COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a Directive of the European Parliament and of the Council amending Directive 2005/44/EC on harmonised river information services (RIS) on inland waterways in the Community
Date: 2024-01-26
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: European Interoperability Framework, exchange of information, harmonisation of standards, information system, inland waterway shipping, maritime safety, network of navigable waterways, technical specification, trans-European network

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 26.1.2024  SWD(2024) 15 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  Accompanying the document Proposal for a Directive of the European Parliament and of the Council amending Directive 2005/44/EC on harmonised river information services (RIS) on inland waterways in the Community {COM(2024) 33 final} - {SEC(2024) 38 final} - {SWD(2024) 16 final}  
 
 
Table of contents 

1 

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

1.1  Context .............................................................................................................. 1 
1.2  What are River Information Services (RIS) ...................................................... 3 
1.3  Political and legal context ................................................................................. 4 
1.4  Evaluation of the RIS Directive ........................................................................ 9 
1.5  Sustainable Development Goals ...................................................................... 10 

2 

PROBLEM DEFINITION ........................................................................................ 10 

2.1  What is the problem? ....................................................................................... 11 
2.2  What are the problem drivers? ........................................................................ 16 
2.3  How likely is the problem to persist? .............................................................. 22 

3  WHY SHOULD THE EU ACT? .............................................................................. 24 

3.1  Legal basis ....................................................................................................... 24 
3.2  Subsidiarity: Necessity of EU action .............................................................. 24 
3.3  Subsidiarity: Added value of EU action .......................................................... 25 

4  OBJECTIVES: WHAT IS TO BE ACHIEVED? ..................................................... 26 

4.1  General objectives ........................................................................................... 26 
4.2  Specific objectives ........................................................................................... 27 

5  WHAT ARE THE AVAILABLE POLICY OPTIONS? .......................................... 28 

5.1  What is the baseline from which options are assessed? .................................. 28 
5.2  Policy measures and policy options ................................................................ 31 

6  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ................................. 41 

6.1  Economic impacts ........................................................................................... 42 
6.2  Social impacts ................................................................................................. 58 
6.3  Environmental impacts .................................................................................... 59 

7  HOW DO THE OPTIONS COMPARE? .................................................................. 61 

7.1  Effectiveness ................................................................................................... 61 
7.2  Efficiency ........................................................................................................ 64 
7.3  Coherence ........................................................................................................ 65 
7.4  Subsidiarity and proportionality ...................................................................... 66 
7.5  Summary of the comparison of policy options ............................................... 67 
7.6  Sensitivity analysis .......................................................................................... 67 

8 

PREFERRED OPTION ............................................................................................ 69 

Identification of the preferred policy option and stakeholders views ............. 69 
8.1 
8.2  REFIT (simplification and improved efficiency) ............................................ 70 
8.3  Application of the ‘one in, one out’ approach ................................................. 71 

9  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? ....... 71 

ANNEX 1: PROCEDURAL INFORMATION ................................................................ 75 

I 

 
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) .................... 78 

ANNEX 3: WHO IS AFFECTED AND HOW? .............................................................. 92 

ANNEX 4: ANALYTICAL METHODS .......................................................................... 96 

ANNEX 5: COMPETITIVENESS CHECK ................................................................... 148 

ANNEX 6: SME TEST ................................................................................................... 150 

ANNEX 7: CONCLUSIONS OF THE EVALUATION ................................................ 154 

ANNEX 8: EFFECTIVENESS OF THE DIFFERENT POLICY OPTIONS ................ 155 

ANNEX 9: OVERVIEW OF RIS ................................................................................... 160 

II 

 
Glossary 

Term or acronym  Meaning 

Definition 

AIS 

Automatic 
System 

Identification 

CCNR 

Central  Commission 
Navigation on the Rhine 

for 

CEF 

Connecting Europe Facility 

AIS 
is  an  automatic  communication  and 
identification  system  that  displays  (on  electronic 
charts)  the  position  and  orientation  of  other 
vessels in the vicinity  

The CCNR is an international organization that is 
responsible  for  promoting  the  development  and 
safety  of  inland  navigation  on  the  Rhine  and  its 
tributaries.  

The CEF is a European Union funding instrument 
that  supports the  development  of  trans-European 
infrastructure networks in the fields of transport, 
energy, and telecommunications.  

CESNI 

for 
European  Committee 
Drawing  Up  Standards  in  the 
Field of Inland Navigation  

The CESNI is an intergovernmental organization 
that  develops  technical  and  safety  standards  for 
inland navigation in Europe.  

CEMT Class 

Classification  of  European 
Inland Waterways 

CEVNI 

European  Code  for  Inland 
Waterways 

An  inland  waterway  classification  according  to 
CEMT  (European  Conference  of  Ministers  of 
Transport) 
vessels 
concerning 
dimensions on a fairway.  

allowed 

CEVNI  contains  the  core  rules  applicable  to  the 
traffic on inland waterways in the UNECE region 
such  as  marks  and  draught  scales  on  vessels, 
visual  signals  on  vessels,  sound  signals  and 
radiotelephony,  waterway  signs  and  markings, 
rules  of  the  road,  berthing  rules,  signalling  and 
reporting  requirements  as  well  as  prevention  of 
pollution of water and disposal of waste  

DINA 

ECDIS 

Digital 
Area 

Inland  Navigation 

DINA  is  a  concept  to  interconnect  information 
between  IWT’s  stakeholders  and  with  other 
transport modes.  

Electronic  Chart  Display  and 
Information System 

ECDIS  is  a  computer-based  navigation  system 
used on ships to display navigational information 
and provide real-time information about the ship's 
position, course, and speed.  

EFTI 

Electronic  Freight  Transport 
Information 

eFTI is a digital system that enables the exchange 
transport 
of 

information 

related 

freight 

to 

III 

 
Term or acronym  Meaning 

Definition 

EHDB 

European Hull Database 

EMSWe 

European  Maritime  Single 
Window environment 

between different actors in the supply chain.  

The  EHDB  is  a  database  kept  by  the  European 
Commission  in  which  the  data  of  the  vessels 
operating  on  European  inland  waterways  is 
collected.  The  EHDB  is  used  to  support  the 
proper  functioning  of  river  information  services 
(RIS) in accordance with Directive 2005/44/EC.  

The main aim of the EMSWe Regulation is to lay 
down  harmonised  rules  for  the  provision  of  the 
information  that  is  required  for  port  calls,  in 
particular by ensuring that the same data sets can 
be  reported  to  each  Maritime  National  Single 
Window  in  the  same  way.  This  Regulation  also 
aims to facilitate the transmission of information 
between  declarants,  relevant  authorities  and  the 
providers of port services in the port of call, and 
other Member States.  

ENC 

Electronic Navigation Charts  ENC are developed in accordance with the Inland 
ECDIS  Standard  for  Electronic  Chart  Display  in 
inland navigation.  

ERDMS 

European  Reference  Data 
Management System 

The ERDMS is a database containing information 
and  data  necessary  to  efficient  and  harmonise 
implementation of RIS.  

ERI 

Electronic 
International 

Reporting 

The  ERI  endeavour  to  harmonise  and  facilitate 
standardised  electronic  inland  ship  reporting  in 
the EU.  

ETA 

Estimated Time of Arrival 

The  ETA,  is  a  frequently  used  term  globally  to 
denote  the  time  of  coming.  In  the  shipping  & 
logistics industry, it is used to forecast when the 
shipment  will  arrive  at 
final  port  of 
destination.  

its 

GDPR 

General  Data 
Regulation 

Protection 

The  GDPR  is  a  regulation  implemented  by  the 
EU  to  protect  the  privacy  and  personal  data  of 
EU citizens.  

IWT 

Inland Waterway Transport 

IWT  refers  to  the  transportation  of  goods  and 
passengers  using  rivers,  canals,  and  other  inland 
waterways.  

IV 

 
Term or acronym  Meaning 

Definition 

NtS 

Notices to Skippers 

RIS 

River Information Services 

RIS COMEX 

RIS 
enabled 
Management Execution 

Corridor 

The NtS serve to communicate information such 
as the status of the inland waterway infrastructure 
(i.e.  bridges  and  locks),  failures  of  aids  to 
navigation,  temporary  blockages  of  waterway 
sections  or  other  types  of  infrastructure,  works, 
water  level  and  water  depth  information,  ice 
information and weather messages.  

RIS  are  a  set  of  digital  services  and  tools 
designed  to  enhance  the  safety,  efficiency,  and 
sustainability of inland waterway transport.  

A  IWT  platform  aiming  at 
specification, 
operation  of  Corridor  River 
Services.  

the  definition, 
implementation  and  sustainable 
Information 

SDG 

SME 

Sustainable 
Goal 

Development 

The SDGs are a set of 17 goals established by the 
United  Nations  in  2015  as  a  blueprint  for 
achieving a better and more sustainable future.  

Small 
Enterprises  

and  Medium-sized 

SMEs refers to businesses with a limited number 
of  employees  and 
revenue 
compared to larger enterprises.  

relatively 

low 

SSMS 

Sustainable 
Mobility Strategy 

and 

Smart 

TEN-T 

Trans-European  Network 
Transport 

- 

Tkm 

Tonne-kilometre 

Comprehensive  EU transport strategy adopted in 
2020  which  lays  the  foundation  for  how  the  EU 
transport system can achieve its green and digital 
transformation  and  become  more  resilient  to 
future crises.  

Key instrument for the development of coherent, 
efficient,  multimodal,  and  high-quality  transport 
infrastructure  across 
It  comprises 
railways,  inland  waterways,  short  sea  shipping 
routes  and  roads  linking  urban  nodes,  maritime 
and inland ports, airports and terminals.  

the  EU. 

Unit  of  measure  of  freight  transport  which 
represents  the  transport  of  one  tonne  of  goods 
(including  packaging  and 
tare  weights  of 
intermodal  transport  units)  by  a  given  transport 
mode  (road,  rail,  air,  sea,  inland  waterways, 
pipeline etc.) over a distance of one kilometre.  

UNECE 

United  Nations  Economic  The  UNECE  is  a  regional  commission  of  the 

V 

 
Term or acronym  Meaning 

Definition 

Commission for Europe 

UN.  

VTT 

Vessel Tracking and Tracing 

It  is  one  component  of  the  “River  Information 
Services”  (RIS), contributing  to more  safety  and 
better efficiency of inland navigation. 

VI 

 
1 

INTRODUCTION 

1.1  Context 

This Impact Assessment accompanies a legislative proposal for a revision of Directive 2005/44/EC 
on harmonised river information services1 (hereinafter “the RIS Directive” or “the Directive”). 

The EU’s inland waterways stretch over 42,286 kilometres (km) and are a key means of connecting 
seaports, cities and industrial centres2. The interconnected waterway network of 13,000 km covers 
13 Member States3 serving over 250 TEN-T inland ports in the TEN-T network. A map of the main 
waterways in the EU is provided below. 

Figure 1: Main waterways in the EU 

Source: European Commission 

Inland Waterway Transport (IWT) plays an important role in the overall European transport system 
despite  its  relatively  small  size.  In  2020,  131.7  billion  tonne-kilometres  (tkm)  were  transported 
through inland waters, making up 4.1% of the total freight transport volumes (with road accounting 

1 Directive 2005/44/EC of the European Parliament and of the Council of 7 September 2005 on harmonised river 
information services (RIS) on inland waterways in the Community, OJ L 255, 30.9.2005, p. 152–159. 
2 Source: EU transport in figures. Statistical pocketbook 2022 (europa.eu) 
3  Austria,  Belgium,  Bulgaria,  Czechia,  Germany,  France,  Croatia,  Hungary,  Luxembourg,  the  Netherlands, 
Poland, Romania and Slovakia. 

1 

 
 
 
for  54.9%,  sea  29.1%  and  rail  11.9%)4.  Dry  cargo  (in  particular  agricultural  products,  ore  and 
metals, building  materials, coal,  etc.)  accounted  for  59.8%  of  IWT  volume in 2020, liquid  cargo 
(chemicals and petroleum products) for 28.1% and containers for 12.1%5. 

IWT  handles  0.9%  of  the  total  imports  and  exports  in  terms  of  weight  in  the  EU.  Despite  its 
geographically limited and focused network, it offers an important alternative to transport via road 
or rail for the European hinterland regions closest to inland waterways. Therefore, IWT is mainly in 
competition and often classified along with land transport modes6, covering 6% of inland freight 
traffic and 0.01% of passenger inland traffic. 

The development of inland waterway activity is highly dependent on geography (location of rivers), 
on the types of goods that are or can be transported, on the location of production and consumption 
sites  in  relation  to  the  inland  waterway  network  and  on  the  availability  of  transhipment 
infrastructure.  In  this  context,  the  sector  faces  limitations  in  terms  of  its  structural  market 
accessibility and growth potential related to two factors7:  

•  Geography.  Contrary  to  road  and  rail,  building  new  waterways  is  generally  not  an  option. 
Therefore,  the  development  of  Inland  Waterway  Transport  depends  essentially  on  the 
respective  locations  of  production  and  consumption  sites  in  relation  to  the  existing  inland 
waterway  network.  Indeed,  depending  on  each  territorial  context  and  the  geographical 
distribution of each site the total cost of Inland Waterway Transport, including handling and 
last miles, may turn out to be very high. 

•  Logistics. Inland Waterway Transport is not always an option as IWT vessels cannot carry all 

kind of goods due to packaging issues (for instance pallets) or size of shipments. 

Besides  constraints  due  to  geography  and  logistics,  IWT  faces  some  challenges  to  achieve  its 
growth potential8. The growth of IWT can be ensured by meeting the objective of NAIADES III 
Communication9, which suggests investing in the infrastructure and research, further digitalisation 
of the sector and improvements in the attractiveness for the crew. Some new and growing markets 
might  trigger  modal  shift  towards  IWT,  for  example,  waste/biomass  transport,  circular 
economy/new materials, urban logistics and passenger transport. 

Connected to the geographical distribution of inland waterways, IWT traffic volumes concentrate in 
a few Member States, with Germany and the Netherlands accounting for 69% of overall EU IWT 
transport  in  202010.  In  terms  of  modal  shares,  IWT  plays  a  significant  role  in  the  land  freight 

4 Source: EU transport in figures. Statistical pocketbook 2022 (europa.eu) 
5 CCNR (2022). Thematic report an assessment of new market opportunities for inland waterway transport. 
Available at: https://inland-navigation-market.org/wp-content/uploads/2022/03/Thematic-
report_20212022_EN_BD.pdf  
6  European  Commission  (2016),  Staff  Working  Document  Refit  Ex-Post  Evaluation  of  Combined  Transport 
Directive 92/106/EEC Final Report, SWD(2016) 140 final 
7 European Commission (2020), Assessment of the potential of maritime and inland ports and inland waterways 
and  of  related  policy  measures, 
including  industrial  policy  measures,  https://op.europa.eu/o/opportal-
service/download-handler?identifier=4ec82fa8-0dc6-11eb-bc07-
01aa75ed71a1&format=pdf&language=en&productionSystem=cellar&part=)  
8 The potential for growth of inland waterway transport (IWT), and its integration into the logistics chains, has 
been  assessed  in  the  context  of  Platina3  project  (H2020  Research  project:  Market  development  and  logistic 
integration (platina3.eu)).  
9 COM/2021/324 final 
10 Source: EU transport in figures. Statistical pocketbook 2022 (europa.eu) 

2 

 
 
transport activity11 within the Netherlands (39.7%), Bulgaria and Romania (28% each) and a lower 
role  in  Belgium  (10.9%),  Luxemburg  (8.2%),  Germany  (7.3%),  Croatia  (6.0%)  and  Hungary 
(4.7%). Furthermore, (freight) IWT tends to be rather limited in the land freight transport activity in 
Slovakia (2.9%), Austria and France (2.1% each)12.  

According to Eurostat, around 5,500 IWT freight transport companies are active in Europe (EU plus 
Bosnia-Herzegovina, Serbia  and  Switzerland),  employing more than  23,000 persons.  In  addition, 
there  are  around  4,000  passenger  companies  which  employ  around  14,000  persons.  Thus,  it  is  a 
small sector when considering the overall number of transport companies. The sector is also small in 
terms of turnover, reporting a turnover of EUR 7 billion in 2020 (1% of the turnover of the transport 
sector)13. 

While  no  detailed  data  is  available  at  EU  level,  one  characteristic  of  the  IWT  sector  is  the  high 
number of Small and Medium Enterprises (SMEs). According to the CCNR, the majority of IWT 
companies  in  Western  Europe  are  small  family  owned  operating  one  or  two  vessels,  while 
companies  in  the  Danube  region  are  bigger  as  they  derive  from  previously  state-owned 
enterprises14.  

1.2  What are River Information Services (RIS)  

Currently,  RIS  concern  the  provision  of  a  range  of  services  to  support  traffic  and  transport 
management  in  inland  navigation15.  The  development  of  these  services  is  based  on  four 
technologies16,  whose  technical  specifications  govern  how the  relevant  information  is shared  and 
presented among the RIS users.  

Member  States  have  set  up  RIS  authorities,  who  are  responsible  for  the  implementation  and 
maintenance of RIS. National RIS authorities inform vessel operators (skippers) about the situation 
on  the  rivers  (current  parameters  of  waterways  like  fairway  depth,  clearance  under  the  bridges, 
closure of waterways due to accidents/works, lock closures, etc.). This helps operators in safe and 
efficient navigation. In managing traffic, authorities may request vessels to adapt their navigation 
(e.g. speed) to avoid bottlenecks. On the other hand, vessel operators report important elements to 
the national RIS authorities, such as their position, carriage of dangerous goods, etc.  

Vessel  operators  need  to  (re)submit  reports  at  various  instances  during  their  voyage,  and  when 
crossing a border. The exchange of information can take place by electronic means or radio and may 
vary depending on the situation and the country of navigation. Basic information on RIS (such as 
geographical positioning of bridges) is included in databases (e.g. RIS Index in ERDMS) which are 
updated by the Member States. Vessel operators communicate with inland ports (e.g. to announce 
their expected time of arrival) individually, often via radio, and there is almost no direct exchange of 

11 Including road, rail, IWT and pipeline transport.  
12 Source: EU transport in figures. Statistical pocketbook 2022 (europa.eu)  
13 https://transport.ec.europa.eu/facts-funding/studies-data/eu-transport-figures-statistical-pocketbook/statistical-
pocketbook-2023_en  
14  CCNR  (2020)  Marker  Report  2014-2019,  Main  features  and  trends  of  the  European  Inland  Waterway 
Transport Sector, Market-report-2014-2019_Web_BD.pdf (inland-navigation-market.org)  
15  This  includes  elements  such  as  fairway  information,  traffic  information,  traffic  management,  calamity 
abatement support, information for transport logistics, information for law compliance, statistics and waterway 
charges and harbour dues.  
16 Inland Electronic Chart Display and Information Systems (ECDIS), Electronic Reporting International (ERI), 
Notices to Skippers (NtS), Vessel Tracking and Tracing (VTT).  

3 

 
 
information with other modes of transport. 

Technical  specifications  for  the  provision  of  RIS  are  adopted  by  the  Commission,  with  the 
assistance  of  RIS  experts  from  the  Member  States.  The  Commission  is  also  responsible  for 
monitoring the overall implementation of RIS by Member States. Further technical information on 
RIS  is  included  in  Annex  9.  The  current  setting  of  RIS  in  the  EU  is  also  illustrated  in  Figure  2 
below. 

Figure 2: Current setting of RIS in the EU 

Source: European Commission 

1.3  Political and legal context 

International, national and regional context 

A range of institutional actors play a role in the development and implementation of RIS activities in 
Europe. These include, at international level: the United Nations Economic Commission for Europe 
(UNECE), and the World Association for Waterborne Transport Infrastructure  (PIANC17), which 
have  developed  non-binding  standards  and  guidelines  for  RIS.  At  EU  level  the  European 
Committee  for  drawing  up  Common  Standards  in  the  field  of  Inland  Navigation  (CESNI)  was 
created  by  the  European  Commission  and  the  Central  Commission  for  Navigation  on  the  Rhine 
(CCNR)  to  develop  technical  specifications  and  requirements  for  vessels,  personal  qualifications 
and digitalisation for IWT. Finally at regional area level, river commissions such as (CCNR), the 
Danube Commission, the  Sava  Commission  and  the Moselle  Commission  should play  a role  by 
facilitating  the  harmonisation  of  rules  in  IWT  in  the  respective  rivers.  Of  these  the  CCNR  is 
developing and applying mandatory requirements and regulations for their Member States in line 
with the EU legislation.  

17 PIANC (formerly the  Permanent International Commission for the Navigation Congresses) is known for the 
RIS guidelines which have been adopted through Commission Regulation (EC) 414/2007. 

4 

                                                                                                                                                                                                                                                                                                                                               
 
 
In addition, the Member States are involved in different platform and expert groups. These include 
the  four  temporary  working  groups  of  CESNI/TI  (working  group  on  information  technologies) 
tasked  with  the  development  and  updating  of  the  technical  specifications  for  the  different  RIS 
technologies18. 

EU policy context 

The Commission’s Communication on a Sustainable and Smart Mobility Strategy (SSMS)19 sets 
out the EU vision for the transport system of the future. The SSMS recognises that significant steps 
have  been  taken  to  support  the  deployment  of  harmonised  RIS  to  enable  seamless  transport  and 
traffic management on the European inland waterways. The evolution of RIS needs however to take 
into  consideration  new  requirements  stemming  from  the  digital  transformation  happening  in  the 
transport sector (e.g. smart shipping applications that increase performance of IWT operations, port 
information  systems,  autonomous  ships  for  inland  waterways,  etc.).  The  revision  of  the  RIS 
Directive  has  been  announced  under  Flagship  6  of  SSMS  (Making  connected  and  automated 
multimodal mobility a reality).  

In 2018, the Council, in its conclusions on Inland Waterway Transport20, invited the Commission to 
develop an implementation strategy for digitalisation, including River Information Services (RIS). 
Following the Council conclusions and the SSMS, the 2021  NAIADES III Communication21 set 
out an action plan to boost the role of inland waterway transport in the EU mobility and logistics 
systems. The core objectives were to shift more cargo to Europe's rivers and canals, and to facilitate 
the  transition  to  zero-emission  barges  by  2050.  The  importance  for  IWT  to  keep  up  with  digital 
developments to improve the sector’s competitiveness and ensure that it becomes an active part of 
broader  multimodal  chains  was  recognised.  Besides  the  revision  of  the  Directive,  the 
Communication  calls  on  Member  States  to  implement  smart  traffic  and  management  solutions 
based on RIS. It also considers that a permanent operational structure to provide a single point of 
access  for  RIS-based  corridor  information  services  developed  by  the  Member  States  could  be 
supported financially by the Connecting Europe Facility (CEF). The Communication confirms that 
the Commission will continue supporting CESNI through the Connecting Europe Facility, with the 
mandate of developing harmonised EU technical specifications for inland waterway transport. 

