on airlines’ 
54 

 
 
 
 
Adjustment costs for carriers and intermediaries  

Only one rail carrier provided an estimation of one-off costs for PM B.2, ranging from EUR 
500,000  to  5,000,000257  per  company,  to  implement  real-time  information  provisions  and 
integrate communication systems to multimodal passengers258. For estimating the costs of PM 
B.2, the lower bound (EUR 500,000 per company) has been used to ensure no overlap with 
costs  associated  to  data  infrastructure  and  management,  as  well  as  access  to  Application 
Programming Interface.  

Rail carriers are assumed to have already implemented the necessary systems to provide real-
time information to passengers under the baseline259. In addition, it is estimated that 90% of air 
carriers in the EU offering multimodal services already provide such information to passengers. 
It should also be noted that SMEs are exempted from this measure. Thus, a total of 35 carriers 
and  intermediaries  (29  carriers  and  6  intermediaries)  are  expected  to  be  affected  by  this 
measure.  

Table 75: Number of carriers and intermediaries affected by PM B.2 

Multimodal Stakeholders 

Number of bus and coach carriers  

Number of air carriers  

Number of waterborne carriers  

Number of intermediaries  

Total 

Multimodal operators affected, excluding 
SMEs 

26 

2 

1 

6 

35 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Thus, the one-off adjustment costs for carriers and intermediaries are estimated at EUR 17.5 
million in 2025 relative to the baseline (EUR 14.5 million for carriers and EUR 3 million for 
intermediaries). No impacts on SMEs are estimated for this measure, which are exempted. 

Table 76: One-off adjustment costs for carriers and intermediaries due to PM B.2  

Cost per company (EUR) 

Number of carriers affected 

Number of intermediaries affected 

One-off adjustment costs in 2025 (EUR, in 2021 prices), of which for: 

Carriers 

Intermediaries 

of which, for SMEs 

500,000 

29 

6 

17,500,000 

14,500,000 

3,000,000 

0 

COVID-19 related cancellation practices, in 2022. Therefore, it has been assumed that only a small number of air 
carriers do not yet provide such information to passengers. 
257 The Czech rail operator mentioned in the targeted survey that the costs could range between EUR 500,000 to 
EUR 5,000,000 for changes in software/IT. 
258  The  one-off  adjustment  costs  due  to  PM  B.2  serve  a  broader  scope  than  pure  information  reporting.  By 
implementing real-time information provisions and integrating communication systems to multimodal passengers, 
their aim is to enable better services for multimodal passengers in case of disruptions and delays. For this reason, 
the one-off costs have been classified as adjustment costs rather than administrative costs. 
259 In accordance with Article 9 of Regulation (EU) 2021/782 of the European Parliament and of the Council on 
rail passengers’ rights and obligations. 

55 

 
 
 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

Administrative costs for carriers and intermediaries  

Carriers and intermediaries are also expected to incur recurrent administrative costs related to 
the maintenance and operation of the real-time information system to passengers on disruptions. 
The effort is estimated at 1 working day. Assuming an hourly worker’s wage corresponding to 
ISCO 3 (technicians and associate professionals) and 7.5 working hours per day, the recurrent 
administrative costs per year are estimated at EUR 8,170. Expressed as present value over 2025-
2050, total recurrent administrative costs for carriers and intermediaries are estimated at EUR 
150,438 relative to the baseline. 

Table 77: Recurrent administrative costs for carriers and intermediaries due to PM B.2  

ISCO 3 Technicians and associate professionals hourly wage (EUR 
per hour in 2021 prices) 

Working days to implement changes 

Workday (in hours) 

Number of carriers affected 

Number of intermediaries affected 

Recurrent administrative costs per year (EUR), of which for: 

Carriers 

Intermediaries 

Recurrent administrative costs, expressed as present value over 
2025-2050 (EUR), of which: 

Carriers 

Intermediaries 

of which, for SMEs 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Enforcement costs for public authorities 

31.1 

0.5 

7.5 

29 

6 

8,170 

6,770 

1,401 

150,438 

124,649 

25,789 

0 

To  estimate  enforcement  costs  for  monitoring  stakeholders’  compliance  with  PM  B.2,  the 
information retrieved from the ex-post evaluation of the ITS Directive 2010/40/EU260 has been 
used as a proxy. As SMEs would be exempted of this measure and rail carriers and 90% of air 
carriers already implement the system in the baseline, the monitoring effort is expected to be 
lower than estimated in the ex-post evaluation of the ITS Directive. The share of intermediaries 
and carriers that are subject to this measure in the total number of multimodal intermediaries 
and carriers (9.2%) has been used as a proxy to calculate the recurrent enforcement costs per 
Member State, estimated at  EUR 3,881 per year. Total  recurrent  enforcement costs are thus 
estimated at EUR 104,800 per year, or EUR 1.9 million expressed as present value over 2025-
2050.  

Table 78: Enforcement costs due to PM B.2 for public authorities for monitoring activities 

260 Support study for the ex-post evaluation of the ITS Directive 2010/40/EU – Contract number 
MOVE/B4/SER/2016-237/SI2.760668. 

56 

 
 
 
 
Recurrent  enforcement  costs  per  MS,  per  year  (EUR,  in  2021 
prices) 

Number of MS 

Total recurrent enforcement costs per year (EUR) 

Ongoing costs expressed as present value for 2025-2050 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

3,881  

27 

104,800 

1,929,695 

PM B.3a: Right to pre-purchase information, right to reimbursement or re-routing, right 
to care and right to PRM assistance for passengers having a single contract of carriage 
(category A)  

In  PM  B.3a,  carriers  and  intermediaries  have  to  ensure  that  passengers  travelling  on  single 
contracts of carriage for a multimodal journey enjoy a set of rights that already apply when 
travelling within a single mode of transport on the basis of the existing Regulations (air, rail, 
bus  and  coach,  and  waterborne),  namely  a  right  to  pre-purchase  information,  a  right  to 
reimbursement or re-routing and a right to care in the event of a missed connection, as well as 
a right to non-discriminatory transport contract conditions and free assistance for PRM. 

One-off  adjustment  costs  for  carriers  and  intermediaries  to  provide  pre-purchase 
information about the type of multimodal ticket 

In the targeted survey, stakeholders argued that to provide pre-purchase information about the 
type of multimodal ticket an update in the communication systems is needed. It is estimated 
that 2 working days on one-off basis are needed, working 7.5 hours per day.  

The market share of multimodal tickets of category A has been used to estimate the number of 
carriers  and  intermediaries  affected  (138).  It  is  noteworthy  that  ticket  category  A  does  not 
encompass air transport.  

Table 79: Number of carriers and intermediaries affected by PM B.3a 

Multimodal Stakeholders 

Total 

Share of Multimodal 
(%) 

Multimodal operators 
affected 

Number  of  bus  and  coach 
carriers 

Number of rail carriers 

Number  of  waterborne 
carriers 

3,778 

283 

523 

Number of intermediaries  

123,000 

Total, of which 

SMEs 

0.2% 

1.2% 

0.5% 

0.1% 

9 

3 

3 

123 

138 

128 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

The one-off adjustment costs for carriers and intermediaries are estimated at EUR 64,428 in 
2025, relative to the baseline, of which EUR 59,759 for SMEs.  

Table 80: One-off adjustment costs for carriers and intermediaries to provide pre-purchase information about 
the type of multimodal ticket, due to PM B.3a 

ISCO 3 Technicians and associate professionals hourly wage (EUR 
per hour in 2021 prices) 

31.1 

57 

 
 
 
 
 
 
Working days to implement changes 

Workday (in hours) 

Number of carriers and intermediaries affected 

One-off adjustment costs in 2025 (EUR, in 2021 prices), of which: 

Carriers 

Intermediaries 

of which for SMEs: 

Carriers 

Intermediaries 

2 

7.5 

138 

64,428 

7,003 

57,425 

59,759 

5,136 

54,623 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

It is important to highlight that separate assistance for PRMs is already provided in most modes 
of transport individually and thus the costs associated to it are part of the baseline.  

Adjustment costs for carriers to provide full reimbursement or re-routing and right to care 
to category A multimodal tickets 

In order to estimate the adjustment costs for carriers to provide full reimbursement or re-routing, 
as  well  as  to  provide  care  to  the  passengers  holding  a  category  A  multimodal  ticket261,  the 
number of bus and coach and rail passengers holding category A multimodal tickets has been 
first estimated. Considering the marginal share of waterborne transport in multimodal journeys, 
the costs for waterborne transport have not been estimated.  

The category A multimodal tickets represents only 5% of the total multimodal tickets sold262, 
and their share is assumed to remain constant over time. Considering the number of multimodal 
passengers  projected  in  the  baseline  and  the  share  of  category  A  multimodal  tickets,  the 
projected number of category A multimodal tickets is provided in the table below.  

The costs related to reimbursement/ re-routing are estimated based on the number of category 
A multimodal tickets, the share of delayed passengers and the average fare per passenger from 
the baseline scenario (see section 2.2 of Annex 4). Concerning the right to care, the costs have 
been derived as a share of the reimbursement/ re-routing costs, drawing on the Steer study on 
the Evaluation of Regulation (EU) No 181/2011 on the rights of passengers travelling by bus 
and coach. The same share has been used for rail, in lack of data. The total adjustment costs for 
bus  and  coach  and  rail  carriers,  for  2025,  2030,  2040  and  2050  relative  to  the  baseline  are 
provided in the table below. Expressed as present value over 2025-2050, the costs are estimated 
at EUR 20.1 million (EUR 11.5 million for bus and coach carriers and EUR 8.6 million for 
rail), of which EUR 9.8 million for SMEs.   

Table 81: Recurrent adjustment costs for carriers to provide full reimbursement or re-routing and right to care 
to category A multimodal tickets, due to PM B.3a, relative to the baseline 

2025 

2030 

2040 

2050 

Bus and coach  

261 Category A tickets: single contracts of carriage offered by carriers (or by ticket vendors on behalf of carriers), 
with the carrier acting as a party to the transport contract with the passenger and guaranteeing, usually in its terms 
and  conditions  of  carriage,  more  comprehensive  protection  including  journey  continuation  in  case  of  missed 
connections when changing modes – the tickets under consideration include combinations between rail, bus and 
coach and waterborne travel (but not air legs). 
262 EY (2019), Exploratory study on passenger rights in the multimodal context. 

58 

 
 
 
  
  
  
  
 
Number of category A multimodal tickets  
Share of passengers delayed (%) 
Total adjustment costs (EUR), of which: 

 Reimbursement/ re-routing costs (EUR)  
 Care costs (EUR)  

Rail 
Number of category A multimodal tickets  
Share of passengers delayed (%) 
Total adjustment costs (EUR), of which: 

 Reimbursement/ re-routing costs (EUR)  
 Care costs (EUR)  

Total adjustment costs (EUR), of which:  
 Reimbursement/ re-routing costs (EUR)  
 Care costs (EUR)  
of which, costs for SMEs 

2040 

2025 

2030 

4.4% 

2050 
       158,463          203,415          243,453          304,251  
4.4% 
       427,556          545,186          682,460          845,241  
       280,768          358,014          448,159          555,055  
       146,788          187,172          234,301          290,187  

4.4% 

4.4% 

7.5% 

8.8% 

8.8% 

       134,354          150,762          199,604          240,640  
6.3% 
       395,346          444,592          493,366          486,512  
       262,725          294,947          326,473          321,380  
       132,621          149,646          166,893          165,132  
  1,331,753  
     822,902  
       543,494          652,961          774,632          876,434  
       279,408          336,818          401,194          455,319  
       363,423          463,408          580,091          718,455  

     989,779  

  1,175,827  

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Enforcement costs for public authorities 

Based  on  the  information  provided  by  one  national  authority  (the  Netherlands)  that 
approximately EUR 20,000 per year should be necessary to monitor these activities, the total 
recurrent  enforcement  costs  per  year  at  EU  level  have  been  estimated  at  EUR  540,000. 
Expressed as present value over 2025-2050, this is equivalent to EUR 9.9 million. 

Table 82: Recurrent enforcement costs due to PM B.3a for public authorities for monitoring activities 

Cost per Member State (EUR) 

Number of Member States affected 

Total recurrent enforcement costs per year (EUR) 

Total  recurrent  enforcement  costs,  expressed  as  present  value 
over 2025-2050 (EUR) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

20,000 

27 

540,000 

9,943,100 

Benefit for consumers (due to the right to reimbursement/ re-routing and the right to care) 

PM  B.3a  would  benefit  multimodal  passengers  that  hold  a  single  contract  of  carriage  for  a 
multimodal journey (category A), that are projected to go up from around 293 thousand in 2025 
to  545  thousand  by  2050.  The  category  A  multimodal  tickets  represents  5%  of  the  total 
multimodal tickets sold263. Under PM B.3a, multimodal passengers will benefit from the i) right 
to reimbursement/re-routing and ii) right to care, which will lead to cost savings for passengers 
who would otherwise incur some of the costs themselves. These elements are perceived as the 
most important rights for passengers (41.7% of passengers considered receiving “alternative 
transport”  as  the  most  relevant,  while  39.6%  consider  the  right  to  care  and  34.7%  of  the 
respondents believe that the right of reimbursement is the most important passenger’s right264).  

The  benefits  related  to  reimbursement/  re-routing  are  estimated  based  on  the  number  of 
category  A  multimodal  tickets,  the  share  of  delayed  passengers  and  the  average  fare  per 
passenger from the baseline scenario (see section 2.2 of Annex 4). Concerning the right to care, 
the benefits have been derived as a share of the reimbursement/ re-routing benefits, drawing on 

263 EY (2019), Exploratory study on passenger rights in the multimodal context. 
264 European Court of Auditors, ECA statistical passenger survey, 2018. 

59 

 
 
  
  
  
  
 
 
the Steer study on the Evaluation of Regulation (EU) No 181/2011 on the rights of passengers 
travelling by bus and coach. The same share has been used for rail, in lack of data. The total 
benefits for bus and coach passengers, for 2025, 2030, 2040 and 2050 relative to the baseline 
are provided in the table below. Expressed as present value over 2025-2050, the benefits are 
estimated at EUR 20.1 million (EUR 11.5 million for bus and coach passengers and EUR 8.6 
million for rail passengers).   

Table 83: Passengers holding multimodal products based on single contracts of service (ticket category A) and 
benefits due to the right to reimbursement/ re-routing and the right to care in 2025, 2030, 2040 and 2050 relative 
to the baseline 

2025 

2030 

2040 

2050 

Bus and coach 
Number of category A multimodal tickets  
Total benefits (EUR), of which for: 

 Reimbursement/ re-routing (EUR)  
 Care (EUR)  

Rail 
Number of category A multimodal tickets  
Total benefits (EUR), of which for: 

 Reimbursement/ re-routing (EUR)  
 Care (EUR)  

Total bus and coach, and rail 
Number of category A multimodal tickets  
Total benefits (EUR), of which for: 

 Reimbursement/ re-routing (EUR)  
 Care (EUR)  

    158,463  
    427,556  
    280,768  
    146,788  

    203,415  
    545,186  
    358,014  
    187,172  

    243,453  
    682,460  
    448,159  
    234,301  

    304,251  
    845,241  
    555,055  
    290,187  

    134,354  
    395,346  
    262,725  
    132,621  

    150,762  
    444,592  
    294,947  
    149,646  

    199,604  
    493,366  
    326,473  
    166,893  

    240,640  
    486,512  
    321,380  
    165,132  

    292,817  
    822,902  
    543,494  
    279,408  

    354,176  
    989,779  
    652,961  
    336,818  

    443,058  
 1,175,827  
    774,632  
    401,194  

    544,891  
 1,331,753  
    876,434  
    455,319  

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Table 84: Total benefits to consumers due to the right to reimbursement/ re-routing and the right to care in PM 
B.3a, expressed as present value over 2025-2050 relative to the baseline (EUR, in 2021 prices) 

Total  benefits  for  passengers  due  to  additional  rights  for 
reimbursement/rerouting 
ticket 
category A passengers (EUR) 

in  multimodal 

journeys 

in 

and 

Bus 
Coach 

Rail 

Total benefits for  passengers due to additional rights for care in 
multimodal journeys in ticket category A passengers (EUR) 

Bus 
Coach 

and 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Benefit for consumers (hassle costs savings) 

Rail 

        7,563,870    

        5,677,239    

        3,954,444    

        2,892,936    

In the baseline scenario, PRMs travelling under category A multimodal tickets are estimated to 
wait  a  maximum  of  60  minutes  to  receive  assistance  to  be  arranged265.  On  the  other  hand, 
quality parameters for assistance to PRMs are established for air transport266. More specifically:  

•  For waiting times for arriving and registered PRM passengers at the gate or aircraft: 

-  For 80% of passengers, the waiting time for assistance must not exceed 5 minutes; 

265 Considering that according to the revised Rail Passenger Rights Regulation, the transport operator may request 
the  passenger  to  be  at  the  station  maximum  60  minutes  before  the  departure  of  the  train  in  order  to  receive 
assistance. 
266 In accordance with the European Civil Aviation Conference’s (ECAC) Doc 30- Annex J- "Code of Good 
Conduct", available at: https://www.ecac-ceac.org/images/documents/ECAC-
Doc_30_Part_1_12th_edition_May_2018_Amendment_4_Nov_2020.pdf.  

60 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
-  90% of passengers must wait no longer than 10 minutes for assistance; 
-  100% of passengers must be picked up within 20 minutes; 

•  For waiting time for arriving and unannounced PRM passengers at the gate or aircraft: 
-  For 80% of passengers, the waiting time for assistance must not exceed 25 minutes; 
-  For 90% of passengers, the waiting time for assistance must not exceed 35 minutes; 
-  100% of passengers must be picked up within 45 minutes. 

Considering that the right to PRM assistance for PRM passengers travelling under category A 
multimodal tickets will ensure that similar time thresholds are met as for air transport, PRMs 
may  save  40  to  60  minutes  per  multimodal  journey  when  arranging  assistance  (taking  into 
account that 100% of passengers must be picked up within 20 minutes) compared to the baseline 
where no such rights are foreseen. This right is foreseen for PRM passengers travelling under 
category A multimodal tickets, regardless of whether they are travelling through a multimodal 
passenger hub. 

Considering the total number of PRMs requests for long-distance bus and coach journeys and 
for  rail  and  waterborne  journeys,  the  share  of  multimodal  market  and  the  fact  that  5%  of 
multimodal  passengers  hold  category  A  multimodal  tickets,  the  number  of  PRM  requests 
affected is  estimated  at  37,020 in  2025, 47,723 in 2030 and 109,312 in  2050 relative to  the 
baseline. As explained, the time saved per PRM request is estimated at 40 (lower bound) to 60 
(upper bound) minutes. Using the consumer value of time estimated at EUR 22.7 per hour267 in 
2021  prices,  the  hassle  costs  savings  for  PRMs  are  provided  in  the  table  below.  Per  PRM 
request, they are estimated at EUR 15.1 to 22.7. Expressed as present value over 2025-2050, 
hassle costs savings for PRMs due to PM B.3a are estimated at EUR 18.6 to 27.9 million relative 
to the baseline. 

Table 85: Hassle costs savings for consumers due to PM B.3a relative to the baseline 

Number of PRM requests affected 

Consumers value of time (EUR) 
Hassle costs savings (EUR) 
Lower bound estimate 
Upper bound estimate 

560,305 
840,458 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

2025 
37,020 
22.7 

2030 
47,723 
22.7 

2040 
78,379 
22.7 

2050 
109,312 
22.7 

722,289 
1,083,433 

1,186,264 
1,779,396 

1,654,436 
2,481,654 

PM B.3b: Enhanced package of rights for passengers holding a single contract of carriage 
(category  A)  (i.e.  same  rights  as  under  PM  B.3a  +  right  to  conclude  an  alternative 
contract)  

In  PM  B.3b,  carriers  have  to  ensure  that,  on  top  of  the  rights  proposed  under  PM  B.3a, 
passengers  have  a  right  to  conclude  an  alternative  contract  where  a  carrier  does  not  make 
provision for the continuation of a passenger’s journey (“right to self re-routing"). This measure 
is similar to what is already required under Article 18(3) of Regulation (EU) 2021/782. 

267 Source: https://www.eurocontrol.int/sites/default/files/publication/files/standard-input-for-eurocontrol-cost-
benefit-analyses-2018-edition-8-version-2.6.pdf. 

61 

 
  
  
  
  
  
 
One-off  adjustment  costs  for  carriers  and  intermediaries  to  provide  pre-purchase 
information about the type of multimodal ticket  

These costs are the same as those under PM B3.a. The one-off adjustment costs for carriers and 
intermediaries in 2025 are estimated at EUR 64,428 in 2025, relative to the baseline, of which 
EUR 59,759 for SMEs. 

Adjustment costs for carriers to provide full i) reimbursement or re-routing, ii) care and iii) 
alternative contract to category a) multimodal ticket 

The calculations of the costs for carriers to provide full reimbursement /re-routing and the right 
to care are the same as those under PM B.3a. The costs related to reimbursement/ re-routing are 
estimated  based  on  the  number  of  category  A  multimodal  tickets,  and  the  share  of  delayed 
passengers and the average fare per passenger from the baseline scenario (see section 2.2 of 
Annex  4).  Concerning  the  right  to  care,  the  costs  have  been  derived  as  a  share  of  the 
reimbursement/ re-routing costs, drawing on the Steer study on the Evaluation of Regulation 
(EU) No 181/2011 on the rights of passengers travelling by bus and coach. The same share has 
been used for rail, in lack of data. 

However, under PM B.3b, to incorporate the costs associated with the option to conclude an 
alternative contract, the average bus and coach ticket fare has been assumed to be 10% higher 
than in the baseline scenario and the average rail ticket fare 30% higher than in the baselilne 
scenario.  This  reflects  the  additional  cost  of  last-minute  ticket  fares  and  it  is  based  on  the 
average ticket price observed for last-minute ticket fares, as determined through desk research 
analysis in the context of the impact assessment support study. 

The total adjustment costs for bus and coach and rail carriers, for 2025, 2030, 2040 and 2050 
relative to the baseline are provided in the table below.  Expressed as present value over 2025-
2050, the costs are estimated at EUR 23.8 million (EUR 12.7 million for bus and coach carriers 
and EUR 11.1 million for rail), of which EUR 10.8 million for SMEs.  

Table 86: Recurrent adjustment costs for carriers to provide full reimbursement or re-routing and right to care 
+ the right to conclude an alternative contract to category A multimodal tickets, due to PM B.3b, relative to the 
baseline 

2025 

2030 

2040 

2050 

Bus and coach  
Number of category A multimodal tickets  
Share of passengers delayed by more than 90 
minutes (%) 
Total adjustment costs (EUR), of which: 

 Reimbursement/ re-routing costs (EUR)  
 Care costs (EUR)  

Rail 
Number of category A multimodal tickets  
Share of passengers delayed by more than 90 
minutes (%) 
Total adjustment costs (EUR), of which: 

 Reimbursement/ re-routing costs (EUR)  
 Care costs (EUR)  

 Total adjustment costs (EUR), of which:  
 Reimbursement/ re-routing costs (EUR)  
 Care costs (EUR)  
of which, costs for SMEs 

                  158,463          203,415          243,453          304,251  
4.4% 
4.4% 

4.4% 

4.4% 

                  442,235          563,904          705,890          874,260  
                  280,768          358,014          448,159          555,055  
                  161,466          205,890          257,731          319,205  

                  134,354          150,762          199,604          240,640  
6.3% 
8.8% 

7.5% 

8.8% 

                  435,132          489,486          543,434          536,051  
                  262,725          294,947          326,473          321,380  
                  172,407          194,539          216,961          214,672  
                877,367  
  1,410,311  
                  543,494          652,961          774,632          876,434  
                  333,873          400,429          474,692          533,877  
                  375,900          479,318          600,007          743,121  

  1,053,390  

  1,249,325  

Source: PWC, TIS and Steer (2023), Impact assessment support study 

62 

 
 
 
  
  
  
  
  
  
  
  
Some  recurrent  adjustment  costs  associated  to  business-to-business  negotiations,  contract 
agreements and business-to-business compensation mechanisms are also expected. The latter 
refers  to  the  reimbursement  costs  that  result  from  the  passengers  concluding  an  alternative 
contract and the carrier seeking to redress such cost to the other transport operators linked to 
the single multimodal contract. However, due to the lack of data on the costs of establishing 
such negotiations and agreements – as well as the fact that they depend on the various carrier 
alliances already in place, it was not possible to estimate such costs. Nevertheless, it is expected 
that a share of these costs are already embedded into the ticket fares used for the calculations 
of the recurrent adjustment costs above. 

One-off adjustment costs for carriers and intermediaries concerning the right to conclude an 
alternative  contract  where  a  carrier  does  not  make  provision  for  the  continuation  of  a 
passenger’s journey within a defined time limit 

The key distinguishing element of this measure relative to PM B.3a is the right to conclude an 
alternative  contract  where  a  carrier  does  not  make  provision  for  the  continuation  of  a 
passenger’s journey within a defined time limit.  

The recurrent costs associated with the right to conclude an alternative contract have already 
been included in the section above. However, this measure is also expected to lead to one-off 
adjustment costs for carriers and intermediaries for informing the passengers about the right to 
conclude an alternative contract where a carrier does not make provision for the continuation 
of a passenger’s journey within a defined time limit, as well as for updating their IT systems. 
The  one-off  adjustment  costs  have  been  assessed  to  be  similar  to  those  for  providing  pre-
purchase information about the type of multimodal ticket, at EUR 64,428 in 2025 relative to 
the baseline.  

Table 87: One-off costs for carriers and intermediaries for informing passengers on the right to conclude an 
alternative  contract  where  a  carrier  does  not  make  provision  for  the  continuation  of  a  passenger’s  journey 
within a defined time limit, due to due to PM B.3b relative to the baseline 

ISCO 3 Technicians and associate professionals hourly wage (EUR 
per hour in 2021 prices) 

Working days to implement changes 

Workday (in hours) 

Number of carriers and intermediaries affected 

One-off adjustment costs in 2025 (EUR, in 2021 prices), of which: 

Carriers 

Intermediaries 

of which for SMEs: 

Carriers 

Intermediaries 

31.1 

2 

7.5 

138 

64,428 

7,003 

57,425 

59,759 

5,136 

54,623 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Enforcement costs for public authorities 

Recurrent  enforcement  costs  for  public  authorities  are  the  same  with  those  under  PM  B.3a. 
They are estimated at EUR 540,000 per year from 2025 onwards. Expressed as present value 
over 2025-2050, this is equivalent to EUR 9.9 million. 

63 

 
 
Benefit for consumers (due to the right to reimbursement/ re-routing and the right to care) 

Under policy measure B.3b, similarly to PM B.3a, multimodal passengers will benefit from the 
i) right to reimbursement/re-routing and ii) right to care. In addition, they will also benefit of 
the provision for consumers to conclude an alternative contract. The benefits of this right for 
consumers  and  passengers  were  taken  into  account  in  the  calculations  for  the  provision  for 
reimbursement and re-routing and are presented below. To reflect the benefits associated with 
the option to conclude an alternative contract, the average bus and coach ticket fare has been 
assumed to be 10% higher than in the baseline scenario and the average rail ticket fare 30% 
higher than in the baselilne scenario. This allows to cover the additional cost of last-minute 
ticket fares. The assumptions are based on the average ticket prices observed for last-minute 
ticket  fares,  as  determined  through  desk  research  analysis  in  the  context  of  the  impact 
assessment support study. 

The total benefits for bus and coach passengers, for 2025, 2030, 2040 and 2050 relative to the 
baseline  are  provided  in  the  table  below.  Expressed  as  present  value  over  2025-2050,  the 
benefits are estimated at EUR 23.8 million (EUR 12.7 million for bus and coach passengers 
and EUR 11.1 million for rail passengers).   

Table 88: Passengers holding multimodal products based on single contracts of service (ticket category A) and 
benefits due to the right to reimbursement/ re-routing and the right to care in 2025, 2030, 2040 and 2050 in PM 
B.3b relative to the baseline 

2025 

2030 

2040 

2050 

Bus and coach 
Number of category A multimodal tickets  
Total benefits (EUR), of which for: 

 Reimbursement/ re-routing (EUR)  
 Care (EUR)  

Rail 
Number of category A multimodal tickets  
Total benefits (EUR), of which for: 

 Reimbursement/ re-routing (EUR)  
 Care (EUR)  

Total bus and coach, and rail 
Number of category A multimodal tickets  
Total benefits (EUR), of which for: 

 Reimbursement/ re-routing (EUR)  
 Care (EUR)  

    158,463  
    427,556  
    280,768  
    146,788  

    203,415  
    545,186  
    358,014  
    187,172  

    243,453  
    682,460  
    448,159  
    234,301  

    304,251  
    845,241  
    555,055  
    290,187  

    134,354  
    395,346  
    262,725  
    132,621  

    150,762  
    444,592  
    294,947  
    149,646  

    199,604  
    493,366  
    326,473  
    166,893  

    240,640  
    486,512  
    321,380  
    165,132  

    292,817  
    822,902  
    543,494  
    279,408  

    354,176  
    989,779  
    652,961  
    336,818  

    443,058  
 1,175,827  
    774,632  
    401,194  

    544,891  
 1,331,753  
    876,434  
    455,319  

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Table 89: Total benefits for consumers due to the right to reimbursement/ re-routing and the right to care in 
PM B.3b, expressed as present value over 2025-2050 relative to the baseline (EUR, in 2021 prices) 

Total cost-savings for consumers from PM B.3a (2021 prices) 

Total  benefits  for  passengers  due  to  additional  rights  for 
reimbursement/rerouting 
ticket 
category  A  passengers,  including  the  option  to  conclude  an 
alternative contract (EUR) 

in  multimodal 

journeys 

in 

and 

Bus 
Coach 

Rail 

Total benefits for  passengers due to additional rights for care in 
multimodal journeys in ticket category A passengers (EUR) 

Bus 
Coach 

and 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Rail 

64 

        8,320,257    

        7,380,410    

        4,349,889    

        3,760,817    

 
  
  
  
  
  
  
  
  
  
  
  
  
  
Benefit for consumers (hassle costs savings) 

The  hassle  costs  savings  for  consumers  due  to  PM  B.3b  are  the  same  as  for  PM  B.3a. 
Considering that the right to PRM assistance for PRM passengers travelling under category A 
multimodal tickets will ensure that similar time thresholds are met as for air transport, PRMs 
may  save  40  to  60  minutes  per  multimodal  journey  when  arranging  assistance  (taking  into 
account that 100% of passengers must be picked up within 20 minutes) compared to the baseline 
where no such rights are foreseen. This right is foreseen for PRM passengers travelling under 
category A multimodal tickets, regardless of whether they are travelling through a multimodal 
passenger hub. 

Considering the total number of PRMs requests for long-distance bus and coach journeys and 
for  rail  and  waterborne  journeys,  the  share  of  multimodal  market  and  the  fact  that  5%  of 
multimodal  passengers  hold  category  A  multimodal  tickets,  the  number  of  PRM  requests 
affected is  estimated at  37,020 in  2025, 47,723 in 2030 and 109,312 in  2050 relative to  the 
baseline. As explained, the time saved per PRM request is estimated at 40 (lower bound) to 60 
(upper bound) minutes. Using the consumer value of time estimated at EUR 22.7 per hour268 in 
2021  prices,  the  hassle  costs  savings  for  PRMs  are  provided  in  the  table  below.  Per  PRM 
request, they are estimated at EUR 15.1 to 22.7.  Expressed as present value over 2025-2050, 
hassle  costs  savings  for  PRMs  due  to  PM  B.3b  are  estimated  at  EUR  18.6  to  27.9  million 
relative to the baseline. 

Table 90: Hassle costs savings for consumers due to PM B.3b relative to the baseline 

Number of PRM requests affected 

Consumers value of time (EUR) 
Hassle costs savings (EUR) 
Lower bound estimate 
Upper bound estimate 

560,305 
840,458 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

2025 
37,020 
22.7 

2030 
47,723 
22.7 

2040 
78,379 
22.7 

2050 
109,312 
22.7 

722,289 
1,083,433 

1,186,264 
1,779,396 

1,654,436 
2,481,654 

PM B.4a: Essential set of rights for passengers holding separate tickets (category B) (i.e. 
right  to  pre-purchase  information  +  right  to  reimbursement  and penalty  of  75%  from 
ticket vendor/tour operator, unless where passengers were properly informed of separate 
nature of the tickets) 

In PM B.4a, ticket vendors and tour operators have to properly inform passengers where they 
bundle separate tickets for a multimodal journey and sell them in one commercial transaction 
to passengers. Where they do not provide information on the separate nature of the transport 
tickets, they would be liable to reimburse the passenger the entire amount paid for the separate 
tickets, together with a penalty of 75% of that amount, in the event where the passengers miss 
a connection during the multimodal journey. This measure is similar to what is already required 
for ticket vendors and tour operators under Article 12(4) and (5) of Regulation (EU) 2021/782. 

Adjustment costs for carriers and intermediaries 

Stakeholders that responded to the targeted survey argued that the implementation of the right 
to pre-purchase information in PM B.4a would entail an update in the communication systems. 