The  2021  European  Parliament  report  “Towards  future-proof  inland  waterway  transport  in 
Europe”22 stressed the need to further harmonise river information services. This should simplify 
procedures in regulating inland navigation, reduce problems arising from different interpretations of 
technical  standards  and  the  lack  of  comparable  data,  and  allow  for  the  speedy  development  and 
deployment  of  innovative  solutions.  In  its  2022  conclusions  on  NAIADES  III23,  the  Council 
encouraged  the  Member  States  to  continue  and  intensify  their  cooperation  in  the  harmonised 
implementation  of  RIS.  It  invited  the  Commission  to  present  a  proposal  for  reviewing  the  RIS 
Directive, to establish the Directive as an effective tool supporting multimodal freight operations, 
with a particular focus on seamless cross-border connections and interoperability. 

18 Inland Electronic Chart Display and Information Systems (ECDIS), Electronic Reporting International (ERI), 
Notices to Skippers (NtS), Vessel Tracking and Tracing (VTT). 
19 COM/2020/789 final 
20 https://data.consilium.europa.eu/doc/document/ST-13745-2018-INIT/en/pdf  
21 COM/2021/324 final 
22 https://www.europarl.europa.eu/doceo/document/A-9-2021-0231_EN.html  
23 https://data.consilium.europa.eu/doc/document/ST-14847-2022-INIT/en/pdf  

5 

 
 
RIS  is  not  the  only  digital  element  for  IWT.  In  accordance  with  the  Directive  on  technical 
requirements for inland waterway vessels24, the Commission maintains the European Hull Database 
(EHDB), containing selected information regarding inland waterway craft, including each vessel’s 
unique European vessel identification number, its name, its dimensions and other data identifying 
the vessel. The Directive on the recognition of professional qualifications in inland navigation25 also 
facilitates the electronic exchange of information about crew members by setting up a system of 
national registers and a database, kept by the Commission (European Crew Database - ECDB).  

RIS has benefited from EU funding support, in particular EUR 29.6 million TEN-T funding for 19 
actions during the period 2007-2013 (for projects of total cost of almost EUR 85 million) and some 
EUR 33 million CEF1 funding for 11 actions (of total cost of EUR 58 million) for the period 2014-
202026.  Under  CEF2  (2021-2027),  so  far,  the  EU  has  supported  1  RIS  project  with  EUR  18.2 
million (out of a total cost of EUR 36.4 million). 

The RIS Directive 

The  legislative  process to regulate RIS  at  EU level started  in 2005  with the  adoption  of the  RIS 
Directive.  The  Directive  establishes  a  framework  for  the  deployment  and  use  of  harmonised, 
interoperable and open RIS aiming to enhance safety, efficiency and environmental friendliness of 
inland waterway transport in the EU. It intended to facilitate interfaces with other transport modes, 
thus  considering  the  multimodal  potential  of  IWT.  At  the  same  time,  however,  the  definition 
(Article 3) makes it clear that RIS is aimed at the exchange of information between authorities and 
between  authorities  and  IWT  companies,  and  not  between  one  or  more  involved  companies  (no 
business-to-business  exchange).  It  specifies  though  that  RIS  should  be  open  for  interfacing  with 
commercial activities. 

One  of  the  objectives  of  RIS  is  to  enhance  the  safety  of  inland  navigation  by  optimizing  the 
waterway and traffic related information exchange between vessels, locks and bridges, terminals, 
and ports. It does not deal with other traffic safety aspects, which are under the responsibility of the 
Member States through the  European Code  for  Inland  Waterways  (CEVNI)27,  or national Police 
Regulations. 

Within  the  EU  framework  established  by  the  Directive,  the  Directive  itself  provides  the  general 
requirements of how RIS should be set up by the Member States, as well as the areas for which 
technical specifications need to be developed and the principles to be followed. The actual technical 
guidelines  and  specifications  are  developed  by  the  Commission  and  are  then  adopted  through 
secondary legislation. Five implementing acts have been adopted to provide the technical aspects of 
the  RIS  Directive’s  requirements  to  make  up  the  RIS  framework28.  Member  States  are  then 
responsible for implementing the Directive and applying the technical specifications in an efficient, 
expandable  and  interoperable  way  (e.g.  establishing  RIS  centres  and  designating  authorities  to 
oversee its application and the exchange of cross-border data).  

24 Directive (EU) 2016/1629. 
25 Directive (EU) 2017/2397. 
26 https://cinea.ec.europa.eu/our-projects_en  
27 This is elaborated within UNECE. The latest version is the sixth revision available here: 
https://unece.org/info/publications/pub/363912. 
28  Commission  Regulation  (EC)  No  414/2007,  Commission  Implementing  Regulation  (EU)  2019/838; 
Commission  Implementing  Regulation  (EU)  2018/2032;  Commission  Implementing  Regulation  (EU) 
2019/1744; Commission Implementing Regulation (EU) 2018/1973. 

6 

 
 
The RIS Directive applies to Member States with cross-border inland waterways of Classification of 
European Inland Waterways (CEMT) class IV29 and above (Article 2). In practice, these are 13 EU 
Member  States:  Austria,  Belgium,  Bulgaria,  Croatia,  Czechia,  France,  Germany,  Hungary, 
Luxembourg, the Netherlands, Poland, Romania and Slovakia, which have all had transposed the 
Directive by 2011. Several other countries apply the Directive voluntarily (i.e. Spain, Italy, Portugal, 
Switzerland, Serbia, Moldova and Ukraine).  

Synergies with other EU policy instruments 

The TEN-T Regulation30 establishes guidelines for the development of the trans-European transport 
network,  which  also  consists  of  the  infrastructure  for  inland  waterway  transport.  Some  of  the 
Regulation’s priorities deal with information and communication technology, such as implementing 
telematics  applications  (including  RIS),  while  others  deal  with  multimodal  aspects,  such  as 
connecting  inland  port  infrastructure  to  rail  freight  and  road  transport  infrastructure.  As  regards 
IWT, the TEN-T network is based on a minimum classification (CEMT class IV and above), but 
unlike the RIS Directive, it is not limited to interconnected waterways (for example the Po in Italy, 
or  the  Douro  in  Portugal  are  part  of  TEN-T  even  if  not  within  the  scope  of  the  RIS  Directive). 
Therefore,  the  scope  of  these  two  acts  is  not  identical.  The  European  Commission  adopted  a 
legislative  proposal31  amending  the  TEN-T  Regulation,  where  RIS  is  a  requirement  for  the  core 
network.  Under  the  proposed  revision  of  the  TEN-T  Regulation,  RIS  requirements  will  not  be 
linked any more to the CEMT classification (which are based on parameters for the vessels), but 
will follow requirements based on the infrastructure (e.g. depth). 

The RIS Directive requires continuity with systems of other modes and, in particular, with maritime 
transport (Article 1). In this regard, the regulation establishing a European Maritime Single Window 
environment32  provides  for  a  legal  and  technical  framework  for  the  electronic  transmission  of 
information  about  reporting  obligations  for  ships  calling  at  EU  ports.  Certain  types  of  this 
information may be relevant to be further exchanged with IWTs.  

The  eFTI  Regulation33,  established  a  legal  framework  that  allows  economic  operators  to  share 
information in an electronic format (i.e. for the transport of goods by road, rail, inland waterways 
and air  in the  European  Union)  with enforcement  authorities.  Operators  are  not  obliged to make 
regulatory  information  available  electronically  to  a  competent  authority.  However,  when  they 
choose to make this information  available  electronically,  they must follow  a  set of  requirements. 
Currently, there is limited interaction between RIS and eFTI, however, there are potential synergies, 
in terms of use of eFTI platforms for the exchange of cargo information required by RIS.  

The  new  Alternative  Fuels  Infrastructure  Regulation  (AFIR)34  introduces  targets  for  shore-side 
electricity supply in inland waterway ports, and requires Member States to prepare national policy 
frameworks, which among others will contain planned initiatives for deployment of infrastructure 
for  alternative  fuels  in  inland  waterway  transport,  such  as  for  hydrogen  and  electricity.  RIS  can 
complement  AFIR,  by  facilitating  the  exchange  of  information  between  inland  vessels  and  ports 

29 80-85 metres in length with tonnage of 100-1500 tonnes 
30 Regulation (EU) No 1315/2013. 
31  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 
32 Regulation (EU) 2019/1239. 
33 Regulation (EU) 2020/1056. 
34 Regulation (EU) 2023/1804. 

7 

 
 
equipped for such alternative fuels and, in particular, on the (real-time) availability of infrastructure. 
This in turn can support the uptake of these fuels by the IWT sector.  

The RIS Directive enables the exchange of data, and certain elements (such as data relating to the 
position of the vessel) can be considered as falling under personal data. Two cross-cutting legislative 
instruments are relevant in the context of digital inland navigation: Regulation (EU) 2016/679 (the 
General  Data  Protection  Regulation  –  GDPR)  and  Regulation  (EU)  2018/1725  on  processing  of 
personal data by the Union institutions35. The GDPR sets forth a single set of rules across the EU to 
protect and empower all EU individuals with regard to the processing of their personal data, and to 
hold  organisations  processing  personal  data  of  individuals  in  the  EU  accountable  for  their 
processing  activities.  It  gives  powers  to  the  competent  data  protection  supervisory  authorities  to 
impose corrective measures, fines and penalties on companies that do not comply with these rules. 
Regulation  (EC) No  45/2001,  mentioned in  the RIS Directive, was  replaced  by Regulation (EU) 
2018/1725.  A  requirement  of  data  protection  acquis  is  to  lay  down  a  clear  legal  framework 
identifying personal data, which must be shared in situations where the sharing is necessary for an 
objective of public interest. However, it needs to be taken into consideration that the RIS Directive 
itself  is  not  obliging  the  exchange  or  disclosure  of  personal  data.  The  RIS  Directive  is  a  legal 
framework providing for the technical requirements, specifications and conditions which ensure the 
electronic exchange of this data if national or international regulations foresee such exchange. It can 
therefore  only  lay  down  requirements  for  organisational  and  technical  data  protection  measures, 
should RIS be used to exchange also personal data to ensure protection of those data.  

Synergies with other non-legislative tools 

•  At European level, the following central systems include IWT elements: The European reference 
data management system (ERDMS) is a publicly accessible database kept by the Commission, 
containing regularly updated data provided by the Member States necessary for the provision of 
RIS.  It  contains  detailed  information  about  the  inland  waterway  infrastructure  (e.g.  bridges, 
locks,  terminals),  including  geolocation  (RIS  Index),  formats  of  Notices  to  Skippers  in  all 
languages,  and  unified  UNECE  coding  for  cargo  and  vessels  necessary  for  reporting 
requirements. In addition, it includes reference data for the European Crew Database (ECDB), 
and information on the competent RIS authorities. This use of standardised lists and data makes 
the ERDMS an enabler of interoperability.  

•  The CEF-funded project RIS COMEX (2016-2022) is a partnership of 13 European countries36 
to  develop  selected  RIS  Corridor  Services  along  7  European  inland  waterway  corridors.  This 
project  resulted  in  a  common  European  RIS  system  called  EuRIS  providing  reliable  fairway, 
infrastructure, traffic and transport information services, including route and transport planning, 
for the waterways of the partner countries. In addition, within RIS COMEX another system was 
developed to tackle administrative barriers and reporting burden for 8 IWT European countries37 
through a common electronic reporting system called CEERIS. CEERIS enables vessel operators 
to easily fulfil all their reporting duties to the different authorities along their route within the 
participating  countries  by  reporting-only-once  with  single-entering-of-data  and  digital-by-
default. The 13 participating Member States and their authorities continue with the use of this 

35 The GDPR replaces the Data Protection Directive (Directive 95/46/EC). Data Protection Directive is currently 
referred to in the RIS Directive in relation to rules on privacy, security and the re-use of information.  
36  Austria,  Belgium,  Bulgaria,  Croatia,  Czech  Republic,  France,  Germany,  Hungary,  Luxembourg,  the 
Netherlands, Romania, Serbia and Slovakia. 
37 Austria, Bulgaria, Croatia, Czech Republic, Hungary, Romania, Serbia and Slovakia. 

8 

 
 
system under a separate European Corridor Management Agreement38. The project has recently 
entered a second stage (RIS COMEX 2) with additional CEF funding39, with Poland joining the 
partnership. It shall continue the work of the first stage by extending the quantity and quality of 
the  related  services  and  provided  data,  by  extending  the  geographical  scope  to  additional 
waterways and even to additional countries (Poland), as well as by focusing on interconnections 
and integrations of existing systems and services40.  

1.4  Evaluation of the RIS Directive 

An evaluation of the  Directive was carried out in  202141. It found that overall, the Directive has 
been one of the main drivers of digitalisation in IWT, facilitating the introduction of information and 
communication technologies.  

In  terms  of  effectiveness  the  evaluation  found  that  standardisation  of  RIS  has  been  the  strongest 
benefit brought about by the Directive. However,  the degree of harmonisation differs  across RIS 
technologies and services (e.g. most harmonisation was achieved in type approval and the least in 
electronic  ship  reporting).  Moreover,  RIS  technologies  are  not  utilised  to  the  same  extent  in  all 
countries and river corridors, which has led to a fragmented development of RIS. Therefore, higher 
benefits of digitalisation and data exchange are hindered by the lack of full harmonisation of data 
provided across the Member States.  

The evaluation also pointed to a slow development of RIS. Public and private stakeholders reported 
on major inefficiencies in the adoption speed of the RIS implementing acts, resulting in permanently 
outdated technical specifications for the sector.  In terms of efficiency, potential for simplification 
was thus identified for the adoption process of technical specifications. Stakeholders also suggested 
that  an  improved  monitoring  of  the  application  of  the  Directive  is  required  to  speed  up  the 
development of RIS. 

As regards the general objectives of the RIS Directive, the available data did not indicate that RIS 
had an impact on the growth of the inland navigation sector, on modal shift or on safety. There were 
some  indications  that  RIS  has  reduced  fuel  consumption  by  1.9%.  Lack  of  evidence  did  not 
however allow to draw conclusions on the optimised use of existing infrastructure. Feedback from 
stakeholders  showed  that  RIS  may  have  a  limited  or  even  indirect  impact  on  competitiveness,  a 
potential for more efficient use of infrastructure (locks), and a positive impact on safety.  

Although  the  evaluation  assessed  that  the  Directive  is  still  relevant,  it  pointed  to  the  fact  that  its 
primary focus on safety of navigation is no longer  sufficiently aligned with sector’s needs. More 
specifically, it does not support the need for improving the efficiency of inland waterway transport 
and its integration into the multimodal supply chains.  In addition, it does not sufficiently  address 
new technological  challenges,  such  as  automation of vessels,  and  the  further  digitalisation of the 
sector.  

38 The  agreement defines the governance structure, financing, sharing of costs, and other elements such as the 
“Partnership Coordinator” who manages the platform. 
39 https://cinea.ec.europa.eu/system/files/2023-06/Overview%20Selected%20Proposals_FINAL.pdf  
40 In this document, the term RIS COMEX is used to refer to the overall project (including RIS COMEX 2 and 
all applications, as EuRIS, CEERIS) as developed by the EU Member States 
41 SWD/2021/0050 final 

9 

 
 
The rationale for public intervention at EU level through the RIS Directive is rooted in the cross-
border character of the inland waterway transport sector and contributes to avoiding fragmentation 
between different national or regional (e.g. between the River Commissions) RIS implementation 
approaches.  Stakeholders  considered  that  the  same  benefits  could  not  have  been  achieved  by 
comparable interventions at the international, regional or national level. However, higher benefits of 
digitalisation  and  data  exchange  are  hindered  by  the  lack  of  full  harmonisation  of  data  provided 
across the Member States.  

Last but not least, it should be noted that the evaluation identified a considerable lack of reliable, 
sufficiently granular and comparable data (in particular for costs and benefits of implementation), 
which in turn limited the quantitative evidence supporting the findings. Thus, the findings had to 
rely  primarily  on  qualitative  analysis  and  input  from  stakeholders.  The  links  between  the 
conclusions of the evaluation and the impact assessment are summarised in Annex 7. 

1.5  Sustainable Development Goals 

The initiative contributes towards the objectives of the European Green Deal (EGD)42 (in particular 
by  supporting  the  shift  away  from  road  transport).  The  revision  of  the  RIS  Directive  contributes 
towards Sustainable Development Goal (SDG) 9 (“Build resilient infrastructure, promote inclusive 
and  sustainable  industrialisation  and  foster  innovation”)  and  SDG  13  (“Take  urgent  action  to 
combat climate change and its impacts”). 

2  PROBLEM DEFINITION 

The key problem, corresponding drivers and consequences that are relevant for the revision of the 
Directive are presented in Figure 3 and further detailed below. 

Figure 3: Problem tree 

Source: European Commission 

42 https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal_en#documents  

10 

 
 
 
2.1  What is the problem? 

Problem:  slow  and  fragmented  deployment  of  River  Information  Services  that  hamper  the 
competitiveness  and  safety  of  the  sector,  and  its  contribution  towards  the  European  Green  Deal 
objectives  

Description of the problem 

The main challenge that RIS faces today is the slow speed and the fragmentation in its deployment. 
The  TEN-T  corridor  studies43  report  that  the  deployment  of  RIS  infrastructure  along  the  Core 
Network  Corridors  cover:  100%  of  the  North  Sea,  Mediterranean  and  Rhine-Danube  Corridors, 
95%  of  the  Atlantic  Corridor,  90%  of  the  East  Mediterranean  Corridor  and  75%  of  the 
Mediterranean Corridor. Thus, despite 17 years since its introduction, it still has not reached 100% 
level  of  implementation.  The  identified  differences  in  implementation  relate  to  prioritisation  by 
Member States of the most important waterways in their territories.  

While the RIS evaluation44 indicated a positive impact of the Directive in terms of harmonising RIS, 
it  found  that  there  is  still  room  for  improvement.  This  is  because,  when  considering  the 
implementation  of  the  Directive,  not  all  RIS  technologies  have  reached  the  same  level  of 
implementation  and  maturity  and  not  all  RIS  technologies  have  been  fully  utilised  to  the  same 
extent in all countries and river corridors. For example, differences in deployment across Member 
States  have  been  identified  for  the  four  key  RIS  technologies  (inland  ECDIS,  Electronic  Ship 
Reporting, Notices to Skippers, Vessel Tracking and Tracing). This is because Member States have 
not always followed the same timeline for implementation and/or because technical specifications 
have  not  always  been  applied  or  interpreted  the  same  way.  The  evaluation  identified  that  RIS 
equipment  has  reached  a  high  level  of  type  approval,  which  ensures  equipment  compatibility. 
Similarly, electronic charts are highly harmonised, which assists in navigation. On the other hand, 
the low harmonisation in electronic ship reporting and different national reporting requirements45 
result  in  resubmissions  of  electronic  reports,  with  time  and  cost  implications  for  operators.  The 
impact assessment support study estimates that a resubmission of information is required in one out 
of three times that a vessel crossed a border during its voyage46. Therefore, the problem is not so 
much  in  relation  to  the  situation  within  a  certain  Member  State,  but  in  how  their  heterogeneity 
affects the international nature of inland waterways.  

The slow update of technical specifications has played an important role in the slow development of 
RIS. In the current setting of adopting implementing acts, it takes between 5 and 12 years until the 
technical specifications are prepared and introduced in the sector. This in turn reduces the efficiency 
of IWT operators due to the use of old technical specifications and technology (for example when 
radio  is  still  used  instead  of  electronic  communication  for  reports  between  the  ship  and  the 

43 https://transport.ec.europa.eu/transport-themes/infrastructure-and-investment/trans-european-transport-
network-ten-t/ten-t-governance_en  
44 SWD(2021)0050 final  
45 For example, in the borders between Germany and Poland, between Germany and Czechia and on the Danube 
Member States. https://www.masterplandiwa.eu/  
46 Ramboll et al. (2024), Impact assessment  support study shows that some 106,622 border crossings required 
repeated notifications in 2020 (around 30% of the total number of border crossings). It should be noted that due 
to the COVID-19 pandemic the number of border crossings in 2020 was particularly low (i.e. 19% lower than in 
2015).  

11 

 
 
authorities)47. This contrasts with the approach followed in Directive (EU) 2016/1629 providing for 
technical  requirements  for  inland  vessels,  which  includes  a  direct  reference  to  technical 
specifications  developed  by  CESNI,  leading  to  a  regular  update  of  technical  specifications  every 
two  years.  As  technological  development  keeps  accelerating,  the  slow  update  of  technical 
specifications in the RIS domain becomes a more acute hindrance.  

The  DINA  report  (2017)48  examined  factors  relating  to  digitalisation  and  their  impact  on  the 
competitiveness of the sector compared to other transport modes. RIS was identified as playing an 
important role in IWT. Thus, if not properly deployed, RIS can hinder the competitiveness potential 
of the sector. The DINA report  also found IWT to be falling behind other modes of transport in 
terms  of  digitalisation  and  development  of  intelligent  systems  for  reasons  ranging  from  legal, 
technical and commercial bottlenecks to sharing of data, the IT set-up of barge operators, and the 
limited size of the sector (making it difficult to achieve economies of scale for new solutions). So 
far, the modal split of IWT has remained fairly stable over the past 20 years and the evaluation was 
not able to conclude if RIS had any impact in this development. 

In terms of increased environmental protection, the evaluation pointed to a very modest reduction in 
fuel consumption by vessels through the use of RIS. However, it can be argued that better planning 
of trips and increased awareness of the traffic situation, could lead to more efficient navigation (e.g. 
by slower steaming when anticipating a long wait at a lock, thus improving fuel consumption49).  

The lack of quantitative data, also identified by the evaluation, does not allow for a more detailed 
and quantitative illustration of the evidence supporting the problem. As the evaluation noted, there is 
considerable  lack  of  reliable,  sufficiently  granular  and  comparable  data,  which  does  not  allow 
quantification  of  the  magnitude  of  the  problem.  Due  to  the  nature  of  inland  waterway  transport 
being  concentrated  in  navigable  waterways,  and  the  scope  of  application  of  RIS,  the  problem  is 
materialising  only  in  those  waterways  where  RIS  is  introduced  and  applied.  It  is  thus  highly 
geographically focused and specialised. When considering the size of the sector, the magnitude of 
the problem will be necessarily limited in any comparison with the rest of the transport sector.  

Still, the immediately affected stakeholders consider this to be an important problem. The Members 
States that participated in the open public consultation (Austria, Belgium, Croatia, France, Germany, 
the Netherlands, Portugal and Romania) supported the need for revising the Directive. This view 
was also supported during the first stakeholder survey50, where 9 out of 13 administrations indicated 
that no EU action would lead to negative developments in terms of RIS deployment. This position 

47 Reporting formalities such as provision of voyage and cargo information to the responsible authorities are 
often done through VHF radio frequencies or, where there is no obligation, the reporting may even be submitted 
on paper: https://platina3.eu/download/digital-and-automated-
infrastructure/?wpdmdl=975&refresh=646f9a8f1ada91685035663 
48 European Commission (2017):  Digital inland waterway areas. Towards a digital inland waterway  area and 
digital multimodal nodes. Final report 
49 The energy consumption of a barge depends, among other things, on the vessel’s cruising speed, the resistance 
the vessel encounters from the water and the depth of the water. Several studies, including Hekkenberg (2017), 
European  Journal  of  Transport  and  Infrastructure  Research,  17  (4),  508-529,  show  a  third-power  relationship 
between the amount of propulsion energy required and speed.  
50 In the context of the impact assessment support study, two surveys were carried out. The first survey collected 
information  on  the  identified  problems  and  policy  measures  from  various  stakeholders  (public  bodies  at 
international, European and national level, private  sector companies/representative organizations, EU citizens). 
This  survey  was  carried  out  between  1  August  2022  and  26  August.  A  second  survey  collected  views  of  the 
stakeholders on the costs and benefits of each of the proposed policy measure. The second survey was carried 
out in second half of 2022. 

12 

 
 
was  reiterated  at  the  first  DINA/NAIADES  expert  groups  meetings.  It  should  also  be  noted,  as 
explained in section 1, that there has been a clear request from both the European Parliament and the 
Council to revise the RIS Directive. 

The  respondents  to  the  stakeholder  consultation,  as  explained  in  Annex  2,  acknowledged  the 
problem identified, mentioning clearly that full harmonisation and interoperability of RIS has not 
yet been achieved due to fragmented implementation. According to the open public consultation, 
stakeholders find that the identified problem (and the drivers) relate to actual challenges of the IWT, 
as shown in Figure 4 below. 

Figure 4: Importance of challenges in the implementation of River Information Services (RIS) in Europe 

Source: Open Public Consultation 

Who is affected and how? 

The  problem  identified  affects  different  actors  (vessel  operators,  navigation  software  service 
providers, national public administrations and society at large) in different ways:  

•  Vessel operators are confronted with time consuming notification processes to authorities, as 
e.g. repeated notifications are required when crossing borders. They are also faced with extra 
efforts and time spent to obtain accurate information for planning their voyage. Non-accurate 
information, in particular regarding the navigation conditions on the river, can have negative 
impacts on the actual voyage of the vessel in terms of timing (e.g. due to congestion at locks) or 
in  rare  situations  contribute  to  accidents.  Sub-optimal  operation  can  translate  into  reliability 
issues  for  the  services  (e.g.  vessel  arriving  later  than  planned),  which,  in  turn,  reduce  the 
attractiveness of the sector for the freight shippers. Non-efficient navigation also translates into 
higher  cruising  speeds  than  necessary,  which  lead  to  increased  fuel  consumption  and  thus 
increased  costs  for  the  sector.  Differences  in  standards  between  countries  and  the  additional 
complications  in  terms  of  operations  that  these  may  require  are  hindering  the  provision  of 
services and creating market distortions. An example is the closure of locks not linked to real-
time information or the predictions on water level in some countries. This in turn reduces the 
reliability  of  IWT  and  its  competitive  position  with  respect  to  other  modes,  thus  leading  to 
market distortion at multimodal level.  

•  Navigation  software  service  providers  are  dependent  for  the  development  of  their  IT 
solutions on access to accurate basic data. To ensure the accuracy of the data under the current 
framework,  they  need  to  allocate  extra  efforts  to  collect  the  data  due  to  wrong  or  outdated 
information.  

•  National  public  administrations  also  face  challenges,  in  particular  when  handling  cargo 
reports  in  paper  format,  which  require  efforts  to  process  them.  Efforts  are  also  required  to 

13 

 
 
process repeated reporting, including those required when a vessel is crossing the border. In 
addition, incomplete information regarding the traffic in the waterways does not allow national 
authorities  to  efficiently  manage  traffic  and  may  hinder  their  ability  to  react  to  emergency 
situations (e.g. in case of an accident if the dangerous cargo information has  been submitted 
with errors).  

•  For  the  society  at  large,  the  overall  challenges  translate  into  external  costs  stemming  from 

freight being transported on road. 

A number of Member States, without navigable waterways or with waterways out of the scope of 
the  Directive,  are  not  affected  by  the  problem.  The  Member  States  withing  the  scope  of  the 
Directive show significant differences driven by the size of their network, the number of ports and 
the level of traffic. For example, as explained in section 1, Germany and the Netherlands accounted 
for  69%  of  overall  EU  IWT  transport  in  202051.  In  terms  of  national  modal  split,  IWT  plays  a 
significant role in the land freight transport activity52 within the Netherlands (39.7%), Bulgaria and 
Romania (28% each) and a lower role in Belgium (10.9%), Luxemburg (8.2%), Germany (7.3%), 
Croatia (6.0%) and Hungary (4.7%).  

An  important  element  of  IWT  is  its  cross-border  dimension.  Thus,  the  challenges  are  more 
important when a difference in a technical specification appears between two Member States with 
high volumes of traffic. Beyond this, there are no specific problems for regions, local authorities, 
private entities or individual EU areas. 

What are the consequences of the problem? 

The slow and fragmented deployment of RIS technologies has a number of consequences. The first 
one  relates  to  the  geographical  dimension.  For  example,  for  the  Notices  to  Skippers  (NtS)  the 
coverage has not reached 100% in all countries. This means that there are areas with gaps, where 
skippers do not receive the same level of information regarding the rivers and their condition. This, 
in turn, impacts the navigation efficiency of the vessel and may lead to safety risks for those areas. 
The  second  consequence  has  to  do  with  missing  technical  specifications,  where  these  have  not 
been  developed  for  Vessel  Traffic  and  Tracing  (VTT).  In  the  absence  of  these  technical 
specifications,  Member  States  are  making  use  of  the  Automatic  Identification  System  (AIS)  for 
their needs, but there is not harmonised way on how, when and for which systems it should be used. 
And  while  its  use  within  a  specific  Member  State  may  not  be  problematic,  this  can  lead  to 
challenges when the vessel is crossing a border.  

Regarding  the  slow  update  of  technical  specifications  and  what  does  this  mean  in  view  of 
technological developments, this  can be illustrated  by  the  reporting of  cargo  information.  This is 
often done through VHF, which can lead to mistakes in the information provided. More up to date 
technical specifications could require the use of electronic exchange. Another illustrative example 
can be when the technical specification refers to specific software characteristics. When a new and 
improved version of the software is available, correcting possible challenges and introducing new 
functionalities,  vessel  operators  are  not  able  to  benefit  from  this  new  version  until  the  technical 
specifications have been updated. 

51 Source: EU transport in figures. Statistical pocketbook 2022 (europa.eu) 
52 Including road, rail, IWT and pipeline transport.  

14 

 
 
IWT  is  considered  generally  a  safe  mode  of  transport,  but  accidents  can  range  from  minimal 
incidents (e.g. a ship goes off course and collides with a bank or quay) to more serious collisions 
with bridges (where ships might completely destroy their wheelhouses).  

Statistics on accidents in inland waterways transport are limited. Eurostat collects accident statistics 
from national statistical offices on a voluntary basis. Not many countries in the EU provide data on 
accidents and there is no clear evidence on a common methodology used among the countries (see 
Figure 5). In addition, the current Eurostat data does not provide information about the type or the 
causes of the accidents. 

Figure 5: Accidents in IWT in selected Member States 

Source: Scheepsongevallenregistratie Rijkswaterstaat and Eurostat  

The  German53  statistics  for  1995-2017  provide  an  indication  of  the  main  causes  for  accidents: 
grounding,  ship  gets  stuck,  collision  between  ships,  collision  with  infrastructure  and  bridges, 
pounding of waves and other accidents. The most frequent types of accidents were the collision with 
infrastructure and bridges  (38-40% of all accidents) and the collision between ships (18-19%). It 
should also be mentioned that a significant share of total accidents (15-20%) involve small pleasure 
boats. No information has been obtained from insurance companies.  

Due to unavailability and unreliability of data on accidents, the RIS Directive evaluation was not 
able  to  identify  a  direct  link  between  RIS  and  improved  safety  on  waterways.  However,  the 
stakeholders  had  a  positive  view  on  its  impact  in  this  regard54.  An  example  is  the  fragmented 
implementation  (i.e.  data  is  available  in  different  national  systems),  which  means  that  there  is 
currently no harmonised system providing information on dynamic parameters for waterways. If the 
information  is  not  up-to-date  or  the  technical  specifications  applied  between  different  Member 
States are not compatible, this creates workload for skippers (who need to anticipate and account for 
possible  mistakes)  and  may  lead  to  accidents  (if  for  example  skippers  do  not  know  exactly  the 
height between the river and the bridge). 

One could think that slow speed would have an impact on safety. However, as explained above, the 
risk to safety comes rather from the lack of accurate information and awareness of the situation on 
the river. In terms of the causes of accidents, groundings are linked with inaccurate knowledge of 
the depth of the river at a certain point and time. Likewise, collisions with bridges are caused when 
the  distance  between  the  river  and  the  bridge  is  not  well  estimated  and  the  wheel  of  the  barge 
collides  with  the  bottom  of  the  bridge.  Collisions  between  vessels  can  happen  when  vessels 
operators are not aware of each other when rounding river bends. 

53 Source: German Waterway and Shipping Administration and the Ministry of Transport 
54  4  out  of  24  interviewees  and  3  out  of  9  survey  respondents  (mainly  vessel  owners),  highlighted  improved 
safety as a benefit resulting from data on navigation and planning. 

15 

 
 
 
As  regards  environmental  concerns,  the  EGD  and  the  SSMS  aim  to  reduce  the  environmental 
impact  of  the  transport  sector.  IWT  is  expected  to  play  its  role.  To  this  aim,  the  SSMS  set  a 
milestone for transport activity by inland waterways and short sea shipping to increase by 25% by 
2030 and by 50% by 2050. Improving the environmental performance of the sector is also one of 
the aims of the Directive. As this is primarily a digital initiative, its environmental contribution is not 
expected to be high; however, it can still play a role. On the one hand, improved technology should 
lead to more efficient navigation resulting in reduced energy use, with clear impacts on emissions. 
On  the  other  hand,  improved  reliability  of  the  sector  and  better  integration  into  the  multimodal 
logistic chains is expected to shift freight from road to inland waterways. The evaluation pointed to 
a small reduction in fuel consumption (1.9%) through the use of RIS. There is nevertheless further 
potential  for  improvement,  so  that  IWT  increases  its  contribution  towards  greening  the  transport 
sector. 

2.2  What are the problem drivers? 

Problem driver 1 (PD1): Missing and non-harmonised RIS information hampers efficient and safe 
navigation 

Users  continue  to  receive  fragmented  or  low-quality  information  from  Member  States  via  RIS, 
hampering  efficient  and  safe  navigation.  This  is  manifested  in  terms  of  differences  in  the  data 
quality of the underlying RIS. According to a stocktaking exercise of the situation in the Member 
States55, the basic requirements of the Directive were implemented (in terms of setting up of RIS 
centres and introducing legislation regarding the four basic RIS key technologies). However, certain 
elements  (like  the  ERDMS  data),  despite  their  importance,  are  not  mandatory,  which  introduces 
gaps and reduces the quality of RIS. Furthermore, the Directive is not prescriptive in the technical 
aspects but sets the higher-level principles and relies on the implementing acts to define the details. 
The implementing acts, despite their level of detail, appear to leave a room for manoeuvre in their 
implementation by the Member States in practice. For example, blockages of locks may be reported 
in the Notices to Skippers (NtS) as a complete blockage in one country but only as partial in others. 
This leads ships operators to spend time to properly interpret and confirm the data, in order to avoid 
surprises when arriving at the lock. These discrepancies impact inland waterways in two ways. On 
the  one  hand  efficient  navigation  is  hindered,  if  the  skippers  require  more  time  to  plan  their 
navigation  or  encounter  unexpected  delays  due  to  the  infrastructure  not  being  available.  It  was 
estimated that in 2020 14,800 hours were “wasted” due to these discrepancies56. On the other hand, 
these differences can lead to accidents if they are not identified on time.  

Figure 6 illustrates the status of electronic reporting system implementation and related international 
exchange  of  ERI  messages  among  neighbouring  countries.  This  is  the  area  where  the  lowest 
harmonisation was found, especially due to different reporting requirements in the Member States 
resulting in resubmissions of electronic reports. It shows that in the Rhine catchment for example, 

55  European  Commission  (2014),  RIS  implementation  survey  and  policy  evaluation  –  Country  Reports. 
https://transport.ec.europa.eu/system/files/2016-09/2014-07-ris-implementation-survey-and-policy-evaluation-
country-reports.pdf  
56 Based on discussions with training institutes and validated by the sector (in the context of the stakeholders’ 
consultation  for  the  impact  assessment)  who  indicated  that  of  an  average  15  minutes  spent  to  prepare  a  cross 
border  journey,  2.5  minutes  are  used  for  addressing  such  discrepancies.  Considering  the  355,406  border 
crossings in 2020, around 14,800 hours were spent, or around EUR 395,000. The weighted average of the tariff 
per  hour  for  non-manual  workers  (ISCO  8  –  Plant  and  machine  operators  and  assemblers)  in  the  13  Member 
State in the scope of RIS (EUR 26.7 per hour), based on Eurostat Structure of earnings survey (in 2022 prices), 
has been used to estimate the costs. 

16 

 
 
the  electronic  transmission  of  reports  is  generally  positive,  while  in  Eastern  Europe  (i.e.  borders 
between  Germany  and  Poland  as  well  as  Germany-Czech  Republic)  and  on  the  Danube,  it  is 
comparatively less harmonised. Thus, the problem is more concentrated in the geographical areas 
where less IWT freight volumes are moved. 

Figure 6: Landscape of electronic reporting systems and services in Europe in November 2020 

Source: DIWA Masterplan57 

This problem driver was indicated as very important by 12 out of 13 respondents in the Open Public 
Consultation (OPC). Furthermore, this was confirmed by the respondents to the first stakeholders’ 
survey58,  who  considered  this  driver  as  relevant  to  the  problem  (42  out  of  65  respondents).  The 
difference  in  data  formats  across  countries,  together  with  the  unreliability  of  the  RIS  Index,  as 
Member States update the information on a voluntary basis, were specifically mentioned as issues in 
the first survey. For example, 3 stakeholders representing international public bodies indicated that 
the RIS Index is not sufficiently reliable or clearly defined.  

During  the  second  stakeholder  workshop59  with  skippers,  it  emerged  that  information  on  water 

57 Masterplan DIWA SuAc 2.4 Final Report RIS Enabled Corridor Management 
58 In the context of the impact assessment support study, two surveys were carried out. The first survey collected 
information  on  the  identified  problems  and  policy  measures  from  various  stakeholders  (public  bodies  at 
international, European and national level, private  sector companies/representative organizations, EU citizens). 
This  survey  was  carried  out  between  1  August  2022  and  26  August.  A  second  survey  collected  views  of  the 
stakeholders on the costs and benefits of each of the proposed policy measure. The second survey was carried 
out in second half of 2022. 
59 Two stakeholder workshops were organised during the stakeholders’ consultation that focused specifically on 
the  vessel  operators  and  in  particular  skippers.  Their  aim  was  to  validate  estimates  on  costs  and  benefits 

17 

 
 
 
 
levels  is  also  crucial  for  skippers  to  plan  a  voyage.  They  also  flagged  that  missing  and  non-
harmonised  RIS  information  is  one  of  the  main  drivers  hampering  efficient  voyage  planning. 
Experts participating in the meetings of the DINA and NAIADES Expert Groups60 mentioned that 
the RIS Directive is in principle helpful but it should have been implemented better. On the other 
hand, the Commission did not receive formal complaints regarding  its implementation that could 
have led to infringements. Experts also mentioned that the newly developed EuRIS portal should 
positively affect the missing and non-harmonised RIS information61. 

Problem  driver  2  (PD2):  Inefficient  processes  for  creation  and  implementation  of  technical 
specifications for River Information Services 

The current system of updating RIS technical specifications is based on implementing acts adopted 
by  the  Commission.  With  the  current  setting  of  working  with  sectoral  experts  to  support  the 
Commission, this process takes around 10 years, which is very lengthy, particularly in view of the 
pace  of  technological  developments.  For  instance,  the  technical  specifications  for  Notices  to 
Skippers and for Vessel tracking and tracing systems, introduced in 2007, were updated in 2018 and 
2019,  respectively.  The  technical  specifications  for  electronic  reporting  of  2010  were  revised  in 
2019,  while  those  on  the  electronic  chart  display  and  information  system  for  inland  navigation 
(Inland  ECDIS)  adopted  in  2013,  were  revised  in  2018.  Moreover,  the  RIS  Guidelines  have  not 
been revised since 2007. 

Currently, the basic work on the preparation of technical specifications is undertaken by Member 
State experts who meet and discuss under different groups. These are then used as a basis for the 
Commission to prepare the relevant implementing acts. The self-organisation of the work by MS 
experts (with contributions from CCNR) seems to constitute an important bottleneck leading to a 
lengthy  process  (sometimes  between  7-8  years)  which  has  accordingly  been  criticised  by 
stakeholders.  In  the  stakeholders’  consultation  process  accompanying  the  RIS  evaluation, 
stakeholders  expressed  the  view  that  the  time  between  updates  is  too  long,  which  may  cause 
problems in terms of their relevance for the future. This is because outdated technical specifications 
do not  ensure  maintaining the  highest  level of  efficiency  and  do not  follow the  developments  in 
digital technology. An illustrative example relates to the technical specifications for Inland ECDIS 
(on points such as the resolution of digital maps, elements to be presented on maps, the way how 
they  should  be  presented,  etc.),  where  the  efficiency  of  digital  maps  is  linked  directly  with  the 
technology used (graphic programmes).  

In the OPC, 10 out of 13 respondents expressed the view that this a very important problem driver 
and 3 out of 13 respondents see it as a somewhat important driver. The first stakeholders’ survey 
showed a similar picture, where 40 out of 65 stakeholders perceived problem driver 2 as important.  

Besides the late introduction of technical specifications, the number of relevant implementing acts 
creates  a  challenge  for  the  sector.  Technical  specifications  are  spread  across  various  legislative 
measures, with negative consequences on their clarity and consequent uptake. This does not enable 

stemming  from  the  proposed  policy  measures.  The  discussions  revolved  around  subjects  such  as  voyage 
planning, the availability of infrastructure for the digital waterway network and the Smart Shipping concepts. 
60 https://ec.europa.eu/transparency/expert-groups-register/screen/expert-
groups/consult?lang=en&groupID=3505 and https://ec.europa.eu/transparency/expert-groups-
register/screen/expert-groups/consult?lang=en&groupID=3497  
61 The aim of the expert group meetings was to gather views on the proposed policy measures, including their 
costs and benefits. The discussions revolved around subjects such as the scope of eFTI and RIS, the complaint 
handling mechanism, the involvement of CESNI in RIS and the use of personal data. 

18 

 
 
the timely uptake of RIS in line with evolving technical innovations for two reasons: a) even minor 
updates  need  to  “wait”  for the  appropriate  technical  specification’s turn  and b) it multiplies the 
efforts  and  time  required  to  prepare  and  adopt  the  implementing  acts.  Participants  in  the  two 
stakeholder workshops organised during the stakeholders’ consultation flagged the existence of a 
wide variety of technical specifications and technical specifications which need to be implemented 
to  allow  RIS  to  remain  up  to  date  with  current  technical  developments.  New  developments  and 
challenges  (e.g.  digital  and  green  transitions,  which  were  not  in  focus  in  2005)  may  require 
additional data to be reported through RIS. To deal with these developments, the sector needs to 
adapt, for instance, through smart shipping approaches in the context of smart logistics framework. 
In this context, accurate information on waterway profiles, water levels and dimensions of structures 
form  an  absolute  necessity.  This  could  be  provided  through  RIS  services;  however,  the  current 
inefficient  processes  for  RIS  technical  specifications  and  delayed  uptake  of  evolving  technical 
innovation hinders the adoption of such technologies and makes IWT less competitive compared to 
other transport modes. 

This problem driver is also linked to problem driver 1. The lack of a frequent and regular update of 
technical specifications does not allow for corrective action to be taken on time. 

Problem driver 3 (PD3): River Information Services do not sufficiently support the integration of 
inland waterways transport into multimodal supply chains (modal shift) 

The  European  Green  Deal  requires  all  transport  modes,  including  inland  waterway  transport,  to 
address the greening and digitalisation transition. This includes a better integration between different 
modes  of  transport  into  a  seamless  intermodal  logistic  chain.  The  RIS  Directive  anticipates  the 
possibility  or  need  for  connecting  RIS  with  systems  of  other  modes,  in  particular  with  maritime 
transport. These links, however, have not been specified by the Directive or the implementing acts 
and no indication was identified that such connectivity exists at Member State level. 

At  the  same  time,  the  transport  sector  saw  developments  in  other  modes.  For  example,  legal 
provisions  for  other  cargo  tools  were  introduced  (2019  for  EMSWe  and  2020  for  eFTI).  The 
Directive lacks the framework to make the necessary links with these systems, and therefore cannot 
support the integration of IWT in the logistic chain.  

The RIS  evaluation  concluded that  the RIS  Directive so far  has  focused on  safety of  navigation, 
while not enabling the integration of inland waterway transport into multimodal supply chains. In 
the OPC, 11 out of 13 respondents considered this as a very or somewhat important problem driver. 
This view was further supported by the respondents to the first stakeholders’ survey, where 33 out 
of 65 respondents found problem driver 3 to be relevant. 