268 Source: https://www.eurocontrol.int/sites/default/files/publication/files/standard-input-for-eurocontrol-cost-
benefit-analyses-2018-edition-8-version-2.6.pdf 

65 

 
  
  
  
  
  
 
The effort required has been estimated, similarly to PM B.3a, to 2 working days per carrier and 
intermediary on one-off basis.  

The market share of multimodal tickets of category B has been used to estimate the number of 
carriers and intermediaries affected. In total, 371 carriers and intermediaries are estimated to be 
affected by this policy measure.  

Table 91: Number of carriers and intermediaries affected by PM B.4a 

Multimodal Stakeholders 

Total 

Share of Multimodal (%) 

Multimodal operators 
Affected 

Number  of  bus  and  coach 
operators  

3,778 

Number of rail operators  

Number of air carriers  

Number of waterborne 
operators  

283 

149 

523 

Number of intermediaries  

123,000 

Total, of which: 

SMEs 

4.3% 

23.2% 

7.2% 

1% 

0.1% 

165 

66 

11 

6 

123 

371 

263 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

The  total  one-off  cost  for  carriers,  ticket  vendors  and  tour  operators  are  estimated  at  EUR 
173,207 in 2025, relative to the baseline, of which EUR 122,786 for SMEs.  

Table 92: One-off adjustment costs for carriers and intermediaries due to PM B.4a  

ISCO 3 Technicians and associate professionals hourly wage (EUR 
per hour in 2021 prices) 

Working days to implement changes 

Workday (in hours) 

Number of carriers and intermediaries affected 

One-off adjustment costs in 2025 (EUR, in 2021 prices), of which: 

Carriers 

Intermediaries 

of which for SMEs: 

Carriers 

Intermediaries 

31.1 

2 

7.5 

371 

173,207 

115,783    

57,425    

122,786    

68,162    

54,623    

Source: PWC, TIS and Steer (2023), Impact assessment support study 

In addition, the proposed measure establishes that if the intermediary fails to inform passengers 
properly  they  would  need  to  reimburse  the  total  amount  paid  for  the  tickets  plus  a  penalty 
equivalent to 75% of that amount. The proposed measure is expected to incentive multimodal 
operators to improve their communication process towards passengers, in order to reduce the 
likelihood of recurring to reimbursements and penalties. Given the uncertainty to establish the 
number of passengers affected, the costs cannot be quantified although they are expected to be 
limited.  

Enforcement costs for national public authorities 

66 

 
 
Considering  the  synergies  with  other  measures  included  in  PO  2.2,  namely  PM  B.3a,  no 
additional monitoring costs for national public authorities are foreseen in PM B.4a. 

PM B.4b: Enhanced rights for passengers holding separate tickets (category B) (i.e. same 
B.3b). The ticket vendor is liable to ensure these rights towards the passenger unless where 
passengers were properly informed of the separate nature of the tickets 

In PM B.4b, ticket vendors and tour operators will have to provide passengers travelling on 
separate tickets (category B) the same rights that passengers having a single contract of carriage 
would enjoy under PM B.3b, unless where passengers were properly informed on the separate 
nature of tickets. 

Adjustment  costs  for  carriers  and  intermediaries  for  providing  pre-purchase  information 
about the type of multimodal ticket  

To provide pre-purchase information about the type of multimodal ticket, similar one-off effort 
as for PM B.4a has been assumed to implement the necessary IT changes, namely 2 working 
days per carrier and intermediary on one-off basis.  

Similarly to PM B.4a, the market share of multimodal tickets of category B has been used to 
estimate  the  number  of  carriers  and  intermediaries  affected.  In  total,  371  carriers  and 
intermediaries are estimated to be affected by this policy measure.  

The  total  one-off  cost  for  carriers,  ticket  vendors  and  tour  operators  are  estimated  at  EUR 
173,207 in 2025, relative to the baseline, of which EUR 122,786 for SMEs.  

Table 93: One-off adjustment costs for carriers and intermediaries to provide pre-purchase information about 
the type of multimodal ticket due to PM B.4b  

ISCO 3 Technicians and associate professionals hourly wage (EUR 
per hour in 2021 prices) 

Working days to implement changes 

Workday (in hours) 

Number of carriers and intermediaries affected 

One-off adjustment costs in 2025 (EUR, in 2021 prices), of which: 

Carriers 

Intermediaries 

of which for SMEs: 

Carriers 

Intermediaries 

31.1 

2 

7.5 

371 

173,207 

115,783    

57,425    

122,786    

68,162    

54,623    

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Adjustment costs for intermediary ticket vendors for improving the communication process 
to passengers regarding enhaced rights and Single Point of Contact 

PM B.4b is expected to result in additional costs for intermediary ticket vendors compared to 
PM B.4a, due to the enhanced package of rights for passengers, which is expected to result in 

67 

 
 
additional  one-off  costs  for  adapting  their  IT  systems  to  provide  information  to  passengers 
regarding the Single Contact Point for PRMs.  

Stakeholder evidence gathered during the targeted survey, showed that the changes required to 
the  system  would  take  around  2  working  days.  Assuming  an  hourly  worker’s  wage 
corresponding to ISCO 3 (technicians and associate professionals) and 7.5 working hours per 
day,  the  total  one-off  adjustment  costs  for  ticket  vendors  for  improving  the  communication 
process to passengers regarding enhaced rights and Single Point of Contact are estimated at 
EUR 57,425 for the EU-27 in 2025 relative to the baseline, of which EUR 54,623 for SMEs. 

Table 94: One-off adjustment costs for intermediary ticket vendors for improving the communication process 
to  passengers  better  inform  them  about  their  rights  and  Single  Point  of  Contact  for  RPM  due  to  PM  B.4b 
relative to the baseline  

ISCO 3 Technicians and associate professionals hourly wage (EUR 
per hour in 2021 prices) 

Working days to implement changes 
Workday (in hours) 
Number of stakeholders affected, of which: 
SMEs 
One-off adjustment costs in 2025 (EUR, in 2021 prices), of which 
for: 

SMEs 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

31.1 

2 
7.5 
123 
117 
57,425 

54,623 

Hence, the total one-off adjustment costs for PM B.4b are estimated at EUR 230,632 (EUR 
115,783 for carriers and EUR 114,849 for intermediaries), of which EUR 177,409 for SMEs. 

Enforcement costs for public authorities 

Considering  the  synergies  with  other  measures  included  in  PO  2.3,  namely  PM  B.3b,  no 
additional monitoring costs for national public authorities are foreseen in PM B.4b. 

PM B.5: Terminal managers and carriers shall establish “Single Points of Contact” (SPC) 
for PRM at multimodal hubs (category A+B+C)  

PM B.5 requires terminal managers and carriers operating via multimodal hubs at urban nodes 
to establish “Single Points of Contact” (SPC) to arrange the assistance for PRMs. The contact 
details of the SPC would be published on their websites. The SPC could be contacted by phone 
and via a dedicated online contact form, enabling PRMs to request assistance when they need 
to transfer between terminals to reach a connecting service provided by another transport mode. 
The SPC would communicate individual requests for assistance to other terminal managers and 
carriers involved in the journey, providing a “one stop shop” for the PRM. Notification would 
need to be provided at least 48 hours ahead of the journey. This measure is inspired by Article 
24 (f) of Regulation (EU) 2021/782. 

Adjustment  costs  for  terminal  managers  to  establish  “Single  Points  of  Contact”  (SPC)  to 
arrange assistance for passengers with disabilities or reduced mobility (PRMs) 

To  implement  this  policy  measure,  additional  personnel  would  be  needed  to  implement  a 
“Single  Point  of  Contact”  (SPC)  devoted  to  arranging  the  assistance  of  passengers  with 
disabilities or reduced mobility (PRMs). Moreover, a central point which connects the already 

68 

 
 
existing request handling procedures for passenger assistance in each mode would have to be 
established as part of the SPC. Based on the targeted survey269 the one-off costs to establish the 
SPC is estimated at EUR 50,000 per terminal, which includes EUR 10,000 to set up the system 
and  EUR  40,000  for  additional  staff  and  infrastructure-related  costs,  and  the  recurrent 
adjustment costs to maintain the structure and staff at EUR 40,000 per terminal per year.  

By channelling assistance requests from PRM travelling through core multimodal passenger 
hubs, the SPC would aim to mobilise the existing assistance means of terminal operators and 
carriers to assist PRM and create synergies between these assistance mechanisms. Indeed, the 
majority of multimodal terminal operators and carriers already have a PRM assistance system 
in place for individual modes270. Therefore, the additional one-off costs to set up the SPC would 
primarily involve business-to-business arrangements between transport operators and terminal 
operators, as well as minor infrastructure related costs.  

The costs are assumed to be borne by one terminal manager per multimodal passenger hub (i.e. 
the multimodal terminal operator). Individual arrangements might be in place at specific Single 
Points of Contacts where carriers (and other terminal managers, if there are several at the hub) 
might also take up part of the costs, but this would depend on a case-by-case basis. Therefore, 
no cost estimate can be made for the latter. 

As  explained  in  section  2.2  of  Annex  4,  the  number  of  multimodal  terminal  operators  is 
estimated at 424, assuming the implementation of the proposal for the review of the TEN-T 
Regulation in the baseline scenario. Thus, 424 terminal operators are expected to be affected 
by the measure. 

Table 95: Number of multimodal terminal operators affected by PM B.5 

Multimodal Stakeholders 

Multimodal operators Affected 

Number of multimodal terminal operators affected 

424 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

The total  one-off costs for multimodal terminal operators are estimated  at  EUR 4.2 million, 
relative to the baseline. 

Table 96: One-off adjustment costs for multimodal terminal operators due to PM B.5  

One-off costs per terminal operator for setting up the system (EUR) 

Number of multimodal terminal operators 

Total one-off adjustment costs (EUR) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

10,000 

424 

4,240,000 

The recurrent adjustment costs for multimodal terminal operators, consisting in costs related to 
staff, are estimated based on stakeholders’ feedback for the costs per year per terminal operator 
and the number of terminal operators. Total recurrent adjustment costs are estimated at EUR 
17 million per year from 2025 onwards relative to the baseline. Expressed as present value over 
2025-2050, the total adjustment costs are estimated at EUR 312.3 million.   

Table 97: Recurrent adjustment costs for multimodal terminal operators due to PM B.5  

269 One carrier and umbrella organisations for other modes than air from Germany. 
270 Evidence from the targeted consultation shows that operators already have in system points of contact to 
provide assistance to PRMs, which it is indicated at the booking stage. 

69 

 
 
 
Recurrent costs per terminal operator per year (EUR) 

Number of multimodal terminal operators 

Recurrent adjustment costs per year (EUR, in 2021 prices) 

Recurrent  adjustment  costs,  expressed  as  present  value  over 
2025-2050 (EUR, in 2021 prices) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

40,000 

424 

16,960,000 

312,286,985 

Hence, the total one-off and recurrent costs for multimodal terminal operators due to PM B.5 
are estimated at EUR 316.5 million, expressed as present value for 2025-2050, of which one-
off costs of EUR 4.2 million. 

Enforcement costs for public authorities 

Under PM B.5, the establishment of the SPC is expected to result in higher monitoring costs 
for  public  authorities.  In  the  targeted  survey,  one  national  authority  provided  information 
suggesting additional annual expenses of approximately EUR 50,000 per year would be needed 
to  carry  out  additional  monitoring  activities  resulting  from  the  establishment  of  the  SPC. 
However, drawing a parallel with the German case, the proposed amendment to the German 
Railway Act271 to align to Regulation (EU) 2021/872 on rail passenger rights establishes that 
1.5 full-time equivalents (FTE) will be necessary to monitor additional 139 complaint measures 
from  PRMs  in  rail transport following the establishment of a SPC for rail in  Germany. The 
German case has been considered to reflect more closely the additional enforcement costs for 
establishing  a  SPC  for  multimodal  transport.  Drawing  on  the  German  case,  107  additional 
working  hours  per  year  per  Member  State  have  been  assumed  for  PM  B.5  for  monitoring 
activities (i.e. 14 working days annually per MS) considering the ratio between the number of 
railway passengers and multimodal passengers and also the ratio between the number of PRM 
requests for rail and the number of PRM requests for multimodal transport as estimated under 
the baseline. 

Overall,  PM  B.5  is  expected  to  lead  to  total  recurrent  enforcement  costs  estimated  at  EUR 
107,917 per year from 2025 onwards or EUR 2 million expressed as present value over 2025-
2050. 

Table 98: Recurrent enforcement costs for authorities due to PM B.5 for monitoring activities 

Additional working hours per MS per year (on average) 

ISCO 2 Professionals hourly wage (EUR per hour in 2021 prices) 

Number of MS affected 

Recurrent enforcement costs per year from 2025 onwards (EUR, in 2021 prices) 

Recurrent enforcement costs, expressed as present value 2025-2050 (EUR, in 2021 
prices) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Benefits for consumers (hassle costs savings) 

107  

37.5 

27 

107,917 

1,987,091 

271 Entwurf eines Gesetzes zur Anpassung des Allgemeinen Eisenbahngesetzes an die Verordnung (EU) 2021/782 
des Europäischen Parlaments und des Rates vom 29. April 2021 über die Rechte und Pflichten der Fahrgäste im 
Eisenbahnverkehr. 

70 

 
 
 
 
This measure may bring additional benefits to passengers, especially PRMs. In the baseline, 
PRMs in multimodal journeys have to request assistance for each individual mode of transport 
they travel on, which typically takes 2-3 phone calls or online requests for assistance, depending 
on how many modes of transport the passenger is using in their multimodal journey. PM B.5 
establishes  a  SPC  for  PRMs  to  request  assistance,  which  would  require  a  single  call  for 
assistance by PRMs.  

Considering that PRMs make on average 2 phone calls to request assistance and that each of 
these calls takes on average 30 minutes, PRMs may save 30 to 60 minutes to request assistance 
in their multimodal journeys. 

Considering the total number of PRMs requests for long-distance bus and coach journeys and 
for  rail  and  waterborne  journeys  and  the  share  of  multimodal  market,  the  number  of  PRM 
requests  affected  is  estimated  at  737,044  in  2025,  950,122  in  2030  and  2,176,299  in  2050 
relative to the baseline. As explained, the time saved per PRM request is estimated at 30 (lower 
bound) to 60 (upper bound) minutes. Using the consumer value of time estimated at EUR 22.7 
per hour272 in 2021 prices, the hassle costs savings for PRMs are provided in the table below. 
Per  PRM  request,  they  are  estimated  at  EUR  11.4  to  22.7.  Expressed  as  present  value  over 
2025-2050, hassle costs savings for PRMs due to PM B.5 are estimated at EUR 277.3 to 554.6 
million relative to the baseline. 

Table 99: Hassle costs savings for consumers due to PM B.5 relative to the baseline 

Number of PRM requests affected 

Consumers value of time (EUR) 
Hassle costs savings (EUR) 
Lower bound estimate 
Upper bound estimate 

2025 
737,044 
22.7 

2030 
950,122 
22.7 

2040 
1,560,451 
22.7 

2050 
2,176,299 
22.7 

8,366,376 
16,732,752 

10,785,081 
18,601,523 

17,713,080 
35,426,161 

24,703,734 
49,407,467 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

PM  B.6:  Member  States  may  require  terminal  managers  and  transport  operators  to 
establish  “Single  Points  of  Contact”  (SPC)  to  PRMs,  also  if  they  are  not  operating  via 
multimodal hubs (category A+B+C) 

Under PM B.6, Member States could require SPCs to be set up at other multimodal hubs than 
the 424 multimodal hubs which ought to be developed under the TEN-T proposal, and should 
therefore be read as a complement to PM B.5. For example, additional multimodal hubs could 
be identified in urban nodes (i.e. more than one hub in a given urban node) or could even be 
located outside the territory of an urban node. 

The  costs  associated  with  PM  B.6  are  expected  to  vary  significantly  across  Member  States, 
especially considering the different ownership of terminals across Member States. Furthermore, 
the implementation of the measure is subject to decisions taken at the national level. Although 
it is not possible to estimate the overall impact  on costs of implementing PM B.6, these are 
estimated to be low, such as in the German example. 

272 Source: https://www.eurocontrol.int/sites/default/files/publication/files/standard-input-for-eurocontrol-cost-
benefit-analyses-2018-edition-8-version-2.6.pdf. 

71 

 
  
  
  
  
  
 
In  Germany,  the  Draft  Law  on  the  amendment  of  the  German  Railway  Act  to  align  to 
Regulation  (EU)  2021/872  on  rail  passenger  rights273  highlights  that  establishing  a  SPC  for 
persons with disabilities or reduced mobility is unlikely to lead to significant costs to transport 
operators and terminal managers as most of these companies already provide passengers with 
electronic  communication  options.  Even  for  those  that  do  not  yet  provide  such  form  of 
electronic communication, the cost of setting up a SPC are estimated to be low, amounting to a 
maximum  one-off  adjustment  cost  of  EUR  4,000  for  those  operators  that  have  not  yet 
established such a contact  point. The overall costs are expected to  be limited, which can be 
attributed to two factors. Firstly, this draft law establishes one single SPC for the entire German 
territory, which simplifies its implementation. Additionally, it is worth noting that, in this case, 
Deutsche Bahn AG was responsible for setting up the SPC on a voluntary basis (which is the 
group  responsible  for  both  the  main  railway  undertaking  and  the  infrastructure  manager  in 
Germany, which may lead to lower costs than a similar SPC set on a compulsory basis in other 
Member States).  

In addition, evidence from the targeted consultation shows that operators already have in place 
points of contact to provide assistance to PRMs, which is indicated at the booking stage274. On 
the other hand, a terminal operator stated that there are already contact points for passengers, 
which arranges assistance for PRMs. However, it is worth noting that the establishment of the 
SPC mostly involve internal efforts between individual operators or terminal managers, rather 
than  a  coordinated  effort  across  these  stakeholders.  Each  individual  transport  and  terminal 
operator should ensure that they reflect the obligations of PM B.6 under the passenger rights 
legislation of individual modes of transport. 

PM  B.7:  Industry  stakeholders  to  establish  complaint-handling  mechanisms  for 
multimodal passengers (category A+B+C) 

PM B.7 enables multimodal passengers to file a complaint on the alleged lack of respect of their 
rights  as  a  passenger  to  carriers,  terminal  managers  and  ticket  vendors/tour  operators,  who 
would have to set up an online and offline complaint-handling mechanism to this effect. This 
measure is  similar to  what  is  already  required under Articles 28(1)  and 12(7) of Regulation 
(EU) 2021/782. 

Adjustment  costs  for  carriers,  terminal  managers  and  ticket  vendors/tour  operators  to 
establish an online and offline complaint-handling mechanism 

The  effort  required  by  the  carriers,  terminal  managers  and  ticket  vendors/tour  operators  to 
establish an online and offline complaint-handling mechanism for multimodal passengers, has 
been  estimated  at  0.5  working  days  on  a  yearly basis,  working  7.5  hours  per  day,  based  on 
evidence  from  stakeholders  in  the  targeted  consultation.  The  total  number  of  stakeholders 
affected by this measure is estimated at 728 (excluding rail operators, for which an online and 
offline  complaint-handling  mechanism  is  already  established  under  the  baseline).  The  total 
recurrent adjustment costs of PM B.7 is estimated at EUR 84,970 per year or EUR 1.6 million, 
expressed as present value over 2025-2050 relative to the baseline. 

Table 100: Recurrent adjustment costs for carriers, terminal managers and ticket vendors/tour operators due 
to PM B.7 relative to the baseline 

273 Entwurf eines Gesetzes zur Anpassung des Allgemeinen Eisenbahngesetzes an die Verordnung (EU) 2021/782 
des Europäischen Parlaments und des Rates vom 29. April 2021 über die Rechte und Pflichten der Fahrgäste im 
Eisenbahnverkehr. 
274 One carrier and umbrella organisation for other modes than air. 

72 

 
 
ISCO 3 Technicians and associate professionals hourly wage (EUR 
per hour in 2021 prices) 

Working days to implement changes 

Workday (in hours) 

Number of stakeholders  

Recurrent adjustment costs per year from 2025 onwards (EUR, 
in 2021 prices), of which for: 

Carriers 

Intermediaries 

Multimodal terminals 

of which SMEs: 

Carriers 

Intermediaries 

Recurrent  adjustment  costs  expressed  as  present  value  over 
2025-2050 (EUR, in 2021 prices) 

Carriers 

Intermediaries 

Multimodal terminals 

of which SMEs: 

Carriers 

Intermediaries 

3.1 

0.5 

7.5 

728 

84,970 

21,126 

14,356 

49,488 

31,513 

17,858 

13,656 

1,564,559 

388,991 

264,342 

911,227 

580,262 

328,815 

251,447 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Enforcement costs for public authorities 

In the targeted survey, one public authority from Denmark (DK) estimated a range between 10 
to  15  working  days  annually  in  additional monitoring  activities  due  to  PM  B.7,  particularly 
concerning  the  monitoring  of  the  implementation  of  new  complaint  forms.  Furthermore, 
another public authority from the Netherlands stated that the implementation of the proposed 
measure would result in additional enforcement costs for NEBs amounting to approximately 
EUR  20,000  per  year  (around  60  additional  working  days  per  year  considering  an  hourly 
worker’s  wage  of  ISCO  2  (professionals)  category).  Considering  the  midpoint  of  the  upper 
bound provided by the public authority in Denmark and the equivalent in working days from 
evidence provided by the Netherlands, 38 additional working days per Member State per year 
are assumed to be needed.   

Total recurrent enforcement costs for public authorities are estimated at EUR 287,338 per year 
or EUR 5.3 million, expressed as present value over 2025-2050. 

Table 101: Recurrent enforcement costs of PM B.7 for public authorities in monitoring activities 

ISCO 2 Professional Authority hourly wage (EUR per hour in 2021 
prices) 

Working days to implement changes  

Workday (in hours) 

37.5 

38  

7.5 

73 

 
 
 
Number of MS affected 

Recurrent enforcement costs per year from 2025 onwards (EUR, 
in 2021 prices) 

Recurrent enforcement costs expressed as present value for 2025-
2050 (EUR, in 2021 prices) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Benefits for consumers (hassle costs savings) 

27 

287,338 

5,290,793 

Drawing on the evidence from the evaluation studies275,276,277, the time spent by a passenger to 
fill in and follow up a complaint made to a carrier, terminal (i.e. airports and ports) and NEB is 
estimated at around 10 hours (or 2 hours if the complaint is made to a carrier and NEB only). 
In the baseline, it is estimated that 6.9% of the multimodal passengers are affected by a delay 
or cancelation in 2025, 7.3% in 2030 and 5.7% in 2050. In addition, it is assumed that 5% of 
the passengers affected by a delay or cancellation would make a complaint. Thus, the number 
of complaints is estimated at 303,575 in 2025, 379,826 in 2030 and 431,489 in 2050. 

Moreover, under a conservative approach it is assumed that passengers would save at least 15 
minutes per complaint handling (lower bound), drawing a parallel with a study by the World 
Bank278. At an upper bound, time savings per complaint may amount to 60 minutes. Using the 
consumer  value  of  time  estimated  at  EUR  22.7  per  hour279  in  2021  prices,  the  hassle  costs 
savings for passengers are provided in the table below. Per complaint, they are estimated at 
EUR  5.7  to  22.7.  Expressed  as  present  value  over  2025-2050,  hassle  costs  savings  for 
passengers due to PM B.7 are estimated at EUR 43.3 to 173.2 million relative to the baseline. 

Table 102: Hassle costs savings for consumers due to PM B.7 relative to the baseline 

Number of complaints 

Consumers value of time (EUR) 
Hassle costs savings (EUR) 
Lower bound estimate 
Upper bound estimate 

2025 
303,575 
22.7 

2030 
379,826 
22.7 

2040 
415,036 
22.7 

2050 
431,489 
22.7 

1,722,979 
6,891,916 

2,155,751 
7,584,352 

2,355,590 
9,422,361 

2,448,971 
9,795,886 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Hassle costs savings for multimodal transport operators and intermediary ticket vendors 

Similarly, it is assumed that multimodal transport operators and intermediaries would benefit 
from less time for handling complaints. Drawing on the same study by the World Bank280, each 
complaint handling would benefit of 15 minutes saved under a conservative approach (lower 

275 Steer (2021), PART A – Evaluation of Regulation (EC) No 1107/2006 on the rights of persons with 
disabilities and with reduced mobility when travelling by air – Study on the EU Framework for Passenger 
Rights. 
276 Steer (2021), Part B – Evaluation of Regulation (EU) No 181/2011 on the rights of passengers travelling by 
bus and coach – Study on the EU Framework for Passenger Rights. 
277 Steer (2021), Part C – Evaluation of Regulation (EU) No 1177/2010 on the rights of passengers travelling by 
sea and inland Waterways - Study on the EU Framework for Passenger Rights. 
278 Available at: https://thedocs.worldbank.org/en/doc/3ecf7262788a3ec69c8a45bbd3342a28-
0080022021/related/Spring2021-governance-talk-asli-0525.pdf.  
279 Source: https://www.eurocontrol.int/sites/default/files/publication/files/standard-input-for-eurocontrol-cost-
benefit-analyses-2018-edition-8-version-2.6.pdf 
280 Available at: https://thedocs.worldbank.org/en/doc/3ecf7262788a3ec69c8a45bbd3342a28-
0080022021/related/Spring2021-governance-talk-asli-0525.pdf. 

74 

 
 
  
  
  
  
  
 
bound) and up to 60 minutes saved (upper bound). In order to calculate the hassle costs savings, 
an hourly worker’s wage corresponding to ISCO 3 (technicians and associate professionals) is 
assumed and an even repartition of complaints between transport operators and intermediary 
ticket vendors, in lack of detailed information. The total number of stakeholders affected and 
the hassle costs savings for each group of multimodal transport operators and intermediaries in 
2025, 2030, 2040 and 2050 relative to the baseline are provided in the table below.  

Table 103: Number of multimodal stakeholders benefiting of hassle costs savings in PM B.7  
Multimodal stakeholders affected 
Bus and coach operators  
Air carriers 
Waterborne transport operators 
Intermediaries 
Total 
 Source: PWC, TIS and Steer (2023), Impact assessment support study 

173                                      147  
2                                         -    
6                                          6  
123                                      117  
270 
304 

of which SMEs 

Total 

Table 104: Hassle costs savings for multimodal transport operators and intermediaries due to PM B.7 (in EUR) 
relative to the baseline 

Lower bound estimate 

Carriers 

Bus and coach operators  
Air carriers 
Waterborne transport operators 

Intermediaries 
of which for SMEs 

Carriers 

Bus and coach operators  
Air carriers 
Waterborne transport operators 

Intermediaries 

Upper bound estimate 

Carriers 

Bus and coach operators  
Air carriers 
Waterborne transport operators 

Intermediaries 
of which for SMEs 

Carriers 

Bus and coach operators  
Air carriers 
Waterborne transport operators 

Intermediaries 

2025 
2,362,149 
1,406,411 
1,344,249 
15,540 
46,621 
955,738 
2,097,961 
1,188,845 
1,142,223 
0 
46,621 
909,117 
9,448,596 
5,625,645 
5,376,997 
62,162 
186,485 
3,822,952 
8,391,846 
4,755,379 
4,568,894 
0 
186,485 
3,636,466 

2030 
2,955,466 
1,759,669 
1,681,894 
19,444 
58,332 
1,195,797 
2,624,921 
1,487,455 
1,429,123 
0 
58,332 
1,137,466 
11,821,865 
7,038,676 
6,727,574 
77,775 
233,326 
4,783,189 
10,499,683 
5,949,820 
5,716,494 
0 
233,326 
4,549,862 

2040 
3,229,439 
1,922,791 
1,837,806 
21,246 
63,739 
1,306,648 
2,868,252 
1,625,343 
1,561,604 
0 
63,739 
1,242,909 
12,917,756 
7,691,164 
7,351,223 
84,985 
254,956 
5,226,592 
11,473,007 
6,501,370 
6,246,415 
0 
254,956 
4,971,636 

2050 
3,357,461 
1,999,015 
1,910,661 
22,089 
66,266 
1,358,447 
2,981,956 
1,689,775 
1,623,509 
0 
66,266 
1,292,181 
13,429,846 
7,996,060 
7,642,643 
88,354 
265,063 
5,433,786 
11,927,824 
6,759,100 
6,494,037 
0 
265,063 
5,168,724 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Expressed as present value over 2025-2050 relative to the baseline, the hassle costs savings are 
estimated at EUR 59.3 to 237.4 million, of which EUR 52.7 to 210.8 million savings for the 
SMEs. 

Table  105:  Hassle  costs  savings  for  multimodal  transport  operators  and  intermediaries  due  to  PM  B.7, 
expressed as present value over 2025-2050 relative to the baseline (in million EUR)  

Lower bound estimate 

75 

Present value over 
2025-2050 

59.3 

 
  
  
Carriers 

Bus and coach operators  
Air carriers 
Waterborne transport operators 

Intermediaries 
of which for SMEs 

Carriers 

Bus and coach operators  
Air carriers 
Waterborne transport operators 

Intermediaries 

Upper bound estimate 

Carriers 

Bus and coach operators  
Air carriers 
Waterborne transport operators 

Intermediaries 
of which for SMEs 

Carriers 

Bus and coach operators  
Air carriers 
Waterborne transport operators 

Intermediaries 

Present value over 
2025-2050 

35.3 
33.8 
0.4 
1.2 
24.0 
52.7 
29.9 
28.7 
0.0 
1.2 
22.8 
237.4 
141.3 
135.1 
1.6 
4.7 
96.0 
210.8 
119.5 
114.8 
0.0 
4.7 
91.4 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

PM B.8: Member States authorities shall handle multimodal complaints from passengers 
(category A+B+C)) 

All NEBs or other bodies designated by Member States to handle complaints from passengers 
under the existing passenger rights Regulations for each transport mode (air, rail, bus and coach, 
waterborne) should be able to review multimodal complaints. Where a NEB competent in one 
mode receives a complaint which also concerns other modes, the NEB responsible for the other 
complaint needs to cooperate with that other NEB. 

Enforcement costs for public authorities 

To estimate the cooperation effort for NEBs due to this measure and the associated enforcement 
costs, the responses from six public authorities that estimated the effort required/costs in the 
targeted  survey have been considered: (i) from 30 to 50 annual working days, by the Danish 
Appeals Board for Bus, Train and Metro; (ii) two additional employees at total cost of EUR 
74,720, by the Civil Aviation Agency of Slovenia; (iii) from 10 to 20 working days annually, 
by  the  State  Railway  Administration  from  Latvia;  (iv)  2  working  days  per  year,  by  the 
Portuguese NEB (AMT); (v) EUR 10,000 per year to communicate with other NEB’s and acting 
as a focal point for these complaints, by the Dutch Authority; (vi) one-off cost of EUR 30,000 
and recurrent costs of EUR 30,000, by the Civil Aviation Authority from the Czech Republic. 
The wide range of  figures is  driven by the fact  that the size and volume  of activities of the 
stakeholders vary among each Member State. For the purpose of the assessment, the median of 
these estimates has been used, equivalent to 30 working days per year. Thus, we assumed an 
average of 50 working days at  an upper bound and 10 working  days at  a lower bound, and 
76 

 
  
assumed an hourly worker’s wage of a professional authority worker281, working 7.5 hours per 
day in the EU-27. Thus, we estimate total ongoing enforcement costs ranging from EUR 1.40 
million to EUR 6.98 million, expressed as present value for 2025-2050. 

Table 106: Recurrent enforcement costs for public authorities due to PM B.8 

ISCO 2 Professional Authority hourly wage (EUR per hour in 2021 prices) 

Additional working days per year 

Workday (in hours) 

Number of MS 

Recurrent  enforcement  costs  from  2025  onwards  (EUR,  in  2021 
prices) 

Recurrent enforcement costs, expressed as present value over 2025-
2050 (EUR, in 2021 prices) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Hassle costs savings for public authorities 

37.5 

30 

7.5 

27 

227,536 

4,189,657 

Similarly to PM B.7, NEBs would benefit of hassle costs savings for processing the complaints 
from passengers concerning multimodal journeys. Drawing on the same study by the World 
Bank282,  each  complaint  handling  would  benefit  of  15  minutes  saved  under  a  conservative 
approach (lower bound) and up to 60 minutes saved (upper bound). In order to calculate the 
hassle  costs  savings,  an  hourly  worker’s  wage  corresponding  to  ISCO  2  (professionals)  has 
been used. The hassle costs savings for public authorities for 2025, 2030, 2040 and 2050 are 
provided in the table below. Expressed as present value over 2025-2050, they are estimated at 
EUR 71.4 to 285.7 million relative to the baseline. 

Table 107: Hassle costs savings for public authorities due to PM B.8 
2025 
303,575 

Number of complaints 

Hassle costs savings (EUR) 
Lower bound estimate 
Upper bound estimate 

2,842,564 
11,370,255 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

2030 
379,826 

2040 
415,036 

2050 
431,489 

3,556,550 
12,512,632 

3,886,243 
15,544,972 

4,040,303 
16,161,212 

Summary of costs and costs savings by option and by measure (problem area 2) 

The  summary  of  recurrent  and  one-off  costs  and  costs  savings  by  option  and  by  measure, 
expressed as present value over 2025-2050, and for 2025, 2030 and 2050 relative to the baseline 
are provided in the tables below.  