The  EU  transport  policy  aims  to  promote  less  polluting  and  more  energy  efficient  modes  of 
transport, including for freight, and actions are taken to support intermodal transport. In addition, 
since  the  adoption  of  the  RIS  Directive,  further  developments  have  taken  place  in  relation  to 
synchro-modality,  and  tools  have  been  developed  to  improve  the  efficiency  of  logistics  supply 
chains.  Initiatives  such  as  EMSWe  and  eFTI,  that  offer  opportunities  to  integrate  IWT  in  the 
logistics chain, were developed after the adoption of the RIS Directive. Thus, the Directive does not 
provide the proper framework to make the necessary links. On the other hand, experts (representing 
Member  State  authorities  and  vessel  operators)  participating  in  the  DINA  and  NAIADES  expert 
group meetings, pointed to the different aims and scopes of the initiatives (e.g. eFTI has a clear role 
for logistic and cargo related information, while RIS is viewed more as a tool for safety and traffic 
management  related  information),  and  cautioned  against  mixing  their  purposes.  Stakeholders 
participating at the dedicated workshops also expressed opposing views, with some seeing eFTI as 

19 

 
unrelated to RIS, while others  considering  that  eFTI  could be  used  by  all modes  (creating  a one 
stop-shop solution).  

The stakeholders participating in the first stakeholder workshop also shed some light on the need to 
find  a  common  denominator  between  different  navigation  transport  modes.  In  this  context,  ports 
play a crucial role as they provide the link between IWT and other modes such as  road and rail. 
However,  participants  pointed  out  that  technology  standards  in  delivering  information  are 
heterogeneous  across  inland  ports  as  they  are  developed  individually.  The  smooth  integration  of 
IWT in intermodal transport requires efficient and accurate information exchange with inland ports. 
As an illustration, a vessel operators representative indicated during the workshop that skippers on 
tanker vessels  need to know that ports have available capacity, as they often transport dangerous 
goods  that  can  only  be  kept  on  board  for  a  specific  period  of  time.  As  this  information  is  not 
foreseen in RIS, it increases the burden on skippers to plan their voyages. This view is confirmed by 
the  network  coverage  of the EuRIS  portal in  Germany.  For  example,  in  ports such as  Duisburg, 
Dusseldorf, Neuss, Mannheim and Karlsruhe, information on the dimensions of bridges over port 
basins  and  operating  times  is  lacking.  This  causes  the  need  for  extra  time  when  making  voyage 
preparations as skippers need to look up the required information on individual port websites. 

This lack of exchange of information with other modes is thus hindering the potential of IWT to 
perform in a multimodal chain and thus deliver on the objectives defined by the SSMS.  

Problem driver 4 (PD4): Inefficient exchange of information (including cross-border) and reporting 

An efficient exchange of information across borders between authorities is important for an efficient 
transport  system.  Despite  improved  Member  State  cooperation  over  time,  not  all  reports  are 
digitalised and, even when they are, Member States use different reporting applications that are not 
compatible  with  each  other62.  According  to  the  evaluation,  despite  the  adoption  of  the  RIS 
Directive, there has been no substantial reduction in the number of resubmissions of electronic ship 
reports at borders due to differences in national reporting obligations. The number of resubmissions 
of  electronic  reports  was  estimated  at  30%  of  total  number  of  border  crossings  (i.e.  106,622 
resubmissions in 2020). Each resubmission is estimated to require 15 minutes for vessel operators. 
Thus, vessel operators are estimated to have spent 25,841 hours for the resubmissions of electronic 
reports in 2020, equivalent to EUR 689,75963.  

In addition, based on the survey and the interviews with inland skippers it is estimated that inland 
skippers spend on average 10 minutes on reporting obligations in inland ports, with an estimated 
annual  total  cost  of  EUR  1.3  million  in  202064.  A  significant  part  of  these  costs  stem  from 
duplications that could be reduced or eliminated if a proper exchange of information between RIS 
and ports were in place. 

All 13 respondents to the OPC found problem driver 4 to be very or somewhat important. In the 

62 Currently, five different platforms/systems are in operation: BIVS, NAMIB, SWING, GINA, VELI. 
63 The weighted average of the tariff per hour for non-manual workers (ISCO 8 – Plant and machine operators 
and assemblers) in the 13 Member State in the scope of RIS (EUR 26.7 per hour), based on Eurostat Structure of 
earnings survey (in 2022 prices), has been used to estimate the costs.  
64 Considering the 294,774 port calls in 2020 and 10 minutes on average spent on reporting obligations per port 
call,  around  49,129  hours  were  estimated  to  be  spent  on  reporting  obligations  in  ports,  or  around  EUR  1.3 
million.  The  weighted  average  of  the  tariff  per  hour  for  non-manual  workers  (ISCO  8  –  Plant  and  machine 
operators and assemblers) in the 13 Member State in the scope of RIS (EUR 26.7 per hour), based on Eurostat 
Structure of earnings survey (in 2022 prices), has been used to estimate the costs. 

20 

 
 
context of the first stakeholders’ survey, 43 out of 65 respondents considered problem driver 4 to be 
relevant. In addition, 7 out of 25 respondents to a question on efforts spent on reporting (specifically 
inland waterway operators) indicated resubmission as a high burden. On the other hand, only 3 out 
of  13  national  authorities  that  responded  indicated  high  or  medium  costs  for  processing  the 
electronic reports, 2 out of 13 indicated low costs and 1 authority indicated no costs at all. 7 out of 
13 national authorities were not able to answer or indicated that it was not applicable to them.  

The DINA (2017)65  report outlined that during a journey on the Danube, more than 20 different 
forms  have to  be  filled in different languages.  The  study  estimated  that filling in  each  form  was 
taking ten to twenty minutes per border-crossing, depending on the type of trip.  

There  are  some  attempts  to  solve  this  problem  on  the  ground  through  various  reporting 
applications66  or  through  elements  of  the  RIS  COMEX.  However,  their  application  is  not 
harmonised as indicated in the  first  DINA/NAIADES  expert group meeting due to, for example, 
challenges in having up-to-date information.  

Problem driver 5 (PD5): Lack of legal certainty about processing of personal data by the inland 
waterway stakeholders 

Several studies suggest that data protection concerns from the side of RIS stakeholders hinder the 
degree to which data from electronic ship reporting is shared between competent authorities. In fact, 
the RIS Directive currently only requires setting up national RIS that enables sharing of personal 
data if national or international law requires it (Article 4(3)c). It further refers to the data protection 
requirements  of  Data  Protection  Directive  that  is  replaced  by  the  General  Data  Protection 
Regulation (GDPR). RIS is basically a platform for data exchange providing harmonised technical 
specifications for data, but not the legal basis on which some personal data is actually collected and 
has to be submitted (e.g. border regulations, police regulations, etc.).  

As it emerged during a targeted stakeholders’ workshop, barge owners often live inside their barge. 
For family-owned companies, the vessel is the home of the skipper and the information about its 
position is often considered by vessel operators as personal data. In these cases, as explained during 
the  specific  workshop  held  for  skippers,  the  exchange  of  information  and  identification  of  the 
position  of  the  vessel  is  often  restricted  for  fear  of  privacy  rule  violations.  On  the  other  hand, 
Member  States  or  other  authorities  are  reluctant  to  share  RIS  information  to  avoid  potentially 
breaching privacy rules. This example indicates that both Member States and stakeholders seem to 
be unaware how far and for which purposes personal data is or could be lawfully exchanged via 
RIS.  Currently  there  is  no  personal  information  exchanged  through  RIS  and  there  are  no  actual 
concerns regarding Data Protection. The issue is therefore only the perceived risk, due to the lack of 
clarity, which leads stakeholders and Member States to be reserved in the context of exchange of 
information.  

According  to  the  evaluation,  to  address  this  issue  Member  States  may  conclude  additional  data 
exchange agreements for RIS purposes. In addition, to ensure legal certainty Member States should 
review their national laws and international commitments and ensure that personal data requests are 
always based on valid legal basis provided by law in line with the GDPR. The incomplete data on 
the position of surrounding vessels impairs the efficient voyage planning for skippers and may limit 

65 European Commission (2017): Digital inland waterway areas. Towards a digital inland waterway  area and 
digital multimodal nodes. Final report. 
66 Currently, five different platforms/systems are in operation: BIVS, NAMIB, SWING, GINA, VELI. 

21 

 
 
the situational awareness of national authorities who have a valid reason for having this information, 
for reasons of safety. Therefore, an update of the RIS Directive is needed to  clarify what are the 
obligations  under the RIS Directive  and  also  clearly make transparent  what is the legal basis  for 
personal data exchange in the context of operating RIS. 

In  the  OPC,  11  out  of  13  respondents  indicated  that  this  problem  driver  is  very  or  somewhat 
important.  In  the  context  of  the  first  stakeholders’  survey  38  out  of  65  respondents  found  this 
problem driver to be definitely or somewhat relevant. 

Views of stakeholders on the problem drivers 

Stakeholders agree with the problem drivers as identified. As  shown in Figure  7, the majority of 
stakeholders responding to the first stakeholders’ survey considered all problem drivers to currently 
be an issue for the sector.  

Figure  7:  “In  your  view,  are  the  problem  drivers  listed  below  problems  which  the  IWT/  RIS  sector 
currently faces?” (n=65) 

Source: Ramboll et al. (2024) impact assessment support study, First survey to stakeholders 

Regarding  the  importance  of  the  problem  drivers,  the  stakeholders  clearly  consider  the  efficient 
exchange of information as the most important element to tackle (see Figure 7). This is followed by 
the need to operate with more harmonised and updated standards. Data protection concerns were 
raised  in  particular  by  vessel  operators,  while  integration  with  other  modes  was  given  the  least 
importance among the problem drivers.  

2.3  How likely is the problem to persist? 

Considering the influence of the megatrends identified in the 2021 Strategic Foresight Report67 and 
especially  the  megatrend68  of  “Accelerating  technological  change  and  hyperconnectivity”,  the 
evolution of the problem has to been seen from the perspective of an increasingly connected world, 
with high levels of access to digital services. Without EU level intervention, the problem of slow 
and  fragmented  deployment  of  River  Information  Services  is  likely  to  persist  over  time  and 
potentially to worsen. As technological development keeps accelerating, the fragmented deployment 

67  European  Commission,  2021.  2021  Strategic  Foresight  Report,  Brussels,  Belgium:  Secretariat  General, 
European Commission. 
68 https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en 

22 

 
 
 
of RIS and the low and slow update of technical specifications can impact the competitiveness and 
safety of the sector, and its contribution towards the EGD objectives.  

In  the  first  stakeholders’  survey,  20  out  of  59  respondents  considered  that  the  problem  will  get 
considerably  worse  (15  of  which  were  representatives  of  the  IWT/RIS  users  or  national  public 
bodies)  and  20  out  of  59  that  it  will  get  somewhat  worsen.  Only  4  respondents  argued  that  the 
problem will be partially or completely solved over time. The views are similar for each one of the 
problem drivers as summarised in Figure 8. 

Figure 8: If the current RIS Directive is not revised, how do you expect the following problem drivers to 
develop in the future? (n=59) 

Source: First stakeholder survey 

The views expressed during the DINA/NAIADES Expert Group meeting of July 2022 were slightly 
more nuanced. Experts expected the problems and problem drivers to persist, or slightly worsen in 
case of no changes to the RIS Directive69.  

In  the  OPC,  stakeholders  expressed  the  view  that  without  EU  level  intervention  there  will  be  a 
negative impact on the integration of IWT in the supply chain (11 out of 13 respondents indicated 
that they expect somewhat or strong negative developments), on the efficient use of RIS (10 out of 
13 respondents), and on the digital transformation (10 out of 13 stakeholders). The views related to 
the impact on safety were roughly split as 7 out of 13 respondents considered this to lead to strong 
or  somewhat  negative  developments.  In  terms  of  the  environment,  8  out  of  13  respondents 
considered  that  the  impacts  will  either  remain  unchanged  or  somewhat  improve,  while  internal 
market  issues  appeared  to  have  been  of  least  concern  (10  out  of  13  respondents  indicated  no  or 
somewhat positive developments). 

The issue of the better implementation of RIS, in particular for ensuring a better harmonisation of 
the technical specifications, was brought up by stakeholders (particularly vessel operators) during 
the  consultation  process.  However,  the  practical  tools  for  ensuring  better  implementation  (i.e.  a 
monitoring  and  feedback  mechanism  given  that  during  this  period  no  formal  complaints  were 
notified to the Commission) are missing from the current Directive.  

69 Experts were asked to rate their expectations on how the problem would develop in the absence of a revision 
to  the  RIS  Directive.  Attributed  scores  were  between  1  and  5,  with  1  representing  the  view  that  the  situation 
would get much worse, and 5 representing the view that the situation would get much better. The average score 
of 2.7, with an even distribution across the different experts who responded during the workshop, indicated that 
expert group members expected the situation to either remain the same, or slightly worsen. 

23 

 
 
 
In addition, the issue related to implementation is only relevant for problem driver 1 and only as 
regards  the  non-harmonised  application  of  the  standards  by  the  Member  States.  The  other  four 
problem drivers cannot be addressed through better implementation. The inefficient processes for 
the creation and implementation of technical specifications for RIS (problem driver 2) increase the 
risk related to the implementation and enforcement. It is worth noting that of 59 respondents to the 
first stakeholder’s survey only 4 indicated that the problem would be resolved without a revision of 
the  Directive  (i.e.  through  better  implementation)70.  Similarly,  among  the  RIS  experts  consulted 
during  the  DINA/NAIADES  expert  group  meeting  only  2  indicated  the  need  for  better 
implementation.  

Furthermore, focusing solely on better implementation means that only the challenges and issues 
identified almost 20 years ago are considered. The sector is now confronted with a number of new 
issues that did not exist at the time of the adoption of the Directive and thus were not properly taken 
into account. These include: developments in technology and digitalisation (e.g. the shift from radio 
communication to an almost digital exchange of data), developments in other modes of transport 
(e.g.  including  systems  like  eFTI  and  EMSWe,  and  the  whole  digital  structure  that  is  developed 
under  the  SSMS),  and  overall  developments  in  the  policy  framework  (i.e.  the  European  Green 
Deal). The evaluation found that the Directive is not sufficiently aligned to the sector’s needs for 
improving  efficiency,  integrating  the  sector  into  the  logistics  chains  and  addressing  new 
technological challenges.  

3  WHY SHOULD THE EU ACT? 

3.1  Legal basis 

Title VI (Articles 90-100) of the Treaty on the Functioning of the EU (TFEU) establishes the EU’s 
prerogative  to  make  provisions  for  the  Common  Transport  Policy.  Article  91(1)  of  the  TFEU 
provides  that  the  Union  has  competence  in  the  field  of  transport  to  common  rules  applicable  to 
international transport to or from the territory of a Member State or passing across the territory of 
one or more Member States.  

Within  this  legal  framework,  the  EU  provides  for  a  coordinated  and  harmonised  deployment  of 
information and communication technologies on inland waterways that help to increase the safety 
and efficiency of transport by inland waterway, instead of relying on the uncoordinated action of 
individual Member States only. 

3.2  Subsidiarity: Necessity of EU action 

Under the principle of subsidiarity, in areas which do not fall within its exclusive competence, the 
Union shall act only if and in so far as the objectives of the proposed action cannot be sufficiently 
achieved by the Member States. The necessity of EU action was recognised at the time of adoption 
of the RIS Directive71, when RIS was being developed at different rates, with different technologies 
and  applications  throughout  Europe,  creating  barriers  to  cross-border  voyages.  The  aim  of  the 
Directive was to harmonise technologies across Europe to enhance cross-border transport, and to 
minimise coordination costs. 

70 Two experts (one representing vessel operators and one representing a Member State) considered that further 
efforts were needed in terms of better implementing current provisions in the Directive. 
71 Recital 12 of the RIS Directive 

24 

 
 
The rationale for EU action, in terms of harmonisation of technologies across Europe to enhance 
cross-border  transport  and  to  minimise  coordination  costs,  has  largely  been  unchanged  since  the 
adoption  of  the  RIS  Directive,  with  inland  waterway  transport  continuing  to  have  a  strong  cross 
border  dimension.  Thus,  in  the  absence  of  EU  action,  differences  in  the  level  and  nature  of  the 
provision of RIS between Member States, or in the approaches of the different River Commissions, 
can lead to barriers for the efficient and seamless operation of inland waterways and hinder their 
development in comparison with other transport modes.  

Since the entry into force of Directive 2005/44/EC, the inland waterway sector has benefited from 
the  provision  of  harmonised  RIS.  However,  the  level  of  harmonisation  between  Member  States 
varies and the introduction of the necessary specifications has proved to be lengthy. In addition, the 
EGD  calls  for  a  further  development  of  an  automated  and  connected  multimodal  mobility.  RIS 
should  be  more  fit  to  address  these  new  challenges,  also  in  line  with  the  Sustainable  and  Smart 
Mobility Strategy, which promotes the creation of a truly smart transport system, efficient capacity 
allocation  and  traffic  management.  The  NAIADES  III  action  plan  indicated  that,  to  support  the 
objective  of  inland  waterways  being  part  of  a  seamless  system  of  harmonised  RIS  by  2030,  a 
revision  of  the  legal  framework  on  RIS  would  be  necessary  to  close  these  harmonisation  and 
interoperability  gaps,  and  to  contribute  to  improved  data  availability,  and  the  reuse  and 
interoperability of data, in line with the European Data Strategy. 

The most affected Member States were the Rhine countries – the Netherlands, Belgium, Germany 
and France. Their views, as expressed in their response to the consultation activities for this impact 
assessment, showed that there is a need for EU legislative action and that there would be negative 
consequences if the legal system would stay the same. Furthermore, as explained in section 1, both 
the European Parliament and the Council, in their reaction to the NAIADES III Communication, 
expressly stated their interest for a revised Directive.  

3.3  Subsidiarity: Added value of EU action 

The  2021  evaluation  concluded  that  the  benefits  of  the  Directive  (in  particular  in  terms  of 
harmonisation)  could  not  have  been  achieved  at  the  national  level,  primarily  due  to  high 
fragmentation  of  technical  specifications  and  implementation  practices.  Stakeholders  consulted 
during  the  evaluation  indicated  as  areas  of  EU  added  value:  the  improved  harmonisation,  the 
standardisation  through  common  technical  specifications,  the  increased  cross-border  cooperation, 
more funding for the sector and an increase in perceived safety.  

This initiative would provide additional EU added value by improving RIS efficiency (in terms of 
technical specifications, process of adoption,  and  improved exchange of information), but also in 
terms of integration of inland waterways in the multimodal supply chains. Furthermore, even though 
the  problem  is  geographically  limited,  impacting  Member  States  with  connected  navigable 
waterways, action at EU level is more likely to ensure that solutions are coherent and uniform for all 
Member States concerned. At the same time, it is through EU action that  connectivity with other 
modes  can  be  ensured.  Furthermore,  EU  level  action  has  an  advantage  over  other  international 
interventions such as the UNECE guidelines, due to its mandatory nature. Action at regional (i.e. 
River  Commission  level),  in  practice  a  form  of  enhanced  cooperation,  is  also  likely  to  lead  to 
regional fragmentation, as each River Commission would focus on applying its own solutions, thus 
introducing barriers to the common market and be a step back in terms of harmonisation. The CEF 
funded  RIS  COMEX,  could  be  considered  as  another  form  of  enhanced  cooperation,  where  the 
Member  States  on  a  voluntary  basis  decided  to  develop  a  platform  for  the  exchange  of  RIS  (as 
described in section 1). However as this is a voluntary initiative, the continuation of its membership 

25 

 
cannot be guaranteed, which could potentially lead to differences in the level of service provided to 
a vessel depending on whether the country it navigates through is part of RIS COMEX or not.  

Stakeholders who responded to the evaluation’s consultation activities noted that the same benefits 
would not have been achieved by comparable interventions at the international, regional or national 
level72. The stakeholders consulted in the context of this impact assessment expect the problem to 
persist in absence of EU level action. Additionally, no sources indicated that the same benefits could 
be  achieved  at  the  national  level,  as  this  would  result  in  a  high  fragmentation  of  standards  and 
implementation practices73. 

4  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1  General objectives 

Based on the analysis of the problem as described in section 2, the revision of the RIS Directive is 
guided by one general objective, that is: to provide an effective framework for the deployment and 
use of RIS. With such a framework in place, IWT can operate in a safe manner, in a competitive 
market environment, and contribute towards the EGD objectives.  

This  objective  is  in  line  with  the  SSMS  that  aims  to  enable  seamless  transport  and  traffic 
management  on  the  European  inland  waterways,  as  well  as  to  improving  the  sustainability  of 
transport.  In  addition,  it  is  in  line  with  the  goals  of  NAIADES  III  Communication  in  terms  of 
improving the performance of RIS along with improving and re-using applications for links with 
other modes, and eventually preserving the competitive position of IWT.  

RIS can contribute to connecting IWT to the logistics chain and to improving its competitiveness 
and modal split. However, it cannot achieve this in isolation as the competitiveness of the sector is 
also  affected  by  factors  such  as  lack  of  infrastructure  developments  and  maintenance,  lack  of 
qualified  staff,  geographic  limitations  of  IWT  network,  lack  of  investments  and  innovation74.  In 
addition, it is not the objective of the revision to develop into a single digital tool for IWT, as RIS 
form part of a family of applications like the databases for crews and vessel information. All these 
cover separate needs and purposes. Furthermore, in terms of links with other modes, and to improve 
syncro-modality,  it  should  not  duplicate  or  aim  to  replace  other  existing  tools,  like  EMSWe,  or 
eFTI,  but  rather  ensure  that  the  necessary  information  flows  seamlessly  among  these  various 
solutions,  as  needed.  In  this  regard,  RIS  is  just  one  of  the  many  pieces  of  the  puzzle  of  the 
digitalisation of IWT. 

The initiative contributes towards the objectives of the European Green Deal (EGD)75 (in particular 
by  supporting  the  shift  away  from  road  transport).  The  revision  of  the  RIS  Directive  contributes 
towards Sustainable Development Goal (SDG) 9 (“Build resilient infrastructure, promote inclusive 
and  sustainable  industrialisation  and  foster  innovation”)  and  SDG  13  (“Take  urgent  action  to 
combat climate change and its impacts”).  

72 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=SWD%3A2021%3A50%3AFIN  
73  Ludden,  V.  et  al.,  2020:  Study  supporting  the  evaluation  of  Directive  2005/44/EC  on  Harmonised  River 
Information Services (RIS). Ramboll, University of Antwerp and DLA Piper. 
74 European Commission (2020), Assessment of the potential of maritime and inland ports and inland waterways 
and  of  related  policy  measures, 
including  industrial  policy  measures,  https://op.europa.eu/o/opportal-
service/download-handler?identifier=4ec82fa8-0dc6-11eb-bc07-
01aa75ed71a1&format=pdf&language=en&productionSystem=cellar&part=  
75 https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal_en#documents  

26 

 
 
4.2  Specific objectives 

The specific objectives (SOs) are discussed below. Their correspondence with the problem drivers 
are presented Figure 9. 

Figure 9: Correspondence between the specific objectives and the problem drivers 

Source: European Commission 

SO1: Ensure improved RIS data availability, and harmonised standards  

For RIS to function properly, this must be based on an appropriate operating environment where the 
required information is available to the users. The first objective therefore aims to address the areas 
where  the  technical  performance  of  RIS  was  found  not  to  be  optimal.  Improving  the  quality, 
efficiency and exchange of RIS data is an important element for addressing the current identified 
challenges,  in  terms  of  non-harmonised  technical  specifications  (‘standards’)  and  lack  of  basic 
information and to improve the process for adoption of technical specifications. Improving the RIS 
information  available  to  both  vessels  operators  and  authorities  can  increase  the  efficiency  of  the 
IWT and reduce the safety risks (PD1). In this context, the technical requirements and specifications 
need  to  be  updated  regularly  and  their  application  across  Member  States  needs  to  be  fully 
harmonised.  Technological  solutions develop fast  and the  RIS  Directive needs to  ensure that the 
process to introduce the necessary changes to the technical specifications can follow a similar pace 
(PD2).  

SO2: Facilitate the integration of IWT into the multimodal chain  

The second objective  aims to prepare RIS to address the missing elements that hinder the sector 
from reaching its potential, and in particular its integration into the multimodal chains. This can be 
attained through improved quality and better shared information. In this regard RIS users need to 
have  access  to  the  appropriate  and  up-to-date  information  for  all  necessary  elements  (PD1). 
Furthermore,  this  information  needs  to  be  better  exchanged  within  the  sector  itself,  in  particular 
when crossing a border, or when approaching an inland port, a lock or a moving bridge and reduce 
reporting  requirements  (PD4).  Moreover,  better  exchange  with  the  systems  of  other  modes  is 
needed to avoid duplications of systems and data flows (PD3). 

27 

 
 
SO3: Ensure a higher uptake and interoperability of digital solutions, and address data protection 
concerns  

The IWT sector is part of the international logistics chains and needs to keep up with developments 
in other sectors to maintain its competitiveness. This objective will aim to increase the digitalisation 
in the sector and ensure a smooth flow of information A digital framework is needed to enable the 
seamless integration of IWT in multimodal supply chains and avoid reverse modal shift. This can 
only be done through improved links with the digital systems developed for other modes, in order to 
enable the exchange of information between them, while avoiding parallel or overlapping systems 
(PD3).  This  initiative should  also provide the  necessary incentives  and  assurances to remove the 
bottlenecks related to the inefficient exchange of information and reporting (PD4) and objections to 
data  exchange  due  to  concerns  on  data  protections  (PD5).  It  should  clarify  the  type  of  data  a 
Member  State  may  collect  and  exchange  via  RIS  and  also  clarify  that  RIS  does  not  create  an 
obligation to share personal data but only facilitates the exchange if there is a legal basis for  the 
processing of personal data under relevant national, Union or international laws. 

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 
initiative.  The  REF2020  takes  into  account  the  impacts  of  the  COVID-19  pandemic  that  had  a 
significant impact on the transport sector. More detailed information about the preparation process, 
assumptions and results are included in the Reference scenario publication76. 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 2021 and of the REPowerEU package proposed by the Commission on 18 
May 2022. The baseline scenario assumes no further EU level intervention beyond the current RIS 
Directive. The effects of projects such as RIS COMEX are however expected to continue over time 
in the baseline scenario. In this context, the RIS COMEX 2 that recently obtained funding through 
the Connecting Europe Facility, is reflected in the baseline. More details on the baseline scenario 
assumptions and results are provided in Annex 4. 

The  baseline  also  incorporates  foresight  megatrends77  and  developments  captured  in  the  2022 
Strategic Foresight Report78. It also considers the influence of the megatrends identified in the 2021 
Strategic Foresight Report79 and especially the megatrend80 of “Accelerating technological change 
and hyperconnectivity”. Among others, it captures the trend of increasing demand for transport as 
population and living standards grow as well as the links between the digital and green transition. In 
particular,  the  projected  transport  activity  draws  on  the  long-term  population  projections  from 
Eurostat and GDP growth from the Ageing Report 202181 by the Directorate General for Economic 
and Financial Affairs.  

In  the  baseline  scenario,  EU  transport  activity  is  projected  to  grow  post-2020,  following  the 
recovery from the COVID pandemic. Road transport would maintain its dominant role within the 

76 EU Reference Scenario 2020 (europa.eu)  
77 https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en#explore  
78 COM(2022) 289 final of 29 June 2022. 
79  European  Commission,  2021.  2021  Strategic  Foresight  Report,  Brussels,  Belgium:  Secretariat  General, 
European Commission. 
80 https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en 
81 The 2021 Ageing Report : Underlying assumptions and projection methodologies  

28 

 
 
EU by 2050. Rail transport activity is projected to grow faster than for road, 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. 
Freight  inland  waterways  activity  represented  147  billion  tonne-kilometres  (tkm)  in  2015,  going 
down to 132 billion tkm in 2020. Following the post-COVID recovery, the freight inland waterways 
activity is projected to increase to 178 billion tkm in 2030 (21% increase relative to 2015) and 212 
billion tkm in 2050 (44% increase for 2015-2050). The passenger segment of IWTs is expected to 
increase as well, with the number of passenger-kilometres projected to increase by 36% by 2030 
compared to 2015 (53% increase for 2015-2050).  

Despite  the  increase  in  terms  of  transport  volumes,  the  modal  share  of  freight  IWT  in  land 
transport82 is projected to decrease from 6.8% in 2015, to 6.3% in 2030 and to remain relatively 
stable, at 6.2%  after that. The decrease in the modal share of IWT relative to 2015 is due to the 
reduction in the specific types of goods transported by inland navigation (petroleum products and 
coal), linked to the energy transition towards greener fuel sources, and due to the higher growth in 
the rail transport activity. The expected growth in the container segment, is not expected to reverse 
the trend. As regards passenger transport, the modal share of IWT only represents around 0.01% of 
land  transport  activity  and  is  projected  to  remain  relatively  stable  over  time  following  the  post-
COVID recovery. 

The number of passenger vessel journeys is projected to increase from 8,867 in 2015 to 12,043 in 
2030 and 13,572 in 2050. The total number of tonnes transport is projected to grow roughly in line 
with  the  transport  activity  in  tonne  kilometres  (from  545  million  tonnes  in  2015  to  690  million 
tonnes in  2030  and 813  million  tonnes in 2050),  while  the number  of  tonnes  per journey  would 
continue to increase but at a slower pace than in the past83. The number of freight vessels journeys is 
projected  to  go  up  from  682,120  in  2015  to  717,838  in  2030  (5%  increase  for  2015-2030)  and 
731,234  in  2050  (7%  increase  for  2015-2050),  following  the  recover  from  the  COVID-19 
pandemic.  

Around 40% of the freight vessels journeys take place within one country, with the rest crossing on 
average 1.3 borders per journey. The share of border crossings in the number of vessel journeys is 
assumed to remain constant over time (at around 60%), in line with the historical developments. 
Thus, the total number of freight border crossings is  projected to go up from 427,947 in 2015 to 
432,442 in 2030 and 440,512 in 2050. For passenger vessels journeys, the share of border crossings 
is much higher (around 90%) and is assumed to remain constant over time. The total number of 
border crossings for passenger IWT is projected to increase from 8,344 in 2015 to 10,882 in 2030 
and 12,264 in 2050. 

The number of cargo vessels has decreased by 23% between 2003 and 202084, from 13,385 ships to 
10,332. The overall downward trend in the number of cargo vessels is expected to reverse by 2030 
(12,371 cargo vessels), driven by the increase in activity and the slower increase in the capacity of 
ships compared to the past, but then it is expected to stay relatively stable until 2050 (12,223 cargo 

82 Excluding pipeline transport.  
83 From 799 tonnes per journey in 2015 and  859 tonnes per journey in 2020 to 961 tonnes per journey in 2030 
and 1,111 tonnes per journey in 2050. 
84 The year 2003 was chosen for the comparison because of data availability on the number of ships in both the 
Rhine, Danube and other river basins.  

29 

 
 
vessels)  due  to  the  increase  in  the  productivity  per  vessel85.  On  the  other  hand,  the  number  of 
passenger vessels had increased from approximately 160 ships in 2004 to 405 ships in 2021. When 
the day-tour ships and smaller cycle holiday ships are counted, around 2,553 passenger ships were 
estimated to operate in the EU in 201586. The number of passenger vessels is projected to follow the 
increase in the number of passengers (3,467 vessels projected in 2030 and 3,908 in 2050). It should 
however be noted that the majority of these vessels are small or very small. In contrast to cargo 
vessels, no further growth in scale or productivity is expected for passenger shipping. 

Energy use in freight IWT is projected to remain relatively stable by 2030 to its 2015 levels, despite 
the increase in activity, and to decrease to 895 ktoe87 by 2050 (11% decrease for 2015-2050), thanks 
to  the  uptake  of  more  fuel-efficient  technologies  including  electrification.  For  passenger  vessels, 
energy  consumption  is  projected  to  increase  by  11%  by  2030  (132  ktoe),  driven  by  the  strong 
growth  in  activity,  and  only  to  slightly  decrease  by  2050  relative  to  its  2015  levels  (112  ktoe). 
Overall,  considering  both  passenger  and  freight,  energy  use  in  inland  waterways  transport  is 
projected to remain relatively stable by 2030 to its 2015 levels and to go down by 10% by 2050, 
relative to 2015.  

In the baseline scenario, CO2 emissions from inland waterways transport are projected to decrease 
much faster than the energy use (21% decrease for 2015-2030 and 67% decrease for 2015-2050). 
This  is  because  of  the  large-scale  uptake  of  renewable  and  low  carbon  fuels,  namely  e-fuels, 
biofuels  and  electricity.  In this  context, it should be noted that the baseline  scenario  assumes the 
implementation of the European Climate Law to which all sectors, including the inland waterways 
sector, need to contribute. In terms of NOx emissions a similar trend is expected, reducing from 73 
ktons in 2015 to just below 20 ktons in 2050. The amount of particulate matter emitted by inland 
navigation is also expected to reduce, from 3.8 ktons in 2015 to 1 kton in 2050. This is due to both 
electrification and the fact that the ships that continue to operate with internal combustion engines 
are  becoming  cleaner.  In  this  context,  it  should  also  be  noted  that  since  2020  new  combustion 
engines  are  considerably  cleaner,  thanks  to  the  implementation  of  non-road  mobile  machinery 
(NRMM) Regulation (NRMM Stage V)88. 

There is little consistent data on safety in the inland navigation sector, with available data coming 
from  Eurostat  and  national  databases  for  Bulgaria,  Czechia,  Germany,  Croatia,  Hungary,  the 
Netherlands, Austria, Poland and Romania. In the baseline scenario, the projected evolution of the 
number of accidents is linked to the evolution of activity expressed in terms of vessel-kilometres. 
The number of accidents per vessel-kilometres is assumed to remain constant over time. Thus, the 
number of accidents is projected to increase to 535 in 2030 and 551 in 2050 in the baseline scenario 
(from 529 in 2015).  

The baseline scenario reflects the projected higher energy prices driven by the Russian invasion of 

85 This is assumed at 1.5% per year per ship/barge. This increase is justified by both technical and operational 
developments: for instance Smart And Autonomous Shipping which may result into a  larger share of the fleet 
being able to sale 24/7 (in spite of labour shortages in the sector), increased attention to good navigational status 
of waterways (including 24/7 operation of bridges and locks on the major waterways) and scale enlargement in 
IWT of both companies (larger number of vessels per company) and vessels (larger load capacities for vessels), 
although at slower pace than in the past. 
86 Prominent (2017) 
87 The tonne of oil equivalent (toe) is a unit of energy defined as the amount of energy released by burning one 
tonne of crude oil. 
88 Regulation (EU) 2016/1628. 

30 

 
 
Ukraine89. Beyond this aspect, it was however not possible to quantify the impact of the Russian 
invasion of Ukraine, as there is large uncertainty with respect to its impacts, in particular for the 
medium  to  long  term.  While  its  impact  is  felt  in  terms  of  trade  (e.g.,  grain,  bulk  fertilizers  and 
hydrocarbons)  and  in  certain  geographical  areas,  the  impact  on  the  baseline  of  this  initiative  is 
expected  to  be  limited.  The  problem  of  slow  and  fragmented  deployment  of  River  Information 
Services that hamper the competitiveness and safety of the sector, and its contribution towards the 
EGD objectives, is likely to persist.  

5.2  Policy measures and policy options 

As  a  first  step,  a  comprehensive  list  of  possible  policy  measures  was  established  after  extensive 
consultations with stakeholders, expert meetings, independent research and the Commission’s own 
analysis.  This  list  was  subsequently  screened  based  on  the  effectiveness,  efficiency  and 
proportionality of the proposed measures in relation to the given objectives, as well as their legal 
and technical feasibility. 

5.2.1  Discarded policy measures 

A number of possible policy measures were considered during the impact assessment process but 
were  discarded  either  because  the  problem  was  not  susceptible  to  a  solution  by  means  of  EU 
legislation or because proposing an action to address the issue at EU level will not yield additional 
results. An overview of the measures and a justification for them not being followed is presented in 
the Table 1. 

Table 1: Overview of discarded measures 

Policy Measure 

Reason for discarding 

Expand scope to all waterways 

CEMT-class III waterways and below exist in Czechia, Croatia, France, 
the  Netherlands,  Poland,  Belgium  and  Hungary.  However,  as  there  is 
very  limited  commercial  navigation  taking  place  on  these  waterways, 
bringing these waterways under the scope of the RIS Directive will result 
in  significant  administrative  burden  for  RIS  authorities  and  hardly  any 
benefit for all stakeholders. 

Create  a  role  for  the  European 
Maritime Safety Agency (EMSA) 

EMSA  has  a  clearly  defined  role  related  to  the  safety  of  the  maritime 
sector. RIS has a different scope which is not in line with the mandate of 
EMSA.  

Provide incentives for IWT users to 
make better use of RIS 

The private  sector already uses RIS to a  large extent.  Financial support 
for  RIS  may  be  provided  under  the  Connecting  Europe  Facility  (CEF) 
and is thus out of scope of this impact assessment. 

Embed the operation of the existing 
DINA  expert  group  (E03505)  into 
the Directive 

Services 

Integrate  the  Directives  of  River 
Information 
(RIS), 
Intelligent Transport Services (ITS) 
and  the  Maritime  Vessel  Traffic 
Monitoring 
Information 
and 
System  (VTMIS)  Directive  into 
one integrated Directive. 

The  involvement  of  Commission  expert  groups  is  well  defined  in  the 
decision-making process and no further requirements are necessary. 

While all of the mentioned Directives (RIS, ITS, VTMIS) handle digital 
aspects, they each have different scope  and area of application and aim 
to cover different needs. The merging of separate legal obligations would 
not necessarily create a simplified system, but could increase complexity 
and legal challenges. Better interconnection between the digital systems 
developed should be pursued instead. 

89 SWD(2022) 230 final.  

31 

 
 
Policy Measure 

Reason for discarding 

Expand 
navigation systems 

the 

set  of 

shipborne 

This  measure  is  out  of  scope  of  RIS  and  would  be  more  appropriately 
covered under CEF. 

Align  investments  in  digital  and 
physical infrastructure 

This  measure  is  out  of  scope  of  RIS  and  would  be  more  appropriately 
covered under CEF. 

Roll out of 5G in the framework of 
CEF along waterways 

This  measure  is  out  of  scope  of  RIS  and  would  be  more  appropriately 
covered under CEF. 

Link  to  cross-disciplinary  digital 
information  and  operation  systems 
for 
waterway 
water- 
management 

and 

This is a technical element relating to the standards to be developed and 
is  thus  relevant  for  the  implementing  acts  and  not  the  main  Directive 
itself. 

that 

regulations 
practices 

and 
Ensure 
operational 
take 
interoperability  of  both  sea  and 
inland 
systems 
waterway 
(RIS/VTS) into account 

Align with DIWA Masterplan 

The development of a common VTS system between maritime and IWT 
is  beyond  the  scope  of  the  RIS  directive.  Technical  aspects  for  the 
interoperability of such services relate to the  standards to be  developed 
and  are  thus  relevant  for  the  implementing  acts  and  not  the  main 
Directive itself. 

The  work  of  DIWA  is  not  concluded  at  the  time  of  preparation  of  this 
report. However, several RIS related aspects discussed in the context of 
DIWA (like the need for better quality data, the links with eFTI, and the 
inland ports, aligning with the maritime and the central roles of CESNI 
and  COMEX)  have  been  taken  on  board.  Moreover,  DIWA  makes 
numerous other recommendations that are of a technical nature and thus 
relevant for secondary legislation and not the main Directive itself. 

Source: European Commission 

5.2.2  Retained policy measures and policy options overview 

The retained policy measures to address the problem and problem drivers identified in section 2 are 
provided in Table 2. A more detailed description of the policy measures is included in section 5.2.3.  

The  retained  policy  measures  have  been  grouped  in  3  policy  options:  policy  option  A  (PO-A), 
policy option B (PO-B) and policy option C (PO-C). Table 2 presents the links of policy measures 
included in the policy options with the problem drivers and specific objectives. 

Table 2: Overview of policy measures and policy options 

Policy Measure 

PM1 - Increase the harmonisation of RIS through guidelines  

PM2 - Introduce a harmonised complaint mechanism (in Member 
States) 
PM3 - Introduce a new Performance Measurement Framework 

PM4 - Strengthen requirements for RIS technical specifications by 
adding new specifications on data for navigation and voyage planning 
(RIS Index)  
PM5 - Require electronic voyage plan reporting 

PM6 - Introduce provisions for supplying data to the ERDMS and its 
operation 
PM7 - Encourage cargo-related information exchange through the 
eFTI mechanism  
PM8 - Mandate cargo-related information to be exchanged through 
the eFTI mechanism 
PM9 - Require information exchange through a RIS platform 

PM10 - Involve CESNI in the development and adoption of technical 

Problem 
driver 
PD1 

Specific 
objective 
SO1 

PD1 

PD1 

SO1 

SO1 

PD1, PD3 

SO1, SO2 

PD1, PD3 

PD1, PD3 

SO1, SO2, 
SO3 
SO1, SO2 

PD1, PD3, 
PD4 
PD1, PD3, 
PD4 
PD1, PD3, 
PD4 
PD2  

SO2, SO3 

 SO2, SO3 

SO1, SO2, 
SO3 
SO1  

PO-A  PO-B  PO-C 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

32 

 
 
 
 
 
 
 
 
 
 
 
 
 
Policy Measure 

Problem 
driver 

Specific 
objective 

PO-A  PO-B  PO-C 

specifications 

PM11 - Link the RIS requirements with those of the TEN-T 
Regulation  
PM12 - Develop new technical specifications for the exchange of 
information relating to IWT ports 
PM13 - Require the exchange of information with IWT ports 
according to new technical specifications 
PM14 - Improve the harmonisation between RIS and information 
services for other modes of transport (e.g. maritime) 
PM15 - Require sharing of all necessary cross-border data for traffic 
and transport management by the Member States 
PM16 - Specify more clearly the cases for exchange of personal data 

PM17 - Develop templates and standards for the exchange of personal 
data 
Source: European Commission 

5.2.3  Description of the policy measures 

A description of the policy measure is provided below: 

PD3 

PD3 

PD3 

PD3 

PD4 

PD5 

PD5 

SO2 

SO2, SO3 

SO2, SO3 

SO2, SO3 

SO2, SO3 

SO3 

SO3 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

• 

Increase the harmonisation of RIS through guidelines (PM1). This is a non-legislative measure. 
The Commission will develop interpretative guidelines for the application of the Directive and 
the  different  technical  specifications90.  The  assistance  of  CESNI  will  be  requested  (through  a 
study) to help identify the areas of most concerns or most frequent issues (e.g. the number of 
masts/radars  transferring  data  between  the  vessels  and  RIS  centres,  the  way  the  infrastructure 
should  be  placed  and  maintain  (frequency  of  inspection).  These  guidelines  will  be  made 
available  to  Member  States,  vessel  operators  and  software  providers  and  should  remove 
ambiguities  on  technical  specifications.  Member  States  will  then  apply  the  technical 
specifications in line with the guidelines. No action is anticipated by the other stakeholders.  

•  PM2: Introduce a harmonised complaint mechanism (in Member States). Improved monitoring 
of the implementation of the Directive will help ensure that RIS is provided in a coherent and 
harmonised manner across the whole length of waterways concerned. As a way of addressing 
this from the “bottom-up”, this measure relies on direct feedback from RIS users to indicate the 
areas where problems appear. Member States will be required to designate a (existing or new) 
competent  governmental  body  to  directly  handle  complaints  filed  by  RIS  users.  To  properly 
function, this body should be independent from RIS related authorities and would have the task 
to  verify  the  complaints  and  request  corrective  action  (e.g.  correct  wrong,  outdated  or  non-
standardised data). Vessel operators and software providers will be aware of whom to refer to. 
National authorities will have visibility of where they need to intervene.  

•  PM3: Introduce a new Performance Measurement Framework. In contrast to PM2, this measure 
aims to improve the monitoring (and thus the overall performance of the Directive), through a 
“top-down”  approach.  The  Commission  with  the  assistance  of  CESNI  will  develop  key 
performance  indicators  such  as  the  number  of  shipping  messages  issued  in  accordance  with 
standards  and  interpretations  from  the  most  recent  RIS  encoding  guide,  and  the  number  of 
electronic cargo reports received in relation to the number of voyages. Member States and other 

90  These  guidelines  are  not  the  same  as  the  “RIS  Guidelines”  as  mentioned  in  Annex  II  of  the  Directive,  and 
which  form  an  integral  part  of  the  standards,  originating  from  the  work  of  PIANC,  and  which  are  in  force 
through Commission Regulation (EC) No 414/2007.  

33 

 
 
 
 
 
 
 
 
 
 
 
 
 
relevant  authorities  will  be  required  to  report  on  these  indicators  on  a  regular  basis  (yearly). 
Having better  information, the  European Commission  will be  able to  follow  more  closely the 
provision of RIS and identify cases where RIS implementation is fragmented. Based on this it 
will be requesting the responsible Member State to undertake corrective action. It will not require 
action from the side of vessel operators. 