Table 108: Recurrent and one-off costs and costs savings in the POs, expressed as present value relative to the 
baseline, in million EUR (2021 prices) 

Difference to the Baseline 
PO 2.2 

PO 2.3 

PO 2.1 

Carriers 
Administrative costs  
PM B.2 
Adjustment costs  

0.00 

20.60 

0.12 
0.12 
35.22 

0.12 
0.12 
38.95 

281 ISCO 2 tariff average. All the ISCO figures have been updated according to the HICP factor (2021/2018). 
282 Available at: https://thedocs.worldbank.org/en/doc/3ecf7262788a3ec69c8a45bbd3342a28-
0080022021/related/Spring2021-governance-talk-asli-0525.pdf. 

77 

 
 
  
  
  
  
  
 
  
  
  
  
 
Difference to the Baseline 
PO 2.2 

PO 2.3 

PO 2.1 

PM B.1 
PM B.2 
PM B.3a 
PM B.3b 
PM B.4a 
PM B.4b 
PM B.7 
Hassle costs savings 
PM B.7* 
Terminal operators 
Adjustment costs  
PM B.1 
PM B.5 
PM B.7 
Intermediaries 
Administrative costs  
PM B.2 
Adjustment costs 
PM B.1 
PM B.2 
PM B.3a 
PM B.3b 
PM B.4a 
PM B.4b 
PM B.7 
Hassle costs savings 
PM B.7* 
Public authorities 
Enforcement costs  
PM B.2 
PM B.3a 
PM B.3b 
PM B.5 
PM B.7 
PM B.8 
Hassle costs savings 
PM B.8* 
Consumers  
Benefits for consumers  
PM B.3a 
PM B.3b 
Hassle costs savings  
PM B.3a* 
PM B.3b* 
PM B.5* 
PM B.7* 
Total costs  
Total benefits 
Net benefits 

0.12 

20.10 

0.39 
35.33 
35.33 

1.11 
0.20 

0.91 

0.00 

0.38 
0.06 

0.06 

0.26 
24.01 
24.01 

19.42 

9.94 

5.29 
4.19 
71.42 
71.42 

20.09 
20.09 

61.86 
18.57 

43.29 
41.51 
212.71 
171.20 

0.12 
14.50 
20.10 

0.12 

0.39 
35.33 
35.33 

317.64 
0.20 
316.53 
0.91 

0.03 
0.03 
3.44 
0.06 
3.00 
0.06 

0.06 

0.26 
24.01 
24.01 

23.34 
1.93 
9.94    

1.99 
5.29 
4.19 
71.42 
71.42 

20.09 
20.09    

339.14 
18.57 

277.28 
43.29 
379.78 
489.99 
110.21 

0.12 
14.50 

23.83 

0.12 
0.39 
35.33 
35.33 

317.64 
0.20 
316.53 
0.91 

0.03 
0.03 
3.55 
0.06 
3.00 

0.11 

0.11 
0.26 
24.01 
24.01 

23.34 
1.93 

9.94 
1.99 
5.29 
4.19 
71.42 
71.42 

23.81 

23.81 
339.14 

18.57 
277.28 
43.29 
383.63 
493.72 
110.09 

78 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Difference to the Baseline 
PO 2.2 

PO 2.3 

PO 2.1 

1.3 
Benefits to costs ratio 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for the lower bound of the 
costs savings estimates. When considering the upper bound of the costs savings estimates, the net benefits of PO 
2.1 are estimated at EUR 702.64 million, of PO 2.2 at EUR 918.94 million and of PO 2.3 at EUR 918.81 million 
and the benefits to costs ratio at 17.9, 3.4 and 3.4 respectively. 

1.3 

5.1 

Table 109: One-off adjustment costs in the POs relative to the baseline scenario, in million EUR (2021 prices) 

Difference to the Baseline 

PO 2.1 

PO 2.2 

PO 2.3 

Carriers 
One-off adjustment costs  
PM B.1 
PM B.2 
PM B.3a 
PM B.3b 
PM B.4a 
PM B.4b 
Terminal operators 
One-off adjustment costs  
PM B.1 
PM B.5 
Intermediaries 
One-off adjustment costs  
PM B.1 
PM B.2 
PM B.3a 
PM B.3b 
PM B.4a 
PM B.4b 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

0.12 
0.12 

0.01 

0.20 
0.20 

0.11 
0.06 

0.06 

14.74 
0.12 
14.50 
0.01 

0.12 

4.44 
0.20 
4.24 

3.17 
0.06 
3.00 
0.06 

0.06 

14.75 
0.12 
14.50 

0.01 

0.12 

4.44 
0.20 
4.24 

3.29 
0.06 
3.00 

0.11 

0.11 

Table 110: Recurrent and one-off costs for carriers in the POs, in 2025, 2030 and 2050 relative to the baseline 
scenario, in million EUR (2021 prices) 

Difference to the Baseline  

PO 2.1 

PO 2.2  

PO 2.3 

2025 

2030 

2050 

2025 

2030 

2050 

2025 

2030 

2050 

1.01 

0.99 

0.83 

0.00 

0.00 

1.35 

0.00 

0.97 
0.12    

0.01 
0.01 
1.01 

0.01 
0.01 
1.20 

0.01 
0.01 
1.58 

0.01 
0.01 
1.35 

0.01 
0.01 
15.58 

0.01 
0.01 
15.75 

0.12    
14.50    
0.83 

Administrative costs  
PM B.2 
Adjustment costs  
PM B.1 
PM B.2 
PM B.3a 
PM B.3b 
PM B.4a 
PM B.4b 
0.02 
PM B.7 
2.00 
Hassle costs savings 
2.00 
PM B.7* 
Net benefits 
0.41 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for the lower bound of the 
costs savings estimates; negative values for ‘net benefits’ represent net costs.  

0.12    
0.02 
1.41 
1.41 
-14.35 

0.02 
1.41 
1.41 
-14.18 

0.02 
2.00 
2.00 
0.64 

0.02 
2.00 
2.00 
0.65 

0.02 
1.76 
1.76 
0.55 

0.02 
1.41 
1.41 
0.44 

0.02 
1.76 
1.76 
0.74 

0.02 
1.76 
1.76 
0.75 

0.12    
14.50    

0.12    

1.33    

1.33 

1.56 

1.18 

0.99 

1.00 

79 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 111: Recurrent and one-off costs for terminal operators in the POs, in 2025, 2030 and 2050 relative to 
the baseline scenario, in million EUR (2021 prices) 

PO 2.1 
2030 

2050 

2025 

Difference to the Baseline 
PO 2.2 
2030 
17.01 

2025 
21.45 

2050 
17.01 

PO 2.3 
2030 
17.01 

2025 
21.45 

2050 
17.01 

0.05 

0.25 

0.05 

0.20    

Adjustment 
costs  
PM B.1 
16.96 
PM B.5 
0.05 
PM B.7 
Net costs 
17.01 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

21.20 
0.05 
21.45 

0.05 
0.05 

0.05 
0.05 

0.05 
0.25 

0.20    

0.20    

21.20 
0.05 
21.45 

16.96 
0.05 
17.01 

16.96 
0.05 
17.01 

16.96 
0.05 
17.01 

Table 112: Recurrent and one-off costs for intermediaries in the POs, in 2025, 2030 and 2050 relative to the 
baseline scenario, in million EUR (2021 prices) 

PO 2.1 
2030 

2025 

2050 

Difference to the Baseline 
PO 2.2 
2030 

2050 

2025 

PO 2.3 
2030 

2050 

2025 

0.00 

0.00 

0.01 

0.00 

0.01 

0.06    

0.13 
0.06    

0.00 
0.00 
0.01 

0.00 
0.00 
0.01 

0.00 
0.00 
0.01 

0.00 
0.00 
0.01 

0.00 
0.00 
3.30 
0.06    
3.00    

0.00 
0.00 
3.19 
0.06    
3.00    
0.06    

Administrative costs  
PM B.2 
Adjustment costs 
PM B.1 
PM B.2 
PM B.3a 
PM B.3b 
PM B.4a 
PM B.4b 
0.01 
PM B.7 
1.36 
Hassle costs savings 
1.36 
PM B.7* 
1.34 
Net benefits 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for the lower bound of the 
costs savings estimates; negative values for ‘net benefits’ represent net costs. 

0.11    
0.01 
0.96 
0.96 
-2.35 

0.01 
0.96 
0.96 
-2.23 

0.01 
1.36 
1.36 
1.34 

0.01 
1.36 
1.36 
1.34 

0.01 
0.96 
0.96 
0.83 

0.01 
1.20 
1.20 
1.18 

0.01 
1.20 
1.20 
1.18 

0.01 
1.20 
1.20 
1.18 

0.11    

0.06    

Table 113: Recurrent costs for national public authorities in the POs, in 2025, 2030 and 2050 relative to the 
baseline scenario, in million EUR (2021 prices) 

PO2.1 
2030 
1.05 

2025 
1.05 

2050 
1.05 

Difference to the Baseline 
PO2.2 
2030 
1.27 
0.10 
0.54 

2050 
1.27 
0.10 
0.54 

2025 
1.27 
0.10 
0.54 

PO2.3 
2030 
1.27 
0.10 

2025 
1.27 
0.10 

2050 
1.27 
0.10 

0.54 

0.54 

0.54 

Enforcement costs  
PM B2 
PM B3a 
0.54 
PM B3b 
0.11 
PM B5 
0.29 
0.29 
PM B7 
0.23 
0.23 
PM B8 
4.04 
4.04 
Hassle costs savings 
4.04 
4.04 
PM B8* 
2.77 
2.99 
Net benefits 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for the lower bound of the 
costs savings estimates. 

0.54 
0.11 
0.29 
0.23 
2.84 
2.84 
1.57 

0.54 
0.11 
0.29 
0.23 
3.56 
3.56 
2.29 

0.11 
0.29 
0.23 
2.84 
2.84 
1.57 

0.11 
0.29 
0.23 
4.04 
4.04 
2.77 

0.11 
0.29 
0.23 
3.56 
3.56 
2.29 

0.29 
0.23 
2.84 
2.84 
1.79 

0.29 
0.23 
3.56 
3.56 
2.50 

80 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table  114: Benefits for consumers in the POs,  in 2025, 2030 and 2050 relative to the baseline scenario, in 
million EUR (2021 prices) 

PO 2.1 
2030 
0.99 
0.99 

2025 
0.82 
0.82 

Difference to the Baseline 
PO 2.2 
2030 
0.99 
0.99 

2050 
1.33 
1.33 

2025 
0.82 
0.82 

2050 
1.33 
1.33 

PO 2.3 
2030 
1.18 

2025 
0.98 

2050 
1.56 

Benefits for consumers  
PM B.3a 
PM B.3b 
Hassle costs savings 
PM B.3a* 
1.65 
PM B.3b* 
24.70 
PM B.5* 
2.45 
2.45 
PM B.7* 
Net benefits 
30.37 
5.44 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for the lower bound of the 
costs savings estimates. 

0.56 
8.37 
1.72 
11.63 

0.72 
10.79 
2.16 
14.84 

24.70 
2.45 
30.14 

10.79 
2.16 
14.65 

8.37 
1.72 
11.47 

1.56 
28.81 

1.18 
13.66 

0.98 
10.65 

28.81 
1.65 

10.65 
0.56 

13.66 
0.72 

1.72 
3.11 

2.16 
3.87 

2.28 
0.56 

2.88 
0.72 

4.10 
1.65 

3.3.  Problem area 3 - Reimbursement rules are unclear when flights were booked 

via an intermediary 

PM  C.1a:  Intermediaries  and  carriers  to  inform  passengers  on  the  reimbursement 
process. The passenger may only request it to the carrier which performs it without the 
involvement of the intermediary 

PM C.1a imposes an obligation on intermediaries and carriers to inform passengers (where their 
contact details are known to the intermediary or carrier) on the reimbursement process, which 
the  passenger  may  only  request  to  the  carrier  and  which  the  carrier  carries  out  without  the 
involvement  of  the  intermediary  (a)  before  booking  on  their  websites,  (b)  on  the  booking 
receipt, (c) when the right to reimbursement is triggered and they are (made) aware of this. 

One-off  administrative  costs  for  intermediary  ticket  vendors  and  air  carriers  to  inform 
passengers on the reimbursement process 

The  obligation  on  intermediaries  and  carriers  to  inform  passengers  on  their  reimbursement 
process  and  the  conditions  that  apply  would  likely  impose  costs  on  the  industry,  namely 
intermediaries  and  air  carriers,  as  this  measure  would  require  them  to  inform  passengers 
regarding the reimbursement process on their booking receipt and the conditions under which 
the passenger is  eligible  for reimbursement. Since some information  is  already disclosed by 
carriers and intermediaries, it can be argued that not all stakeholders would require updating 
the  information.  Nevertheless,  for  the  assessment  it  has  been  assumed  that  the  level  of 
information required by this measure would require some changes to the information already 
disclosed.   

Thus,  it  is  expected  that  123,000  intermediary  ticket  vendors283  would  incur  one-off 
administrative  costs  for  implementing  this  measure.  According  to  evidence  collected  in  the 
targeted consultation, 2 additional working days on a one-off basis would be needed to deal 
with  the  changes  that  this  measure  would  impose.  Assuming  an  hourly  worker’s  wage 
corresponding to ISCO 3 (technicians and associate professionals) and 7.5 working hours per 
day, it is estimated that this measure would lead to one-off administrative costs for intermediary 

283 Evidence provided by travel agents’ industry association for 2019. 

81 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
ticket vendors of EUR 57.4 million in 2025 relative to the baseline (EUR 467 per intermediary 
ticket vendor on average), of which EUR 54.6 million for SMEs. 

Table 115: One-off administrative costs for intermediary ticket vendors due to PM C.1a 

ISCO 3 Technicians and associate professionals hourly wage (EUR per hour 
in 2021 prices) 

Working days to implement changes 

Workday (in hours) 

Number of stakeholders affected 

One-off administrative costs in 2025 (EUR), of which for: 

SMEs 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

31.1 

2 

7.5 

123,000 

57,424,559 

54,553,331 

In addition, taking into account the 149 airlines operating in the EU and 2 additional working 
days on one-off basis to deal  with  the  changes that  this  measure  would impose, the one-off 
administrative costs for air carriers are estimated at EUR 69,563 in 2025. 

Table 116: One-off administrative costs for air carriers due to PM C.1a 

ISCO 3 Technicians and associate professionals hourly wage (EUR per hour 
in 2021 prices) 

Working days to implement changes 

Workday (in hours) 

Number of stakeholders affected 

One-off administrative costs in 2025 (EUR) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

31.1 

2 

7.5 

149 

69,563 

Recurrent administrative costs for air carriers to process manual reimbursement 

According to evidence received from one large air carrier and also confirmed by other airlines 
in the targeted survey and online interviews, in case of tickets issued by intermediaries acting 
as the Merchant of Record (MoR) and reimbursement requests made to carriers by passengers, 
reimbursements have to be issued manually, as an automatic reversal of payment is not possible 
and  a  lot  of  additional  information  needs  to  be  collected  from  the  passengers,  and  checks 
performed.  

In this regard, some large network carriers pointed out that for airlines to properly identify the 
passenger that paid for the ticket and thus, have the right of reimbursement, carriers need to 
collect certain personal information such as: i) the PNR (passenger name record), ii) the ticket 
number, iii) proof of identity, iv) name of the passengers and the email address of the passenger. 
Moreover, they need the bank details of the customer (IBAN/BIC and name of the bank), proof 
that the ticket was not paid for by a corporate third-party (business travelling) and confirmation 
that  the  customer  has  not  done  a  chargeback  via  their  credit  card.  The  majority  of  airlines, 
mostly  network  carriers  and  small  low-cost  carriers,  would  need  to  process  this  manually 
(according to stakeholer information). Currently, the IATA BSP system processes 80% of all 
reimbursement values when Merchant of Record intermediares are involved, through a reversal 
of the payment flow. 

82 

 
 
 
 
 
A  different  stakeholder  representing  an  airline  association  stated  in  the  targeted  survey  that 
airlines would need to receive the proof of the original purchase and any subsequent changes, 
identify the payment instrument  (e.g. credit card, Paypal,  Ideal,  Klarna, etc.) and its details, 
identify the refund benefiting entity with potentially additional KYC (Know your customer) 
and  AML  (Anti-Money  Laundering)  procedures.  A  further  complication  arises  when  the 
passenger paid the ticket to the intermediary via a payment instrument that the airline does not 
have (e.g. a local means of payment, available to the (local) intermediary, but not the airline.)  
Therefore, this measure may entail recurrent administrative costs for carriers in order to issue 
reimbursement  for  passengers  in  case  of  tickets  booked  via  intermediary  ticket  vendors, 
especially in the case of intermediaries acting as the MoR for the transaction. No one-off costs 
are foreseen, as most carriers are expected to make minor adaptations to their existent online 
reimbursement procedures.  

However, it is worth pointing out that some large low-cost carriers have implemented or are 
implementing  an  automatic  verification  system  to  issue  reimbursements  to  passengers  who 
booked via intermediaries. The business model of these LCCs relies mostly on direct sales via 
their own websites284. In order to overcome issues arising from passengers booking tickets via 
intermediaries with whom airlines do not have a commercial  agreement as well as the cost of 
the  manual  verification  process,  at  least  three  low-cost  carriers  have  implemented  or  are 
implementing an online verification tool provided by a third-party, which expedites the process 
of reimbursement and streamlines it, as the manual verification from customer service agents 
may have taken too long and be too costly. Evidence from one large low-cost carrier which has 
already fully implemented such a system shows that passengers are required to make a payment 
of  59  cents  for  such  third-party  verification.  According  to  the  carrier,  this  fee  collected 
contributes directly toward the third-party costs invoiced to the carrier and the costs of such 
biometrics verification system.  

As explained in section 2.2 of Annex 4, there are 149 airlines operating in the EU and their 
number is  assumed to remain constant  over time in  the baseline. According to  the feedback 
received from  one large network carrier during the targeted stakeholder  consultation  a web-
based  reimbursement  system  would  cost  approximately  EUR  2.5  million  in  2022  prices 
(equivalent to EUR 2.3 million in 2021 prices) per year, based on a parallel refund structure 
which  would  consider  verifying  all  passengers’  data  that  would  need  to  be  confirmed,  as 
explained above. According to the carrier, this cost would cover additional staff to check all 
refund  requests  (passenger  details,  contact  details,  payment  made  to  third  party  and  bank 
account details) twice. According to evidence provided, the aforementioned airline carried 14.0 
million passengers in 2022. In addition, the share of indirect ticket sales (i.e. tickets issued by 
all  intermediary  ticket  vendors)  represented  46.4%  of  all  tickets  issued  by  this  carrier. 
Considering that the share of passengers requesting reimbursements represents 3% of bookings 
via intermediary ticket vendors285, the cost of the reimbursement procedure has been estimated 
at EUR 11.7 per passenger request (in 2021 prices).  

284 This is reflected in the evidence gathered, which shows that intermediary ticket sales account for 15% of all 
ticket sales for LCCs, on average, while intermediary ticket sales account for approximately 53% of all ticket sales 
for network carriers. 
285 According to evidence provided by the same airline for 2019. One large OTA provided a similar figure for 
reimbursement requests in 2019 (3.2%). However, evidence from an airline association shows that on average 6% 
of  passengers  booking  via  intermediaries  request  reimbursement.  In  turn,  one  large  LCC  pointed  out  that 
reimbursement requests represented 0.5% of passengers booking via intermediary ticket vendors. The mid-point 
of these figures has been considered for the estimations, i.e. on average 3% of passengers booking via intermediary 
ticket vendors request reimbursement. 

83 

 
 
As previously mentioned, stakeholder evidence shows that 3286 large low-cost carriers (which 
account  for  66%  of  all  LCC  traffic  in  the  EU-27  (i.e.  19.8%  of  passengers  booking  via 
intermediary ticket vendors) are implementing or have already implemented such a verification 
tool,  thus  not  being  affected  by  the  additional  costs  of  handling  reimbursement  requests  in 
tickets booked via intermediary ticket vendors, as these costs are part of the baseline.  

Table 117: Airline ticket payment flows  

Payment flows 

% of volume 
of tickets in 
terms of 
number of 
passengers287,
288 

Reimburseme
nt procedure 
in the baseline 

Role of ticket 
vendor 

Knowledge of 
payment 
details 

1.  Direct Sales (via airlines’ direct 

distribution channels) 

60% 

1a. Pass-through 
sales (mainly Travel 
Management 
Companies, TMCs) 

10% 

2. 

sales 

Indirect 
via 
intermediary 
ticket vendors 

2a. Intermediary 
acts as the MoR 
(OTAs, brick and 
mortars,) 

24% 

The airline 
knows the 
payment 
instrument and 
its reference 
(such as the 
card number) 

The airline  
knows the 
payment 
instrument and 
its reference 

The airline 
does not know 
the payment 
instrument or 
its reference 

Controlled by 
the airline 
(greater 
compliance 
with the 7-day 
deadline); 
mostly 
automated 

95% through 
the GDS 
(automated) 
and 5% non-
GDS 
(reimbursemen
t most likely 
issue after 14 
days) 

Payments via 
IATA’s BSP 

Airline is the 
ticket vendor 

Travel agent 
acts as a 
booking 
intermediator 
to the carrier 

Passengers 
book travel 
services via a 
travel agent, 
which are a 
MoR for the 
transaction. 

The travel 
agent receives 
payment from 
the passenger 
and then 
arranges a 
second B2B 
transaction to 
the carrier 
from its own 
account. 

2b. Scheduled flights 
as part of package 
travel (tour 
operators) 

1.5-3%289 

Mostly non-
automated 
(reimbursemen

Passengers 
book travel 
services via a 
travel agent, 

The airline 
does not know 
the payment 

286 According to evidence gathered in the context of the impact assessment support study, Ryanair has an accessible 
reimbursement procedure already implemented.  We assume that two other large low cost carriers are currently 
implementing such a system, as these airlines also promote direct booking via their websites. 
287 Based on evidence provided by IATA and estimates in the  context of the impact assessment support study 
(based on evidence gathered by a group of 5 airlines, which shows that approximately 36% of all passengers book 
via intermediary ticket vendors).  
288 Comparing the information provided by air carriers on the share of tickets sold via intermediary ticket vendors 
and the information provided by IATA on the amount (in euros) of ticket flows in ticket, it has been assumed that 
the share of tickets sold via intermediary ticket vendors is more or less proportional to the share of tickets sold (in 
paid  amounts,  as  provided  by  IATA).  The  share  of  tickets  sold  via  intermediary  ticket  vendors  is  considered 
proportional to the share of passengers booking via intermediary ticket vendors. 
289 Given the lack of clarity on the share of tickets under flows 2b and 3a which are or not under the remit of the 
Passenger Rights Regulation, it has been assumed, using a conservative approach, that between 25% and 75% of 
ticket flows may fall within the scope of the Passenger Rights Regulation. The mid-point of this range has been 
considered, i.e. 3%, when including flow 2b in the calculation of impacts. In addition, it has been considered that 
3% of ticket flows are under the Package Travel Directive (flow 3). 

84 

 
 
 
 
Payment flows 

Flight sold as part of 
a package (mostly 
within the remit of 
Reg. 261/2008) 

3a. Charter flights as 
part of package 
travel (tour 
operators) 

3. 

sales 

Indirect 
via 
intermediary 
ticket  vendors 
(charter  flights 
only; 
mostly 
outside  remit  of 
Regulation 
261/2008) 

% of volume 
of tickets in 
terms of 
number of 
passengers287,
288 

Reimburseme
nt procedure 
in the baseline 

Role of ticket 
vendor 

Knowledge of 
payment 
details 

t most likely 
after 14 days) 

1.5-3% 

N/A 

becoming a 
MoR for the 
transaction. 

The travel 
agent receives 
payment from 
the passenger 
and then 
arranges a 
second B2B 
transaction to 
the carrier 

instrument or 
its reference 

Charter flights 
sold as part of 
a travel 
package 
(within the 
remit of the 
PTD) 

 Source:  PWC,  TIS  and  Steer  (2023),  Impact  assessment  support  study  (based  on  evidence  provided  in  the 
stakeholder consultation) 

For the purpose of the assessment, the estimated cost per passenger request for issuing manual 
reimbursement for tickets sold via intermediary ticket vendors (EUR 11.7) is assumed to be 
similar across all carriers which would need to process such reimbursements, and it is assumed 
to remain constant over time in real prices (in 2021 prices). In addition, it has been assumed 
that  for  approximately  27%  of  reimbursements  the  carrier  does  not  have  access  to  the 
passengers’ payment details (intermediaries acting as MoR of the transaction)290 and that on 
average 3% of passengers request reimbursement, as explained above. For estimating the costs 
of PM C.1a it has been considered that it would have an impact only on passengers flying with 
airlines which have not yet implemented a third-party verification tool in the baseline (as in the 
case of the large LCCs, as outlined above).  

Therefore, the recurrent administrative costs for air carriers to process manual reimbursement 
to passengers in case of indirect sales via intermediaries are estimated at EUR 73.9 million in 
2025, EUR 80.6 million in 2030 and EUR 104.1 million in 2050. Expressed as present value 
over  2025-2050,  the  administrative  costs  are  estimated  at  EUR  1.6  billion  relative  to  the 
baseline. 

For the purpose of the application of the ‘one in, one out’ approach, the annual average number 
of  passengers  affected  over  2025-2035  is  estimated  at  6,888,612.  Considering  the  cost  per 
passenger to process the manual reimbursement (EUR 7.1), the annual average administrative 
costs over 2025-2035 are estimated at EUR 80.7 million per year. 

Table 118: Recurrent administrative costs for carriers due to PM C.1a 

Percentage of intermediaries acting as the MoR 
of the transaction (%) 

Percentage of passengers requesting 
reimbursement (%) 

2025 

27% 

2030 

27% 

2040 

27% 

2050 

27% 

3% 

3% 

3% 

3% 

Number of passengers’ requests affected  

6,306,886   

6,878,786  

7,997,614  

8,885,799  

Cost per passenger to process manual 
reimbursement (EUR, in 2021 prices)  

11.7 

11.7 

11.7 

11.7 

290 It has been assumed that airlines only have access to the passengers’ payment details in bookings via pass-
through agents (flow 2a). Thus, intermediaries acting as MoR for the transaction correspond to 27% (referring to 
payment flows 2a and 2b). 

85 

 
 
 
 
Recurrent administrative costs (EUR, in 
2021 prices) 

2025 

2030 

2040 

2050 

73,865,756 

80,563,813 

93,667,438 

104,069,784 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Administrative costs savings for intermediary ticket vendors 

As intermediaries would no longer handle reimbursement requests which they would otherwise 
have handled, this measure is expected to result in costs savings for intermediaries relative to 
the baseline. In the context of the targeted consultation, one large intermediary stated that the 
cost of manually processing reimbursements for passengers is between EUR 5 to EUR 7 per 
passenger request. The median has been chosen for the estimates below (EUR 6 per passenger). 

The total administrative costs savings for intermediary ticket vendors are thus estimated at EUR 
37.8 million in 2025, EUR 41.3 million in 2030 and EUR 53.3 million in 2050 relative to the 
baseline.  Expressed  as  present  value  over  2025-2050,  the  administrative  costs  savings  for 
intermediary ticket vendors are estimated at EUR 828.5 million, of which EUR 787 for SMEs.  

However, intermediaries may incur indirect costs as a result of no longer being able to offer the 
processing of reimbursements to their customers (and to airlines, as part of their  agreements 
with them) as part of their service package. It may also damage to a certain extent their business 
model  of  maintaining  an  exclusive  relationship  with  their  customers.  No  data  on  this  is 
available, but during the stakeholder consultation, intermediaries and their associations have 
pointed out that they want to continue processing the reimbursements of their customers. 

For the purpose of the application of the ‘one in, one out’ approach, the annual average number 
of passengers’ requests affected over 2025-2035 is estimated at 41,331,669. Considering the 
costs  savings  per  passenger  request  for  processing  the  manual  reimbursement  (EUR  6),  the 
annual average administrative costs over 2025-2035 are estimated at EUR 8.3 million per year. 

Table 119: Recurrent administrative costs savings for intermediary ticket vendors due to PM C.1a 

2025 

2030 

2040 

2050 

Number of passengers’ requests affected  

6,306,886   

6,878,786  

7,997,614  

8,885,799  

Cost saving per passenger for processing 
manual reimbursement (EUR, in 2021 prices)  

Recurrent administrative costs savings 
(EUR, in 2021 prices), of which for: 

6 

6 

6 

6 

  37,841,314   41,272,719  

47,985,686  

53,314,792  

SMEs 

35,949,249  

39,209,083  

45,586,402  

50,649,052  

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Hassle costs for consumers (for requesting the reimbursement from air carriers)  

Requesting reimbursement from air carriers is expected to lead to additional hassle costs for 
consumers, given the additional information  that will need to  be provided before requesting 
their reimbursement in case of tickets bought via intermediaries. As previously pointed out291, 
airlines do not often have all the necessary information from passengers to be able to issue the 
reimbursement. Therefore, passengers may be requested to go through lengthy processes for 
providing  their  information  to  carriers  before  being  able  to  request  their  reimbursement. 
According to some carriers replying to the stakeholder consultation, the following details may 
be needed: the PNR (passenger name record), the ticket number, proof of identity, name of the 

291 See in this annex PM C.1a, adjustment costs for carriers. 

86 

 
 
 
 
passenger(s),  the  email  address  of  the  passenger(s),  the  bank  details  of  the  customer(s) 
(IBAN/BIC and name of the bank), proof that the ticket was not paid for by a corporate third-
party (business travelling), confirmation that the costumer has not done a chargeback via their 
credit card. It is assumed that passengers would need between 30 and 50 minutes to search for 
and provide all the information requested. The time needed for the passenger to provide each 
type of information is provided in the table below. 

Table 120: Additional time spent per reimbursement request, by type of information (in minutes) 

Type of information 

Additional time needed (in minutes) 

Proof of identification 

Bank details 

10-20 minutes 

5 minutes 

Proof that ticket was not paid by a corporate third 
party 

5-10 minutes 

No charge back confirmation 

Total 

10-15 minutes 

30-50 minutes 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

As explained above, alternatively, some airlines currently use an automatic verification system 
to issue reimbursements to passengers who booked via intermediaries. In order to overcome 
issues arising and the cost of the manual verification process, at least three low-cost carriers 
have implemented or are implementing an online verification tool provided by a third-party, 
which expedites the process of reimbursement and streamlines it, as the manual verification 
from  customer  service  agents  may  have  taken  too  long  and  be  too  costly292.  In  such  cases, 
passengers are required to use facial recognition technology to verify the passengers’ details, 
as described in the specific case of one of these low-cost carriers293.  

It  is  estimated  that  passengers  requesting  reimbursement  via  a  general  online  form  of  the 
intermediary may spend on average 10 minutes doing so. Therefore, the additional time spent 
per reimbursement request to air carriers, for providing the information requested by them, is 
estimated at 20 to 40 minutes. This excludes the cases when an automatic verification system 
is used, in which case no additional time would be needed. 

As explained above, and shown in the below table,Table 137 the number of passengers’ requests 
affected by PM C.1a is estimated at 6.3 million in 2025, 6.9 million in 2030 and 8.9 million in 
2050.  These  exclude  the  requests  for  which  an  automatic  verification  system  is  used. 
Considering the consumer value of time estimated at EUR 22.7 per hour294 in 2021 prices, and 
the additional time spent per reimbursement request of 20 minutes (lower bound estimate) to 
40 minutes (upper bound estimate), the hassle costs for 2025, 2030, 2040 and 2050 relative to 
the baseline are provided in the table below. Per consumer, they are estimated at EUR 7.6 to 
15.1. Expressed as present value over 2025-2050, they are estimated at EUR 1,044.9 million to 
EUR 2,089.8 million. 

292 In the baseline, 19.8% of passengers booking via intermediaries are estimated to have tickets with these low-
cost carriers. 
293 Available at: https://www.ryanair.com/ie/en/useful-info/help-centre/terms-and-conditions. 
294 Source: https://www.eurocontrol.int/sites/default/files/publication/files/standard-input-for-eurocontrol-cost-
benefit-analyses-2018-edition-8-version-2.6.pdf. 

87 

 
 
 
Table 121: Hassle costs for consumers due to PM C.1a 

Number of passengers’ requests affected  
Hassle costs (EUR) 

Lower bound estimate 
Upper bound estimate 

2025 
6,306,886 

2030 
6,878,786 

2040 
7,997,614 

2050 
8,885,799 

47,727,390 
95,454,780 

52,055,252 
98,917,070 

60,521,988 

67,243,327 
121,043,976  134,486,653 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Hassle costs savings for consumers (clarity of the information available) 

PM C.1a would also provide greater clarity to passengers, who would no longer be sent around 
and could be sure that the company they would approach for their refund (as explained under 
the information obligation) would indeed process the refund. This would ensure that passengers 
save  time  when  searching  for  the  information  on  whom  they  should  approach  for  their 
reimbursement, providing greater confidence to consumers. 

On  average,  as  explained  above,  3%  of  passengers  booking  via  intermediaries  request 
reimbursement295, and around 46% of air passengers book their tickets via intermediaries. In 
the baseline scenario, the total number of air passengers booking via intermediaries who request 
reimbursement is projected at 13.5 million in 2025, 14.7 million in 2030 and 19 million in 2050. 
Under PM C.1a, it is assessed that passengers would spend 15 minutes (lower bound) to 30 
minutes  (upper  bound)  less  when  looking  for  information  on  their  reimbursement  process. 
Considering the consumer value of time estimated at EUR 22.7 per hour296 in 2021 prices, the 
hassle costs savings for 2025, 2030, 2040 and 2050 relative to the baseline are provided in the 
table below. Per consumer, they are estimated at EUR 5.7 to 11.4. Expressed as present value 
over 2025-2050, they are estimated at EUR 1,679.1 million to EUR 3,358.2 million. 

Table 122: Hassle costs savings for consumers due to PM C.1a 
2025 

2030 

2040 

2050 

Number of air passengers booking via 
intermediaries who request reimbursement 
Hassle costs savings (EUR) 
Lower bound estimate 
Upper bound estimate 

13,513,196 

14,738,556 

17,135,768 

19,038,801 

76,695,886 
153,391,773 

83,650,576 
167,301,152 

97,256,261 
194,512,521 

108,057,166 
216,114,333 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

PM  C.1b:  Intermediaries  and  carriers  to  inform  passengers  on  the  reimbursement 
process. The carrier can decide whether the passenger has to request the reimbursement 
from the intermediary or the carrier.  

Under  PM  C.1b  intermediaries  and  carriers  shall  inform  passengers  on  the  reimbursement 
process. The carrier can decide whether the passenger has to request the reimbursement from 
the intermediary or the carrier (both free of charge for the passenger), e.g. by including in its 
terms and conditions whether, and if so with which intermediaries it processes reimbursements. 
It can do so on an individual intermediary basis. The intermediary can disagree with processing 

295 According to evidence provided by the same airline for 2019. One large OTA provided a similar figure for 
reimbursement requests in 2019 (3.2%). However, evidence from an airline association shows that on average 6% 
of  passengers  booking  via  intermediaries  request  reimbursement.  In  turn,  one  large  LCC  pointed  out  that 
reimbursement requests represented 0.5% of passengers booking via intermediary ticket vendors. The mid-point 
of these figures has been considered for the estimations, i.e. on average 3% of passengers booking via intermediary 
ticket vendors request reimbursement. 
296 Source: https://www.eurocontrol.int/sites/default/files/publication/files/standard-input-for-eurocontrol-cost-
benefit-analyses-2018-edition-8-version-2.6.pdf. 

88 

 
  
  
  
  
  
  
  
  
  
  
 
reimbursement requests for (certain or all) carriers, and needs to inform about this, e.g. in the 
terms and conditions on its website, and the passenger on the booking receipt and when the 
right to reimbursement is triggered. 

Under PM C.1b it is expected that the number of requests for reimbursement to carriers and 
intermediaries  remain  unchanged  compared  to  the  baseline.  Therefore,  no  additional 
administrative costs for carriers or costs savings for intermediaries are foreseen under PM C.1b. 

Administrative costs for intermediary ticket vendors and air carriers to inform passengers on 
the reimbursement process 

Similarly to PM C.1a, this measure is estimated to lead to one-off administrative costs for the 
123,000  intermediary  ticket  vendors.  According  to  evidence  collected  in  the  targeted 
consultation,  2  additional  working  days  on  one-off  basis  would  be  needed  to  deal  with  the 
changes that this measure would imposes. Assuming an hourly worker’s wage corresponding 
to  ISCO  3  (technicians  and  associate  professionals)  and  7.5  working  hours  per  day,  it  is 
estimated that this measure would lead to one-off administrative costs for intermediary ticket 
vendors of EUR 57.4 million in 2025 relative to the baseline (EUR 467 per intermediary ticket 
vendor on average), of which EUR 54.6 million for SMEs. 

Table 123: One-off administrative costs for intermediary ticket vendors due to PM C.1b 

ISCO 3 Technicians and associate professionals hourly wage (EUR per hour 
in 2021 prices) 

Working days to implement changes 

Workday (in hours) 

Number of stakeholders affected 

One-off administrative costs in 2025 (EUR), of which for: 

SMEs 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

31.1 

2 

7.5 

123,000 

57,424,559 

54,553,331 

In addition, taking into account the 149 airlines operating in the EU and 2 additional working 
days on one-off basis to deal  with  the  changes that  this measure  would impose, the one-off 
administrative costs for air carriers are estimated at EUR 69,563 in 2025. 

Table 124: One-off administrative costs for air carriers due to PM C.1b 

ISCO 3 Technicians and associate professionals hourly wage (EUR per hour 
in 2021 prices) 

Working days to implement changes 

Workday (in hours) 

Number of stakeholders affected 

One-off administrative costs in 2025 (EUR) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Hassle costs savings for consumers (clarity of the information available) 

31.1 

2 

7.5 

149 

69,563 

PM C.1b would also provide greater clarity to passengers, who would no longer be sent around 
and could be sure that the company they would approach for their refund (as explained under 

89 

 
 
 
 
 
the information obligation) would indeed process the refund. This would ensure that passengers 
save  time  when  searching  for  the  information  on  whom  they  should  approach  for  their 
reimbursement, providing greater confidence to consumers. 

On  average,  as  explained  above,  3%  of  passengers  booking  via  intermediaries  request 
reimbursement297, and around 46% of air passengers book their tickets via intermediaries. In 
the baseline scenario, the total number of air passengers booking via intermediaries who request 
reimbursement is projected at 13.5 million in 2025, 14.7 million in 2030 and 19 million in 2050. 
Under PM C.1b, it is assessed that passengers would spend 15 minutes (lower bound) to 30 
minutes  (upper  bound)  less  when  looking  for  information  on  their  reimbursement  process. 
Considering the consumer value of time estimated at EUR 22.7 per hour298 in 2021 prices, the 
hassle costs for 2025, 2030, 2040 and 2050 relative to the baseline are provided in the table 
below. Per consumer, they are estimated at EUR 5.7 to 11.4. Expressed as present value over 
2025-2050, they are estimated at EUR 1,679.1 million to EUR 3,358.2 million. 

Table 125: Hassle costs savings for consumers due to PM C.1b 
2025 

2030 

2040 

2050 

Number of air passengers booking via 
intermediaries who request reimbursement 
Hassle costs savings (EUR) 
Lower bound estimate 
Upper bound estimate 

13,513,196 

14,738,556 

17,135,768 

19,038,801 

76,695,886 
153,391,773 

83,650,576 
167,301,152 

97,256,261 
194,512,521 

108,057,166 
216,114,333 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

PM C.1c: Intermediaries and carriers to inform passengers on the reimbursement process 
and  the  option  for  the  passenger  to  choose  between  intermediary  and  carrier  for 
requesting reimbursement. Intermediaries to inform  whether they charge a fee  for the 
reimbursement request 

PM C.1c imposes an obligation on intermediaries and carriers to inform passengers (a) before 
booking on their websites, (b) on the booking receipt, (c) when the right to reimbursement is 
triggered and they are (made) aware of this: on the reimbursement process and the option for 
the  passenger  to  choose  between  intermediary  and  carrier  for  requesting  reimbursement. 
Intermediaries would need to inform whether they charge a fee for the reimbursement request. 

Administrative costs for intermediaries ticket vendors and air carriers to inform passengers  
on the reimbursement process 

The  measure  aims  at  ensuring  that  intermediary  ticket  vendors  and  air  carriers  provide  pre-
purchase information to all air passengers. This measure would require intermediaries and air 
carriers to update their online procedures regarding the information passed on to passengers. 

Thus, it is expected that 123,000 intermediary ticket vendors would incur one-off administrative 
costs  for  implementing  this  measure.  According  to  evidence  collected  in  the  targeted 
consultation,  2  additional  working  days  on  one-off  basis  would  be  needed  to  deal  with  the 

297 According to evidence provided by the same airline for 2019. One large OTA provided a similar figure for 
reimbursement requests in 2019 (3.2%). However, evidence from an airline association shows that on average 6% 
of  passengers  booking  via  intermediaries  request  reimbursement.  In  turn,  one  large  LCC  pointed  out  that 
reimbursement requests represented 0.5% of passengers booking via intermediary ticket vendors. The mid-point 
of these figures has been considered for the estimations, i.e. on average 3% of passengers booking via intermediary 
ticket vendors request reimbursement. 
298 Source: https://www.eurocontrol.int/sites/default/files/publication/files/standard-input-for-eurocontrol-cost-
benefit-analyses-2018-edition-8-version-2.6.pdf. 

90 

 
  
  
  
  
  
 
changes that this measure would impose. Assuming an hourly worker’s wage corresponding to 
ISCO 3 (technicians and associate professionals) and 7.5 working hours per day, it is estimated 
that this measure would lead to one-off administrative costs for intermediary ticket vendors of 
EUR 57.4 million in 2025 relative to the baseline (EUR 467 per intermediary ticket vendor on 
average), of which EUR 54.6 million for SMEs. 

Table 126: One-off administrative costs for intermediary ticket vendors due to PM C.1c 

ISCO 3 Technicians and associate professionals hourly wage (EUR per hour 
in 2021 prices) 

Working days to implement changes 

Workday (in hours) 

Number of stakeholders affected 

One-off administrative costs in 2025 (EUR), of which for: 

SMEs 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

31.1 

2 

7.5 

123,000 

57,424,559 

54,553,331 

In addition, taking into account the 149 airlines operating in the EU and 2 additional working 
days on one-off basis to deal  with  the  changes that  this measure  would impose, the one-off 
administrative costs for air carriers are estimated at EUR 69,563 in 2025. 

Table 127: One-off administrative costs for air carriers due to PM C.1c 

ISCO 3 Technicians and associate professionals hourly wage (EUR per hour 
in 2021 prices) 

Working days to implement changes 

Workday (in hours) 

Number of stakeholders affected 

One-off administrative costs in 2025 (EUR) 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

31.1 

2 

7.5 

149 

69,563 

Administrative costs for air carriers to process manual reimbursement to passengers in case 
of indirect sales via intermediaries 

Under PM C.1c, passengers will have the choice to request reimbursement from the carrier or 
the intermediary in case of indirect ticket sales. Similar to PM C.1a, air carriers are expected to 
incur  additional  costs  for  processing  manual  reimbursement  whenever  passengers  opt  for 
requesting  reimbursement  from  carriers.  For  assessing  the  costs,  it  has  been  assumed  that 
around 20% of passengers may request reimbursement from the carrier. All other assumptions 
are the same as explained under PM C.1a.  

Therefore, the recurrent administrative costs for carriers to process reimbursements manually 
are estimated at EUR 14.8 million in 2025, EUR 16.1 million in 2030 and EUR 20.8 million in 
2050. Expressed as present value over 2025-2050, the recurrent administrative costs amount to 
EUR 323.4 million relative to the baseline. 

For the purpose of the application of the ‘one in, one out’ approach, the annual average number 
of passengers’ requests affected over 2025-2035 is estimated at 1,377,722. Considering the cost 

91 

 
 
 
 
 
per  passenger  request  to  process  the  manual  reimbursement  (EUR  7.1),  the  annual  average 
administrative costs over 2025-2035 are estimated at EUR 16.1 million per year. 

Table 128: Recurrent administrative costs for carriers due to PM C.1c 

Percentage of intermediaries acting as the MoR 
of the transaction (%) 

Percentage of passengers requesting 
reimbursement (%) 

Share of passengers requesting reimbursement 
from the carrier (%) 

2025 

27% 

2030 

27% 

2040 

27% 

2050 

27% 

3% 

3% 

3% 

3% 

19.8% 

19.8% 

19.8% 

19.8% 

Number of passengers’ requests affected  

1,261,377  

    1,375,757  

    1,599,523  

  1,777,160  

Cost per passenger request to process manual 
reimbursement (EUR, in 2021 prices)  

Recurrent administrative costs (EUR, in 
2021 prices) 

11.7 

11.7 

11.7 

11.7 

14,773,151 

16,112,763 

18,733,488 

20,813,957 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Administrative costs savings for intermediary ticket vendors 

As  intermediaries  would  no  longer  handle  a  part  of  the  reimbursement  requests  which  they 
would  otherwise  have  handled  (considering  that  passengers  have  the  choice  to  request 
reimbursements from the carrier or the intermediary ticket vendors), this measure is expected 
to result in costs savings for intermediaries relative to the baseline. In the context of the targeted 
consultation, one large intermediary stated that the cost of manually processing reimbursements 
for passengers is between EUR 5 to EUR 7 per passenger. The median has been chosen for the 
estimates below (EUR 6 per passenger). 

The total administrative costs savings for intermediary ticket vendors are thus estimated at EUR 
7.6 million in 2025, EUR 8.3 million in 2030 and EUR 10.7 million in  2050 relative to the 
baseline.  Expressed  as  present  value  over  2025-2050,  the  administrative  costs  savings  for 
intermediary ticket vendors are estimated at EUR 165.7 million, of which EUR 157.4 for SMEs.  

However, intermediaries may incur indirect costs as a result of no longer being able to offer the 
processing of reimbursements to their customers (and to airlines, as part of their agreements 
with them) as part of their service package. It may also damage to a certain extent their business 
model  of  maintaining  an  exclusive  relationship  with  their  customers.  No  data  on  this  is 
available, but during the stakeholder consultation, intermediaries and their associations have 
pointed out that they want to continue processing the reimbursements of their customers. 

For the purpose of the application of the ‘one in, one out’ approach, the annual average number 
of passengers affected over 2025-2035 is estimated at 1,377,722. Considering the costs savings 
per  passenger  for  processing  the  manual  reimbursement  (EUR  6),  the  annual  average 
administrative costs over 2025-2035 are estimated at EUR 8.3 million per year. 

Table 129: Recurrent administrative costs savings for intermediary ticket vendors due to PM C.1c 

2025 

2030 

2040 

2050 

Number of passengers’ requests affected  

1,261,377  

    1,375,757  

    1,599,523  

  1,777,160  

Cost saving per passenger for processing 
manual reimbursement (EUR, in 2021 prices)  

6 

6 

6 

6 

92 

 
 
 
Recurrent administrative costs savings 
(EUR, in 2021 prices), of which for: 

2025 

2030 

2040 

2050 

7,568,263 

8,254,544 

9,597,137 

10,662,958 

SMEs 

7,189,850 

 7,841,817  

9,117,280  

10,129,810  

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Hassle costs for consumers (for requesting the reimbursement from air carriers) 

Requesting reimbursement from air carriers is expected to lead to additional hassle costs for 
consumers, given the additional information  that will need to  be provided before requesting 
their reimbursement in  case of tickets  bought  via intermediaries. As previously  pointed out, 
airlines do not often have all the necessary information from passengers to be able to issue the 
reimbursement. Therefore, passengers may be requested to go through lengthy processes for 
providing  their  information  to  carriers  before  being  able  to  request  their  reimbursement. 
According to some carriers in the stakeholder consultation, the following details may be needed: 
the  PNR  (passenger  name  record),  the  ticket  number,  proof  of  identity,  name  of  the 
passenger(s),  the  email  address  of  the  passenger(s),  the  bank  details  of  the  customer(s) 
(IBAN/BIC and name of the bank), proof that the ticket was not paid for by a corporate third-
party (business travelling), confirmation that the costumer has not done a chargeback via their 
credit card. As in PM C.1a, it is assumed that passengers would need between 30 and 50 minutes 
to search for and provide all the information requested.  

As explained above, alternatively, some airlines currently use an automatic verification system 
to issue reimbursements to passengers who booked via intermediaries. In order to overcome 
issues arising and the cost of the manual verification process, at least three low-cost carriers 
have implemented or are implementing an online verification tool provided by a third-party, 
which expedites the process of reimbursement and streamlines it, as the manual verification 
from  customer  service  agents  may  have  taken  too  long  and  be  too  costly.  In  such  cases, 
passengers are required to use facial recognition technology to verify the passengers’ details, 
as described in the specific case of one of these low-cost carriers299.  

It  is  estimated  that  passengers  requesting  reimbursement  via  a  general  online  form  of  the 
intermediary may spend on average 10 minutes doing so. Therefore, the additional time spent 
per reimbursement request to air carriers, for providing the information requested by them, is 
estimated at 20 to 40 minutes. This excludes the cases when an automatic verification system 
is used, in which case no additional time would be needed. 

As explained above, the number of passengers’ requests affected by PM C.1c is estimated at 
1.3 million in 2025, 1.4 million in 2030 and 1.8 million in 2050. These exclude the requests for 
which  an  automatic  verification  system  is  used.  Considering  the  consumer  value  of  time 
estimated  at  EUR  22.7  per  hour300  in  2021  prices,  and  the  additional  time  spent  per 
reimbursement  request  of  20  minutes  (lower  bound  estimate)  to  40  minutes  (upper  bound 
estimate), the hassle costs for 2025, 2030, 2040 and 2050 relative to the baseline are provided 
in the table below. Per consumer, they are estimated at EUR 7.6 to 15.1. Expressed as present 
value over 2025-2050, they are estimated at EUR 301.8 million to EUR 603.5 million. 

Table 130: Hassle costs for consumers due to PM C.1c 

Number of passengers’ requests affected  

2025 
1,261,377 

2030 
1,375,757 

2040 
1,599,523 

2050 
1,777,160 

299 Available at: https://www.ryanair.com/ie/en/useful-info/help-centre/terms-and-conditions. 
300 Source: https://www.eurocontrol.int/sites/default/files/publication/files/standard-input-for-eurocontrol-cost-
benefit-analyses-2018-edition-8-version-2.6.pdf. 

93 

 
 
  
 
Hassle costs (EUR) 

Lower bound estimate 
Upper bound estimate 

9,545,478 
19,090,956 

10,411,050 
19,783,414 

12,104,398 
24,208,795 

13,448,665 
26,897,331 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

Hassle costs savings for consumers (clarity of the information available) 

PM C.1c would also provide greater clarity to passengers, who would no longer be sent around 
and could be sure that the company they would approach for their refund (as explained under 
the information obligation) would indeed process the refund. This would ensure that passengers 
save  time  when  searching  for  the  information  on  whom  they  should  approach  for  their 
reimbursement, providing greater confidence to consumers. 

On  average,  as  explained  above,  3%  of  passengers  booking  via  intermediaries  request 
reimbursement301, and around 46% of air passengers book their tickets via intermediaries. In 
the baseline scenario, the total number of air passengers booking via intermediaries who request 
reimbursement is projected at 13.5 million in 2025, 14.7 million in 2030 and 19 million in 2050. 
Under PM C.1c, it is assessed that passengers would spend 15 minutes (lower bound) to 30 
minutes  (upper  bound)  less  when  looking  for  information  on  their  reimbursement  process. 
Considering the consumer value of time estimated at EUR 22.7 per hour302 in 2021 prices, the 
hassle costs for 2025, 2030, 2040 and 2050 relative to the baseline are provided in the table 
below. Per consumer, they are estimated at EUR 5.7 to 11.4. Expressed as present value over 
2025-2050, they are estimated at EUR 1,679.1 million to EUR 3,358.2 million. 

Table 131: Hassle costs savings for consumers due to PM C.1c 
2025 

2030 

2040 

2050 

Number of air passengers booking via 
intermediaries who request reimbursement 
Hassle costs savings (EUR) 
Lower bound estimate 
Upper bound estimate 

13,513,196 

14,738,556 

17,135,768 

19,038,801 

76,695,886 
153,391,773 

83,650,576 
167,301,152 

97,256,261 
194,512,521 

108,057,166 
216,114,333 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

PM  C.2a:  Intermediary  may  not  charge  a  fee  for  processing  the  passenger’s 
reimbursement request  

This measure is expected to impact intermediaries who charge passengers reimbursement fees. 
According  to  evidence  from  stakeholders  and  desk  research  in  the  context  of  the  impact 
assessment support study, approximately 10% of intermediary ticket vendors charge a fee for 
reimbursement, which varies between EUR 25 and EUR 60. However, it is expected that this 
loss  of  revenue  will  be  passed  on  to  consumers  through  other  fees.  Assuming  EUR  25  that 
would be charged by 10% of intermediaries, this represents around EUR 0.43 increase in fees 
passed on to  passengers  per ticket.  Overall, this is  expected to  have marginal effects  on the 
business model of intermediaries and their costs, and on the average cost of tickets.  

301 According to evidence provided by the same airline for 2019. One large OTA provided a similar figure for 
reimbursement requests in 2019 (3.2%). However, evidence from an airline association shows that on average 6% 
of  passengers  booking  via  intermediaries  request  reimbursement.  In  turn,  one  large  LCC  pointed  out  that 
reimbursement requests represented 0.5% of passengers booking via intermediary ticket vendors. The mid-point 
of these figures has been considered for the estimations, i.e. on average 3% of passengers booking via intermediary 
ticket vendors request reimbursement. 
302 Source: https://www.eurocontrol.int/sites/default/files/publication/files/standard-input-for-eurocontrol-cost-
benefit-analyses-2018-edition-8-version-2.6.pdf. 

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PM C.2b: Intermediary may charge a fee for processing the passenger’s reimbursement 
request  

No significant costs are expected to be borne by either intermediaries or airlines, as under the 
baseline some intermediaries already charge a fee for processing the passenger’s reimbursement 
request. For this reason, no significant impact is also expected on passengers.   

PM C.3: (MoR) Intermediary to enable the passenger (with the data needed) to request 
the reimbursement directly to the carrier  

No significant costs are expected due to this measure for intermediary ticket vendors. The costs 
savings for intermediaries asociated to the reimbursement are explained under PM C.1a. Both 
PM C.1a and PM C.3 are included in PO 3.1. 

Hassle costs savings for consumers 

Many intermediaries generate their own ticket identification numbers or booking  references, 
with  the  consequence  that  the  passenger  does  not  know  the  carrier’s  booking  reference  and 
cannot provide it when asking the carrier for a reimbursement303. By providing the passenger 
with the data needed to request the reimbursement directly to the carrier, passengers will benefit 
from  less  time  for  requesting  their  reimbursement,  in  the  case  of  airlines  with  an  indirect 
booking  model.  Under  PM  C.3  passengers  are  estimated  to  save  10  to  20  minutes  when 
requesting  their  reimbursement  from  air  carriers  due  to  the  information  provided  by  the 
intermediary. No additional benefits are expected for passengers with bookings with large low-
cost carriers using an automatic verification tool.  

As  explained  under  PM  C.1a,  included  in  PO  3.1  together  with  PM  C.3,  the  number  of  air 
passengers’ requests affected by this measure is 6.3 million in 2025, 6.9 million in 2030 and 
8.9 million in 2050. These exclude the requests for which an automatic verification system is 
used. Considering the consumer value of time estimated at EUR 22.7 per hour304 in 2021 prices, 
and  the  time  saved  per  reimbursement  request  of  10  minutes  (lower  bound  estimate)  to  20 
minutes (upper bound estimate), the hassle costs savings for 2025, 2030, 2040 and 2050 relative 
to the baseline are provided in the table below. Per consumer, they are estimated at EUR 3.8 to 
7.6. Expressed as present value over 2025-2050, they are estimated at EUR 522.5 million to 
EUR 1,044.9 million. 

Table 132: Hassle costs savings for consumers due to PM C.3 

Number of passengers’ requests affected 
Hassle costs savings (EUR) 
Lower bound estimate 
Upper bound estimate 

2025 
6,306,886 

2030 
6,878,786 

2040 
7,997,614 

2050 
8,885,799 

23,863,695 
47,727,390 

26,027,626 
52,055,252 

30,260,994 
60,521,988 

33,621,663 
67,243,327 

Source: PWC, TIS and Steer (2023), Impact assessment support study 

303 It is assumed that this would normally cover all situations where the passenger had not yet received a boarding 
pass.  
304 Source: https://www.eurocontrol.int/sites/default/files/publication/files/standard-input-for-eurocontrol-cost-
benefit-analyses-2018-edition-8-version-2.6.pdf. 

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PM  C.4  Additional  rules  when  intermediaries  which  are  a  ‘Merchant  of  Record’  are 
involved 

(1) When the passenger requests the reimbursement: intermediary to enable the passenger 
(with the data needed and which only the intermediary has, such as carrier booking 
reference) to request the reimbursement directly to the carrier.  

If the intermediary does  not agree to process the reimbursement request,  it shall enable the 
passenger  at  booking,  with  the  data  needed  and  which  only  he  has,  to  request  the 
reimbursement directly from the carrier.  

This element of PM C.4 is not expected to have a significant impact on costs for the industry, 
as only minor changes are required. On the other hand, it is expected to lead to hassle costs 
savings for consumers as explained below. 

Hassle costs savings for consumers 

Many intermediaries generate their own ticket identification numbers or booking references, 
with  the  consequence  that  the  passenger  does  not  know  the  carrier’s  booking  reference  and 
cannot provide it when asking the carrier for a reimbursement305. By providing the passenger 
with the data needed to request the reimbursement directly to the carrier, passengers will benefit 
from  less  time  for  requesting  their  reimbursement,  in  the  case  of  airlines  with  an  indirect 
booking model. Similarly to PM C.3, under PM C.4 passengers of network carriers and small 
low-cost carriers are estimated to save 10 to 20 minutes when requesting their reimbursement 
from air carriers due to the information provided by the intermediary. No additional benefits 
are  expected  for  passengers  with  bookings  with  large  low-cost  carriers  using  an  automatic 
verification tool.  

In PO 3.2, including PM C.1b together with PM C.4, it is expected that the number of requests 
for reimbursement to carriers and intermediaries remains unchanged compared to the baseline. 
Therefore, no hassle costs savings for consumers are estimated due to this measure.  

In PO 3.3, including PM C.1c together with PM C.4, the number of air passengers’ requests 
affected by this measure is estimated at 1.3 million in 2025, 1.4 million in 2030 and 1.8 million 
in 2050. These exclude the requests for which an automatic verification system is used (large 
low cost carriers). Considering the consumer value of time estimated at EUR 22.7 per hour306 
in  2021  prices,  and  the  time  saved  per  reimbursement  request  of  10  minutes  (lower  bound 
estimate) to 20 minutes (upper bound estimate), the hassle costs savings for 2025, 2030, 2040 
and  2050  relative  to  the  baseline  are  provided  in  the  table  below.  Per  consumer,  they  are 
estimated at EUR 3.8 to 7.6. Expressed as present value over 2025-2050, they are estimated at 
EUR 104.5 million to EUR 209 million. 

Table 133: Hassle costs savings for consumers due to PM C.4 in PO 3.3 

Number of passengers' requests affected 

Hassle costs savings (EUR) 
Lower bound estimate 
Upper bound estimate 

2025 
1,261,377 

2030 
1,375,757 

2040 
1,599,523 

2050 
1,777,160 

4,772,739 
9,545,478 

5,205,525 
10,411,050 

6,052,199 
12,104,398 

6,724,333 
13,448,665 

305 It is assumed that this would normally cover all situations where the passenger had not yet received a boarding 
pass.  
306 Source: https://www.eurocontrol.int/sites/default/files/publication/files/standard-input-for-eurocontrol-cost-
benefit-analyses-2018-edition-8-version-2.6.pdf. 

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Source: PWC, TIS and Steer (2023), Impact assessment support study 

(2)  Carrier to reimburse the intermediary at the latest within 7 days, in one  transaction, via 
the same payment method used at the time of booking, and linking the payment with the original 
booking reference. The intermediary has to reimburse the passenger at the latest within another 
7 days.  

This element of PM C.4 may lead to costs savings for some intermediaries who have to advance 
payments to passengers ahead of the carrier paying them compared to the baseline. However, 
there is no reliable data that allow estimating such savings for the entire industry. 

In addition, ensuring that reimbursements by carriers are made in one transaction and linked to 
the amount paid with the specific original booking number is also  expected to lead to some 
costs savings for intermediaries, as, under the baseline, some intermediaries carry out manual 
verification procedures to link the amount received by the carrier to the passenger’s booking 
number, as pointed out by two large OTAs and one intermediary association. 

(3)  If  the  intermediary  did  not  receive  the  carrier’s  reimbursement,  with  the  result  that  the 
intermediary did not reimburse the passenger within 14 days,   

The  passenger  can  request  the  reimbursement  from  the  carrier.  The  carrier  shall 

a. 
reimburse the passenger within 7 days.  

On average 5% of passengers are currently paid after 14 days307. Under the baseline, passengers 
are already entitled to request reimbursement from carriers if the intermediary does not process 
their  reimbursement.  Therefore,  no  additional  costs  or  costs  savings  are  expected  from  this 
element of PM C.4. 

b. 

The intermediary can reimburse the passenger by advancing the money to the carrier. 

Some intermediaries already advance payments to passengers ahead of the carrier paying them 
under the baseline. No additional costs are foreseen for intermediaries, as they will have the 
choice of advancing the money or not. 

(4)    If  the  intermediary  received  the  carrier’s  reimbursement  and  did  not  reimburse  the 
passenger within 14 days, the passenger can request the reimbursement from the carrier.  

As this is already the case under the baseline, no cost implications are foreseen. 

307 The 5% of reimbursements taking longer than 14 days to be paid to passengers is linked to the share of BSP 
remittance periods made on a monthly basis, which we assume to have a greater likelihood of reaching the 
passenger’s bank account after 14 days. We applied the 10.9% of BSP payments on a monthly basis to the 
respective shares of intermediary flows within IATA (GDS and non-GDs), which led to 5% of ticket bookings 
who may most likely receive their payments after 14 days. It is also important to point out that under PO 3.2, 
carriers are incentivised to reimburse the intermediary within their deadline of 7 days in order to avoid any 
additional administrative costs that they would incur if the passenger contacted them for reimbursement. 
Intermediaries are also incentivised to comply with their reimbursement deadline as otherwise, carriers would no 
longer choose them for processing the reimbursement. 

97 

 
 
 
Summary of costs and costs savings by option and by measure (problem area 3) 

The  summary  of  recurrent  and  one-off  costs  and  costs  savings  by  option  and  by  measure, 
expressed as present value over 2025-2050, and for 2025, 2030 and 2050 relative to the baseline 
are provided in the tables below.  

Table 134: Recurrent and one-off costs and costs savings in the POs, expressed as present value relative to the 
baseline, in million EUR (2021 prices) 

Difference to the Baseline 
PO 3.2 

PO 3.1 

PO 3.3 

0.07 

0.07 

0.00 

57.42 

57.42 

323.50 

323.50 

57.42    

57.42 
165.69 

57.42 
57.42    

1,617.22 
1,617.22 

828.47 
828.47    

Carriers 
Administrative costs  
PM C.1a 
PM C.1b 
PM C.1c 
Intermediaries 
Administrative costs  
PM C.1a 
PM C.1b 
PM C.1c 
Administrative costs savings 
PM C.1a 
PM C.1c 
Consumers 
Hassle costs 
PM C.1a* 
PM C.1c* 
Hassle costs savings 
PM C.1a* 
PM C.1b* 
PM C.1c* 
PM C.3* 
PM C.4* 
104.49 
Total costs  
682.69 
Total costs savings 
1,949.30 
Net benefits 
1,266.61 
2.9 
Benefits to costs ratio 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for the lower bound of the 
hassle costs and costs savings estimates. When considering the upper bound of the hassle costs and costs savings 
estimates, the net benefits of PO 3.1 are estimated at EUR 1,467.1 million, of PO 3.2 at EUR 3,300.7 million and 
of PO 3.3 at EUR 2,748.5 million, while the benefits to costs ratio at 1.4, 58.4 and 3.8 respectively. 

57.49 
1,679.11 
1,621.62 
29.2 

2,719.55 
3,030.03 
310.48 
1.1 

301.76 
1,783.61 

2,201.57 
1,679.11 

1,044.90 
1,044.90 

1,679.11 

1,679.11 

1,679.11 

165.69 

301.76 

522.45 

0.00 

Table  135:  One-off  administrative  costs  in  the  POs  relative  to  the  baseline  scenario,  in  million  EUR  (2021 
prices) 

Difference to the Baseline 
PO 3.2 

PO 3.1 

PO 3.3 

Carriers 
One-off administrative costs  
PM C.1a 
PM C.1b 

0.07 
0.07    

0.07 

0.07 

0.07    

98 

 
 
 
  
  
  
  
  
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
Difference to the Baseline 
PO 3.2 

PO 3.1 

PO 3.3 

Carriers 
PM C.1c 
Intermediaries 
One-off administrative costs 
PM C.1a 
PM C.1b 
PM C.1c 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

57.42 
57.42    

0.07 

57.42 

57.42 

57.42    

57.42 

Table 136: Recurrent and one-off costs for carriers in the POs, in 2025, 2030 and 2050 relative to the baseline 
scenario, in million EUR (2021 prices) 

Difference to the Baseline 

PO 3.1 
2025 
2030 
73.94  80.56  104.07 
73.94  80.56  104.07 

2050 

PO 3.2 

PO 3.3 

2025 

2030  2050  2025 

0.07  0.00  0.00 

2030  2050 
14.84  16.11  20.81 

Administrative costs  
PM C.1a 
PM C.1b 
PM C.1c 
Total costs  
Source: PWC, TIS and Steer (2023), Impact assessment support study 

73.94  80.56  104.07 

0.07 

0.07  0.00  0.00 

14.84  16.11  20.81 
14.84  16.11  20.81 

Table 137: Recurrent and one-off costs and costs savings for intermediaries in the POs, in 2025, 2030 and 2050 
relative to the baseline scenario, in million EUR (2021 prices) 

Difference to the Baseline 
PO 3.2 

PO 3.3 

PO 3.1 
2030 
0.00 

2025 
57.42 
57.42    

2050 
0.00 

2025 
57.42 

2030  2050 
0.00 
0.00 

2025 
57.42 

2030  2050 
0.00 
0.00 

Administrative costs  
PM C.1a 
PM C.1b 
PM C.1c 
Administrative costs savings 
PM C.1a 
8.25  10.66 
PM C.1c 
Net benefits 
8.25  10.66 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: negative values for ‘net benefits’ 
represent net costs. 