•  PM4: Strengthen requirements for RIS technical specifications by adding new specifications on 
data  for  navigation  and  voyage  planning  (RIS  Index).  This  measure  aims  to  strengthen  the 
requirements  of  the  current  RIS  Directive  by  introducing  new  technical  specifications 
(‘standards’) on data for navigation and voyage planning (‘RIS Index’). It will improve traffic 
management in the EU waterways. The new technical specifications will ensure that information 
related  to  the  efficiency  of  navigation  is  available  and  shared  between  the  different  actors. 
Member States will be required to create systems providing adequate information for skippers - a 
series of data including for instance clearance heights at bridges, fairway profiles and  data on 
vessel  traffic  signs  will  have  to  be  collected.  Moreover,  the  system  should  also  include 
information on the real-time traffic situation, such as current and expected waiting times at locks. 
Obtaining and sharing these data requires investment in both digital hardware and software (to 
monitor  and  report  on  the  information  mentioned  above).  Member  States  will  also  need  to 
undertake  digital  hardware  and  software updates in order to  provide  the  required information. 
Vessel operators and software providers will have access to the provided information for their 
purposes.  

•  PM5:  Require  electronic  voyage  plan  reporting.  This  measure  aims  to  improve  traffic 
management and navigation efficiency in the waterways. Vessel operators already prepare and 
submit to the authorities their plan for the voyage at the start of the journey. However, with this 
measure the reporting will need to be made through electronic means, and be adapted for any 
changes,  which  will  increase  the  reporting  requirements.  As  a  trade-off  vessel  operators  will 
receive directions from national authorities to adapt their navigation to take into account of the 
situation in the waterways thus improving the voyage efficiency (e.g., through reduced speed of 
ships and less manoeuvring movements like, mooring at waiting jetties, leaving and entering the 
lock, etc.). National authorities will have to invest in software to receive, process and act upon 
the information transmitted by the vessels, but this will allow them to have greater visibility on 
the navigation situation, plan and manage traffic, and account for changes (e.g. instruct vessels 
navigate slower in case of bottlenecks).  

•  PM6: Introduce provisions for supplying data to the ERDMS and its operation. The  ERDMS 
contains basic information that is important for the provision of RIS. Currently though the level 
of  accuracy  of  the  information  provided  by  Member  States  varies.  This  measure  will  require 
Member  States  to  provide  accurate  and  up-to-date  data  to  the  ERDMS  so  as  to  improve  the 
quality  of  the  contained  information.  This  will  create  costs  for  the  Member  States  as  the 
frequency and/or content of their reporting will need to be increased. Vessel operators will make 
use of the provided information for navigation planning purposes and software providers for the 
development of their products. This information will also be made available to the RIS platform 
(PM9). 

•  PM7:  Encourage  cargo-related  information  exchange  through  the  eFTI  mechanism.  This 
measure  will  require  that  standards  are  developed  so  that  RIS  cargo  related  information  (i.e. 
electronic ship reports as specified in Commission Implementing Regulation 2019/1744) can be 
shared on a voluntary basis through the electronic freight transport information (eFTI) platforms. 
Before starting the voyage, vessel operators will upload the required information to eFTI, and 
will transmit through ERI to the relevant authorities the link to the eFTI with their information. 

34 

 
 
Member State authorities will, as appropriate, use the link to access the cargo information for 
their  purposes.  Member  States  will  also  have  the  option  to  transmit  the  eFTI  links  to  their 
counterparts in other Member States. In PM7, the digital applications will be developed but not 
made obligatory for use. The Member States will need to develop the capacity to receive and 
process  information through  eFTI,  and  replace the  processing of  paper cargo  reports  with the 
electronic reports. Vessel operators will only need to upload the information once on eFTI, and 
then report to the authorities through ERI only the relevant link. 

•  PM8: Mandate cargo-related information to be exchanged through the eFTI mechanism.  The 
difference of this measure with PM7 is that it will be now obligatory for vessel operators to use 
an eFTI platform for the transmission of the cargo information. 

•  PM9:  Require  information  exchange  through  a  RIS  platform.  A  single  digital  platform  that 
would act as the main exchange node for RIS information and basis for development of digital 
applications would help to streamline and improve the provision of RIS in the EU. As explained 
in section 1, 13 Member States91 through an agreement and CEF funding have already developed 
the project RIS COMEX which in effect is a one stop shop platform for the exchange of RIS 
information and can fulfil the role of a RIS platform. Building on the success of this project, and 
in order to not duplicate efforts, this measure proposes to designate this platform as the main and 
central platform for RIS, where all functionalities will be built upon, and work in combination 
with other measures (e.g. PM4, PM6, PM8, PM12, PM14). Therefore, this impact assessment 
will make reference to and be based on information of RIS COMEX. By mandating the use of 
RIS COMEX, efficient use of EU funds is ensured, as the development was already supported 
under  CEF,  and  any  costs  for  the  Member  States  (including  for  those  like  Spain,  Italy  and 
Portugal) will be limited to development and update of the necessary digital applications. It will 
be an important change for vessel operators, who will use a single platform of interaction instead 
of several portals and systems. Software providers will also have access to information from RIS 
COMEX platform for their product development. 

•  PM10: Involve CESNI in the development and adoption of technical specifications. This measure 
aims  to  tackle  the  long  period  that  has  so  far  been  required  to  introduce  new  technical 
specifications  for  the  sector.  In  this  case,  CESNI  will  be  involved  in  the  preparation  of  the 
technical specifications and provide regular updates as required. CESNI already has a working 
group dealing with RIS (CESNI/TI).  

•  PM11:  Link  the  RIS  requirements  with  those  of  the  TEN-T  Regulation.  Currently,  all 
interconnected waterways of CEMT class IV and higher (which refers to the size of the vessel 
they can accommodate) are within the scope of the RIS Directive. Member States may decide to 
include further waterways in this scope (for example Italy, Spain and Portugal). This scope does 
not match the TEN-T network, which with its current proposed revision will not refer any more 
to CEMT classification but will be based on the characteristics of the waterways themselves. As 
the  TEN-T  network  covers  the  most  important  waterways  it  is  therefore  considered  that  an 
alignment of scope between the two is required.  

•  PM12:  Develop  new  technical  specifications  for  the  exchange  of  information  relating  to  IWT 
ports.  Data  related  to  ports  is  not  easily  available  to  vessel  operators  (for  example,  the 

91  Austria,  Belgium,  Bulgaria,  Croatia,  Czechia  France,  Germany,  Hungary,  Luxembourg,  the  Netherlands, 
Romania, Serbia and Slovakia 

35 

 
 
dimensions of bridges over port basins and operating times), or the ports do not always have the 
vessels' cargo and voyage information and this information has to be reported again at the ports. 
The  aim  of  this  measure  is  to  develop  new  technical  specifications  for  the  exchange  of 
information  to  and  from  IWT  ports.  Overall,  PM12  would  lead  to  better  data  quality  for  all, 
leading to simpler travel planning. National authorities and the ports will need to develop and 
maintain the  necessary  systems to share  and process  this information  (exchange  can  be made 
through PM9). Under this measure, while inland ports will need to have developed the necessary 
digital  infrastructure,  vessel  operators  will  only  make  use  of  it  on  a  voluntary  basis.  Vessel 
operators will have access to improved and updated information regarding the situation in their 
inland port of destination (e.g. access constraints on opening of bridges, the availability of berths, 
the availability of clean fuels at the time of arrival).  

•  PM13:  Require  the  exchange  of  information  with  IWT  ports  according  to  new  technical 
specifications.  The difference of this measure with PM12 is that it will be now obligatory for 
vessel operators to exchange information with inland ports through the provided systems. 

•  PM14: Improve the harmonisation between RIS and the information services for other modes of 
transport  (e.g.  maritime).  Currently  the  RIS  Directive  envisages  continuity  with  other  modal 
traffic  management  services,  in  particular  with  maritime.  However,  no  further  details  are 
included,  and  no  technical  standard  has  been  developed  along  these  lines.  Therefore,  this 
measure  aims to strengthen  the interoperability  of  RIS  with other  modes of  transport,  but  not 
create  new  or  duplicate  existing  systems.  The  Directive  will  provide  a  clear  reference  to  the 
European Maritime Single Window environment (EMSWe) and introduce requirements for the 
exchange of information with RIS (e.g. regarding the ETA of a vessel to the port), along with the 
main principles and technical requirements for the links between the two systems. Similarly, a 
provision will also be included for links of RIS with systems of other modes (to be indicated by 
Member States). As identified in the PLATINA III project92 such connections are important for 
the coordination of shipments and increasing the supply chain visibility for shippers and logistic 
providers. The technical specifications will be developed by CESNI (in collaboration with the 
standard setting entities for the other systems) and introduced through secondary legislation. A 
common  data  exchange  mechanism  (such  as  application  programming  interfaces)  will  be 
developed to enable both systems to access the data of one another. An important principle in 
their development will be to anticipate the possibility for links with other systems in the future.  

•  PM15: Require sharing of all necessary cross-border data for traffic and transport management 
by the Member States. Currently not all information provided by vessel operators to authorities is 
shared  with  the  authorities  of  other  Member  States,  which  creates  a  challenge  when  crossing 
borders as in many cases the information needs to be retransmitted. This measure would require 
Member States to share cross-border all necessary data that is required for traffic and transport 
management. This includes for example information provided by vessel operators regarding the 
cargo, the position of the vessel, ERI information, but also the exchange of information between 
authorities  such  as  changes  in  the  navigation  parameters,  limitations  of  traffic,  speed,  etc. 
Member States will need to invest in digital tools,  which will now be used to process reports. 
Vessel operators will only be required to report once (e.g. for the cargo report), as when a border 
is crossed the information will be exchanged between the authorities and not resubmitted by the 
vessel operator. 

92 https://platina3.eu/download/economic-barriers-to-modal-
shift/?wpdmdl=1123&refresh=65100c29521071695550505  

36 

 
 
•  PM16: Specify more clearly the cases for exchange of personal data. Due to concerns express by 
stakeholders on handling of personal data, and as it is not always clear on which basis the data is 
being  processed  and  whether  this  is  allowed,  authorities  are  reluctant  to  process  and  transmit 
positioning information to other authorities. This in turn leads to resubmission of the information 
by the vessel operators to different national authorities or refusal to share information. Under this 
measure,  the  RIS  Directive  would  provide  more  clarity  on  the  specific  cases  and  legal  basis 
where exchange of personal data would be justified (e.g. for reasons of safety, to streamline the 
process,  etc.).  This  measure  is  designed  to  work  in  complementarity  with  PM12,  PM13  and 
PM15  as  it  covers  a  specific  case  (personal  data)  that  they  do  not.  Member  States  would 
therefore  need  to  assess  if  personal  data  and  accordingly  consider  how  best  to  apply  the 
provisions of GDPR to ensure that  RIS information is shared efficiently. They  would have to 
develop and maintain an application where the position of the vessel through AIS can be used for 
port-related matters, such as berth management and collection of port fees, and benefit from a 
simpler procedure of handing this information. Vessel operators will not be required to resubmit 
information (unless there is a change).  

•  PM17: Develop templates and standards for the exchange of personal data. The difference of 
this measure with PM16 is that it goes beyond in that it will develop and mandate new standards 
and technical specifications for the exchange of personal information when this is required by 
national or international legislation. It will thus provide a further step of harmonisation. The roles 
of all stakeholders is similar to that of PM16.  

Expected importance of measures 

The importance of the measures is linked to the importance of the problem driver they address, as 
well as their expected impact in addressing the driver. In this regard, ERDMS (PM6) and CESNI 
(PM10) are the most important measures. As they are both supported by the stakeholders, they are 
included in all policy options. The first is important as it will be the basis of accurate and up-to-date 
basic information on the rivers and in a sense the “IT library” for the functioning of RIS. It will 
contribute to addressing the lack of coherence of technical specifications and provide a basis for 
links  with  the  multimodal  system.  In  addition,  further  developments  in  digitalisation  and 
information cannot take place unless this information is available (for example, an automated vessel 
will require accurate information on the gap between river and a bridge in order to navigate safely). 
PM10  is  likewise  of  high  importance  as  it  will  change  the  currently  inefficient  technical 
specifications setting and adoption procedure and ensure that they updated more regularly. It is a 
tried  and  tested  measure  as  reference  to  CESNI  technical  specifications  has  already  been 
introduced by Directive (EU) 2016/1629 laying down technical requirements for inland waterway 
vessels and by Directive (EU) 2017/2397 on the recognition of professional qualifications in inland 
navigation.  CESNI  has  been  able  to  provide  the  necessary  updates  to  these  technical 
specifications  on  average  every  two  years,  which  is  a  significant  improvement  compared  to  the 
current process for adoption of RIS technical specifications. Both these measures were considered 
to  have  high  potential  to  address  the  respective  problem  drivers  by  the  sector  experts  in  the 
DINA/NAIADES expert group meeting.  

Among the  other measures, the introduction  of  a RIS platform  (PM9) is very important.  It is  an 
existing  EU  funded  project,  providing  reliable  fairway,  infrastructure,  traffic  and  transport 
information  services,  including  route  and  transport  planning,  for  the  waterways  of  the  partner 
countries, as well as a common electronic reporting system. The system was developed voluntarily 
by 13 Member States with inland waterways, with EU funding, and in 2023 it has entered its second 
development stage. This measure will mandate the use application of RIS COMEX in all waterways 
covered by the Directive. It will thus develop into the IT backbone for the provision of RIS and one 

37 

 
upon which the other measures introducing new requirements (e.g. the links with inland ports) will 
be built. Vessel operators, national authorities and software providers will use this platform for all 
RIS  interactions  in  the  daily  operations.  Vessel  operators  will  have  to  interact  with  one  single 
system  instead  of  each  national  one.  By  monitoring  the  flow  and  usage  of  RIS  COMEX  the 
Commission will benefit of a set of indicators to monitor the performance of RIS (as explained also 
in section 9). An important element is that by mandating the system, its operation and usage, a high 
standard of harmonisation is ensured and coverage of the whole relevant network. 

The complaint handling mechanism (PM2) is also an important measure in that it will provide a 
path to identify and rectify problems in the implementation of the Directive and the secondary acts. 
This  will  be  done  based  on  a  bottom-up  approach,  at  a  Member  State  level,  thus  enhancing 
subsidiarity. The Commission will benefit of an overview of the state of implementation.  

Finally, the need to support the integration of inland waterways into the multimodal supply chains 
was identified as an important problem driver by the stakeholders. Two measures (i.e. adding new 
technical specifications for navigation and voyage planning (PM4), as well as with the systems of 
other modes (PM14)) address this problem driver. These measures aim to cover different aspects, 
and  in  particular  the  exchange  of  cargo  information,  the  smooth  operation  with  the  inland  ports 
(which are the transhipment centres for IWT cargo), and the direct links with other modes which 
can help streamline operations in the supply chain as a whole.  

5.2.4  Description of the policy options 

As explained in section 5.2.2, the measures were combined in three policy packages, which have 
been designed to address all policy drivers and contribute to all policy objectives. They differ in the 
level of ambition and obligations that they introduce. No alternative policy options or packages of 
measures were suggested by stakeholders.  

Policy option A (PO-A)  

Policy  option  A  proposes  a  basic  update  of  the  Directive  addressing  the  basic  identified 
shortcomings  but  without  changing  the  scope.  The  overall  structure  of  RIS,  as  regards  the 
technology elements, and the way information is exchanged between stakeholders remains mainly 
the same (such as described in section 1). Interpretative guidelines on the technical specifications 
and their application by the Member States (PM1) play a central role, as a non-regulatory measure 
in this policy option. An important new element is also the introduction of CESNI with a role in the 
development  of  technical  specifications  (PM10).  Member  States  will  be  required  to  increase  the 
frequency by which they provide updates to the ERDMS (PM6), as well as to set up a complaint 
handling mechanism (PM2) for RIS users to report issues with the implementation to RIS (and will 
need to report in turn to the European Commission on an annual basis). Cargo-related information 
exchange will be encouraged through the eFTI mechanism (PM7). Finally, Member States will have 
to  assess  (based  on  provided  clarifications  under  PM16)  the  extent  to  which  personal  data  are 
concerned and ensure that they are processed in the appropriate way.  

In  terms  of  addressing  the  different  specific  objectives,  for  SO1  (Ensure  improved  RIS  data 
availability,  and  harmonised  standards),  the  harmonisation  aspect  will  be  tackled  by  the 
interpretative guidelines (PM1), combined with the complaint handling mechanism (PM2) and the 
development  of  technical  specifications  by  CESNI  (PM10),  whose  updates  should  also  correct 
possible issues (including unclarity) with existing technical specifications that affect harmonisation. 
Data availability will be tackled by the requirement to Member States to provide frequent updates to 
the ERDMS database (PM6). For SO2 (Facilitate the integration of IWT into the multimodal chain), 
an up-to-date ERDMS database (PM6) is important to ensure that the latest information required for 
38 

 
the performance of IWT is available. Providing the cargo information through an eFTI platform, 
even on voluntary basis by the vessel operators (PM7), sets the basis for this information to be re-
used  by  authorities  and  other  RIS  users,  as  appropriate,  in  planning  and  organising  logistic 
operations. As regards SO3 (Ensure a higher uptake and interoperability of digital solutions, and 
address  data  protection  concerns),  the  option  to  exchange  the  cargo-required  data  through  eFTI 
(PM7) would be an important step towards an interoperability of digital systems in a multimodal 
environment.  Finally, PM16, as explained in section 5.2.3, is specifically designed to address the 
data protection concerns, by guiding Member States to take appropriate action.  

Figure 10: RIS structure under PO-A 

Source: European Commission 

Policy option B (PO-B)  

Policy  option  B,  retains  several  measures  from  PO-A  like  the  complaint  mechanism  (PM2), 
ERDMS requirement (PM6), CESNI (PM10) and the clarification regarding personal data (PM16). 
However, it goes beyond PO-A by adding elements on key areas of the Directive. It introduces an 
important change in the architecture of RIS, as it brings RIS COMEX (PM9) as the central node for 
the  exchange  of  information  and  the  provision  of  services.  Unlike  the  baseline  and  PO-A, 
information now is not exchanged directly between the different users (like the vessel operator with 
inland ports) but it is done through the platforms and functionalities of RIS COMEX. New technical 
specifications on navigation and voyage planning (PM4), that are currently missing, are introduced 
and will provide additional information to vessel operators. The exchange of information takes also 
a more prominent role. The reporting of cargo information through eFTI becomes mandatory for 
vessel  operators  (PM8),  who  will  now  also  have  the  option  to  exchange  operational  information 
electronically  with  inland  ports  (PM12).  The  exchange  of  operational  information  will  also  be 
possible with other modes of transport (PM14). RIS will focus on the most important waterways as 
its scope will match that of the TEN-T waterways (PM11).  

In  terms  of  addressing  the  different  specific  objectives,  for  SO1  (Ensure  improved  RIS  data 
availability, and harmonised standards), on top of PM2, PM6 and PM10 (discussed under PO-A), 
vessel  operators  will  have  access  to  more  information  regarding  the  situation  in  the  waterways 

39 

 
 
(PM4),  while  RIS  COMEX  (PM9)  will  provide  a  single  platform  for  information,  replacing  the 
need  to  refer  to  several  national  ones.  For  SO2  (Facilitate  the  integration  of  IWT  into  the 
multimodal chain), measures PM4, PM6 and PM9 also contribute (in addition to addressing SO1). 
The voluntary exchange of information with inland ports (PM12) will allow those vessel operators 
that chose this option to exchange information necessary for logistic operations. This is also the case 
of standards and links with other modes in PM14. The mandatory reporting of cargo information 
through eFTI for vessel operators (PM8) will also contribute towards ensuring improved RIS data 
availability. Furthermore, by ensuring that the scope is the same as for the TEN-T, focus is put on 
multimodal  operations.  Finally,  for  SO3  (Ensure  a  higher  uptake  and  interoperability  of  digital 
solutions, and address data protection concerns) in addition to PM8 (as the mandatory version of 
PM7), and PM16 (already included in PO-A), the use of RIS COMEX (PM9) will create a single 
platform simplifying the interaction with digital systems. The links with inland ports (PM12) and 
other  modes  (PM14),  as  described  in  section  5.2.3,  are  specifically  designed  to  increase 
interoperability.  

Figure 11: RIS structure under PO-B 

Source:  European  Commission.  Note:  RIS  COMEX  includes  also  RIS  COMEX  2  and all  applications  such as 
EuRIS and CEERIS 

Policy option C (PO-C) 

Policy  option  C  adds  two  mandatory  measures  to  PO-B,  namely  the  electronic  voyage  planning 
(PM5) and the exchange of data with inland ports (PM13), which introduce a new framework for 
traffic  management  and  for technical developments such  as  digitalisation  and automation.  It  also 
introduces a new Performance Measurement Framework (PM13). 

In terms of addressing the specific objectives, for SO1 (Ensure improved RIS data availability, and 
harmonised standards), PO-C includes several policy measures as in PO-B (PM4, PM6, PM9 and 
PM10). In addition, the introduction of a performance measurement framework (PM3), to control 
the  performance  of  RIS  in  a  top-down  approach,  is  proposed  instead  of  the  bottom-up  approach 
used in the complaint handling mechanism (PM2 under PO-A and PO-B). A new requirement on 
electronic  voyage  plan  reporting  (PM5)  will  provide  additional  information  on  the  current  and 

40 

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            
 
expected traffic in the waterways and allow national authorities to plan waterway traffic. For SO2 
(Facilitate  the  integration  of  IWT  into  the  multimodal  chain),  measures  PM4,  PM6,  PM8,  PM9, 
PM11 and PM14 will perform the same way as for PO-B. A significant change is that now vessel 
operators  will  be  required  to  electronically  exchange  operational  information  with  inland  ports 
(PM13); this was voluntary under PM12 in PO-B. Moreover, the requirement for Member States to 
share  cross  border  data  for  traffic  and  transport  management  purposes  (PM15)  would  directly 
facilitate the exchange of data not only within IWT, but also unlock potential for other modes. The 
electronic  voyage  planning  (PM5)  will  also  contribute  towards  SO2.  Finally,  for  SO3  (Ensure  a 
higher uptake and interoperability of digital solutions, and address data protection concerns), on 
top of the measures discussed under PO-B (PM8, PM9 and PM14), by moving from a voluntary to 
a  mandatory  exchange  of  information  with  inland  ports  (PM13)  will  force,  by  design,  vessel 
operators  to  take  up  this  application.  Mandating  the  cross-border  sharing  of  data  for  traffic  and 
transport management purposes (PM15) will force Member States to use electronic applications for 
this exchange. In addition, in relation to data protection PO-C would introduce specific templates 
and standards for the exchange of personal information (PM17) within RIS (compared to simple 
clarifications as in PM16 under PO-A and PO-B). 

Figure 12: RIS structure under PO-C 

Source:  European  Commission.  Note:  RIS  COMEX  includes  also  RIS  COMEX  2  and all  applications  such as 
EuRIS and CEERIS. 