37.84  41.27  53.31 
37.84  41.27  53.31    

-19.58  41.27  53.31 

57.42    
7.57 

7.57 
-49.86 

8.25  10.66 

57.42    

-57.42 

0.00 

0.00 

0.00 

0.00 

0.00 

Table  138: Benefits for consumers in the POs,  in 2025, 2030 and 2050 relative to the baseline scenario, in 
million EUR (2021 prices) 

Hassle costs  
PM C.1a* 
PM C.1c* 
Hassle costs savings 
PM C.1a* 
PM C.1b* 
PM C.1c* 
PM C.3* 

PO 3.1 
2025 
2050 
2030 
47.73  52.06  67.24 
47.73  52.06  67.24 

Difference to the Baseline 
PO 3.2 
2030 
0.00 

2050 
0.00 

2025 
0.00 

PO 3.3 
2030 

2025 

2050 
9.55  10.41  13.45 

9.55  10.41  13.45 
100.56  109.68  141.68  76.70  83.65  108.06  81.47  88.86  114.78 
76.70  83.65  108.06 

   76.70  83.65  108.06 

   76.70  83.65  108.06 

23.86  26.03  33.62 

99 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
     
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
PO 3.1 
2030 

Difference to the Baseline 
PO 3.2 
2030 

2050 

2025 

PO 3.3 
2030 
5.21 

2025 

2050 
6.72 
PM C.4* 
Net benefits 
52.83  57.62  74.44  76.70  83.65  108.06  71.92  78.45  101.33 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for the lower bound of the 
hassle costs and costs savings estimates. 

2025 
4.77 

2050 

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ANNEX 5: COMPETITIVENESS CHECK 

1.  OVERVIEW OF IMPACTS ON COMPETITIVENESS 
Impact of the initiative  
Dimensions of competitiveness 
(++ / + / 0 / - / -- / n.a.) 

Cost and price competitiveness 

Capacity to innovate 

International competitiveness 

- 

+ 

0 

SME competitiveness 

+/- 

References to sub-sections of the 
main report or annexes 

Section 6.1 on economic impacts 
(in particular sections 6.1.1, 6.1.2, 
6.1.3 and 6.1.5) as well as section 
6.2 on social impacts 

Section 6.1.8 on impacts on 
digitalisation 

Section 6.1 for enforcement 
related to carriers: the new rules 
will apply to EU carriers and non-
EU carriers equally, so the level 
playing field remains the same. 

Section 6.1 and 6.1.1 for 
reimbursements through 
intermediaries: new rules applying 
to air carriers will apply to EU and 
non-EU carriers operating flights 
departing from an airport located 
on the territory of an EU Member 
State.  

Section 6.1.6 on impacts on SMEs 
as well as Annex 8 – SME Test 

2.  SYNTHETIC ASSESSMENT  

2.1.   COST AND PRICE COMPETITIVENESS 

The package of preferred policy options will entail compliance costs for carriers, intermediaries, 
and terminal operators. However, this will only constitute an overall impact of very moderate 
magnitude on these stakeholders’ costs. No major restructuring of the sector is expected for any 
of  the  modes  considered.  It  is  anticipated  that  the  measures  proposed  will  not  require  large 
increases in staff numbers, nor changes in competencies. Hence, they will not have a significant 
impact on the labour costs. The potential for cost pass-through to passengers via an increase in 
ticket  prices  has  been  assessed  and  is  estimated  to  be  unsignificant.  Therefore,  the  price 
competitiveness of carriers and intermediaries will remain largely unaffected. 

On the other hand, the increased transparency regarding compliance and protection offered may 
affect  passengers’  choices.  Establishing  service  quality  standards  and  publishing  carrier’s 
results on these standards will provide transparency on the best performing carriers in terms of 
passenger rights. Therefore, compliance with passenger rights is likely to become a factor on 
which carriers can compete, albeit marginally. This may provide a competitive advantage to 
well-performing carriers, while incentivising all carriers to comply with passenger rights. The 
publication of NEBs’ risk assessments is expected to increase the general level of monitoring 

101 

 
 
 
and enforcement across the EU. Operators located in Member States with less active NEBs will 
no longer unfairly benefit from the competitive advantage of being monitored less frequently 
for their compliance with passenger rights.  

In addition, there is a possibility for carriers and intermediaries to become first movers on the 
multimodal market, providing for a competitive advantage. 

 2.2.   CAPACITY TO INNOVATE 

The  package  of  preferred  policy  options  will  promote  the  digitalisation  of  several  business 
practices  and  increase  the  usability  for  passengers  and  speed  up  internal  processes.  The 
Commission  will  support  the  development  of  a  prototype  of  an  e-surveillance  tool  (Web 
Crawler).  The  e-surveillance  tool  could  automate  the  process  of  monitoring  the  industry’s 
compliance with passenger rights, specifically online information obligations. The promotion 
of real time information can facilitate more entrants to the multimodal market and can enhance 
the sharing of data for the benefit of both the passenger and third parties involved in the booking 
process,  in  particular  ticket  vendors  and  tour  operators.  Thanks  to  the  sharing  of  real-time 
information from carriers to other businesses such as ticket vendors, the latter would be in a 
position to adapt and improve their multimodal travel offers for passengers. Intermediaries are 
likely to take up digital solutions in order to ensure their new reimbursement deadline of 7 days 
to their customers can be complied with. 

2.3.   INTERNATIONAL COMPETITIVENESS 

The preferred options are anticipated to have no impact on international competitiveness. 

The new rules on  enforcement will apply  in  the  same way to  EU  carriers and third country 
carriers  which  have  to  comply  with  EU  passenger  rights,  therefore  the  level  playing  field 
between them will remain the same. 

The new rules on  multimodal passenger rights will apply to (i) EU air carriers operating flights 
departing  from  and  arriving  at  EU  airports,  and  non-EU  carriers  operating  flights  departing 
from EU airports; (ii) railway undertakings licensed by EU Member States; (iii) EU waterborne 
carriers and non-EU waterborne carriers where the port of disembarkation is situated in the EU; 
(iv)  regular  bus  and  coach  services  for  non-specified  categories  of  passengers  where  the 
boarding or the alighting point of the passengers is situated in the territory of a Member State 
and where the scheduled distance of the service is 250 km or more; (v) ticket vendors and tour 
operators,  both  EU  and  non-EU,  offering  multimodal  tickets  concerning  a  combination  of 
services from (i) to (iv); and (vi) multimodal hubs located in EU Member States. Given the 
application  of  the  rules  to  both  EU  and  non-EU  carriers,  ticket  vendors  and  tour  operators 
operating  in  the  EU,  there  would  be  no  significant  competitive  disadvantage  of  non-EU 
undertakings  because  of  the  clear  and  uniform  legal  framework  where  they  decide  to  offer 
tickets to passengers.   

The rules regarding reimbursement of air tickets when intermediaries are involved will apply 
to EU and non-EU air carriers operating flights departing from an EU airport.  

2.4.   SME COMPETITIVENESS 

SMEs  represent  a  big  part  of  the  impacted  stakeholders,  as  they  are  numerous  in  the  ticket 
vending sector, and many bus and coach and waterborne carriers are SMEs as well. The package 
of preferred policy options is anticipated to entail some compliance costs for SMEs carriers and 
intermediaries  that  are  only  partly  compensated  by  the  benefits  (see  Annex  8).  All  policy 
measures proposed in the area of multimodal passenger rights result in net benefits for SME 

102 

 
intermediaries.  Limited  costs  for  SMEs  are  expected  as  a  result  of  the  policy  measures  on 
enforcement and the reimbursement of air tickets booked via them. 

On the other hand, better information to intermediaries in the multimodal context gives them 
the  possibility  to  sell  tickets  and  inform  passengers  in  a  way  that  is  currently  not  possible, 
thereby  giving  them  a  chance  to  expand  their  market.  This  was  however  not  possible  to 
quantify.  The  competitiveness  of  SME  air  intermediaries  might  be  strengthened  through  an 
official role in the reimbursement process. 

103 

 
 
 
 
 
 
ANNEX 6: DISCARDED MEASURES 

During the Impact Assessment process, a number of possible policy measures have been 
discarded, based on the analytical work and feedback from the stakeholders. This annex gives 
a detailed description of policy measures discarded at an early stage of the impact assessment.  

Table 139 - Discarded measures 

PROBLEM 
1 

POLICY MEASURE 
Member States are required to set up a 
national digital platform for complaint 
handling process. This platform would 
be accessible to all passengers, 
carriers, NEBs as appropriate 

PROBLEM 
1 

Give the European Commission a 
mandate to perform quality control of 
the monitoring and enforcement 
practices of the NEBs (based on this 
mandate, the Commission could 
request immediate remediation to the 
NEBs)  

PROBLEM 
1 

PROBLEM 
1 

Carriers and intermediaries to execute 
automated reimbursement payments to 
passengers who opted for 
reimbursement (when given choice 
between reimbursement and re-routing 
/journey continuation) and who 
provided the necessary information at 
the time of purchasing the ticket and 
as far as legally and technically 
feasible (still with the choice of the 
means for the passenger) 
Encourage NEBs to organise joint 
assessments of carriers and terminal 
operators, in which the Commission 
could occasionally participate as an 
observer 

REASON FOR DISCARDING 
This policy measure was considered because it was 
presented as good practice already implemented by 
one Member State. However, in that Member State the 
digital platform covers all consumer services 
(transport, public utilities, communication sale of 
consumer goods, etc), therefore the establishment of 
such digital platform is much more cost effective than 
to establish such a platform for passenger transport 
services only. Establishment of a digital platform for 
passenger transport services only would cause 
disproportionate costs. 
Enforcement  by  NEBs  varies  depending  on  their 
competences  given  to  them  according  to  national  law 
(including on binding/non-binding decisions, effective 
sanctioning, handling of individual complaints, etc).   

Whilst in its current role the Commission does monitor 
the enforcement practices of the NEBs, it does not have 
a  mandate  to  assess  and  control  the  quality  of  the 
enforcement practices of the NEBs. Most stakeholders 
participating  in  the  targeted  public  consultation  in  all 
stakeholder groups opposed such a measure. 

Policy measure A.5 which would impose the 
obligation on NEBs to carry out monitoring activities 
on the basis of a risk assessment which would allow 
the Commission to assess whether NEBs take 
monitoring action on the basis of the risks identified 
was inspired by this discarded policy measure.   
This policy measure would be difficult to implement as 
the information on whether the passenger has made the 
choice between re-routing and reimbursement could be 
hard to monitor, meaning that the passenger possibly 
could lose the re-routing option if the reimbursement 
was automatically administered. Instead, an easily 
accessible form for reimbursement requests is 
applicable in the preferred option. 

This  policy  measure  was  considered  because  a  joint 
assessment  of  carriers  and  terminal  operators  is  a 
successful  pilot  project  under  the  auspices  of  the 
European  Civil  Aviation  Conference’s  (ECAC)  PRM 
Facilitation Subgroup. Several NEBs responsible for the 
enforcement of Regulation (EC) 1107/2006 participated 
in such joint assessments. 

It was discarded because the NEBs concerned 
indicated that such a joint assessment is based on very 
detailed standards which are difficult to adopt in case 
of other passenger rights Regulations. As a non-
binding measure, it was assessed as likely to have 
limited impact on the objective of ensuring effective 

104 

 
 
 
 
 
PROBLEM 
1 

PROBLEM 
1 

PROBLEM 
1 

PROBLEM 
2 

PROBLEM 
3 

PROBLEM 
3 

Encourage the industry to adopt 
“passenger friendly” labels, to be 
granted to those carriers or terminal 
operators that agree to disclose public 
data on their performance related to 
passenger rights (whether they have a 
plan how to implement the 
Regulations, their key performance 
indicators related to punctuality, 
handling passenger complaints, 
assisting PRM passengers, etc.), and 
where such data indicate good 
performance 
Carriers and terminal operators shall 
adopt a plan to implement their quality 
standards. The plan shall describe the 
methods and procedures which are to 
be followed by the carrier and terminal 
operator in order to comply with the 
plan. The plan shall be submitted to 
the NEB or any other appropriate 
authority designated by the Member 
State, which may take further action if 
appropriate. Carriers shall publish 
their approved implementation plans 
on their website 
The Commission will adopt formal 
Recommendations on the 
interpretation and application of 
passenger rights after consulting the 
Passenger Rights Comitology 
Committee (All modes except air as 
the same policy measure exists in the 
2013 Commission proposal on the 
revision of air passenger rights) 
Encourage the conclusion of voluntary 
agreements across transport modes 
regarding journey continuation, as 
well as the communication on such 
agreements towards passengers, ticket 
vendors and tour operators 
Ensure that the MoR intermediary 
passes to the airline the passenger’s 
original form of payment, so that the 
airline can reimburse the passenger 
directly, without the involvement of 
the intermediary. 

Ensure that the intermediary pre-
finances the reimbursement (before 
having received it from the carrier) – 
either fully, or only when the carrier 
has not paid the intermediary within 
the deadline 

enforcement, complaint handling and reimbursement 
for passengers 
This would have been a non-binding measure, so it is 
likely that it could have had limited impact on the 
objective of ensuring effective enforcement, complaint 
handling and reimbursement for passengers. 

This policy measure was not supported by the majority 
of stakeholders in all stakeholder groups (with the 
exception of NEBs). It was considered that imposing 
such obligations on carries and terminal operators 
would be a disproportionate burden on them. 

This measure will not add any additional costs, as the 
Committee will meet at the same interval as the 
already existing Expert Groups. Therefore, it was 
deemed not necessary to do a cost-benefit analysis of 
the measure 

This policy measure would have been a non-binding 
measure, meaning that it would have been unlikely to 
have a major impact. In addition, such a policy 
measure would require that a similar measure is 
already applied within the transport modes first, which 
is currently not the case.  
When the intermediary is the Merchant of Record, it 
cannot pass on the customer’s credit card information, 
as the intermediary does not have it. The credit card 
details are stored in the safe environment of the credit 
card’s acquirer and not the merchant. The merchant 
can process the reimbursement through the acquirer. 

The liquidity position of travel intermediaries may not 
allow to pre-finance reimbursements, especially if a lot 
of reimbursement requests are made at the same time. 
At least 95% of travel intermediaries are SMEs. 51% 
in terms of numbers are not part of IATA’s Billing and 
Settlement Plan (BSP, a private industry mechanism), 
through which, for most reimbursement transactions, 
their liquidity position may be better308. However, also 
under this system there are risks to intermediaries 

308 IATA and travel intermediaries disagree on this point. (Stakeholder meeting (IATA and travel intermediaries) 
held on 8 May 2023 and position paper by travel intermediary stakeholders received on 12 May 2023.) 

105 

 
 
 
PROBLEM 
3 

PROBLEM 
3 

Joint and several liability between 
intermediaries and carriers for the 
reimbursement 
Oblige (online) intermediaries to be 
“pass-through agents” (just passing on 
the customer’s means of payment to 
the carrier, and not making a payment 
from their own accounts to the carrier) 
instead of “Merchants of Record”, 
unless a valid agreement is in place 
between air carrier and intermediary, 
and which covers the reimbursement 

when they pre-finance the reimbursement: the airline 
might be suspended from the BSP, despite an approved 
automated GDS refund, or the airline may become 
insolvent, in which case the intermediary would most 
likely not be able to recover any pre-financed amounts 
from the airlines.  
For reasons similar to the above, the intermediary 
should not be obliged to pre-finance the 
reimbursement payment of the carrier. 
This measure was discarded as it significantly differed 
from the current practices of the intermediaries, and 
the preferences of their customers. Intermediaries use 
their own payment details as Merchant of Record 
because the customer may want to use a different form 
of payment than the one that the airline accepts, e.g., 
pay by invoice, and the intermediary has to settle with 
the airline in another way. Another reason may be that 
the intermediary only wants to bill the customer one 
amount. If the customer’s credit card is passed through 
to the airline, this may include several separate 
amounts (e.g., for the flight ticket, the service fee of 
the intermediary, rental car, etc.). A Tour Operator 
may include the air ticket as part of a package, and 
then charge the whole amount of the package under the 
name of the intermediary. The intermediary may add a 
mark-up to air ticket fares and thus charge only the 
total price to the customer under the intermediary’s 
name. 

106 

 
 
 
ANNEX 7: DETAILED POLICY MEASURES 

Table 140 - Detailed policy measures Problem 1 

Passengers do not fully benefit from their rights 
due  to  shortcomings  in  implementation  and 
enforcement 

and 

and 

terminal 

information  at 

infrastructure 
Carriers, 
managers, 
tour 
ticket  vendors 
operators to provide the NEB with relevant 
documents  and 
their 
request,  without  undue  delay  and  in  any 
event within one month from the receipt of 
the  request  (similar  to  what  is  already 
required under Article 32(2) of Regulation 
(EU)  2021/782  on  rail  passenger’s  rights 
and obligations). (All modes except rail as 
such  a  provision  already  exist  in  rail 
passenger rights) 

a 

implement 

Carriers  shall  establish  service  quality 
standards, 
quality 
management  system  and  publish  biennial 
reports on the results. 
Terminal  operators  shall  establish  service 
quality  standards,  implement  a  quality 
management  system,  and  disclose  results 
with NEBs if requested to do so (All modes 
except rail as such a provision already exist 
in rail passenger rights) 

via 

requests 

The  Commission  adopts  an  EU-wide 
standardised form for reimbursements and 
compensation 
an 
implementing act - carriers, ticket vendors 
and  tour  operators  are  obliged  to  accept 
this form, but passengers are not forced to 
use  it  (All  modes  except  rail  as  such  a 
provision  already  exist  in  rail  passenger 
rights). 

carriers, 

Each Member State to require its NEB(s) 
compliance  monitoring 
perform 
to 
terminal 
activities  of 
the 
operators, 
tour 
ticket  vendors 
operators based on a risk assessment. The 
outline  of  this  risk  assessment  and  an 
explanation in general terms on how it has 
been developed has to be produced by the 
NEB(s) every two years. 

and 

PM 
A.1 

PM 
A.2 

PM 
A.3 

PM 
A.4 

  Specific 
objectives 

SO1 
PO 1.1 
PO 1.2 

SO1 
PO 1.1 
PO 1.2 

Detailed descriptions 

The aim of the measure is to ensure that 
operators have a legal obligation to 
comply with information requests from 
the NEBs. While a failure to reply 
currently can result in procedural harm, 
NEBs will now be offered with an 
additional tool to ensure cooperation 
from market operators to the easement of 
the NEBs’ enforcement efforts. 
Additionally, the measure provides a 
harmonisation of the procedural-deadline 
for replies across Member States. 
The measures require that carriers and 
terminal operators establish standards on 
which their service quality will be 
evaluated.  

In the rail regulation, certain minimum 
requirements have been made as to what 
these standards must encompass, such as 
number of delays, cancellations 
complaint handling (number of 
complaints the problem raised in them, 
outcome) and customer satisfaction (e.g. 
results of customer surveys).  

Operators will have to monitor their 
performance on the basis of these 
standards: carriers will have to publish 
the results while terminal operators have 
to collect data about the results and send 
it to the responsible NEB if that NEB 
requests it. 

With this measure, the Commission will 
provide passengers with a standard and 
easily accessible claims form, which 
passengers will always be able to use, but 
won’t be forced to use. 

SO2 
PO 1.1 
PO 1.2 

This is to ensure a form and process for 
passengers, which serves them. If the 
carrier’s or intermediary’s form is not 
suitable for the passenger or the process 
is otherwise cumbersome, the passengers 
will always be able to resort to this EU-
wide standard form.  
The aim of this measure is to ensure that 
NEBs focus their monitoring and 
enforcement efforts on a relevant data- 
and information-based approach relying 
on an assessment of the risk for non-
compliance against passenger rights. In 
this context, NEBs will then develop and 
implement monitoring programmes 
corresponding to the findings of the risk 

107 

SO1 
PO 1.2 

 
 
 
 
 
 
 
 
assessment with a view to ensuring that 
operators perform according to passenger 
rights rules. While minimum 
requirements for the programme will be 
set up at EU level (e.g. inspections, 
audits, verifications etc), the design and 
implementation of the detailed 
programmes will be left to NEBs which 
are best equipped at operational level. 
Finally, swift rectification of non-
compliances by operators should be 
ensured, as appropriate. Reporting to 
Commission will be made and will 
contribute to guarantee effectiveness at 
European level. 

With this measure, carriers and terminal 
operators will specify how they provide 
information to passengers effectively. 
Information to passengers on their rights 
will be succinct and made easily, 
prominently and directly available. It will 
have to be provided in a clear and 
comprehensible manner and not merely 
in the standard terms and conditions or 
similar contractual documents. It will 
have to  be provided by electronic means 
as far as possible.. Operators and 
passengers will have a common 
understanding of the way information is 
shared, resulting in a higher level of 
awareness about passenger rights.  
The operators will have to will have to 
inform passengers about the possibility 
of using an ADR option, should a 
conflict arise. Furthermore, the operators 
will have to make the passengers aware 
of the different ADR Bodies, by 
providing a link for the EU ADR 
website. The information about ADR is 
intended to reduce judicialisation since it 
is an alternative public service to the 
judicial way which offers a faster and 
free option.   

PM 
A.5 

Carriers  and  terminal  operators  to  better 
inform passengers about their rights when 
booking their journeys, when a disruption 
occurs including on the complaint handling 
mechanisms  with  the  view  to  raise  their 
awareness about their rights (all modes) 

PM 
A.6 

Carriers, ticket vendors, tour operators and 
terminal  operators  are  obliged  to  inform 
passengers about the ADR option and the 
ADR  bodies  (all  modes)  and  NEBs  are 
obliged to inform the passengers about the 
right  to  complain  to  ADR  bodies  to  seek 
individual  redress  where  necessary  (in 
cases  where  the  NEBs  cannot  decide 
individual cases) (all modes except rail) 

Table 141 - Detailed policy measures Problem 2 

Insufficient  protection  of  passengers  during 
multimodal journeys 

Detailed description 

PM 
B.1 

Ensure  that  carriers,  ticket  vendors/tour 
operators  and  multimodal  hub  managers 
provide  guidance 
to  passengers  on 
minimum connecting times and other useful 
information  when 
switching  between 
modes of transport, e.g., on accessibility of 
transport infrastructure (category A+B+C) 

Under 
ticket 
this  measure  carriers, 
vendors/tour  operators  and  multimodal 
hub  managers  have  to  provide  essential 
pre-purchase  information  to  multimodal 
passengers  on  the  type  of  multimodal 
tickets  (single  contract  of  carriage  or 
time 
integrated 
schedules,  available  connections  and 
tariffs, and the accessibility of services and 

separate 

tickets), 

108 

SO2 
PO 1.2 

SO2 
PO 1.1 
PO 1.2 

Specific 
objectives 

SO3/SO4 
PO 2.1 
PO 2.2 
PO 2.3 

 
 
 
 
 
 
apply 

to  all 

terminals for PRM. The information to be 
provided  is  established  on  an  EU-wide 
the 
basis  and  would  apply 
abovementioned  actors.  This  measure, 
which  would  apply  to  all  multimodal 
passengers (category A+B+C) is similar to 
what  is  already  required  under  Article  9 
and Annex II of Regulation (EU) 2021/782 
on rail. 
Carriers and ticket vendors/tour operators 
have  to  provide  real-time  information  to 
passengers  on  disruptions,  possible  next 
connections and security alerts during the 
journey,  where  technically  feasible.  This 
measure,  which  would 
to 
multimodal  passengers  having  a  single 
contact of carriage (category A), and those 
having  separate  tickets  for  a  multimodal 
journey  which  are  combined  and  sold  in 
one  commercial  transaction  by  a  ticket 
vendor/tour  operator  (category  B), 
is 
similar  to  what  is  already  required  under 
Article 9, 10, 20(6), Annex II and Annex 
III  of  Regulation  (EU)  2021/782.  SMEs 
would be exempted from this measure. 
Carriers  have  to  ensure  that  passengers 
travelling  on  single  contracts  of  carriage 
for  a  multimodal  journey  enjoy  a  set  of 
rights  that  already  apply  when  travelling 
within  a  single  mode  of  transport  on  the 
basis of the existing Regulations (air, rail, 
bus and coach, and waterborne), namely a 
right  to  pre-purchase  information,  a  right 
to reimbursement or re-routing and a right 
to care in the event of a missed connection, 
as  well  as  a  right  to  non-discriminatory 
transport  contract  conditions  and  free 
assistance for PRM. 
Carriers have to ensure that, on top of the 
rights 
under  PM  B.3a, 
passengers  have  a  right  to  conclude  an 
alternative  contract  where  a  carrier  does 
not make provision for the continuation of 
a  passenger’s  journey  (“right  to  self-re-
routing"). This measure is similar to what 
is already required under Article 18(3) of 
Regulation (EU) 2021/782. 
Ticket vendors and tour operators have to 
properly  inform  passengers  where  they 
bundle  separate  tickets  for  a  multimodal 
journey  and  sell  them  in  one  commercial 
transaction  to  passengers.  Where  they  do 
not  provide  information  on  the  separate 
nature of the transport tickets, they would 
be  liable  to  reimburse  the  passenger  the 
entire amount paid for the separate tickets, 
together  with  a  penalty  of  75%  of  that 
amount, in the event where the passengers 
misses a connection during the multimodal 
journey. This measure is similar to what is 
already required for ticket vendors and tour 

proposed 

109 

SO3 
PO 2.2 
PO 2.3 

SO3 
PO 2.1 
PO 2.2 

SO3 
PO 2.3 

S03 
PO 2.2 

PM 
B.2 

Ensure that carriers and ticket vendors/tour 
operators (except SMEs) provide real-time 
information to passengers (category A+B) 

PM 
B.3a 

PM 
B.3b 

PM 
B.4a 

Ensure  a  basic  package  of  rights  for 
passengers  holding  a  single  contract  of 
carriage for a multimodal journey (i.e., right 
to 
to  pre-purchase 
reimbursement  or  re-routing,  right  to  care 
(accommodation, meals and refreshments), 
right  to  non-discrimination  and  free  PRM 
assistance) (category A)  

information, 

right 

Ensure  an  enhanced  package  of  rights  for 
passengers  holding  a  single  contract  of 
carriage  for  a  multimodal  journey  (i.e., 
same  rights  as  under  PM  B.3a  +  right  to 
conclude  an  alternative  contract  where  a 
carrier  does  not  make  provision  for  the 
continuation  of  a  passenger’s 
journey 
within a defined time limit) (category A) 

Ensure  an  essential  set  of  rights  for 
passengers  holding  separate  tickets  for  a 
multimodal  journey  combined  and  sold  in 
one  commercial  transaction  by  a  ticket 
vendor  or  tour  operator  (i.e.  right  to  pre-
purchase 
to 
reimbursement  and  penalty  of  75%  from 
ticket  vendor/tour  operator,  unless  where 
passengers  were  properly  informed  of 
separate nature of the tickets) (category B) 

information 

right 

+ 

 
 
PM 
B.4b 

PM 
B.5 

PM 
B.6 

PM 
B.7 

Ensure  an  enhanced  package  of  rights  for 
passengers  holding  separate  tickets  for  a 
multimodal  journey  combined  and  sold  in 
one  commercial  transaction  by  a  ticket 
vendor or tour operator (i.e., same enhanced 
set  of  rights  as  for  passengers  holding  a 
single  contract  of  carriage  (see  measure 
B.3b). The ticket vendor is liable to ensure 
these  rights  towards  the  passenger  unless 
where  passengers  were  properly  informed 
tickets 
of 
(category B) 
Ensure  that  Member  States  require  the 
establishment of “Single Points of Contact” 
(SPC)  for  PRM  at  multimodal  passenger 
hubs  in  urban  nodes  on  their  territory 
(category A+B+C) 

the  separate  nature  of 

the 

require 

States  may 

Member 
the 
establishment of “Single Points of Contact” 
(SPC) 
to  PRMs  at  other  multimodal 
passenger hubs on their territory. (category 
A+B+C) 

Ensure that carriers, terminal managers, and 
ticket  vendors/tour  operators  establish  an 
online  and  offline  complaint-handling 
mechanism for multimodal passengers with 
clear deadlines. (category A+B+C) 

operators  under  Article  12(4)  and  (5)  of 
Regulation (EU) 2021/782. 

Under  this  measure,  ticket  vendors  and 
tour  operators  will  have 
to  provide 
passengers  travelling  on  separate  tickets 
(category  B) 
that 
passengers  having  a  single  contract  of 
carriage  would  enjoy  under  PM  B.3b, 
unless  where  passengers  were  properly 
informed on the separate nature of tickets. 

rights 

same 

the 

they  need 

This  measure  requires  Member  States  to 
ensure  the  set  up  of  “Single  Points  of 
Contact”  (SPC)  to  arrange  the  assistance 
for PRMs at multimodal passenger hubs at 
urban nodes, which ought to be developed 
by 2030 in line with the TEN-T proposal. 
These  SPCs  would  be  managed  by  a 
terminal manager (airport, station, port or 
bus  terminal  manager)  operating  at  a 
multimodal  passenger  hub.  The  terminal 
manager(s)  and  carriers  operating  at  the 
multimodal  passenger  hub  would  have  to 
cooperate to this effect. The contact details 
of  the  SPC  would  be  published  on  their 
websites. The SPC could  be contacted by 
phone  and  via  a  dedicated  online  contact 
form, enabling PRMs to request assistance 
when 
transfer  between 
to 
terminals  to  reach  a  connecting  service 
provided  by  another  transport  mode.  The 
individual 
SPC  would  communicate 
requests  for  assistance  to  other  terminal 
managers  and  carriers  involved  in  the 
journey,  providing  a  “one  stop  shop”  for 
the  PRM.  Notification  would  need  to  be 
provided at least 48-24 hours ahead of the 
journey, depending on the transport modes 
involved.  This  measure  is  inspired  by 
(EU) 
Article  24 
2021/782. 
Under this measure, Member States could 
require SPCs to be set up beyond  the 424 
multimodal  hubs  (e.g.  in  case  where  an 
urban node has more than one such hub or 
where  such  hubs  are  located  outside  the 
territory  of  an  urban  node)  and  should 
therefore be read as a complement to PM 
B.5. 
This  measure 
enables  multimodal 
passengers  to  file  a  complaint  on  the 
alleged lack of respect of their rights as a 
passenger  to  carriers,  terminal  managers 
and  ticket  vendors/tour  operators,  who 
would have to set up an online and offline 
complaint-handling  mechanism  to  this 

(f)  of  Regulation 

110 

SO3 
PO 2.3 

SO4 
PO 2.2 
PO 2.3 

SO4 
PO 2.2 
PO 2.3 

SO3/SO4 
PO 2.1 
PO 2.2 
PO 2.3 

 
PM 
B.8 

Member  States  to  designate  a  NEB  to 
handle 
from  multimodal 
complaints 
passengers. (category A+B+C) 

effect.  This  measure  is  similar  to  what  is 
already required under Articles 28(1) and 
12(7) of Regulation (EU) 2021/782. 

Under  this  measure,  Member  States  need 
to designate a NEB or other body to handle 
complaints  from  multimodal  passengers. 
Member States could designate a NEB that 
is already responsible for the enforcement 
of  one  or  more  of  the  existing  passenger 
rights Regulations.  Where the designated 
complaint-handling  body 
another 
authority than the NEB, these bodies shall 
cooperate  in  the  context  of  an  individual 
complaint  to  identify  a  lead  body,  which 
shall serve as a single point of contact for 
passengers.  All  the  involved  bodies  shall 
cooperate to facilitate the resolution of the 
complaint, 
sharing 
information and providing information on 
the circumstances of incidents. 

including 

by 

is 

SO3/SO4 
PO 2.1 
PO 2.2 
PO 2.3 

Specific 
objective 
and 
Policy 
options 
SO5 
3.1 

SO5 
3.2 

Table 142 - Detailed policy measures Problem 3 

Reimbursement  rules  are  unclear  when 
flights were booked via an intermediary 

Detailed description 

PM 
C.1a 

PM 
C.1b 

on 

passengers 

Intermediaries  and  carriers  shall 
the 
inform 
reimbursement 
The 
passenger  may  only  request  the 
reimbursement  to  the  carrier, 
which  performs  it  without  the 
involvement of the intermediary. 

process. 