6  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

This section summarizes the main expected economic, social and environmental impacts of each 
policy  option  (PO)93.  The  proposed  measures  included  in  the  policy  options  are  assumed  to  be 
implemented from 2025 onwards, so that the assessment has been undertaken for the 2025-2050 
period, and it refers to EU27. Costs and benefits are expressed as present value over the 2025-2050 

93 The analysis in this section is based on Ramboll et al. (2024), Impact assessment support study. 

41 

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               
 
 
period, using a 3% discount rate. All costs and benefits are expressed in 2022 prices. Further details 
on the methodological approach are provided in Annex 4. 

6.1  Economic impacts 

This section provides the economic impacts of the policy options on the national public authorities, 
the  European  Commission  and  the  private  sector  (vessel  operators  and  RIS  software  services 
providers). It also provides an assessment of impacts on small and medium enterprises (SMEs), the 
functioning of the internal market and competition, competitiveness, digital by default, congestion 
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 study94. 

6.1.1 

Impact on national public authorities 

National  public  authorities  include  all  Member  States’  bodies  responsible  for  ensuring  the 
implementation of RIS. All policy options are expected to lead to adjustment costs, administrative 
costs  and  administrative  cost  savings  for  national  authorities  (see  Table  3  and  Table  4).  Each 
category of costs/costs savings is discussed below, while a detailed analysis including the estimates 
and the assumptions used for deriving the costs and costs savings for each policy measure included 
in the policy options is provided in Annex 4. Summary tables by policy option and policy measure, 
for 2030, 2040 and 2050 and expressed as present value over 2025-2050 relative to the baseline are 
also provided in section 3 of Annex 4. 

One-off adjustment costs for national public authorities. All policy options are expected to lead to 
one-off  adjustment  costs  for  the  national  administrations  (see  Table  3).  In  PO-A  these  cover 
investment  costs  for  setting  up  the  complaint  mechanism  (PM2),  investment  costs  for  adapting 
existing data flows so that RIS cargo-related information is linked with eFTI (PM7) and costs for 
developing applications that would handle personal data (PM16), with a total cost estimated at EUR 
5.6 million in 2025 relative to the baseline. More specifically, the costs for setting up the complaint 
mechanism (PM2) would amount to EUR 2.76 million in 2025, which is three times the recurrent 
annual  costs  for  running  the  mechanism,  based  on  the  experience  of  European  Maritime  Safety 
Agency  for  setting  up  the  e-certificate  registry.  Regarding  investment  costs  for  adapting  existing 
data flows so that RIS cargo-related information is linked with eFTI (PM7), there are currently five 
systems in place: BICS (the Netherlands), eRIBa (Belgium), VELI (France), NAMIB (Germany), 
and CEERIS (Rest of Europe). Based on feedback from RIS authorities during the stakeholders’ 
consultation  process,  the  investment  costs  for  adjusting  each  of  these  systems  are  estimated  at 
around EUR 250,000 per system. Thus, the total one-off adjustment costs for PM7 would amount to 
EUR 1.25 million in 2025, relative to the baseline. The investment costs for developing applications 
that would handle personal data (PM16) are estimated at EUR 5,839 per port (in 2022 prices)95. For 
the  265  ports,  the  total  one-off  costs  due  to  PM16  would  amount  to  EUR  1.55  million  in  2025 
relative to the baseline. 

In  addition,  PO-B  would  require  investments  in  hardware  and  software  to  gather  and  share 
information for navigation and voyage planning (PM4), to implement new technical specifications 
for the exchange of information with ports (PM12), and to integrate RIS information systems with 

94 Ramboll et al. (2024), Impact assessment support study. 
95 Based on the DINA study (Source: European Commission (2017), Digital inland waterway areas. Towards a 
digital inland waterway area and digital multimodal nodes – Final report).  

42 

 
 
information  systems  of  other  modes  (PM14).  For  PM4,  based  on  interviews  with  the  Dutch 
Directorate General for Public Works and Water Management (Rijkswaterstaat), the costs for the 
Netherlands are estimated at EUR 500,000. Extrapolating to the other twelve Member States, based 
on each country’s share of the network in terms of length and infrastructure elements such as locks 
and  bridges,  the  total  one-off  costs  for  PM4  are  estimated  at  EUR  4.55  million  relative  to  the 
baseline.  To  implement  new  technical  specifications  for  the  exchange  of  information  with  ports 
(PM12), investment costs per port are estimated at EUR 29,197 in 2022 prices, based on the DINA 
study96. Assuming that all 54 core ports of the European TEN-T network for which no RIS data is 
available  would implement the  new  technical specifications, the total one-off costs  due to PM12 
would amount to EUR 1.58 million in 2025. For PM14, the IT investment costs are based on the 
CoRISma project and are estimated at EUR 3.14 million relative to the baseline97.  

The  compulsory  connection  with  eFTI  (PM8)  is  assumed  to  have  the  same  cost  as  the  optional 
connection in PO-A (EUR 1.25 million), as the same digital requirements will apply. The inclusion 
of new Member States in RIS COMEX (PM9) will also require some investment costs, estimated at 
EUR 3.5 million. As a result, in PO-B the total one-off adjustment costs for national authorities are 
estimated at EUR 18.3 million in 2025 relative to the baseline.  

PO-C has few common measures with PO-B (PM4, PM8, PM9 and PM14) that lead to the same 
adjustment costs. In addition, in PO-C investment costs are needed for developing the software that 
can process and convert the voyage plan notification messages from inland waterway operators into 
accurate lock predictions (PM5) and for software to exchange information with the authorities of 
other Member States (PM15). For PM5, building on estimates for the Netherlands from the Dutch 
Directorate General for Public Works and Water Management (Rijkswaterstaat), the costs for the 
other Member States have been derived based on the network usage and the size of the network in 
each Member State, relative to that of the Netherlands. The one-off costs due to PM5 are estimated 
at EUR 3.07 million in 2025 relative to the baseline. For PM15, investment costs are estimated at 
EUR  5  million,  based  on  comparable  projects  in  the  rail  freight  sector  (ELETA  and  EDICT). 
Compared to PO-B, mandating the exchange of information with ports (PM13)98 increases the total 
costs  compared  to  PM12,  and  similarly  for  the  costs  of  development  of  personal  data  exchange 
templates (PM1799 in PO-C, compared to PM16 in PO-A and PO-B).  

Thus, the one-off adjustment costs in PO-C are estimated to be the highest, at EUR 28.2 million in 
2025  compared  to  the  baseline,  followed  by  PO-B  (EUR  18.3  million)  and  PO-A  (EUR  5.6 
million).  

Table 3: One-off adjustment  costs for national public authorities by policy option and measure in 2025, 
relative to the baseline (in million EUR, in 2022 prices) 

PM2 
PM4 

Difference to the Baseline 
PO-B 

PO-A 

PO-C 

2.76 

2.76    
4.55 

4.55 

96 Source: European Commission (2017), Digital inland waterway areas. Towards a digital inland waterway area 
and digital multimodal nodes – Final report.  
97 CoRISMa was a TEN-T project running between January 2014 and December 2015 that studied and defined 
the next steps in the development of RIS. 
98 The investment costs per port are the same as in PM12, estimated at EUR 29,197 in 2022 prices. However, in 
PM13 they apply to 169 ports. 
99 The investment costs for such an application are estimated at EUR 10,219 per port (in 2022 prices) based on 
the DINA study. The total one-off adjustments costs for all 265 ports are thus estimated at EUR 2.71 million. 

43 

 
  
  
 
Difference to the Baseline 
PO-B 

PO-A 

PO-C 

PM5 
PM7 
PM8 
PM9 
PM12 
PM13 
PM14 
PM15 
PM16 
PM17 

Total one-off adjustment costs 
Source: Ramboll et al. (2024), impact assessment support study  

1.25    

1.55 

5.56 

1.25 
3.50 
1.58    

3.14 

1.55    

18.33 

3.07 

1.25 
3.50 

4.93 
3.14 
5.00 

2.71 
28.15 

Recurrent administrative costs for national public authorities. Under all policy options (see Table 
4),  Member  States  will  need  to  provide  the  information  required  by  the  RIS  Directive  to  the 
ERDMS  (PM6).  For  the  Netherlands,  PM6  is  estimated  to  require  additional  1.5  full  time 
equivalents (FTE) relative to the baseline, based on the feedback received during the stakeholders’ 
consultation.  This  has  been  extrapolated  to  the  other  Member  States  based  on  the  size  of  their 
network in relation to that of the Netherlands. Assuming 240 working days per year and 7.3 hours of 
work per day on average and using the tariff per hour for non-manual workers (ISCO 8 – Plant and 
machine  operators  and  assemblers)  from  Eurostat  Structure  of  earnings  survey,  the  recurrent 
administrative costs for national public authorities due to PM6 are estimated at EUR 0.66 million 
per year relative to the baseline from 2025 onwards. 

Moreover,  the  complaint  mechanism  introduced  by  PO-A  and  PO-B  is  expected  to  generate 
administrative costs for  handling the  RIS related  complaints  (PM2).  The  recurrent  administrative 
costs for PM2, totalling EUR 0.92 million per year from 2025 onwards, are estimated based on the 
costs for the Netherlands (EUR 150,000) provided by Rijkswaterstaat, and the network usage and 
the size of the network in each Member State relative to that of the Netherlands. Furthermore, PO-A 
and PO-B entail administrative costs of EUR 0.39 million per year for managing and maintaining 
the  system  of  exchange  of  personal  data  (PM16)100.  PO-B  is  additionally  expected  to  result  in 
recurrent administrative costs for maintaining and updating the system for the collection and update 
of data for voyage planning and navigation (RIS Index) on a regular basis (PM4), for managing the 
exchange with the ports (PM12), as well as with the systems of other modes (PM14). The recurrent 
administrative costs for PM4, PM12 and PM14 are assumed to be 25% of the investment costs in 
PM4, PM12 and PM14, respectively, based on the DINA study. 

In PO-C, the common measures with PO-B (PM4, PM6 and PM14) would result in the same costs. 
In addition, PO-C would also lead to recurrent administrative costs for the collection and processing 
of data for the new Performance Measurement Framework (PM3)101, higher costs for maintaining 

100 Recurrent administrative costs are assumed to be 25% of the investment costs in PM16 based on the DINA 
study, or EUR 1,460 per port. 
101  Based  on  two  interviews  with  national  authorities,  it  is  estimated  that  each of  the  13 Member  States  using 
inland waterways for commercial purposes would spend EUR 50,000 per year.  

44 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
the information exchange systems with ports (PM13) and the systems for exchange of personal data 
(PM17), as well as the maintenance of the system for the electronic voyage plan reporting (PM5)102. 

Overall, PO-C is estimated to lead to the highest recurrent administrative costs, estimated at EUR 
5.9 million per year relative to the baseline (see Table 4), followed by PO-B (EUR 4.3 million per 
year), and PO-A (EUR 2 million per year). Expressed as present value over 2025-2050, they are 
estimated at EUR 104.3 million in PO-C, EUR 75.3 million in PO-B and EUR 34.9 million in PO-
A relative to the baseline (see Table 67 in section 3 of Annex 4).  

Recurrent administrative cost savings for national public authorities. In PO-A, by introducing the 
information exchange of cargo data through eFTI (PM7), national public authorities are expected to 
benefit of reduced efforts as all cargo reports would be reported in an electronic manner (see Table 
4). According to the estimates provided by the Dutch authorities, a total elimination of the paper 
reports would lead to a reduction in the effort required equivalent to 8 full time equivalents (FTE) 
relative to  the  baseline. Considering the voluntary system in PM7,  a 50%  reduction  in  the  paper 
cargo  reports  is  assumed,  equivalent  to  4  FTEs  saved  relative  to  the  baseline  in  2026.  This  is 
extrapolated to the other Member States based on their respective transport activity relative to that of 
the Netherlands. In addition, the growth in the number of paper cargo reports over time is also taken 
into account. The costs savings have been estimated assuming 240 working days per year and 7.3 
hours of work per day on average and using the tariff per hour for non-manual workers (ISCO 8 – 
Plant and machine operators and assemblers) from Eurostat Structure of earnings survey. They are 
projected at EUR 0.62 million in 2030 and EUR 0.74 million in 2050, relative to the baseline.  

In  PO-B  and  PO-C,  mandating  cargo-related  information  to  be  exchanged  through  the  eFTI 
mechanism (PM8) is expected to lead to higher costs savings (EUR 1.25 million in 2030 and EUR 
1.47 million in 2050, relative to the baseline) than for PM7, due to the full elimination of the paper 
reports103. The use of RIS COMEX (PM9) in PO-B and PO-C will bring further costs savings of 
EUR 0.5 million per  year,  relative to  the  baseline,  by  gradually  replacing the national platforms. 
PO-C will result in additional costs savings relative to PO-B through reduced efforts for controls at 
borders (PM15). Based on interviews during the stakeholders’ consultation, border officers spend 
on average 5 minutes for these controls on each side of the border. Considering the labour cost per 
hour  (EUR  26.7  per  hour)  and  the  number  of  vessels  that  cross  borders  where  a  control  is 
established (87,420 on average), the administrative costs savings for national public authorities due 
to PM15 are estimated at EUR 0.39 million per year from 2026 onwards relative to the baseline. 

Overall, PO-C is estimated to lead to the highest recurrent administrative costs savings, estimated at 
EUR  2.1  million  in  2030  and  EUR  2.4  million  in  2050  relative  to  the  baseline  (see  Table  4), 
followed by PO-B (EUR 1.8 million costs savings in 2030 and EUR 2 million in 2050), and PO-A 
(EUR 0.6 million costs savings in 2030 and EUR 0.7 million in 2050). Expressed as present value 
over 2025-2050, they are estimated at EUR 37.4 million in PO-C, EUR 30.6 million in PO-B and 
EUR 11.4 million in PO-A relative to the baseline (see Table 67 in section 3 of Annex 4). 

102 Recurrent administrative costs for PM5, PM13 and PM17 are assumed to be 25% of the investment costs in 
PM5, PM13 and PM17, respectively, based on the DINA study. 
103 According to the estimates provided by the Dutch authorities, a total elimination of the paper reports would 
lead to a reduction in the effort required equivalent to 8 full time equivalents (FTE) relative to the baseline. 

45 

 
 
Table 4: Recurrent costs and costs savings for national public authorities by policy option and measure in 
2030, 2040 and 2050, relative to the baseline (in million EUR, in 2022 prices) 

Administrative costs 

PM2 
PM3 
PM4 
PM5 
PM6 
PM12 
PM13 
PM14 
PM16 
PM17 

PO-A 
2040 

1.97 
0.92 

2030 

1.97 
0.92 

2050 

1.97 
0.92 

0.66 

0.66 

0.66 

0.39 

0.39 

0.39 

Difference to the Baseline 
PO-B 
2040 

2050 

2030 

4.29 
0.92 

4.29 
0.92 

4.29 
0.92    

1.14 

1.14 

1.14 

0.66 
0.39 

0.79 
0.39 

0.66 
0.39 

0.79 
0.39 

0.66 
0.39    

0.79 
0.39    

PO-C 
2040 

2030 

2050 

5.91 

5.91 

5.91 

0.65 
1.14 
0.77 
0.66 

1.23 
0.79 

0.65 
1.14 
0.77 
0.66 

1.23 
0.79 

0.65 
1.14 
0.77 
0.66 

1.23 
0.79 

0.68 

0.68 

0.68 

0.62 
0.62 

Administrative cost 
savings 
PM7 
PM8 
PM9 
PM15 
Net costs  
Source: Ramboll et al. (2024), impact assessment support study  

0.74 
0.74    

0.68 
0.68 

1.23 

1.29 

1.34 

1.25 
0.50 

2.54 

1.75 

1.86 

1.97 

2.14 

2.24 

2.36 

1.36 
0.50 

1.47 
0.50 

2.43 

2.31 

1.25 
0.50 
0.39 
3.78 

1.36 
0.50 
0.39 
3.67 

1.47 
0.50 
0.39 
3.55 

Net costs for national public authorities. All policy options result in net costs for national public 
authorities. Net recurrent costs are estimated to be the highest in PO-C (EUR 3.8 million in 2030 
and EUR 3.6 million in 2050 relative to the baseline), followed by PO-B (EUR 2.5 million in 2030 
and EUR 2.3 million in 2050) and PO-A (EUR 1.3 million in 2030 and EUR 1.2 million in 2050). 
These come in addition to the one-off costs of EUR 28.2 million in PO-C, EUR 18.3 million in PO-
B and EUR 5.6 million in PO-A. Expressed as present value over 2025-2050 relative to the baseline 
(see Table 67 in section 3 of Annex 4), PO-C results in the highest net one-off and recurrent costs 
for national public authorities of EUR 95 million, followed by PO-B (EUR 63 million) and PO-A 
(EUR 29.1 million). 

6.1.2 

Impact on the European Commission 

Adjustment costs for the European Commission. PO-A is expected to lead to one-off adjustment 
costs  for  the  Commission,  for  the  development  of  guidelines  (PM1).  The  development  of  the 
guidelines is assumed to proceed in two steps. A study will be carried out to compile the required 
elements  and  propose  several  options  for  the  establishment  of  the  technical  specifications.  In  a 
second stage, an expert group will use the findings of the study to draft the guidelines. The one-off 
costs of the study are estimated at EUR 400,000. The average cost for a two-day workshop hosted 
by  European  Commission  (EC),  where  participants  are  reimbursed  by  the  EC,  is  around  EUR 
30,000.  Two  of  such  in-person  workshops  may  be  required  as  well  as  two  online  meetings. 
Compensation  for  the  experts  contributing  to  the  online  meetings  is  estimated  at  EUR  5,000  for 
each meeting. Therefore, the one-off adjustment costs for the European Commission are estimated 
at EUR 0.47 million in 2025. No additional costs for the Commission are foreseen in PO-B and PO-
C relative to the baseline.  

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6.1.3 

Impact on businesses  

The two categories of businesses expected to be affected by this initiative are the vessel operators 
and the RIS software service providers104 (see Table 5 and Table 6). Detailed explanations on the 
estimates and assumptions used for deriving the costs and costs savings for each policy measure 
included in the options and each stakeholder group are provided in Annex 4. Summary tables by 
policy  option,  policy  measure,  and  stakeholder group  for  2030, 2040  and  2050  and  expressed  as 
present value over 2025-2050 relative to the baseline are also provided in section 3 of Annex 4. 

Vessel operators 

Administrative costs for vessel operators. Only PO-C is expected to lead to administrative costs for 
vessel operators (see Table 5). In PO-C, the recurrent administrative costs for vessel operators are 
due to the mandatory electronic voyage plan reporting (PM5), as vessel operators will need to spend 
more time in preparing these reports (estimated at around 1 hour per voyage). Based on replies by 
inland skippers in the context of stakeholders’ consultation, preparing and communicating a voyage 
plan will take 34 minutes for the first notification and 14 minutes for follow-up notifications. The 
total number of vessel voyages (passenger and freight) is projected at 729,880 in 2030 and 744,806 
in 2050 in the baseline. It is estimated that for these voyages 729,880 first notifications would be 
required in 2030  and  744,806  in  2050,  as well  as 1,416,312  follow-up notifications in  2030  and 
1,518,409 in 2050105. Thus, the additional administrative costs due to PM5 are estimated at EUR 
19.7 million in 2030 and EUR 20.6 million in 2050 relative to the baseline. Expressed as present 
value  over  2025-2050  they  are  estimated  at  EUR  367.5  million  relative  to  the  baseline.  For  the 
purpose of the ‘one in, one out’ approach, the average annual administrative costs per vessel voyage 
are estimated at EUR 27.1, while the average number of vessel voyages during 2025-2035 at EUR 
727,100. The annual average administrative costs for 2025-2035 due to PM5 are thus estimated at 
EUR 19.7 million in PO-C. 

As  explained  in  section  1,  the  turnover  of  the  sector  was  EUR  7  billion  in  2020106,  and  this  is 
expected to grow over time in line with the projected transport activity. Therefore, the costs of PO-C 
are estimated to represent a very small share of the turnover, while PO-A and PO-B result in no 
additional costs for vessel operators.  

Adjustment costs savings for vessel operators. PO-A is expected to bring adjustment cost savings 
to vessel operators in the form of reduced effort to plan their journey due to the guidelines (PM1) 
and due to the better RIS data as problems get resolved through the complaint mechanism (PM2). In 
the baseline scenario, the time required for preparing an international trip is estimated at 15 minutes 
and that for a domestic trip at 10 minutes. Based on discussions with training institutes in inland 
navigation  (and  validated  by  the  sector  in  the  targeted  workshop),  trip  preparation  time  for 
international trips is expected to decrease by 2.5 minutes relative to the baseline from 2026 onwards 
due  to  PM1  and  by  8%  for  international  and  domestic  trips  due  to  PM2  (1.2  minutes  for 
international trips and 0.8 minutes for domestic trips). PM1 is expected to lead to adjustment costs 
savings of EUR 0.49 million in 2030 and EUR 0.5 million in 2050 relative to the baseline, while 

104 It should be noted that all the costs savings related to software have been assigned to the providers. However, 
depending on the relative negotiation power of vessel operators and software service providers, a part of these 
savings could potentially be passed on to vessel operators. 
105 For further details see Annex 4. 
106 https://transport.ec.europa.eu/facts-funding/studies-data/eu-transport-figures-statistical-pocketbook/statistical-
pocketbook-2023_en  

47 

 
 
PM2 at costs savings of EUR 0.35 million in 2030 and EUR 0.36 million in 2050. Furthermore, 
improved  quality  of  RIS  data  in  the  ERDMS  (PM6)  will  reduce  the  time  needed  for  voyage 
planning. Based on feedback from vessel operators, the time needed for voyage planning can be 
reduced by 20% due to PM6 (2 minutes saved for each domestic voyage and 3 minutes saved for 
each international trip) relative to the baseline, equivalent to costs savings of EUR 0.85 million in 
2030 and EUR 0.86 million in 2050. Thus, total adjustment cost savings in PO-A are estimated at 
around EUR 1.7 million in 2030 and 2050 relative to the baseline (see Table 5), equivalent to EUR 
29.6 million expressed as present value over 2025-2050. 