Intermediaries and carriers to inform 
passengers  on  the  reimbursement 
process.  The  carrier  can  decide 
whether  the  passenger  has  to 
request  the  reimbursement  from 
the  (MoR)  intermediary  or  the 
carrier  (both  free  of  charge for  the 
passenger),  e.g.,  by  stating  publicly 
if  so  with  which 
whether,  and 
intermediaries, 
processes 
reimbursements.  It  can  do  so  on  an 
individual intermediary basis. 
intermediary 
The  MoR 
disagree 
with 
reimbursement 
(certain or all) carriers. 
If the carrier decides to carry out the 
reimbursement  by  itself:  like  PO 
3.1). 

can 
processing 
for 

requests 

it 

In order to ensure that passengers are 
well informed about their rights and 
how to make use of them, 
intermediaries and carriers are to inform 
passengers on the reimbursement 
process (a) before booking on their 
websites, (b) on the booking receipt, 
and (c) when the right to reimbursement 
is triggered and they are (made) aware 
of this, and in an accessible way. 
In order to ensure that passengers are 
well informed about their rights and 
how to make use of them, 
intermediaries and carriers are to inform 
passengers on the reimbursement 
process (a) before booking on their 
websites, (b) on the booking receipt, 
and (c) when the right to reimbursement 
is triggered and they are (made) aware 
of this, and in an accessible way. 

If the intermediary does not want to 
process reimbursement requests (also 
on a carrier basis), further conditions 
then apply for the intermediary, see PM 
C4 (1). 

111 

 
 
 
 
 
 
PM 
C.1c  

like  PO 

Intermediaries and carriers to inform 
passengers  on  the  reimbursement 
process  and  the  option  for  the 
passenger 
to  choose  between 
(MoR)  intermediary  and  carrier 
for requesting reimbursement (when 
3.1.  When 
carrier: 
intermediary:  like  PO  3.2  when  the 
carrier decided for the intermediary, 
with the difference that in PO 3.3, the 
intermediary  may  charge  a  fee  for 
reimbursement 
processing 
request). 
Intermediaries  to  inform  whether 
they 
the 
a 
charge 
reimbursement request 

fee 

the 

for 

PM 
C.2a 

Intermediary may not charge a fee 
the  passenger’s 
for  processing 
reimbursement request 

PM 
C.2b  

Intermediary  may  charge  a  fee  for 
processing 
passenger’s 
the 
reimbursement request 

PM 
C.3 

MoR  Intermediary  to  enable  the 
passenger (with the data needed and 
which  only  the  intermediary  has, 
such as carrier booking reference) to 
request reimbursement directly to the 
carrier. 

Additional rules when intermediaries 
which are a ‘Merchant of Record’ are 
involved: 

PM 
C.4  

1.  When 

the 

passenger 
the 

requests 
reimbursement: 
intermediary  to  enable  the 
passenger  (with  the  data 
needed and which only the 
intermediary  has,  such  as 
carrier  booking  reference) 
the 
request 
to 

SO5 
3.3 

SO5 
3.2 

SO5 
3.1 

SO5 
3.1 

SO5 
3.2, 3.3 

In order to ensure that passengers are 
well informed about their rights and 
how to make use of them, 
intermediaries and carriers are to inform 
passengers on the reimbursement 
process (a) before booking on their 
websites, (b) on the booking receipt, 
and (c) when the right to reimbursement 
is triggered and they are (made) aware 
of this, and in an accessible way. 

The intermediary may charge a fee 
because the passenger has a choice 
between carrier and intermediary. 

Under PO 3.2, the passenger cannot 
choose between intermediary and 
carrier. Therefore, the same rule on a 
reimbursement fee needs to apply to 
both the carrier (no fee under the 
baseline) and the intermediary. 

Under PO 3.3, the intermediary may 
choose whether to charge a fee for the 
reimbursement or not, since the 
passenger has the choice between 
carrier and intermediary and this 
element can be part of her/his decision. 
Sometimes, when passengers book via 
an intermediary, intermediaries use their 
own booking reference, and not that of 
the carrier. This makes it very difficult 
for the passenger (and the carrier) when 
he or she approaches the carrier for a 
reimbursement. In order for the 
passenger to be able to request the 
reimbursement, and the carrier to be 
able to handle it, the intermediary only 
needs to provide the passenger with 
these data when the passenger requests 
the reimbursement. If the intermediary 
goes insolvent, which will be rare (see 
further conditions below in PM C4), the 
passenger will still be able to approach 
the carrier, but it will be more 
burdensome for the passenger. 

When the passenger books a ticket via 
an intermediary who is Merchant of 
Record (i.e. who makes the payment for 
the ticket from its own account), 
additional rules are needed, as the 
carrier does not have the information of 
the passenger that is needed in order to 
process the reimbursement request 
(means of payment, most importantly). 

Ad (1): as explained under PM C3. 
N.B.: The data are linked to PM C4.3 
and 3 – the “plan B” for the passenger 

112 

 
 
 
 
 
 
 
 
 
 
 
in case the intermediary has not 
transferred the money within 14 days. 
This provision is only triggered when 
the passenger requests the 
reimbursement, unless the intermediary 
does not want to be involved. In this 
case, the provision applies at a different 
moment, namely at booking. 

Ad (2): the intermediary receives a 
payment deadline of 7 days to the 
passenger upon receipt of the funds 
from the carrier. 

Ad (3): We are not foreseeing a right of 
redress for the intermediary towards the 
carrier for point (3) b) because this right 
would exist already as per the provision 
under PM C4 (2) that the carrier needs 
to reimburse the intermediary within 7 
days. 

reimbursement  directly  to 
the carrier.  

If the intermediary does not agree 
the  reimbursement 
to  process 
request, 
the 
shall  enable 
it 
passenger  at  booking,  with  the 
data  needed  and  which  only  he 
has, to request the reimbursement 
directly from the carrier.  

2. Carrier 

shall 

reimburse 

the 
intermediary at the latest within 7 
days,  in  one  transaction,  via  the 
same payment method used at the 
time  of  booking  and  linking  the 
payment with the original booking 
reference. The intermediary has to 
reimburse  the  passenger  at  the 
latest within another 7 days. 

3. If the intermediary did not receive 
the  carrier’s  reimbursement,  with 
the result that the intermediary did 
the  passenger 
reimburse 
not 
within 14 days, 
a.  The passenger can request the 
the 
shall 
passenger 

reimbursement 
from 
carrier.  The  carrier 
reimburse 
the 
within 7 days, or: 

b. The 

intermediary 

can 
the 
(voluntarily) 
passenger  by  advancing  the 
money to the carrier.309 

reimburse 

4.  If  the  intermediary  received  the 
carrier’s  reimbursement  and  did 
not 
the  passenger 
within 14 days, the passenger can 
request  the  reimbursement  from 
the carrier.   

reimburse 

309 No right of redress is foreseen for the intermediary against the carrier as it already exists due to the carrier’s 
obligation to reimburse the intermediary within 7 days. 

113 

 
 
 
 
 
 
 
 
 
 
Overview table of Options for Problem 3: Reimbursement rules are unclear 

when flights were booked via an intermediary 

the 

Option 3.1: Passenger may only 
reimbursement 
request 
carrier,  which 
from 
the 
performs 
involvement 
the 
intermediary. 

it  without 

the 

of 

from 

intermediaries, 

reimbursement 

Option  3.2:  The  carrier  can  decide 
whether  the  passenger  has  to  request 
the 
the 
intermediary  or  the  carrier  (both  free 
of  charge  for  the  passenger),  e.g.  by 
stating publicly whether, and if so with 
it  processes 
which 
reimbursements.  It  can  do  so  on  an 
individual intermediary basis. 
The  intermediary  can  disagree  with 
processing reimbursement requests for 
(certain  or  all)  carriers,  and  needs  to 
inform about this, e.g. in the terms and 
conditions  on  its  website,  and  the 
passenger.  If  the  carrier  decides  to 
carry out the reimbursement by itself: 
like PO 3.1). 

to 

enable 

Intermediary 
the 
to 
passenger  (with  the  data  needed) 
to  request 
the  reimbursement 
directly to the carrier. 
Obligation  on  intermediaries  and 
inform  passengers 
carriers 
(where  their  contact  details  are 
known  to  the  intermediary  or 
carrier)  on 
the  reimbursement 
process,  which  the  passenger 
may only request to the carrier 
and  which  the  carrier  carries 
out  without  the  involvement  of 
(a)  before 
the 
the  booking 
booking,  (b)  on 
receipt,  (c)  when  the  right  to 
reimbursement  is  triggered  and 
they are (made) aware of this, and 
in an accessible way. 

intermediary 

on 

(a) 

inform 

passengers 
process 

Obligation on intermediaries and carriers 
the 
to 
reimbursement 
before 
booking,  (b)  on  the  booking  receipt,  (c) 
when  the  right  to  reimbursement  is 
triggered  and  they  are  (made)  aware  of 
this, and in an accessible way. 
(The  carrier  can  decide  whether  the 
passenger 
the 
reimbursement from the intermediary 
(in  agreement  with  the  intermediary) 
or the carrier.) 

request 

has 

to 

Option  3.3:  The  passenger  can  choose 
to request the reimbursement from the 
the  carrier.  The 
intermediary  or 
intermediary  may  charge  a  fee  for 
processing the reimbursement request. 
Like  option  3.1  when  choice  is  for 
carrier.  Like  option  3.2  (intermediary 
procedure)  when  choice  is  for  the 
intermediary. 

 Obligation on intermediaries and carriers 
to inform passengers (a) before booking, 
(b) on  the  booking receipt,  (c)  when  the 
right  to  reimbursement  is  triggered  and 
they are (made) aware of this, and in an 
accessible  way:  on  the  reimbursement 
process and the option for the passenger 
to  choose  between  intermediary  and 
carrier  for  requesting  reimbursement 
(when  carrier:  like  option  3.1.  When 
intermediary:  like  option  3.2,  with  the 
difference  that  the  intermediary  may 
charge  a 
the 
reimbursement request). 
they 
Intermediaries: 
charge  a  fee  for  the  reimbursement 
request 

inform  whether 

for  processing 

fee 

Intermediary  may  not  charge  a  fee  for 
processing 
passenger’s 
the 
reimbursement request 

Intermediary  may  charge  a  fee  for 
processing 
passenger’s 
the 
reimbursement request  

intermediaries 
Additional  rules  when 
which  are  a  ‘Merchant  of  Record’  are 
involved: 

intermediaries 
Additional  rules  when 
which  are  a  ‘Merchant  of  Record’  are 
involved: 

Like  option  3.2  when  the  passenger 
chooses the intermediary procedure. 

1. When 

the  passenger  requests 

the 
reimbursement: intermediary to enable 
the  passenger  (with  the  data  needed 
and  which  only  the  intermediary  has, 
such  as  carrier  booking  reference)  to 
request  the  reimbursement  directly  to 
the carrier.  

114 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
If  the  intermediary  does  not  agree  to 
process  the  reimbursement  request,  it 
shall enable the passenger at booking, 
with the data needed and which only he 
has,  to  request  the  reimbursement 
directly from the carrier.  

2. Carrier 

shall 

reimburse 

transaction,  via 

the 
intermediary at the latest within 7 days, 
in  one 
the  same 
payment  method  used  at  the  time  of 
booking and linking the payment with 
the  original  booking  reference.  The 
intermediary  has  to  reimburse  the 
passenger at the latest within another 7 
days. 

reimbursement,  with 

3. If the intermediary did not receive the 
carrier’s 
the 
result  that  the  intermediary  did  not 
reimburse  the  passenger  within  14 
days, 
a)  The  passenger  can  request  the 
reimbursement  from  the  carrier. 
The  carrier  shall  reimburse  the 
passenger within 7 days, or: 

b)  The intermediary can (voluntarily) 
by 
the 
the 
the  money 

passenger 
to 

reimburse 
advancing 
carrier.310 

4. If 

the 

received 

intermediary 

the 
carrier’s  reimbursement  and  did  not 
reimburse  the  passenger  within  14 
days,  the  passenger  can  request  the 
reimbursement from the carrier. 

310 No right of redress is foreseen for the intermediary against the carrier as it already exists due to the carrier’s 
obligation to reimburse the intermediary within 7 days. 

115 

 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8: SME TEST 

SMEs play a significant role among carriers and intermediaries. Therefore, the initiative is considered 
relevant for the SMEs and the SME test has been performed.  

Step 1/4: Identification of affected businesses 

While many carriers in the air and rail transport, and terminal operators, are medium and some even 
large companies, bus and coach carriers, waterborne carriers as well as intermediaries are often SMEs. 
Around 85%311 (3,211  out  of  3,778)  of  bus  and  coach  carriers  and  99%312  (518  out  of  523) 
waterborne  carriers  are  SMEs.  Regarding  intermediaries,  ECTAA  estimates  that  there  are 
123,000 travel agents and tour operators across EU, of which 95% (116,850) are SMEs313. 

The  proposed  options  impact  different  market  segments.  Problem  area  3  targets  directly 
intermediary ticket vendors, which is a sector primarily composed of SMEs (95% of the sector). 
Concerning  problem  areas  1  and  2,  in  addition  to  impacts  on  intermediary  ticket  vendors, 
passenger transport operators are also likely to be impacted.  

Step 2/4: Consultation of SME Stakeholders 

This initiative included stakeholder consultation in the form of: (i) an open public consultation 
(OPC), (ii) a targeted survey, (iii) 7 workshops (4 with NEBs and 3 with industry stakeholders), 
(iv)  40  interviews.  SMEs  and  representative  organisations  were  invited  to  all  consultation 
activities and have actively participated in the debates.  

The following paragraphs summarise the answers provided by 22 SMEs in the targeted survey 
(out  of  the  172  survey  respondents),  taking  into  consideration  companies  that  identified 
themselves as either micro, small or medium enterprises and excluding umbrella organisations. 
These  22  SMEs  included  carriers  or  terminal  managers,  intermediary  ticket  vendors,  claim 
agencies,  insurance  companies  and  insolvency  protection  funds,  as  well  as  one  company 
providing technology solutions for PRMs. It is worth noting that, in addition to expressing their 
level of agreement or disagreement with the presented problems and objectives of the initiative, 
some stakeholders provided reasoning, although not all did.  

For  problem  1  on  enforcement,  15  out  of  17  SMEs  agreed  or  strongly  agreed  with  the  first 
problem  statement  that  carriers,  terminal  operators,  and  NEBs  apply  EU  passenger  rights 
legislation in different ways, including 9 out of 11 carriers or terminal operators. In turn, 14 out 
of 17 SMEs strongly agreed or agreed with the second problem statement identified for problem 
1, on the statement that the enforcement of EU passenger rights legislation by NEBs is neither 
harmonised or consistent, including 8 out of 11 carriers or terminal managers.  

Regarding the specific objective identified for the area of enforcement, which seeks to ensure 
that passengers fully enjoy their rights, 15 out of 17 SMEs agreed or strongly agreed with it, 
including 9 out of 11 carriers or terminal managers. One SME terminal manager added that the 

311 SMEs were estimated to account for around 85% of the occasional passenger transport, drawing on studies by 
International the Road Transport Union (IRU) and the European Transport Workers’ Federation (ETF). Source: 
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;  ETF  Report,  2018,  Driven 
to 
the  EU,  https://www.etf-europe.org/wp-
distraction?  Long-distance 
content/uploads/2018/09/ETF-report-on-woking-conditions-of-bus-and-coach-1.pdf. 
312 According to Eurostat data, around 99% of water transport businesses were classified as SMEs. 
313 Figures from Eurostat, confirmed by ECTAA. 

and  bus  drivers 

coach 

in 

116 

 
 
 
primary issue concerning air passengers’ rights revolves around the inconsistent application of 
Regulation 261/2004. 

As for problem 2 on multimodal passenger rights, 13 agreed or strongly agreed with the first 
problem statement, which concerns the issue that passengers are not protected by existing rights 
when switching between transport modes, while  4 disagreed or strongly  agreed.  Of these, 6 
SME carriers, 4 SME intermediaries and 1 company providing technology solutions for PRMs 
agreed or strongly agreed with the first problem identified, while 2 SME carriers disagreed or 
strongly disagreed. In turn, 8 out 13 SMEs agreed or strongly agreed with the second problem 
statement, of which 5 were SME carriers and 3 SME intermediaries.  

Regarding the objective identified for problem area 2, on ensuring an adequate framework of 
rules for the protection of passengers who experience travel disruptions when changing from 
one  transport  mode  to  another,  12  SMEs  agreed  or  strongly  agreed  with  the  first  objective 
identified, of which 5 were answers provided by SME carriers or terminal managers, 5 from 
SME intermediaries and 1 from a company providing technology solutions for PRMs. 4 SME 
intermediaries stated that there “must be a very clear definition of the three different categories 
and what that means in practice”. 

Out  of  11  SME  respondents  for  problem  area  3  on  intermediaries,  of  which  most  were 
intermediary ticket vendors, 5 agreed or strongly agreed with the problem identified, related to 
the fact that cash reimbursements are not always quick, and rules are unclear when flights were 
booked via an intermediary, while 5 disagreed or strongly disagreed and 1 provided no opinion. 
3 out of 5 SME ticket vendors replying agreed with the problem identified, while 1 disagreed 
and 1 strongly disagreed. 2 out of the 2 SME claim agencies strongly agreed with the problem 
identified. 

10  SMEs  agreed  or  strongly  agreed  with  the  objective  identified  in  the  OPC,  on  ensuring 
reimbursement of air passengers boking via an intermediary ticket vendor, whilst 1 strongly 
disagreed. 4 out of 5 intermediary SMEs replying strongly agreed with the objective identified 
for problem area 3, while 1 strongly disagreed. One intermediary SME which strongly agreed 
with  the  objective  identified  added  the  importance  to  ensure  timely  reimbursement  of 
passengers through travel intermediaries, and that carriers must have clear business-to-business 
obligations to refund ticket vendors within a set timeframe. 2 out of the 2 SME claim agencies 
agreed or strongly agreed with the first objective identified. In addition, one SME claim agency 
argued that passengers face unclear additional imposed by intermediary ticket vendors during 
purchases and often receive incomplete reimbursement.  

Regarding the OPC, SMEs mostly agreed with the problem statements identified. For instance, 
concerning  the  lack  of  reimbursement  in  seven  days  of  air  passengers  when  the  flight  is 
cancelled and the ticket was booked through an intermediary, 14 out of 29 SMEs fully agreed 
with  the  statement  that  “air  carriers  cannot  always  respect  the  obligation  to  reimburse 
passengers  within  seven  days  following  the  cancellation  when  the  flight was  booked  via  an 
intermediary ticket vendor”, whilst 5 fully disagreed. 7 out of the 10 SME carriers and terminal 
managers  agreed  or  fully  agreed  with  the  same  statement.  In  addition,  4  out  of  the  5  SME 
intermediaries  somewhat  agreed  or  fully  agreed  with  the  statement.  In  turn,  10  out  of  29 
stakeholders fully agreed with the statement that “intermediary ticket vendors are not obliged 
to  reimburse  passengers  who  booked  with  them  when  the  flight  was  cancelled  by  the  air 
carrier”, while 6 out of 29 agreed whilst 3 fully disagreed and 2 disagreed somewhat out of 29. 
Of which 4 out of 5 SME intermediaries somewhat agreed or fully agreed and 9 SME carriers 
or terminal managers somewhat agreed or fully agreed with the statement.  

117 

 
Additionally,  17  out  of  39  SMEs  somewhat  agreed  or  fully  agreed  with  the  statement  that 
passengers  are  not  protected  by  the  existing  passenger  rights  rules  when  switching  between 
transport modes (of which 10 are SME carriers and terminal managers), whilst 15 out of 39 
somewhat  disagreed  or  fully  disagreed.  On  the  other  hand,  20  out  of  40  fully  or  somewhat 
agreed with the statement that “passengers are not protected by the existing passenger rights 
rules  when  switching  between  different  transport  modes”,  whilst  15  out  of  40  disagreed 
somewhat  or  fully  disagreed,  of  which  12  SME  carriers  and  terminal  managers  somewhat 
agreed or fully agreed and 2 disagreed. Lastly, 25 out of 50 respondents somewhat agreed or 
fully agreed with the statement that the enforcement of passenger rights is not effective enough, 
whilst  16  out  of  50  somewhat  disagreed  or  fully  disagreed.  8  SME  carriers  and  terminal 
managers somewhat agreed or fully agreed with this statement and 2 disagreed.  

Step 3/4: Assessment of the impact on SMEs 

The following  paragraphs  outline the  economic impacts  expected to be borne by  SMEs.  As 
explained  in  step  1,  SMEs  account  for  95%  of  air  intermediaries,  85%  of  bus  and  coach 
operators  and  99%  of  waterborne  passenger  operators  affected  by  the  initiative.  Details  on 
calculations of impacts related to individual policy measures can be found in Annex 4. 

Options related to enforcement (problem area 1). Both PO 1.1 and PO 1.2 lead to an increase 
of the administrative and adjustment costs for SME carriers and of the adjustment costs for 
SME intermediaries, compared to the baseline. Administrative costs stem from policy measure 
PM A.2, while adjustment costs stem from policy measures PM A.2 and PM A.3 in PO 1.1 and 
PO 1.2. In addition, PM A.5 also results in adjustment costs for PO 1.2. 

For SME carriers, PO 1.2 shows higher costs than PO 1.1 in 2025 (EUR 17.8 million compared 
to EUR 13.5 million respectively), while in 2030 and 2050 the costs are similar for both options 
(EUR 4.4 million). This is because of PM A.5 (included only in PO 1.2) that requires carriers 
to better inform passenger about their rights. In terms of present value over 2025-2050, total 
costs for carriers are estimated at EUR 89.3 million in PO 1.1 and at EUR 93.6 million in PO 
1.2. The increase in administrative costs compared to the baseline is generated in both policy 
options by PM A.2 linked to reporting by SME carriers (EUR 80.1 million, expressed as present 
value over 2025-2050).  

The intermediary ticket vendors and tour operators bear one-off adjustment costs of EUR 13.6 
million in 2025. The tables below illustrate details about these costs. 

Table 143: Total recurrent and one-off costs for SMEs in the POs addressing problem area 1, expressed as 
present value over 2025-2050 relative to the baseline scenario, in million EUR (2021 prices) 

Carriers 
Administrative costs   
Adjustment costs   

Bus and coach operators  
Administrative costs   
Adjustment costs   
Waterborne transport operators 
Administrative costs   
Adjustment costs   

Intermediaries 
Adjustment costs   

118 

Difference to the Baseline 
PO 1.2 
PO 1.1 

89.27 
80.14 
9.14 
76.9 
69.0 
7.9 
12.4 
11.1 
1.3 
13.6 
13.6 

93.63 
80.14 
13.49 
80.6 
69.0 
11.6 
13.0 
11.1 
1.9 
13.6 
13.6 

 
 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

Table 144: Total recurrent and one-off costs for SMEs in the POs addressing problem area 1, in 2025, 2030 
and 2050 relative to the baseline scenario, in million EUR (2021 prices) 

Difference to the Baseline 

PO 1.1 
2030 

2025 

2050 

2025 

PO 1.2 
2030 

2050 

Carriers 
Administrative costs   
Adjustment costs   

Bus and coach operators  
Administrative costs   
Adjustment costs   
Waterborne transport operators 
Administrative costs   
Adjustment costs   

13.49 
4.35 
9.14 
11.62 
3.75 
7.87 
1.87 
0.60 
1.27 
13.64 
13.64 

4.35 
4.35 
0.00 
3.75 
3.75 
0.00 
0.60 
0.60 
0.00 
0.00 
0.00 

4.35 
4.35 
0.00 
3.75 
3.75 
0.00 
0.60 
0.60 
0.00 
0.00 
0.00 

17.84 
4.35 
13.49 
15.37 
3.75 
11.62 
2.48 
0.60 
1.87 
13.64 
13.64 

4.35 
4.35 
0.00 
3.75 
3.75 
0.00 
0.60 
0.60 
0.00 
0.00 
0.00 

4.35 
4.35 
0.00 
3.75 
3.75 
0.00 
0.60 
0.60 
0.00 
0.00 
0.00 

Intermediaries 
Adjustment costs   
Source: PWC, TIS and Steer (2023), Impact assessment support study 

Table  145: Recurrent and one-off costs for SMEs carriers in the POs addressing problem area 1, by policy 
measure, expressed as present value over 2025-2050 relative to the baseline scenario, in million EUR (2021 
prices) 

Difference to the Baseline 
PO 1.2 
PO 1.1 

Administrative costs   
PM A.2 

Bus and coach 
Waterborne 

Adjustment costs   
PM A.2 

Bus and coach 
Waterborne 

PM A.3 

Bus and coach 
Waterborne 

PM A.5 

Bus and coach 
Waterborne 

Net costs 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

80.14 
80.14 
69.01 
11.13 
9.14 
8.70 
7.50 
1.21 
0.44 
0.37 
0.06 

89.27 

80.14 
80.14 
69.01 
11.13 
13.49 
8.70 
7.50 
1.21 
0.44 
0.37 
0.06 
4.35 
3.75 
0.60 
93.63 

Table  146: Recurrent and one-off costs  for SMEs carriers in the POs addressing problem area 1, by policy 
measure, in 2025, 2030 and 2050 relative to the baseline scenario, in million EUR (2021 prices) 

Administrative costs   
PM A.2 

Bus and coach 
Waterborne 

Difference to the Baseline 

PO 1.1 
2030 

2025 

4.35 
4.35 
3.75 
0.60 

4.35 
4.35 
3.75 
0.60 

2050 

2025 

4.35 
4.35 
3.75 
0.60 

4.35 
4.35 
3.75 
0.60 

PO 1.2 
2030 

2050 

4.35 
4.35 
3.75 
0.60 

4.35 
4.35 
3.75 
0.60 

119 

 
  
 
  
  
  
  
Difference to the Baseline 

PO 1.1 
2030 

2025 

2050 

2025 

Adjustment costs   
PM A.2 

Bus and coach 
Waterborne 

PM A.3 

Bus and coach 
Waterborne 

PM A.5 

Bus and coach 
Waterborne 

0.00 

0.00 

9.14 
8.70 
7.50 
1.21 
0.44 
0.37 
0.06 

Net costs 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

13.49 

4.35 

4.35 

13.49 
8.70 
7.50 
1.21 
0.44 
0.37 
0.06 
4.35 
3.75 
0.60 
17.84 

PO 1.2 
2030 

2050 

0.00 

0.00 

4.35 

4.35 

Table 147: One-off costs for SMEs intermediaries in the POs addressing problem area 1, by policy measure, 
expressed as present value over 2025-2050 relative to the baseline scenario, in million EUR (2021 prices) 
Difference to the Baseline 
PO 1.2 
PO 1.1 

Adjustment costs   
PM A.3 
Net costs 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

13.64 
13.64 
13.64 

13.64 
13.64 
13.64 

Table 148: One-off costs for SMEs intermediaries in the POs addressing problem area 1, by policy measure, in 
2025, 2030 and 2050 relative to the baseline scenario, in million EUR (2021 prices) 

Difference to the Baseline 

PO 1.1 
2030 

2025 

2050 

2025 

PO 1.2 
2030 

2050 

Adjustment costs   
PM A.3 
Net costs 
Source: PWC, TIS and Steer (2023), Impact assessment support study 

13.64 
13.64 
13.64 

0.00 

0.00 

0.00 

0.00 

13.64 
13.64 
13.64 

0.00 

0.00 

0.00 

0.00 

The costs per SME carrier (for bus and coach operators and waterborne transport operators) are 
estimated at EUR 3,618 in 2025 and EUR 1,167 per year from 2026 onwards, while for SME 
intermediaries at EUR 117 in 2025. Considering the annual average turnover per SME (EUR 
2.1  million  per  bus  and  coach  operator  and  EUR  13.7  million  per  waterborne  transport 
operator314),  the  total  cost  per  bus  and  coach  operator  is  estimated  at  less  than  0.2%  of  the 
turnover in 2025 (including also one-off costs) and less than 0.1% of the turnover post-2025, 
while the cost per waterborne transport operator is estimated at less than 0.1% of the turnover 
for all periods. 

Given  that  these  costs  are  relatively  low  for  the  SMEs  and  that  an  SME  exemption  would 
exclude  a  significant  part  of  the  targeted  carriers  and  intermediaries  from  the  obligations  – 
decreasing the policy measure’s effectiveness – no SME exemption is proposed for any of the 
policy measures included in PO 1.1 and PO 1.2. 

314 Eurostat. 

120 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
 
Options related to multimodal passenger rights (problem area 2). All three policy options PO 
2.1, PO 2.2 and PO 2.3 result in an increase in adjustment costs for carriers and intermediaries 
SMEs, compared to the baseline. These costs stem from policy measures PM B.1 and PM B.7 
which are common to all policy options, and from PM B.3 (a or b) and PM B.4 (a or b). PM 
B.1 and PM B.7 are expected to have an impact on 270 SMEs, PM B.3a and PM B.3b on 128 
SMEs, and PM B.4a and PM B.4b on 263 SMEs. 

Carriers bear the largest share of the total costs. PO 2.3 shows the highest increase in costs for 
carriers relative to the baseline (EUR 11.25 million, of which EUR 11.23 million for bus and 
coach operators and EUR 0.02 million for waterborne transport operators), followed by PO 2.2 
(EUR 10.26 million, of which EUR 10.24 million for bus and coach operators and EUR 0.02 
million for waterborne transport operators) and PO 2.1 (EUR 10.2 million, of which EUR 10.18 
million for bus and coach operators and EUR 0.02 million for waterborne transport operators), 
expressed as present value over 2025-2050. The difference is due to PM B.3b included in PO 
2.3, as opposed to PM B.3a included in PO 2.1 and PO 2.2. The reason is that under PM B.3b 
passengers  have  a  right  to  conclude  alternatives  contracts  where  a  carrier  does  not  make 
provision for the continuation of the journey, in addition to the more limited rights foreseen by 
PM B.3a. For intermediaries, PO 2.3 is also the most costly option relative to the baseline (EUR 
0.52 million), followed closely by PO 2.2 (EUR 0.36 million) and PO 2.1 (EUR 0.31 million), 
expressed as present value over 2025-2050.  

At the same time, SMEs would benefit of significant hassle costs savings that outweigh the 
costs. Hassle costs savings for carriers are estimated at EUR 29.9 million and for intermediaries 
at EUR 22.8 million in PO 2.1, PO 2.2 and PO 2.3. Thus, all policy options result in net benefits 
for SME carriers (EUR  19.7 million in  PO 2.1, EUR 19.6 million  in PO 2.2 and EUR 18.6 
million in PO 2.3) and intermediaries (around EUR 22.5 million in PO 2.1 and PO 2.2 and EUR 
22.3 million in PO 2.3), expressed as present value over 2025-2050 relative to the baseline.   

The  tables  below  illustrate  details  about  the  costs  and  costs  savings.  In  addition,  Annex  4 
provides detailed explanations of the costs and costs savings corresponding to each measure. It 
should be noted that for hassle costs savings presented in this section a conservative approach 
has been used (lower bound estimates).  

Table 149: Total costs and costs savings for SMEs in the POs addressing problem area 2, expressed as present 
value over 2025-2050 relative to the baseline scenario, in million EUR (2021 prices) 

Difference to the Baseline 
PO 2.2 

PO 2.3 

PO 2.1 

Carriers (net benefits) 
Adjustment costs   
Hassle costs savings* 

Bus and coach operators (net benefits) 
Adjustment costs   
Hassle costs savings* 
Waterborne transport operators (net benefits) 

Adjustment costs   
Hassle costs savings* 

Intermediaries (net benefits) 
Adjustment costs   
Hassle costs savings* 

121 

19.67 
10.20 
29.87 
18.52 
10.18 
28.70 
1.15 

0.02 
1.17 
22.53 
0.31 
22.84 

19.60 
10.26 
29.87 
18.45 
10.24 
28.70 
1.15 

0.02 
1.17 
22.48 
0.36 
22.84 

18.62 
11.25 
29.87 
17.47 
11.23 
28.70 
1.15 

0.02 
1.17 
22.32 
0.52 
22.84 

 
 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for lower bound estimates. 

Table 150: Total costs and costs savings for SMEs in the POs addressing problem area 2, in 2025, 2030 and 
2050 relative to the baseline scenario, in million EUR (2021 prices) 

PO 2.1 

Difference to the Baseline 
PO 2.2 

2025 

0.73 
0.46 
1.19 
0.69 

0.45 
1.14 
0.04 

2030  2050 
0.95 
1.01 
0.74 
0.48 
1.69 
1.49 
0.89 
0.95 

0.48 
1.43 
0.06 

0.74 
1.62 
0.07 

2025 

0.66 
0.53 
1.19 
0.62 

0.52 
1.14 
0.04 

2030  2050 
0.95 
1.01 
0.74 
0.48 
1.69 
1.49 
0.89 
0.95 

0.48 
1.43 
0.06 

0.74 
1.62 
0.07 

PO 2.3 

2025 

0.62 
0.57 
1.19 
0.58 

0.56 
1.14 
0.04 

2030  2050 
0.88 
0.96 
0.81 
0.53 
1.69 
1.49 
0.82 
0.90 

0.53 
1.43 
0.06 

0.81 
1.62 
0.07 

Carriers (net benefits) 
Adjustment costs   
Hassle costs savings* 

Bus and coach operators (net 
benefits) 
Adjustment costs   
Hassle costs savings* 
Waterborne transport 
operators (net benefits) 
Adjustment costs   
Hassle costs savings* 

0.00 
0.07 
1.28 
Intermediaries (net benefits) 
0.01 
Adjustment costs   
1.29 
Hassle costs savings* 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for lower bound estimates. 

0.00 
0.06 
1.12 
0.01 
1.14 

0.00 
0.07 
1.28 
0.01 
1.29 

0.00 
0.06 
1.12 
0.01 
1.14 

0.00 
0.05 
0.79 
0.12 
0.91 

0.00 
0.07 
1.28 
0.01 
1.29 

0.01 
0.05 
0.73 
0.18 
0.91 

0.00 
0.06 
1.12 
0.01 
1.14 

0.01 
0.05 
0.62 
0.29 
0.91 

Table 151: Costs and costs savings for SMEs carriers in the POs addressing problem area 2, by policy measure, 
expressed as present value over 2025-2050 relative to the baseline scenario, in million EUR (2021 prices) 
Difference to the Baseline 
PO 2.2 

PO 2.1 

PO 2.3 

Adjustment costs  
PM B.1 

Bus and coach 
Waterborne 

PM B.3a 

Bus and coach 
Waterborne 

PM B.3b 

Bus and coach 
Waterborne 

PM B.4a 

Bus and coach 
Waterborne 

PM B.4b 

Bus and coach 
Waterborne 

PM B.7 

Bus and coach 
Waterborne 

Hassle costs savings* 
PM B.7 

Bus and coach 
Waterborne 

Net benefits 

10.20 
0.07 
0.07 
0.00 
9.80 
9.79 
0.00 

0.33 
0.32 
0.01 
29.87 
29.87 
28.70 
1.17 
19.67 

10.26 
0.07 
0.07 
0.00 
9.80 
9.79 
0.00 

0.07 
0.07 
0.00 

0.33 
0.32 
0.01 
29.87 
29.87 
28.70 
1.17 
19.60 

11.25 
0.07 
0.07 
0.00 

10.78 
10.78 
0.00 

0.07 
0.07 
0.00 
0.33 
0.32 
0.01 
29.87 
29.87 
28.70 
1.17 
18.62 

122 

 
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Difference to the Baseline 
PO 2.2 

PO 2.3 

PO 2.1 

Bus and coach 
Waterborne 

17.47 
1.15 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for lower bound estimates. 

18.52 
1.15 

18.45 
1.15 

Table 152: Costs and costs savings for SMEs carriers in the POs addressing problem area 2, by policy measure, 
in 2025, 2030 and 2050 relative to the baseline scenario, in million EUR (2021 prices) 

PO 2.1 

Difference to the Baseline 
PO 2.2 

PO 2.3 

2025 

2030  2050 
0.74 
0.48 

2025 

2030  2050 
0.74 
0.48 

2025 

2030  2050 
0.81 
0.53 

0.46 
0.07    
0.07    
0.00    
0.37 
0.37 
0.00    

0.46 
0.46 

0.72 
0.72 

0.53 
0.07    
0.07    
0.00    
0.37 
0.37 
0.00    

0.07    
0.07    
0.00    

0.46 
0.46 

0.72    
0.72    

0.51 
0.51 

0.79 
0.79 

0.41 
0.41 
0.00    

Adjustment costs  
PM B.1 

Bus and coach 
Waterborne 

PM B.3a 

Bus and coach 
Waterborne 

PM B.3b 

Bus and coach 
Waterborne 

PM B.4a 

Bus and coach 
Waterborne 

PM B.4b 

Bus and coach 
Waterborne 

PM B.7 

Bus and coach 
Waterborne 

Hassle costs savings* 
PM B.7 

0.02 
0.02 
0.00 
1.69 
1.69 
1.62 
0.07 
0.88 
0.82 
0.07 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for lower bound estimates. 

0.02 
0.02 
0.00 
1.49 
1.49 
1.43 
0.06 
1.01 
0.95 
0.06 

0.02 
0.02 
0.00 
1.69 
1.69 
1.62 
0.07 
0.95 
0.89 
0.07 

0.02 
0.02 
0.00 
1.49 
1.49 
1.43 
0.06 
0.96 
0.90 
0.06 

0.02 
0.02 
0.00 
1.19 
1.19 
1.14 
0.05 
0.73 
0.69 
0.04 

0.02 
0.02 
0.00 
1.19 
1.19 
1.14 
0.05 
0.66 
0.62 
0.04 

0.02 
0.02 
0.00 
1.49 
1.49 
1.43 
0.06 
1.01 
0.95 
0.06 

0.02 
0.02 
0.00 
1.69 
1.69 
1.62 
0.07 
0.95 
0.89 
0.07 

Bus and coach 
Waterborne 

Bus and coach 
Waterborne 

Net benefits 

Table 153: Costs and costs savings for SMEs intermediaries in the POs addressing problem area 2, by policy 
measure, expressed as present value over 2025-2050 relative to the baseline scenario, in million EUR (2021 
prices) 

Difference to the Baseline 
PO 2.2 

PO 2.3 

PO 2.1 

Adjustment costs  
PM B.1 
PM B.3a 
PM B.3b 
PM B.4a 
PM B.4b 
PM B.7 

0.31 
0.05 

0.36 
0.05 

0.05 

0.25 

0.25 

0.52 
0.05 

0.11 

0.11 
0.25 

123 

0.57 
0.07    
0.07    
0.00    

0.07    
0.07    
0.00    
0.02 
0.02 
0.00 
1.19 
1.19 
1.14 
0.05 
0.62 
0.58 
0.04 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
Difference to the Baseline 
PO 2.2 

PO 2.3 

PO 2.1 

22.84 
Hassle costs savings* 
22.84 
PM B.7 
Net benefits 
22.32 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for lower bound estimates. 

22.84 
22.84 
22.53 

22.84 
22.84 
22.48 

Table 154: Costs and costs savings for SMEs intermediaries in the POs addressing problem area 2, by policy 
measure, in 2025, 2030 and 2050 relative to the baseline scenario, in million EUR (2021 prices) 

PO 2.1 

Difference to the Baseline 
PO 2.2 

PO 2.3 

2025 

2030  2050 
0.01 
0.01 

2025 

2030  2050 
0.01 
0.01 

2025 

2030  2050 
0.01 
0.01 

0.29 
0.05    

0.12 
0.05    
0.05    

0.18 
0.05    
0.05    

Adjustment costs  
PM B.1 
PM B.3a 
PM B.3b 
PM B.4a 
PM B.4b 
0.01 
PM B.7 
1.29 
Hassle costs savings* 
1.29 
PM B.7 
Net benefits 
1.28 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: * stands for lower bound estimates. 

0.11    
0.01 
0.91 
0.91 
0.62 

0.01 
1.14 
1.14 
1.12 

0.01 
1.29 
1.29 
1.28 

0.01 
1.14 
1.14 
1.12 

0.01 
0.91 
0.91 
0.79 

0.01 
1.29 
1.29 
1.28 

0.01 
0.91 
0.91 
0.73 

0.01 
1.14 
1.14 
1.12 

0.11    

0.05    

Options  related  to  intermediaries  (problem  area  3).  SME  intermediaries  consist  mostly  of 
brick and mortar travel agents. All three policy options lead to identical one-off administrative 
costs for the 116,850 SME intermediary ticket vendors in 2025, amounting to EUR 54.6 million. 
These  costs  are  due  to  PM  C.1  (a,  b  or  c)  which  obliges  them  to  inform  passengers  on  the 
reimbursement  process.  Per  SME  intermediary,  the  administrative  costs  are  estimated  to  be 
limited, at EUR 467 in 2025. 

These costs are largely overcompensated by administrative costs savings in PO 3.3 (EUR 7.2 
million in 2025, EUR 7.8 million in 2030 and EUR 10.1 million in 2050) and especially in PO 
3.1  (EUR  36  million  in  2025,  EUR  39.2  million  in  2030  and  EUR  50.7  million  in  2050). 
Expressed as present value over 2025-2050, the total cost savings relative to the baseline are 
estimated at EUR 157.4 million in PO 3.3 and EUR 787 million in PO 3.1. The administrative 
cost  savings  are  explained  by  the  fact  that  intermediaries  would  no  longer  handle 
reimbursement requests to the same extent (PM C1.a under PO 3.1 and PM C1.c under PO 3.3).  

The tables below illustrate details about the costs and costs savings. 

Table 155: Total costs and costs savings for SMEs in the POs addressing problem area 3, expressed as present 
value over 2025-2050 relative to the baseline scenario, in million EUR (2021 prices) 

Difference to the Baseline 
PO 3.2 

PO 3.3 

PO 3.1 

Intermediaries 
54.55 
Administrative costs   
157.41 
Administrative costs savings 
Net costs savings 
102.86 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: negative values stand for net costs. 

54.55 
787.04 
732.49 

54.55 
0.00 
-54.55 

124 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
Table 156: Total costs and costs savings for SMEs in the POs addressing problem area 3, in 2025, 2030 and 
2050 relative to the baseline scenario, in million EUR (2021 prices) 

PO 3.1 
2030 

2025 

Difference to the Baseline 
PO 3.2 

PO 3.3 

2050 

2025 

2030  2050 

2025 

2030  2050 

Intermediaries 
0.00 
0.00 
Administrative costs   
7.84  10.13 
Administrative costs savings 
Net costs savings 
7.84  10.13 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: negative values stand for net costs. 

54.55 
0.00 
0.00 
35.95  39.21  50.65 
-18.60  39.21  50.65 

54.55 
7.19 
-47.36 

54.55 
0.00 
-54.55 

0.00 
0.00 
0.00 

0.00 
0.00 
0.00 

Table 157: Costs and costs savings for SMEs intermediaries in the POs addressing problem area 3, by policy 
measure, expressed as present value over 2025-2050 relative to the baseline scenario, in million EUR (2021 
prices) 

Difference to the Baseline 
PO 3.2 

PO 3.3 

PO 3.1 

54.55 

54.55 
54.55    

Administrative costs  
PM C.1a 
PM C.1b 
PM C.1c 
Administrative costs savings 
PM C.1a 
PM C.1b 
157.41 
PM C.1c 
Net costs savings 
102.86 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: negative values stand for net costs. 

787.04 
787.04    

54.55 
157.41 

54.55    

732.49 

-54.55 

54.55 

0.00 

Table 158: Costs and costs savings for SMEs intermediaries in the POs addressing problem area 3, by policy 
measure, in 2025, 2030 and 2050 relative to the baseline scenario, in million EUR (2021 prices) 

Difference to the Baseline 
PO 3.2 

PO 3.3 

PO 3.1 
2030 
0.00 

2025 
54.55 
54.55    

2050 
0.00 

2025 
54.55 

2030  2050 
0.00 
0.00 

2025 
54.55 

2030  2050 
0.00 
0.00 

Administrative costs  
PM C.1a 
PM C.1b 
PM C.1c 
Administrative costs savings 
PM C.1a 
PM C.1b 
7.84  10.13 
PM C.1c 
Net costs savings 
7.84  10.13 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: negative values stand for net costs. 

35.95  39.21  50.65 
35.95  39.21  50.65    

-18.60  39.21  50.65 

54.55    
7.19 

7.19 
-47.36 

7.84  10.13 

54.55    

-54.55 

0.00 

0.00 

0.00 

0.00 

0.00 

However, intermediaries may incur indirect costs under PO 3.1, and to a lesser degree in PO 
3.2 and 3.3 for the share where the reimbursement will be conducted without their involvement, 
as a result of no longer being able to offer the processing of reimbursements to their customers 
(and to airlines, as part of their agreements with them) as part of their service package. It may 
also damage to a certain extent their business model of maintaining an exclusive relationship 
with  their  customers.  No  data  on  this  is  available,  but  during  the  stakeholder  consultation, 
intermediaries and their associations have pointed out that they want to continue processing the 
reimbursements of their customers. 

125 

 
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Impact on SMEs in the package of preferred policy options. The total costs for SMEs in the 
package of preferred policy options are estimated at EUR 86.7 million in 2025, EUR 4.8 million 
in 2030 and EUR 5.1 million in 2050 relative to the baseline. The benefits in terms of hassle 
costs savings are estimated at EUR 2.1 million in 2025, EUR 2.6 million in 2030 and EUR 3 
million in 2050. 

Table 159: Costs and costs savings for SMEs in the package of preferred policy options, in 2025, 2030 and 2050 
relative to the baseline scenario, in million EUR (2021 prices) 

Preferred package of options (difference to the 
baseline) 
2030 

2025 

2050 

Bus and coach operators (net costs) 
2.9 
Administrative costs   
3.7 
Adjustment costs   
0.7 
Hassle costs savings 
1.6 
Waterborne transport operators (net costs) 
0.5 
Administrative costs   
0.6 
Adjustment costs   
0.0 
Hassle costs savings 
0.07 
Intermediaries (net costs) 
-1.3 
Administrative costs   
0.0 
Adjustment costs   
0.0 
Hassle costs savings 
1.3 
Total costs 
5.1 
Total benefits 
3.0 
Net costs 
2.1 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: negative values for intermediaries 
represent net benefits. 

14.7 
3.7 
12.1 
1.1 
2.4 
0.6 
1.9 
0.05 
67.5 
54.6 
13.8 
0.9 
86.7 
2.1 
84.6 

2.8 
3.7 
0.5 
1.4 
0.5 
0.6 
0.0 
0.06 
-1.1 
0.0 
0.0 
1.1 
4.8 
2.6 
2.2 

When considering the total number of SMEs affected by the policy options, the net costs per 
SME for the bus and coach and waterborne sector are limited. They are estimated at around 
EUR 5,000 per operator in 2025 (including also one-off costs) and between EUR 900 and EUR 
1,100 per operator post-2025 relative to the baseline. For intermediaries, the costs are estimated 
at EUR 600 in 2025. Post-2025 SME intermediaries are estimated to incur net benefits. 

Table 160: Costs per SME in the package of preferred policy options in 2025, 2030 and 2050 relative to the 
baseline scenario, in EUR (2021 prices) 

Preferred package of options (difference to the 
baseline) 

2025 

2030 

2050 

Bus and coach operators (net costs) 
891 
Waterborne transport operators (net costs) 
1,041 
Intermediaries (net costs) 
-11 
Source: PWC, TIS and Steer (2023), Impact assessment support study; Note: negative values for intermediaries 
represent net benefits. 

4,591 
4,709 
577 

872 
1,056 
-10 

Considering the annual average turnover per SME (EUR 2.1 million per bus and coach operator 
and EUR 13.7 million  per waterborne transport  operator315), the net  cost  per bus and coach 
operator is estimated at 0.2% of the turnover in 2025 (including also one-off costs) and less 
than  0.1%  of  the  turnover  post-2025,  while  the  cost  per  waterborne  transport  operator  is 
estimated at less than 0.1% of the turnover for all periods. 

315 Source: Eurostat. 

126 

 
  
  
 
Step 4/4: Minimising negative impacts on SMEs 

Under problem area 1, both PO 1.1 and PO 1.2 are expected to result in additional costs for 
SMEs. It should however be noted that as explained above these costs are limited. Nonetheless, 
impacts on SMEs can be minimised by ensuring flexibility in the implementation of certain 
measures  that  have  a  greater  impact  on  SME  companies,  such  as  PM  A.2  and  PM  A.7.  In 
addition, it is important to ensure that the impact on the turnover and staff turnover of SMEs 
are  appropriately  monitored  throughout  the  implementation  period.  For  this  purpose,  DG 
GROW’s  SME  panel  could  be  used  about  three  years  after  the  Regulation’s  entry  into 
application. 

Regarding problem area 2, all options proposed (i.e. PO 2.1, PO 2.2 and PO 2.3) result in net 
benefits for SME intermediaries and SME carriers. It should be noted that in order to reduce 
the burden on SMEs, exemptions for SMEs are already considered under PM B.2 (obligation 
to provide real-time information to passengers). 

Based on the assessment of the policy options addressing problem area 3 (PO 3.1, PO 3.2 and 
PO 3.3), SME intermediary ticket vendors may incur net costs in PO 3.2 and net benefits in PO 
3.1 and PO 3.3. Per SME intermediary, the net costs in PO 3.2 are however estimated to be 
limited, at EUR 467 in 2025. However, as stated above, intermediaries may incur indirect costs 
under PO 3.1, and to a lesser degree under 3.3 for the share where the reimbursement will be 
conducted without their involvement, as a result of no longer being able to offer the processing 
of reimbursements to their customers (and to airlines, as part of their agreements with them) as 
part  of  their  service  package.  Under  these  options,  which  are  not  proposed  as  the  preferred 
options,  the  SMEs’  business  model  of  maintaining  an  exclusive  relationship  with  their 
customers  may  to  a  certain  extent  be  damaged.  The  preferred  option  3.2  gives  SME  air 
intermediaries an official role in the reimbursement process, which is difficult to quantify as 
benefits but may outweigh the limited costs.  

In order to minimise the economic burden for SMEs, it is necessary to consider monitoring the 
impact on SMEs. As explained above, DG GROW’s SME panel could be used for this purpose 
about three years after the Regulation’s entry into application. 

127 

 
 
 
 
 
 
ANNEX 9: BACKGROUND ON THE DEVELOPMENT OF EU PASSENGER RIGHTS 

This annex presents background information on the development of EU passenger rights. 

Political context 

EU passenger rights apply to more than 13 billion annual passenger travels in the EU by either 
air, rail, bus and coach or waterborne transport316 . In this context, the protection of passengers 
has become a cornerstone of the EU transport policy.   

Passenger rights are at the heart of the EU transport and consumer policy and have become a 
flagship initiative of the EU; it is worth noting that the EU is the only area in the world where 
passengers using collective modes of transport are protected by a full set of rights prior, during 
and after their journey.  

Despite  the  substantial  progress  made  in  this  area  since  2004  in  view  of  the  ten  core  rights 
identified by the Commission in its Communication on a European vision for passengers of 
2011, major challenges  still remain to  be tackled. This  is  why this new initiative is  a major 
additional step to the long-term vision of passenger rights.  

The ten core passenger rights highlighted in the 2011 Communication are presented below: 

Box 1 – The ten EU core passenger rights 
Passenger  rights  are  based  on  three  cornerstones:  non-discrimination;  accurate,  timely  and 
accessible information; immediate and proportionate assistance. The following ten rights that 
stem from these principles form the core of EU passenger rights: 
(1) Right to non-discrimination in access to transport 
(2) Right to mobility: accessibility and assistance at no additional cost for disabled passengers 
and passengers with reduced mobility (PRM) 
(3) Right to information before purchase and at the various stages of travel, notably in case of 
disruption 
(4) Right to renounce travelling (reimbursement of the full cost of the ticket) when the trip is 
not carried out as planned 
(5)  Right  to  the  fulfilment  of  the  transport  contract  in  case  of  disruption  (rerouting  and 
rebooking) 
(6) Right to get assistance in case of long delay at departure or at connecting points 
(7) Right to compensation under certain circumstances 
(8) Right to carrier liability towards passengers and their baggage 
(9) Right to a quick and accessible system of complaint handling 
(10) Right to full application and effective enforcement of EU law 
Source: COM/2011/898 final. 

These core rights contribute to a level playing field for transport operators within and across 
modes, through creating a European standard for passenger protection.  

318 See Annex 4, section 2.2. 

128 

 
 
 
 
Legal context 

The  EU  framework  on  passenger  rights  consists  of  five317  Regulations  on  passenger  rights 
addressing all passenger transport modes:  

-  Regulation  (EC)  No  261/2004  establishing  common  rules  on  compensation  and 
assistance  to  passengers  in  the  event  of  denied  boarding  and  of  cancellation  or  long 
delay of flights; 

-  Regulation (EC) No 1107/2006 concerning the rights of disabled persons and persons 

with reduced mobility (PRM) when travelling by air; 

-  Regulation (EC) No 1371/2007 on rail passengers’ rights and obligations318 , which is 
repealed by Regulation (EU) No 2021/782 on rail passengers’ rights and obligations, as 
of 7 June 2023 onwards; 

-  Regulation (EU) No 1177/2010 concerning the rights of passengers when travelling by 

sea and inland waterway; 

-  Regulation  (EU)  No  181/2011  concerning  the  rights  of  passengers  in  bus  and  coach 

transport. 

Due to specific operational field requirements and the magnitude of damages on passengers in 
the  event  of  disruptions,  the  Regulations  differ  per  mode  e.g.  regarding  the  scope  of  the 
transport services covered, financial compensations in case of disruptions, how information, 
assistance and care has to be provided to passengers, the rules for PRM, but they have all similar 
rules on enforcement: Member States have to set up national enforcement bodies (e.g. leaving 
it  to  the  Member  State  whether  these  bodies  can  decide  on  individual  complaints  between 
passengers and operators) and Member States set the rules for penalties.319 

As regards air passenger rights, Regulation (EC) 261/2004 applies to passengers departing 
from an airport located in the territory of an EU country to which the EU treaties apply; and to 
passengers departing from an airport located in a non-EU country to an airport situated in the 
territory of an EU country to which the EC treaties apply if the operating air carrier of the flight 
is an EU carrier. It establishes passengers’ rights if they are denied boarding against their will; 
their  flight  is  delayed;  or  their  flight  is  cancelled,  on  condition  that  the  passengers  have  a 
confirmed reservation on the flight concerned and, except in the case of cancellation, present 
themselves in time for check-in. It does not apply to passengers travelling free of charge or at 
a  reduced  fare  not  available  directly  or  indirectly  to  the  public.  While  many  aspects  of  the 
Regulation have been clarified over the years by the Court of Justice of the EU, such as the 
exact scope of the Regulation and the notion of 'extraordinary circumstances’, the enforcement 
can  still  be  improved,  notably  the  role  of  NEBs,  and  the  right  to  information  of  passengers 
strengthened. In addition, in order to ensure that persons with disabilities and persons with 
reduced  mobility  could  use  air  transport  similar  to  other  citizens,  Regulation  (EC)  No 
1107/2006  introduced  the  prohibition  of  discrimination  based  on  disability  (notably,  PRM 
cannot  be  denied  transported  because  of  their  disability)  and  the  right  of  assistance  free  of 
charge in order to be able to use air transport.  

The rights of rail passengers are ensured by Regulation (EU) 2021/782, which aims to provide 
significantly improved protection to  rail passengers in  the event  of travel disruptions and to 
respond better to the needs of PRM. This Regulation builds on Regulation (EC) No 1371/2007, 

317 See the list of other relevant legislation at the end of this document. 
318 Recast into Regulation (EU) No 2021/782, which will apply from 7 June 2023 onwards. 
319 Member States shall lay down the rules on penalties applicable to infringements and shall take all measures 
necessary to ensure that they are implemented. The penalties provided for shall be “effective, proportionate and 
dissuasive”. 

129 

 
 
 
 
which  initially  established  the  rights  and  obligations  for  rail  passengers.  The  Regulation 
concerns all rail journeys and services provided under licence by one or more rail undertakings 
under  Directive  2012/34/EU.  Under  the  Regulation,  passengers  should  be  given  clear  and 
accessible  information  before  and  during  the  journey.  It  also  sets  rules  for  assistance  and 
compensation to passengers so PRM can travel in a way that is comparable to other citizens. In 
addition, it defines procedures for complaint-handling and defines the need for enforcement by 
Member  States.  Regulation  (EU)  2021/782  contains  a  number  of  new  and  improved  rules 
compared to its predecessor, in particular with respect to the provision of real-time information 
to passengers on disruptions, the carriage of bicycles on trains and the right to self-re-routing, 
and  provides  clarity  with  regard  to  cancellations,  delays  and  missed  connections  due  to 
extraordinary circumstances.320 

As  regards  waterborne  passenger  rights,  Regulation  (EU)  No  1177/2010  applies  to 
passengers on a passenger service where the port of embarkation is situated in the territory of a 
Member State or, in the case of services departing from outside the territory of a Member State 
by a Union carrier, in the port of disembarkation. The Regulation ensures rights for PRM and 
obligations in this regard to carriers and port terminals, ensures assistance in the event of travel 
cancellations and delays, sets minimum quality standards and defines information obligations. 
The Regulation is enforced by the Member States via their NEBs, who every other year has to 
report on their compliance. However, as only one in a million passengers makes a complaint to 
the National Enforcement Bodies, many NEBs seem to not have much to report. The Regulation 
was evaluated in December 2021, which showed that the Regulation has ensured that an equal 
level of rights are benefitted from across the EU. It however also showed that there is room for 
improvement when it comes to clarification of the Regulation itself321, the rights it grants, but 
also  implementation,  and  monitoring  and  enforcement  by  Member  States.  The  Commission 
intends  to  further  investigate  the  findings  from  the  evaluation  with  stakeholders  and  NEBs 
throughout 2023 and 2024. 

As  regards  bus  and  coach  passenger  rights,  Regulation  (EU)  No  181/2011  applies  to 
passengers travelling with regular services, national and cross-border, by bus or coach, where 
the boarding or alighting point of the passengers is situated in the territory of a Member State 
and where the scheduled distance of the service is 250 km or more. Passengers travelling on 
only a part of such a long-distance service are also covered since there is no requirement in the 
text for the passenger to have travelled on the entire service. The Regulation provides for a set 
of basic passenger rights (for example non-discriminatory transport conditions including tariffs) 
and extended passenger rights, for instance a right to compensation and assistance in the event 
of an accident. The 2021 evaluation of the Regulation demonstrated several issues undermining 
its  effectiveness.  The  Commission  services  are  therefore  conducting  a  fact-finding  study  to 
gather more evidence on the current level of protection of passengers in bus and coach transport 
for schedules services of less than 250 km, to find solutions to identified issues or legal gaps 
such as the absence of an explicit reference to rights in case of delays during the journey and 
travellers  feel  on  arrival,  to  assess  the  bus  and  coach  market  evolution  and  to  identify  the 
concerns of the relevant stakeholders in order to prepare possible new rules for passenger rights 
in bus and coach transport. 

As the passenger rights Regulations have been developed at different times and have different 
specificities,  any  new  addition  to  these  will  have  to  carefully  take  into  consideration  the 

320 Overview of the new rules Rail passenger rights FAQ document.  
321 The judgment in case C-570/19 of the Court of Justice of the European Union (Irish Ferries) provided some 
clarifications in the meantime, in particular regarding the notion of extraordinary circumstances or re-routing under 
comparable conditions. 

130 

 
 
different aspects of each Regulation. Here is particularly the new Rail Regulation, which has 
recently been amended as well as the 2013 Commission amending proposal for Air passenger 
rights. This of course interacts with multimodality where there so far are no rules, other than a 
rule proposed in the 2013 proposal for Air where any single ticket that is together with an air 
ticket is to have the air rules apply. Below is a representation of how the three different problems 
addressed in this impact assessment apply to the different existing Regulations as well as the 
proposed ones or those underway. 

Figure 10 - Representation of the initiatives impact on the different existing modes 

State of play  

In recent years, a number of analyses322 on the protection of passenger rights have identified 
that  there  are  significant  challenges  for  the  protection  passengers:  passengers  are  often  not 
aware of their rights, as shown by the Eurobarometer on Passenger rights of 2020, they have 
difficulties asserting them in case of disruption, while the enforcement of passenger rights is 
set by national law which leads to different ways of enforcement. A minority of passengers feel 
that they are well-informed about their rights by transport companies before travelling: 40% for 
air travel, 29% for ship or ferry journeys, 26% for rail and in coach services. In general terms, 
only 22% of EU citizens say they have read, heard or seen information about passenger rights 
in the last 12 months.  

The Commission’s proposal for the revision of Regulation (EC) No 261/2004 on air passenger 
rights, adopted in 2013, has since been on the table of the co-legislators. The objectives of this 
proposal are to ensure an effective and consistent enforcement, to better take into account the 
financial capacities of the air carriers, to ensure better enforcement with regard to mishandled 
baggage and to adapt the liability limites in accordance to general prie inflation.  The European 
Parliament  adopted  its  position  in  first  reading  in  2014  and  Transport  Committee  of  the 
European Parliament confirmed it as its basis to enter into inter-institutional negotiations on 24 
September 2019, but the deliberation in Council is still pending. This file remains a priority 
pending file for the Commission for 2023323 and has been a common legislative priority for all 
three EU institutions for 2023 and 2024324. 

322 Studies on passenger rights: https://transport.ec.europa.eu/transport-themes/passenger-rights/passenger-rights-
studies_en. 
323 Commission Work Programme 2023 Annex III Point 6. 
324 See https://oeil.secure.europarl.europa.eu/oeil/popups/thematicnote.do?id=41380&l=en:   
The  three  EU  institutions  established  common  legislative  priorities  for  2023  and  2024,  to  which  they  want  to 
ensure  substantial  progress.  The  list  of  procedure  files  refers  also  to  the  2013  proposal  (Joint  Declaration  of 
17.02.2023). 

131 

 
  
 
Several reports and evaluations have also contributed to the understanding of the problems and 
their scale when it comes to the current passenger rights.  

In its Special Report on passenger rights in 2018325, the European Court of Auditors (ECA) 
recommended  further  harmonisation  and  simplification  of  the  EU  framework  on  passenger 
rights.  More  recently,  in  June  2021,  the  ECA  issued  another  Special  Report  on  the 
implementation of air passenger rights during the COVID-19 pandemic326, calling for better 
enforcement and protection of air passenger rights, but asked also to assess this for the other 
modes of transport.  

The study on the ‘Current level of protection of Air Passenger Rights in the EU (completed 
in January 2020) confirmed that the Commission’s 2013 proposal was welcome by stakeholders 
but  identified  a  series  of  problems  and  proposed  suggestions  as  to  address  them.  The  study 
shows that the need for reform has become even more urgent since 2013. For passengers it is 
still rather difficult to enforce their rights (due to the complexity of the regulatory setting and 
the  lack  of  information),  and  for  airlines  the  burden  has  increased  (due  to  increasing  claim 
rates).  Passengers’  priorities  have  been  identified  are  being  as  follows,  from  more  to  less 
important: care and assistance to be provided in the event of travel disruption; re-routing to be 
offered so that passengers may arrive at their destination as soon as possible; and reimbursement 
and/or compensation to be paid, where relevant. 

In line with the above ECA recommendations, the Commission performed three evaluations of 
the regulatory framework for air PRM327, waterborne328 and bus and coach329 passenger rights 
in 2021. The three evaluations show that the PR introduced especially a coherent level of rights 
for ship and bus passengers as well as air PRM throughout the EU, resulting in better protection; 
they  also  highlight  that  there  are  still  gaps  to  be  closed  as  well  as  some  rules  which  need 
clarification. 

The evaluation of Regulation (EC) No 1107/2006 on air PRM330 showed that the Regulation 
effectively protects PRM against non-discrimination in air travel. Moreover, the free assistance 
they  receive  gives  them  more  comparable  opportunities  to  use  air  transport  than  before  the 
adoption of the Regulation. Generally, airports and airlines acknowledge the necessity of this 
Regulation and have made considerable efforts to implement it. The total amount of complaints 
submitted to  the NEBs relating  to  the Regulation is  very low:  about  150  complaints for the 
whole EU in 2019 (around 15 complaints per million passengers). Many PRMs are not aware 
of their rights, and even when they are, it is often difficult for them to get individual redress. In 

325 Special report No 30/2018: EU passenger rights are comprehensive but passengers still need to fight for them. 
326 Special Report No 15/2021: Air passenger rights during the COVID-19 pandemic: Key rights not protected 
despite Commission efforts. 
327 European Commission, Directorate-General for Mobility and Transport, Study on the EU Regulatory 
Framework for Passenger Rights. Part A, Evaluation of Regulation (EC) No 1107/2006 on the rights of persons 
with disabilities and with reduced mobility when travelling by air: final report, Publications Office of the 
European Union, 2021. 
328 European Commission, Directorate-General for Mobility and Transport, Study on the EU Regulatory 
Framework for Passenger Rights. Part C, Evaluation of Regulation (EU) No 1177/2010 on the rights of 
passengers travelling by sea and inland waterways: final report, Publications Office of the European Union, 
2021. 
329 European Commission, Directorate-General for Mobility and Transport, Study on the EU Regulatory 
Framework for Passenger Rights. Part B, Evaluation of Regulation (EU) No 181/2011 on the rights of 
passengers travelling by bus and coach: final report, Publications Office of the European Union, 2021. 
330 Regulation (EC) No 1107/2006 of the European Parliament and of the Council of 5 July 2006 concerning the 
rights of disabled persons and persons with reduced mobility when travelling by air (OJ L 204, 26.7.2006, p. 1-
9). 

132 

 
 
 
addition,  some  legal  gaps  (e.g.  definition  of  mobility  equipment,  medical  equipment, 
recognised assistance dogs) were also detected, making it difficult to apply the Regulation in 
certain situations. 

Regulation (EU) No 1177/2010 on waterborne passenger rights331 was introduced into a very 
diverse market: while some Member States with a sizeable market for waterborne passenger 
traffic already had a high level of passenger rights, other Member States with less traffic had 
no protection in place prior to the Regulation. Hence, the Regulation ensured that waterborne 
travellers have the same level of rights across the Union. The evaluation has however shown 
that there is room for improvement, both when it comes to clarification of the Regulation itself 
and  the  rights  it  grants,  and  to  its  implementation  and  Member  States'  monitoring  and 
enforcement. In that context, it should be noted that a recent judgment of the Court of Justice 
of the European Union (CJEU)332 has provided clarity on the interpretation of some provisions 
in the waterborne passenger rights Regulation. Furthermore, there may be also a lack in public 
awareness on passenger rights, as only one in a million passengers makes a complaint to the 
NEBs. 

As  regards  the  evaluation  of  Regulation  (EU)  No  181/2011  on  bus  and  coach  passenger 
rights333, several gaps have been identified in the existing legal framework, including limited 
protection for passengers travelling on scheduled services of less than 250 km, non-coverage 
of  delays  en-route  and  on  arrival  as  well  as  limited  liability  for  damage  or  lost  luggage. 
Furthermore, the evaluation has shown shortcomings and a lack of clarity in some provisions 
of the Regulation  on enforcement, sometimes leading  to  inconsistent  enforcement processes 
across the EU. Despite a low number of passengers’ complaints to the NEBs (1.5 complaints 
per  million  passengers),  the  evaluation  also  identified  limitations  in  the  coordination  of  the 
NEBs.  

Next to these evaluations, a comparative analysis of good practices on the implementation of 
passenger rights by carriers and national authorities across the various modes of transport was 
also  performed  by  the  Commission.334  The  study  also  identified  some  good  practices  in  a 
sample  of  ten  non-EU  countries335  and  concluded  on  the  limited  availability  of  rules  for 
protecting passenger in all modes, while putting forwards a certain trend in favour of a higher 
protection level for passengers. Good practices as implemented in the EU were identified for 
each  of  the  ten  individual  PR.  On  top  of  them,  fourteen  were  recommended  for  further 
consideration:  if  well  implemented,  these  good  practices  could  have  a  real  and  measurable 
impact on the EU PR framework, and on the actual travel experience of passengers.  

As regards the multimodal perspective of passenger rights, the Commission also performed an 
‘Exploratory  study  on  passenger  rights  in  the  multimodal  context’;  the  study  identifies  the 
limited size of the multimodal market as well as the main reasons for this from a passenger 

331 Regulation (EU) No 1177/2010 of the European Parliament and of the Council of 24 November 2010 
concerning the rights of passengers when travelling by sea and inland waterway and amending Regulation (EC) 
No 2006/2004 (OJ L 334, 17.12.2010, p. 1-16). 
332 CJEU – C-570/19. 
333 Regulation (EU) No 181/2011 of the European Parliament and of the Council of 16 February 2011 
concerning the rights of passengers in bus and coach transport and amending Regulation (EC) No 2006/2004 (OJ 
L 55, 28.2.2011, p. 1-12). 
334 European Commission, Directorate-General for Mobility and Transport, Study on the EU Regulatory 
Framework for Passenger Rights: comparative analysis of good practices: final report, Publications Office of the 
European Union, 2021. 
335 The sample was made of the following countries: Australia, Brazil, Canada, Chile, India, Japan, Malaysia, 
South Africa, South Korea and the United States. 

133 

 
 
rights dimension. It focuses on identifying those legal gaps and proposes solutions to fill them. 
It observes that the mode-oriented approach of the five existing regulations can potentially lead 
to legal gaps and, overall, an insufficient coverage of passenger rights in a multimodal context. 
The availability of data also constitutes a limitation in terms of both the scope and the detail of 
the analysis. 

These reports and evaluations have contributed in different ways to the Impact Assessment as 
shown below: 

Figure 11: Overview of studies done by the European Institutions impacting the Impact Assessment 

The  COVID-19  pandemic  shed  more  light  on  the  difficulties  with  the  implementation  of 
passenger rights in the event of a mass cancellation of transport services leading to a financial 
liquidity crisis for many carriers. While millions of passengers should have been offered the 
choice between a timely reimbursement or rerouting, they were often pushed to accept vouchers 
from  carriers  instead  and  were  regularly  not  granted  their  reimbursement  in  money  during 
several months.  

To counter this, the Commission consistently emphasised that passenger rights remain valid 
and that national measures to support the travel and tourism industry must not lower them336.  

There are other EU rules contributing to the protection of passengers. For instance, Directive 
(EU) 2015/2302 on package travel and linked travel arrangements (‘PTD’) applies to travellers 
having purchased packages and linked travel arrangements and includes rules on the level of 
protection for such services which are quite different compared to those for a stand-alone ticket 
under  the  five  passenger  rights  Regulations. The  European  Accessibility  Act  (Directive 
2019/882/EU), which will become applicable in 2025, will oblige operators and terminals to 
make the homepages, apps, ticket services, real-time travel information as well as ticketing and 

336 Action to remedy this situation has been taken by the Commission swiftly; Commission Interpretative 
Guidelines on EU passenger rights regulations in the context of the developing situation with COVID-19 
(2020/C 89 I/01) and Commission Recommendation (EU) 2020/648 of 13 May 2020 on vouchers offered to 
passengers and travellers as an alternative to reimbursement for cancelled package travel and transport services 
in the context of the COVID-19 pandemic. 

134 

 
 
 
check-in  machines  compliant  with  accessibility  standards.337  Finally,  both  Directive 
2013/11/EU  on  alternative  dispute  resolutions  for  consumer  disputes  and  Regulation  (EU) 
2017/2394  on  cooperation  between  national  authorities  responsible  for  the  enforcement  of 
consumer protection laws also have the five passenger rights Regulations in its scope. Both of 
these instruments are currently under revision. An indicative list of other EU rules contributing 
to the protection of passengers is available below.   

EU rules contributing to the protection of passengers 

Transport mode-specific legislation 

Rules specific to air transport 

Council Regulation (EC) No 2027/97 of 9 October 1997 on air carrier liability in the event 
of accidents338, as amended by Regulation (EC) No 889/2002 of the European Parliament 
and of the Council of 13 May 2002339 

Regulation  (EC)  No  1008/2008  of  the  European  Parliament  and  of  the  Council  of 
24 September 2008 on common rules for the operation of air services in the Community 
(Recast)340 

Regulation  (EC)  No  2005/2111  of  the  European  Parliament  and  of  the  Council  of  14 
December  2005  on  the  establishment  of  a  Community  list  of  air  carriers  subject  to  an 
operating  ban  within  the  Community  and  on  informing  air  transport  passengers  of  the 
identity of the operating air carrier, and repealing Article 9 of Directive 2004/36/EC341 

Regulation (EC) No 80/2009 of the European Parliament and of the Council of 14 January 
2009  on  a  Code  of  Conduct  for  computerised  reservation  systems  and  repealing  Council 
Regulation (EEC) No 2299/89342 

Rules specific to railway transport 

Directive 2012/34/EU of the European Parliament and of the Council of 21 November 2012 
establishing a single European railway area343 

Rules specific to waterborne transport 

Regulation (EC) No 392/2009 on the liability of carriers of passengers by sea in the event of 
accidents344 

Rules specific to bus and coach transport 

Directive 2009/103/EC of the European Parliament and of the Council of 16 September 2009 
relating to insurance against civil liability in respect of the use of motor vehicles, and the 
enforcement of the obligation to insure against such liability345  

Horizontal consumer protection legislation 

General consumer protection framework 

Directive (EU) 2015/2302 of the European Parliament and of the Council of 25 November 
2015  on  package  travel  and  linked  travel  arrangements,  amending  Regulation  (EC)  No 

337 This exercise should remain consistent with the European Accessibility Act (Directive 2019/882) and explore 
the possible complement it for modes and types of transport not covered therein. 
338 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:31997R2027.  
339 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32002R0889&qid=1637246812437.  
340 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32008R1008&qid=1637246783072.  
341 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02008R1008-20201218.  
342 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32009R0080.  
343 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32012L0034.   
344 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32009R0392. 
345 https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX%3A32009L0103.  

135 

 
 
2006/2004 and Directive 2011/83/EU of the European Parliament and of the Council and 
repealing Council Directive 90/314/EEC346 
Council Directive 93/13/EEC of 5 April 1993 on unfair terms in consumer contracts347 

Directive  2005/29/EC  of  the  European  Parliament  and  of  the  Council  of  11  May  2005 
concerning unfair business-to-consumer commercial practices in the internal market 348 

Directive 2011/83/EU of the European Parliament and of the Council of 25 October 2011 
on consumer rights, amending Council Directive 93/13/EEC and Directive 1999/44/EC of 
the European Parliament and of the Council and repealing Council Directive 85/577/EEC 
and Directive 97/7/EC of the European Parliament and of the Council349 

Public enforcement mechanisms 

Regulation (EU) 2017/2394 of the European Parliament and of the Council of 12 December 
2017  on  cooperation  between  national  authorities  responsible  for  the  enforcement  of 
consumer protection laws and repealing Regulation (EC) No 2006/2004350 

Private enforcement mechanisms 

Directive 2011/83/EU of the European Parliament and of the Council of 25 October 2011 
on consumer rights351, as amended by Directive (EU) 2019/2161 of the European Parliament 
and the Council of 27 November 2019 

Regulation  (EU)  No  1215/2012  of  the  European  Parliament  and  of  the  Council  of  12 
December 2012 on jurisdiction and the recognition and enforcement of judgments in civil 
and commercial matters (recast)352  

Directive 2013/11/EU of the European Parliament and of the Council of 21 May 2013 on 
alternative  dispute  resolution  for  consumer  disputes  and  amending  Regulation  (EC)  No 
2006/2004 and Directive 2009/22/EC (Directive on consumer ADR)353  

Regulation (EU) No 524/2013 of the European Parliament and of the Council of 21 May 
2013 on online dispute resolution for consumer disputes and amending Regulation (EC) No 
2006/2004 and Directive 2009/22/EC (Regulation on consumer ODR)354 

Directive 2020/1828/EU of the European Parliament and of the Council of 25 November 
2020 on representative actions for the protection of the collective interests of consumers and 
repealing Directive 2009/22/EC355 

Other horizontal legislation 

Regulation  (EU) 2018/1724  of the European Parliament and of the Council of 2 October 
2018 establishing a single digital gateway to provide access to information, to procedures 

346 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32015L2302.  
347 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A31993L0013.  
348 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32005L0029.  
349 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32011L0083.  
350 https://eur-lex.europa.eu/eli/reg/2017/2394/oj. 
351 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02011L0083-20180701.  
352 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02012R1215-20150226.  
353 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32013L0011&qid=1637245852106.  
354 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013R0524.  
355 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2020.409.01.0001.01.ENG. 

136 

 
 
 
and  to  assistance  and  problem-solving  services  and  amending  Regulation  (EU)  No 
1024/2012356 

Directive 2019/882/EU of the European Parliament and of the Council of 17 April 2019 on 
the accessibility requirements for products and services357 

356https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2018.295.01.0001.01.ENG&toc=OJ:L:2018:295:TOC.  
357 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0882.  

137 

 
 
 
 
ANNEX 10: PAYMENT FLOWS /  PROBLEM OF UNCLEAR REIMBURSEMENT RULES FOR 
TICKETS BOOKED VIA INTERMEDIARIES 

The  following  table  has  been  provided  by  IATA  in  the  stakeholder  consultation  process 
showing  the  different  payment  flows  when  an  intermediary  is  involved  in  a  purchase  and 
reimbursement process. 

Figure 17 - Payment flows and magnitudes in Europe 

138 

 
 
 
 
 
ANNEX 11: REIMBURSEMENT POLICIES FOR TICKETS BOOKED VIA INTERMEDIARIES 

When flights358 are cancelled or suffer major delays, or when passengers are denied boarding, 
passengers have a right to reimbursement or re-routing, at their choice. According to current 
rules, when passengers choose reimbursement, they are to be reimbursed the full cost of the 
ticket, within seven days359.  

Airlines  have  two  different  distribution  models  which  influence  how  they  reimburse 
passengers: direct sales to passengers (mainly via their websites) and indirect sales (through 
intermediaries:  (online  and  offline)  travel  agents  and  travel  management  companies,  tour 
operators and resellers of charter flights). In the reference year 2019. In total, about 46.4% of 
tickets  in  the  EU  pass  through  intermediaries  (450  million  passengers  in  EU-27,  including 
passengers from network carriers and low-cost carriers)360. 361 

When  a  reimbursement  is  requested  of  a  ticket  sold  via  indirect  sales,  airlines  have  two 
possibilities, which passengers are normally not aware of: 

a)  to  process  the  reimbursement  through  the  intermediary,  by  reversing  the  original 
payment flow. The large network and regional carriers mainly use this model, also 
due  to  the  systems  in  place  (e.g.  IATA’s  Billing  and  Settlement  Plan  (BSP)362) 
which facilitate this through agreements with the intermediaries; or 

b)  to process the reimbursement to the passengers by themselves, without involving 
the  intermediary.  This  latter  model  is  either  used  when  passengers  request  the 
reimbursement directly to  the carrier, which is  rare, or by large low-cost  carriers 
which have an exclusive direct (online) distribution model and prefer not to involve 
intermediaries.   

Even if an airline has an exclusive direct (online) distribution model, it is worth noting that 
certain intermediaries circumvent it and book tickets with the airline nevertheless (often known 
as  screen  scraping).  Therefore,  a  part  of  these  airlines’  tickets  sold  via  direct  sale  channels 
include  those  sold  by  intermediaries  which  do  not  have  any  formal  (interline/codeshare) 
agreement with the airline.  Although no reliable data is available, figures from one large low-
cost carrier show that bookings via such screen scraping intermediaries may represent up to 
13% of all air tickets sold by this carrier. In the absence of more granular data, if we assume 
that  tickets  sold  via  screen  scraping  intermediaries  represent  13%  of  all  bookings,  this  may 
affect up to 129 million passengers in 2019. However, airlines are often unable to identify such 
booking and are therefore unaware when such bookings are made, preventing an exact estimate 
on how many passengers may be affected. 

The airline either does not know that an intermediary booked the ticket363, or the airline detects 
that the ticket was booked by an “unauthorised intermediary”. This creates extra complexity 
when it comes to reimbursements, where the carriers may oblige the passenger to request the 
reimbursement  directly  from  them  (in  order  not  to  have  to  deal  with  intermediaries  whose 

358 The Call for Evidence and other evidence collected did only show problems with reimbursements for airline 
tickets, but not for bus, rail or ship tickets. 
359 Art. 8.1 (a) of Regulation (EC) No 261/2004. 
360 Information provided by IATA, the global trade association of airlines. 
361 Network carriers in the EU sold about 53% of their tickets (about  382 million passengers in terms of tickets 
sold in 2019) through intermediaries, whereas this share is 15% for low-cost carriers (about 68 million passengers 
in 2019).  
362 IATA’s Billing and Settlement Plan (BSP) is a system designed to facilitate and simplify the selling, reporting 
and remitting procedures of IATA Accredited Passenger Sales Agents, as well as improve financial control and 
cash flow for BSP Airlines.  
363 E.g. with the intermediary pretending to be a passenger and providing the intermediary’s contact email address 
as the passenger’s contact details, according to stakeholder evidence. 

139 

 
 
activity it has not authorised). Carriers may then ask passengers for a biometric identity check 
before  check-in364  and  request  the  passenger  to  provide  additional  information  for  the 
reimbursement, including the bank details of the original customer, so that the reimbursement 
payment does not arrive with the intermediary.  

When reimbursements are processed through intermediaries (possibility (a) above), there are 
again two possible ways, which passengers are usually not aware of either:  

1)  The  intermediary’s  customers  may  be  reimbursed  by  the  airline  directly  to  the  means  of 
payment that they used when they paid for the flight. This happens in 10% of ticket sales in 
Europe in paid amounts365 when the intermediary is a ‘pass-through agent’ and just passes the 
customer’s debit or credit card details to the airline as a means of payment (in a secure way, i.e. 
without  itself  seeing  the  details),  and  is  not  itself  involved  in  the  financial  transaction.  The 
intermediary may then request the reimbursement to the airline, the airline reverses the original 
payment and it arrives directly with the customer.  

2)  The  intermediary’s  customers  may  be  reimbursed  by  the  intermediary,  from  the 
intermediary’s account. This happens in 30% of ticket sales in Europe in paid amounts366. These 
intermediaries act as “Merchants of Record”. This means: they have received the passenger’s 
payment,  and  then  paid  the  carrier  from  their  own  bank  account.  This  adds  an  additional 
payment transaction to the payment flow, but also to the reimbursement flow, under which 
the original two payments367 are simply reversed. 

Figure 12 - Indirect booking via Merchant of Record intermediary 

If the passenger has given the intermediary a valid mandate to receive the reimbursement on 
the passenger’s behalf, the intermediary has to receive the reimbursement from the air carrier 
within  seven  days.  The  deadline  within  which  the  intermediary  has  to  forward  the 
reimbursement to the passenger depends in this case on the agreement between the passenger 
and the intermediary. The terms and conditions of the intermediary may sometimes not foresee 
any  deadline  for  the  transaction  from  the  intermediary  to  the  passenger,  i.e.  not  giving  the 
passengers  any  certainty  on  when  they  will  be  reimbursed,  or  a  very  long  deadline  (several 

364 E.g. see Ryanair’s terms and conditions, art. 6.2.9., “Express verification” (ryanair.com). Passengers are asked 
to provide a photo of their passport or identification card, then to take a photo of their face to allow the carrier to 
verify the travel documentation which they provided and then to carry out a liveness check of the passenger’s face. 
365 According to IATA, see Annex 11 – Payment flows.  
366 According to IATA, see Annex 11 – Payment flows. 
367 Payment 1: from customer to intermediary, payment 2: from intermediary to carrier. 

140 

 
  
 
weeks)368.  

Another problem for passengers who book via an intermediary ticket vendor is unclarity on 
whom to contact with a reimbursement claim. This issue was also pointed out by the European 
Court of Auditors in its report of June 2021. In some cases, passengers ‘bounced’ between the 
airline  and  travel  agency.  Passenger  and  consumer  organisations  confirmed  that  the 
responsibility  for  reimbursement  is  unclear  to  the  passengers  and  needs  to  be  clarified.  An 
airline umbrella association reported that passengers may get over-refunded, in cases where a 
passenger requests the reimbursement to  both  the airline and the intermediary, or where the 
passenger requests the reimbursement from the airline and at the same time launches a credit 
card chargeback369 against the Merchant of Record intermediary.  

368 See below the European Commission’s online search result of intermediaries‘ terms and conditions on refund 
transfer, 3/6/2023. 
369 The major credit card companies reimburse customers for services not rendered; the responsible entity is the 
respective Merchant of Record. 

141 

 
 
 
 
ANNEX 12: INTERMEDIARIES’ TERMS AND CONDITIONS ON THEIR REIMBURSEMENTS TO 
CUSTOMERS 

The  Commission  has  conducted  research  into  selected  merchant  of  record  intermediaries’ 
reimbursement payment  deadlines to  the  customer, after having  received the reimbursement 
payment from the airline, according to the intermediaries’ terms and conditions. This research 
was done as an online research on 05 June 2023. 

E-Dreams terms and conditions 

Terms and conditions: Review our general terms & conditions - eDreams 

Time: Be assured that after due receipt of the refund and of the relevant and valid information 
attached to it, we will transfer it back to you in 7 days. 

E-traveli terms and conditions 

Terms and conditions: Cancellations to bookings - FAQs (e-travel.ie) 

Time: The time between cancellation and refund may vary, depending on the service provider 
we are partnering with. Accommodation booking refunds can be within 10 working days. Flight 
cancellation  refunds  can  be  up  to  6  to  10  weeks  as  a  result  of  delays  with  refunds  being 
processed by IATA back to us, the agent, on behalf of the airline. We will refund our customers 
as soon as we receive the refunds from the airline. 

Kayak 

Terms and conditions: Book with KAYAK Terms & Conditions - KAYAK 

Time: In most cases, the refundable amount will be credited back to the original method of  
payment;  however,  there  are  exceptional  situations  in  which  tickets  will  be  refunded  via 
alternative methods such as check or PayPal. We will issue refunds for eligible tickets within 
20 business days for credit/debit card purchases, but please note that this does not include 
Your own bank processing time. 

Kiwi 

Terms and conditions: Terms and Conditions | Kiwi.com 

No deadline foreseen for Kiwi’s reimbursement to the passenger, after it has received the funds 
from the carrier. 

Opodo 

Terms and conditions: Opodo general terms and conditions 

Time: In some cases, the refunds from third party providers will be received by us and passed 
on  to  you.  Be  assured  that  after  due  receipt  of  the  refund  and  of  the  relevant  and  valid 
information attached to it, we will transfer it back to you in 7 days. 

Kissandfly: 

Terms and conditions: Kissandfly | Terms of Service 

Time: In case of payment for flight tickets directly to the Agency, a refund will be carried out 
after receiving the refund from the Carrier by the Agency. The Agency has no influence on the 
timely refund by the Carrier. In case the payment was made directly to the Carrier, a refund is 

142 

 
usually  carried  out  within  10-60  business  days,  while  the  Agency  has  no  influence  on  the 
timely refund by the Carrier. 

Travelstart: 

Travelstart | Travel conditions 

Time: The refund is dependent on the airline's processing times. These can vary significantly 
between the different airlines, and unfortunately we cannot influence the processing times. 
We will certainly do our best to ensure that any refund that you are owed is made to you as 
soon as possible. 

Govoyages: 

Terms and conditions: Govoyages – Comment se faire rembourser? 

Time: Bien que les compagnies aériennes soient tenues de procéder à un remboursement dans 
un délai de 7 jours en vertu du règlement CE 261/2004 de l'UE, elles mettent actuellement 
30 jours en moyenne pour traiter les remboursements. 

Nous recevons les paiements des prestataires tiers avant de vous les transférer. Une fois que 
nous avons reçu le remboursement avec les informations correspondantes et valides de la part 
des compagnies aériennes, nous procédons au transfert dans un délai de 7 jours, en utilisant le 
même mode de paiement que celui de votre réservation d'origine. 

Bravofly: 

Terms and conditions: Bravofly | General Terms and Conditions for booking plane tickets 

Time:  If  you  do  not  make  a  refund  method  choice  and  no  response  is  received  by  us,  the 
Company will finalise the refund as a cash refund after 60 days. 

Finally, we inform you that airlines may take up to 12 months to refund your money or provide 
the corresponding economic compensation. 

Mytickets: 

Terms and conditions: Mytickes | Terms of Service 

Time: In case of payment for flight tickets directly to the Agency, a refund will be carried out 
after receiving the refund from the Carrier by the Agency. The Agency has no influence on 
the timely refund by the Carrier. In case the payment was made directly to the Carrier, a 
refund is usually carried out within 10-60 business days, while the Agency has no influence 
on the timely refund by the Carrier. 

On the beach: 

Terms and conditions: onthebeach.co.uk/terms_of_business 

Time: In case of any refund payable to you in accordance with these Booking Conditions, you 
will receive the monies back on the most recent debit/credit card you used to pay for the Travel 
Arrangements. If that card has expired or been cancelled and the refund is unsuccessful, then 
please contact our customer service department. 

143 

 
  
 
 
 
Dohup: 

Terms and conditions: Terms & Conditions – Dohop 

Dohop  will  use  the  payment  method  provided  by  the  Customer  to  issue  the 
reimbursement.  The  Customer  represents  and  warrants  to  Dohop  that  the 
payment information provided is accurate and that the Customer is authorised 
to  use  the  payment  instrument.  Incorrect  payment  information  may  result  in 
Dohop  being  unable 
the 
reimbursement amount received by the Customer as the exchange currency rate 
on the day Dohop receives the correct information will be used, not the currency 
rate  on  the  day  the  incorrect  information  was  received,  and  any  and  all 
additional costs in relation to the provision of incorrect payment information 
must be borne by the Customer. 

the  reimbursement  and/or  affect 

issue 

to 

4.7 

Hopper: 

Terms and conditions:  Can I receive a refund for my flight? (hopper.com) 

•  Our agreement with most lost-cost carriers such as Spirit, Frontier or Norwegian Air 
requires that we collect the funds directly and then forward payment to the airline from 
Hopper’s account. If you are waiting to receive a refund, please note that it may take 1-
2 weeks for this to be processed back to your account. For these bookings, your Hopper 
confirmation code will usually begin with a "Z-" or "X-" (example Z-ABCDEFG). 

144 

 
 
 
ANNEX 13: CPC ACTION 

CPC action on airline intermediaries, 2020-2022,  Air travel (europa.eu), question 7 to airlines: 
“Inform passengers about the possibility of requesting a refund directly from the airline and any 
conditions for requesting a direct refund on their websites, for passengers who booked their 
flights through an intermediary and are experiencing difficulties” 

Table 161: Information on possibility to request a direct refund in the CPC action 
Possibility to request a direct refund 

Airline 

Aegean Airlines 

For intermediate sales, Aegean Airlines has activated (since July 2020) an open access 
mechanism where the on-line intermediaries / travel agents could apply unilaterally the 
“refund notice” and proceed with immediate  available funds for refund to the entitled 
passengers. 

In  cases  that  passengers  have  directly  contacted  the  intermediary  for  refund,  and 
encountered  delays,  and  Aegean  was  subsequently  contacted,  we  have  assisted  and 
coordinated all actions available to ensure that the refund will be made in the timeliest 
manner. If the intermediate did not reply or refused to proceed with a refund, then Aegean 
satisfied such claim and proceeded with the direct refund to the passenger. 

Aegean has recently launched new regulations to the travel agents whereby requires them 
to share passengers’ data also with the airline so that in case of any delay, change or a 
cancellation of a flight, the passenger is on a prime basis in the list of contacts of the 
airline. 

When purchased through a third party, in the sole benefit of the passengers, Air France 
suggests  its  passengers  to  first  contact  the  said  third  party  in  order  for  them  to  be 
reimbursed  of  the  full  price  they  have  paid,  consequently  including  services  fees  that 
might have been charged. 

If the third party does not respond to the customer and the customer does not receive a 
refund, the customer may contact Air France who will handle the refund request so that 
the amount of the ticket can be effectively refunded. 

Air France 

Austrian 

As discussed before, Austrian will reimburse passengers who are entitled for a refund, 
regardless of how they purchased their ticket. 

As requests are handled on a case -by -case basis, there is no default routine to handle 
intermediary bookings in a specific way. If a customer is eligible for a refund, he will be 
reimbursed. 

British Airways 

On its website British Airways invites passengers that require assistance with obtaining 
a refund from intermediaries to contact BA. 

Where  travel  agents  have  consistently  failed  to  pass  on  refunds,  a  relevant  British 
Airways’  account  manager  is  in  contact  with  the  organisation  directly  to  prompt 
refunding. The airline has and continues to terminate relationships with intermediaries 
that fail to abide by its agency terms and conditions (which include the requirement to 
comply with refunding requirements). 

Where a travel agent has become insolvent, the airline has been able to assist customers. 

Brussels Airlines 

Brussels Airlines NV/SA refunds passengers who are entitled for a refund, regardless of 
how they purchased their ticket. 

As  requests  are  handled on  a  case-by  case basis,  there  is no  default  routine  to  handle 
intermediary bookings in a specific way. If a customer is eligible for a refund, he/she will 
be reimbursed in compliance with Regulation 261/2004. 

145 

 
Airline 

EasyJet 

Eurowings 

Iberia 

Possibility to request a direct refund 

EasyJet  already  allows  passengers  to  contact  the  airline  directly  to  manage  bookings 
(alternative flight, voucher or refund) either online or by contacting the Customer Service 
team.  If  the  passenger  does  not  have  the  booking  reference,  they  can  contact  our 
Customer Service team who will process requests for them on passing of appropriate data 
protection security questions (passenger names, flight details etc.) and confirmation that 
they have authorisation to manage the booking. 

We  are  not  involved  in  or  responsible  for  any  ‘package’  put  together  by  third  party 
holiday  companies  (and  we  are  not  responsible  for  refunds  under  the  Package  Travel 
Regulations). 

Passengers who booked their ticket via an intermediary are informed about the possibility 
of  requesting  a  refund  directly  from  easyJet  via  the  Help  Hub  and  the  Delays  and 
Cancellations  page.  In  the  spirit  of  full  cooperation  with  the  CPC,  easyJet  has  further 
improved the transparency of the information provided in these pages. 

As  stated  before,  Eurowings  will  reimburse  passengers  who  are  entitled  for  a  refund, 
regardless of how they purchased their ticket. 

In  present  passengers  who  booked  through  an  agency/intermediary  and  are  having 
difficulties  obtaining  a  cash  reimbursement  may  contact  Iberia  customer  center  and 
his/her request will be managed directly. Soon these requests may be also submitted via 
an online webform in our webpage www.iberia.com 

In the FAQ section of our webpage information is provided to our customers on how to 
proceed  in  case  they  are  not  able  to  obtain  reimbursement  of  their  ticket  from  their 
intermediary in case of flight disruption. 

Passengers are also informed in their “Manage My Booking” area that they may reach 
our contact center to obtain reimbursement in case of flight disruption. 

KLM 

For tickets booked through the KLM website, a refund can be requested via the website. 
The request will be processed within 7 days. In case of questions, our Contact Centres 
will be happy to assist. Information on all contact options can be found on the website.  

Lufthansa 

Norwegian 

For tickets booked via a travel agent, the online refund system can, unfortunately, not be 
used. We advise passengers contacting their travel agent first, as they have all needed 
information  to  arrange  the  refund.  Contact  details  can  be  found  on  the  travel  agent’s 
website.  However,  if  preferred,  passengers  can  also  contact  KLM  directly  to  help 
arranging a refund of a ticket booked via an agent. 

For tickets booked via a travel agency, we recommend that customers also get in touch 
with the travel agency. If they do not receive a response in a timely manner or it seems 
necessary for other reasons, they are asked to contact us again for further processing. 

We have been made aware that some travel agencies are either rejecting to make a full 
refund or is charging a fee for doing this, so although the contract is between the customer 
and the travel agency, and the payment is made to the agency, Norwegian has created an 
online form for direct refund requests specifically to our customers that booked through 
a third-party. 

If trying to use the online claim form for direct bookings, the customer will be redirected 
to the appropriate form. If the passenger contacts us by phone, chat, social media etc, we 
will inform about the form. 

Ryanair 

For safety and security reasons, passengers who booked their flight via an unauthorised 
intermediary  and  request  a  refund  directly  from  us  are  required  to  complete  customer 
verification before their refund can be processed. Such passengers can either verify their 
identity using online verification or manually using our customer verification form.  

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Airline 

Possibility to request a direct refund 

Alternatively, the unauthorised intermediary may avail of our letter of authority process 
to claim any refunds already paid to the passenger. 

Additionally, we have an “OTA Information Hub” on our website dedicated to informing 
customers about the risks associated with unauthorised intermediary bookings, and clear 
guidance on how to claim a refund if the passenger has booked through an unauthorised 
intermediary. 

On  30  September  2021  we  issued  an  “unauthorised  intermediary  reminder  email”  to 
unauthorised intermediary bookings with outstanding cash refund requests, reminding of 
the Letter of Authority and Customer Verification processes which can be availed of to 
obtain  a  cash  refund.  In  addition,  we  have  updated  our  “OTA  Information  Hub 
(https://www.ryanair.com/ie/en/onlinetravel-agents/)  to  allow  passengers  who  booked 
through  an  unauthorised  intermediary  to  “identify  themselves”  to  Ryanair  in  order  to 
update their contact details in our reservation system. 

Tap 

The refund request flow presents the passenger with information about the acceptance of 
refund requests for bookings that have been made through intermediaries. 

Vueling 

Wizzair 

TAP accepts requests from all passengers who have evidence and/or claim that they are 
unable to contact or obtain their refund through the intermediary. 

When a flight is cancelled, customers receive an email with the possibility to self-manage 
their  refund  request  on  http://www.vueling.com  even  if  they  booked  through 
intermediaries. 

Wizz Air initiated an information campaign against online travel agencies (OTA). In this 
regard Wizz Air has updated its information page on the advantages of direct booking at 
Wizz  Air’s  website  and  the  possible  disadvantages  that  may  occur  if  one  uses 
intermediaries: 

https://wizzair.com/en-gb/informationand-services/booking-information/directbooking-
benefits 

Nevertheless,  Wizz  Air  Customer  Service.  Department  reached  out  to  online  travel 
agencies seeking for their cooperation in specific cases but - to Wizz Air’s astonishment 
- they never replied. This experience underlines the necessity to regulate online travel 
agencies  at  EU  level  as  they  can  act  without  any  further  responsibility  which  is 
detrimental to passengers. 

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