PO-B  includes  the  same  benefits  as  PO-A  for  PM2  and  PM6,  with  additional  adjustment  costs 
savings  coming  from  reduced  efforts  for  voyage  planning  due  to  better  navigation  information 
(PM4).  The  time  needed  for  voyage  planning  can  be  reduced  by  15%  due  to  PM4  (1.5  minutes 
saved  for  each  domestic  voyage  and  2.25  minutes  saved  for  each  international  trip),  based  on 
feedback from vessel operators, equivalent to costs savings of EUR 0.63 million in 2030 and EUR 
0.65 million in 2050. Savings for voyage planning will also materialise for skippers thanks to the 
centralisation  of  information  in  the  RIS  platform  (PM9)  and  the  better  exchange  with  ports  for 
planning  their  voyage  (PM12).  In  PM9,  a  50%  reduction  in  the  time  required  for  preparing  an 
international voyage is assumed (7.5 minutes) from 2026 onwards relative to the baseline, based on 
stakeholders’  feedback,  equivalent  to  costs  savings  of  EUR  1.48  million  in  2030  and  EUR  1.51 
million in 2050. With regard to PM12, an average of 5 minutes per port call is assumed  for trip 
preparation for the ports’ section in the baseline. In the process, important information should be 
retrieved, such as how deep the port is in relation to the depth of the channel, as well as where berths 
are and where loading/unloading can take place, etc. This information is difficult to obtain now. The 
new  technical  specification  for  ports  will  facilitate  the  voyage  preparation  for  the  ports’  section. 
Based on stakeholders’ input, PM12 could reduce the time for voyage planning by 21% per port call 
(1  minute  saved),  equivalent  to  costs  savings  of  around  EUR  0.17  million  in  2030  and  in  2050 
relative to the baseline. Total adjustment costs savings in PO-B are estimated at EUR 3.5 million in 
2030 and EUR 3.6 million in 2050 relative to the baseline (see Table 5), equivalent to EUR 72.1 
million expressed as present value over 2025-2050. 

In PO-C, savings for vessel operators for PM4, PM6 and PM9 are the same as in PO-B. In addition, 
the  new  performance  measurement  framework  (PM3)  is  expected  to  bring  savings  in  the  time 
needed  to  plan  the  voyage  due  to  more  accurate  information,  while  the  electronic  voyage  plan 
reporting (PM5) will lead to operation costs savings (i.e. fuel costs savings) due to more efficient 
voyages. For PM3, the vessel operators that responded to the survey estimated that the time spent on 
planning  trips  will  decrease  by  4%  on  average  relative  to  the  baseline  (0.6  minutes  for  each 
international trip and 0.4 minutes for each domestic trip) from 2026 onwards, equivalent to costs 
savings of  around EUR 0.18 million in 2030  and  in 2050.  For PM5, operation  costs  savings  for 
vessel  operators  are  expected  through  reduced  speed  of  ships  and  less  manoeuvring  movements 
(e.g. braking the ship, mooring at waiting jetties, leaving and entering the lock). These savings are 
mainly related to the crossing of locks and adaptation of the speed in the proximity of a lock (i.e. the 
last hour). The adjustment of speed in the proximity of a lock (i.e. during the last hour) is estimated 
to lead to 5% savings in fuel consumption. Based on statistics for the Netherlands, vessels cross on 
average 4 locks per trip. Also considering the total number of voyages and a consumption of 60 
litres per hour of sailing, savings are estimated at around 0.9% of the energy consumption (9.3 kilo 

48 

 
tonnes of oil equivalent in 2030 and 8.3 kilo tonnes of oil equivalent in 2050), equivalent to costs 
savings of EUR 15.04 million in 2030 and EUR 15.24 million in 2050 relative to the baseline107.  

Better managing of cargo information and exchanges with ports for planning the voyage (PM13) is 
also expected to lead to adjustment costs savings. Based on stakeholders’ input, PM13 could reduce 
the time for voyage planning per port call by 65% (3.2 minutes saved) relative to the baseline from 
2026 onwards, equivalent to costs savings of EUR 0.52 million in 2030 and EUR 0.53 million in 
2050. Thus, the total  adjustment cost  savings  for vessel operators in PO-C are estimated at EUR 
18.7 million in 2030 and EUR 19 million in 2050 relative to the baseline (see Table 5), equivalent to 
EUR 324 million expressed as present value over 2025-2050. 

Administrative cost savings for vessel operators. All policy options result in administrative costs 
savings for vessel operators (see Table 5). In PO-A, skippers will spend less time in re-registering 
cargo  information  as  reporting  will  be  possible  through  eFTI  (PM7).  Around  30%  of  all  cross-
border  trips  are  estimated  to  require  repeated  notifications.  Based  on  the  interviews  and 
stakeholders’  survey,  repeated  notifications  take  around  15  minutes  per  vessel  operator.  PM7  is 
expected to reduce the share of repeated notifications by 10 percentage points relative to the baseline 
from 2026 onwards, equivalent to administrative costs savings of around EUR 0.29 million in 2030 
and in 2050. 

Legal clarity for private data exchanges (PM16) will reduce re-reporting efforts in PO-A and PO-B. 
It is estimated that PM16 would lead to a decrease by 20% in the number of resubmitted reports to 
ports relative to the baseline (72,988 reduction in 2030 and 74,481 in 2050). The resubmission of 
electronic cargo reports to ports takes around 10 minutes per port call. Thus, the costs savings due to 
PM16  are  estimated  at  EUR  0.32  million  in  2030  and  EUR  0.33  million  in  2050  relative  to  the 
baseline108. For the purpose of the ‘one in, one out’ approach, the average reduction in the number 
of resubmitted cargo reports over 2026-2035 due to PM16 has been estimated at 72,799 per year 
relative to the baseline and the average costs saved per resubmission at EUR 4.4. Thus, the average 
annual administrative costs savings for vessel operators due to PM16  are estimated at EUR 0.32 
million relative to the baseline. 

Both PO-B and PO-C will bring administrative cost savings to vessel operators (savings in PO-C 
being higher) due to the reduction in the number of cargo reports resubmitted to inland ports (PM12 
in PO-B and PM13 in PO-C, see Table 5). The time for preparing and re-submitting the reports is 
estimated at 10 minutes in the baseline. For PM12, administrative costs savings are expected for all 
83 core TEN-T network ports. PM12 could reduce the number of resubmitted cargo reports by 31% 
relative  to  the  baseline,  equivalent  to  costs  savings  of  EUR  0.51  million  in  2030  and  EUR  0.52 
million in 2050. In PM13, all 262 inland ports of the core and comprehensive TEN-T network will 
be  automatically  receiving  the  (electronic)  cargo  reports  and  therefore,  vessel  operators  will  not 
have to resubmit them. Thus, the costs savings for PM13 are estimated at EUR 1.62 million in 2030 
and  EUR  1.66  million  in  2050  relative  to  the  baseline.  For  the  purpose  of  the  ‘one  in,  one  out’ 
approach,  the  average  reduction  in  the  number  of  resubmitted  cargo  reports  due  to  PM12  over 

107 The projected average energy prices per tonne of oil equivalent (toe), from the baseline scenario developed 
with the PRIMES-TREMOVE model, have been used to estimate the adjustment costs savings. These average 
prices per toe take into account the projected development of the fuel mix, including biofuels, electricity and e-
fuels. 
108 The weighted average of the tariff per hour for non-manual workers (ISCO 8 – Plant and machine operators 
and assemblers) in the 13 Member State in the scope of RIS (EUR 26.7 per hour), based on Eurostat Structure of 
earnings survey, is used to estimate the costs. 

49 

 
 
2026-2035 is estimated at 114,006 per year relative to the baseline and the average costs saved per 
resubmission at EUR 4.4. Thus, the average annual administrative costs savings for vessel operators 
due to PM12 during 2026-2035 are estimated at EUR 0.5 million relative to the baseline. For PM13, 
the average reduction in the number of resubmitted cargo reports over 2026-2035 is estimated at 
363,996 per year relative to the baseline and the average annual administrative costs savings at EUR 
1.6 million. 

In PO-B and PO-C, administrative costs savings for vessel operators are also expected due to the 
use of eFTI for the cargo reporting that reduces resubmissions (PM8), as well as through the use of 
RIS COMEX as the single platform (PM9) (see Table 5). Around 30% of all cross-border trips are 
estimated  to  require  repeated  notifications.  Based  on  the  interviews  and  stakeholders’  survey, 
repeated notifications take around 15 minutes per vessel operator. PM8 is expected to reduce the 
share of repeated notifications by 20 percentage points relative to the baseline from 2026 onwards, 
equivalent to costs savings of EUR 0.57 million in 2030 and EUR 0.59 million in 2050. In addition, 
when the use of RIS COMEX, including the CEERIS tool, becomes mandatory, vessel operators on 
the Danube will benefit from a single electronic notification of cargo data. Thus, PM9 is expected to 
reduce the share of repeated notifications by 8 percentage points relative to the baseline from 2026 
onwards, equivalent to costs savings of EUR 0.22 million in 2030 and EUR 0.23 million in 2050. 
For the purpose of the ‘one in, one out’ approach, in PM8 the average reduction in the number of 
repeated notifications over 2026-2035 is estimated at 88,397 per year relative to the baseline and the 
average costs saved per repeated notification at EUR 6.5. Thus, the average annual administrative 
costs savings for vessel operators due to PM8 during 2026-2035 are estimated at EUR 0.6 million 
relative to the baseline. For PM9, the average reduction in the number of repeated notifications over 
2026-2035  is  estimated  at  34,448  per  year  relative  to  the  baseline  and  the  average  annual 
administrative costs savings at EUR 0.2 million.  

In addition, in PO-C vessel operators will also benefit from costs savings due to the reduction in the 
number of resubmissions of cargo reports when crossing borders (PM15) and to ports, driven by the 
improved  clarity  on  the  exchanges  of  information  which  may  contain  personal  data  (PM17). 
Considering the synergies with PM8 and PM9 (both included in PO-C), PM15 is expected to reduce 
the  share  of  repeated  notifications  by  2  percentage  points  relative  to  the  baseline  from  2026 
onwards, equivalent to costs savings of EUR 0.06 million in 2030 and EUR 0.07 million in 2050. In 
PM17, by clarifying instances when Automatic Identification System (AIS) data can and cannot be 
shared,  it  is  estimated  that  the  number  of  resubmitted  reports  to  ports  would  decrease  by  30% 
relative to the baseline from 2026 onwards, equivalent to costs savings of EUR 0.49 million in 2030 
and EUR 0.50 million in 2050. 

Total administrative costs savings for vessel operators (see Table 5) are estimated to be the highest 
in PO-C (around EUR 3 million in 2030 and in 2050) relative to the baseline, followed by PO-B 
(EUR 1.6 million in 2030 and EUR 1.7 million in 2050) and PO-A (around EUR 0.6 million in 
2030 and in 2050). Expressed as present value over 2025-2050 they are estimated at EUR 51.9 in 
PO-C, EUR 28.5 million in PO-B and EUR 10.7 million in PO-A relative to the baseline scenario.  

Table  5:  Recurrent  costs  and  costs  savings  for  vessels  operators  by  policy  option  and  measure  in  2030, 
2040 and 2050, relative to the baseline (in million EUR, in 2022 prices) 

PO-A 
2040 

2050 

2030 

Difference to the Baseline 
PO-B 
2040 

2050 

2030 

Administrative costs 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

PM5 

Adjustment costs savings 

PM1 

1.69 
0.49 

1.70 
0.50 

3.48 

3.50 

3.55 

1.73 
0.50    

50 

PO-C 
2040 
20.16 
20.16 
18.04 

2030 
19.74 
19.74 
18.70 

2050 
20.60 
20.60 
18.98 

 
  
  
  
  
  
  
  
  
  
  
  
  
PO-A 
2040 

2050 

2030 

Difference to the Baseline 
PO-B 
2040 

2050 

2030 

PM2 
PM3 
PM4 
PM5 
PM6 
PM9 
PM12 
PM13 

Administrative costs 
savings 
PM7 
PM8 
PM9 
PM12 
PM13 
PM15 
PM16 
PM17 

Net costs savings  

0.35 

0.36 

0.36 

0.35 

0.36 

0.36    

0.85 

0.85 

0.86 

0.63 

0.64 

0.65 

0.85 
1.48 
0.17 

0.85 
1.49 
0.17 

0.86 
1.51 
0.17    

0.61 

0.62 

0.62 

1.63 

1.64 

1.66 

0.29 

0.29 

0.29    

0.57 
0.22 
0.51 

0.58 
0.22 
0.51 

0.59 
0.23 
0.52    

0.32 

0.33 

0.33 

0.32 

0.33 

0.33    

2.30 

2.32 

2.35 

5.11 

5.14 

5.22 

PO-C 
2040 

2030 

2050 

0.18 
0.63 
15.04 
0.85 
1.48 

0.18 
0.64 
14.36 
0.85 
1.49 

0.18 
0.65 
15.24 
0.86 
1.51 

0.52 
2.97 

0.53 
2.99 

0.53 
3.03 

0.57 
0.22 

1.62 
0.06 

0.49 
1.93 

0.58 
0.22 

1.63 
0.06 

0.49 
0.88 

0.59 
0.23 

1.66 
0.07 

0.50 
1.42 

Source: Ramboll et al. (2024), impact assessment support study  

Net costs savings for vessel operators. Overall, all policy options are estimated to result in net costs 
savings for vessel operators. The costs savings are expected to be the highest in PO-B (EUR 5.1 
million in 2030 and EUR 5.2 million in 2050) relative to the baseline, followed by PO-A (EUR 2.3 
million in 2030 and EUR 2.4 million in 2050) and PO-C (EUR 1.9 million in 2030 and EUR 1.4 
million  in  2050).  Expressed  as  present  value  over  2025-2050,  they  are  estimated  at  EUR  100.6 
million in PO-B, EUR 40.2 million in PO-A and EUR 8.4 million in PO-C relative to the baseline 
(see Table 62 in section 3 of Annex 4).  

RIS software services providers 

Adjustment costs savings for software services providers. Providers of RIS software services are 
expected  to  benefit  of  costs  savings  thanks  to  access  to  more  and  better  quality  data.  More 
specifically, PO-A will lead to adjustment costs savings as the guidelines (PM1) and the provision 
of data to the ERDMS by the Member States (PM6) will reduce the efforts of introducing data in 
their systems and correcting mistakes. The complaint mechanism will also streamline the procedure 
of  contacting  authorities  to  report  incorrect  data  (PM2).  The  average  cost  for  software  service 
providers for introducing the data into their systems is estimated at EUR 452 per year, per vessel (in 
2022 prices) in the baseline. Considering the evolution of the fleet in the baseline scenario the total 
costs  for  navigation  software  service  providers  for  introducing  the  data  into  their  systems  are 
estimated  at  EUR  7.2  million  in  2030  and  EUR  7.3  million  in  2050.  According  to  feedback 
provided  by  the  RIS  software  service  providers  (i.e.  by  the  two  navigation  software  service 
providers that serve around 90% of the market) during the second stakeholder survey, PM1 would 
allow to reduce the average cost per vessel by 1% relative to the baseline (i.e. EUR 4.52 saved per 
vessel) from 2026 onwards. PM6 is estimated to reduce the average cost per vessel by 2% relative to 
the baseline (i.e. EUR 9.04 saved per vessel), while PM2 by 0.5% (i.e. EUR 2.26 saved per vessel). 
The  total  adjustment  costs savings  for software services providers in PO-A  are  thus  estimated  at 
around EUR 0.3 million in 2030 and in 2050 relative to the baseline (see Table 6).  

51 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
In PO-B, the costs savings due to PM2 and PM6 are the same as in PO-A. In addition, adjustment 
costs savings for software services providers are expected because of obtaining easier and better-
quality data through the RIS Index (PM4), from RIS COMEX (PM9), from ports (PM12) and from 
better links with the systems of other modes (PM14). For PM4, based on stakeholders’ feedback, 
the average cost reduction per vessel is estimated at 2% relative to the baseline (i.e. EUR 9.04 saved 
per vessel), equivalent to total costs savings of EUR 0.14 million in 2030 and EUR 0.15 million in 
2050 (see Table 6). For PM9, the average cost reduction per vessel is estimated at 1% relative to the 
baseline (i.e. EUR 4.52 saved per vessel), while for PM12 at 0.75% (i.e. EUR 3.39 saved per vessel) 
and for PM14 at 0.25% (i.e. EUR 1.13 saved per vessel). Thus, total costs savings due to PO-B are 
estimated at around EUR 0.5 million in 2030 and in 2050 relative to the baseline (see Table 6). 

In PO-C, besides the costs savings due to PM4, PM6, PM9 and PM14 that are the same as in PO-B, 
software services providers will benefit from access to more and better-quality data thanks to the 
new performance measurement framework (PM3) and the link with the inland ports (PM13). For 
PM3, the reduction in the average cost per vessel is estimated at 0.25% (i.e. EUR 1.13 saved per 
vessel), based on stakeholders’ feedback, equivalent to total costs savings of EUR 0.02 million in 
2030 and in 2050 relative to the baseline. For PM13, the reduction in the average cost per vessel is 
estimated at 1.25% (i.e. EUR 5.65 saved per vessel), equivalent to total costs savings of EUR 0.09 
million  in  2030  and  in  2050  relative  to  the  baseline.  Thus,  total  adjustment  costs  savings  for 
software services providers in PO-C are estimated at around EUR 0.5 million in 2030 and in 2050 
relative to the baseline. 

Expressed as present value over 2025-2050 relative to the baseline (see Table 64 in section 3  of 
Annex  4),  the  highest  costs  savings  for  RIS  software  services  providers  are  estimated  for  PO-C 
(EUR 8.4 million), followed by PO-B (EUR 8.1 million) and PO-A (EUR 4.4 million). 

Table  6:  Adjustment  costs  savings  for  navigation  software  services  providers  by  policy  option  and 
measure in 2030, 2040 and 2050, relative to the baseline (in million EUR, in 2022 prices) 

PM1 
PM2 
PM3 
PM4 
PM6 
PM9 
PM12 
PM13 
PM14 

PO-A 
2040 

0.07 
0.04 

2030 

0.07 
0.04 

Difference to the Baseline 
PO-B 
2040 

2050 

2030 

2050 

0.07    
0.04 

0.04 

0.04 

0.04    

PO-C 
2040 

2030 

2050 

0.14 

0.14 

0.15 

0.14 
0.14 
0.07 
0.05 

0.02 
0.14 
0.14 
0.07 

0.09 
0.02 
0.48 

0.15 
0.15 
0.07 
0.05    

0.02 
0.47 

0.02 
0.14 
0.14 
0.07 

0.09 
0.02 
0.49 

0.02 
0.15 
0.15 
0.07 

0.09 
0.02 
0.49 

0.14 
0.14 
0.07 
0.05 

0.02 
0.47 

Total adjustment costs 
savings  
Source: Ramboll et al. (2024), impact assessment support study  

0.26 

0.25 

0.25 

0.02 
0.47 

6.1.4 

Impact on new reporting obligations 

For national public administrations, in all policy options Member States would need to provide all 
information  required by  the RIS  Directive  to the European Reference  Data  Management System 
(due  to  PM6),  which  contains  regularly  updated  data  necessary  for  the  provision  of  RIS  and  is 
owned and operated by the European Commission. As explained in section 6.1.1, PM6 would lead 
to recurrent administrative costs for national public administrations estimated at EUR 0.66 million 
per year from 2025 onwards, equivalent to EUR 12.2 million expressed as present value over 2025-
2050 relative to the baseline. It should however be noted that thanks to PM6 the time needed for 
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voyage planning can be reduced by 20%, leading to adjustment costs savings for vessel operators of 
EUR 0.85 million in 2030 and EUR 0.86 million in 2050, or EUR 14.8 million expressed as present 
value  over  2025-2050  relative  to  the  baseline.  In  addition,  for  software  services  providers  the 
adjustment  costs savings  due to PM6  are  estimated  at  EUR  0.14  million  in  2030  and  EUR  0.15 
million in 2050, equivalent to EUR 2.5 million expressed as present value over 2025-2050 relative 
to the baseline109. Thus, the costs related to reporting obligations for national public authorities due 
to PM6 are outweighed by the costs savings for businesses (vessel operators and software services 
providers). In addition, PO-C requires Member States (measure PM3) to report to the Commission, 
on a regular basis, on key performance indicators (e.g. the number of shipping messages issued in 
accordance  with standards  and interpretations  from  the  most  recent  RIS  encoding  guide,  and the 
number of electronic cargo reports received in relation to the number of voyages). The recurrent 
administrative  costs  for  national  public  administrations  due  to  PM3  are  estimated  at  EUR  0.65 
million per year from 2025 onwards, or EUR 12 million expressed as present value over 2025-2050 
relative to the baseline. At the same time, PM3 is estimated to lead to adjustment costs savings for 
vessel  operators  (around  EUR  0.18  million  in  2030  and  in  2050,  equivalent  to  EUR  3.1  million 
expressed as present value over 2025-2050 relative to the baseline) and software providers (around 
EUR 0.02 million in 2030 and in 2050, equivalent to EUR 0.3 million expressed as present value 
over 2025-2050 relative to the baseline). 

For businesses, no reporting obligations arise in PO-A and PO-B. PO-C includes a requirement on 
electronic  voyage  plan  reporting  (PM5)  for  vessel  operators.  As  explained  in  section  6.1.3,  this 
requirement would lead to recurrent administrative costs for vessel operators estimated at EUR 19.7 
million  in  2030  and  EUR  20.6  million  in  2050,  equivalent  to  EUR  367.5  million  expressed  as 
present value over 2025-2050 relative to the baseline. At the same time, PM5 is expected to result in 
energy savings for vessel operators estimated at EUR 15 million in 2030 and EUR 15.2 million in 
2050, or EUR 248.7 million expressed as present value over 2025-2050 relative to the baseline.  

6.1.5 

Impacts on SMEs 

According to Eurostat, around 5,500 IWT freight transport companies are active in Europe (EU plus 
Bosnia-Herzegovina, Serbia  and  Switzerland),  employing more than  23,000 persons.  In  addition, 
there are around 4,000 passenger companies which employ around 14,000 persons. While no data is 
available  at EU level  for  the  number  of Small  and  Medium Enterprises (SMEs)  within the  IWT 
sector, one characteristic of the IWT sector is the high number of SMEs. According to the CCNR, 
the majority of companies in Western Europe are small family owned operating one or two vessels, 
while  companies  in  the  Danube  region  are  bigger  as  they  derive  from  previously  state-owned 
enterprises. For the software providers CESNI provides a list of around 20 companies as providers 
for ECDIS and inland AIS110, while a Member State expert estimated the potential number to be up 
to  50  companies.  A  review  of  the  information  related  to  these  companies,  based  on  their  public 
websites, indicates that the majority of them are SMEs, employing less than 250 employees. At the 
same time, it should be noted that two navigation software service providers serve around 90% of 
the market. Therefore, the initiative is considered “relevant” for the SMEs due to the high share of 
SME vessel operators and software companies within the IWT sector. It is not however considered 

109 Software service providers carry out quality checks on the data and correct erroneous data if necessary, when 
receiving complaints. Obliging RIS authorities to periodically update the data, the number of errors is expected 
to  decrease.  This  would  also  reduce  the  efforts  required  for  navigation  software  service  providers  to  obtain 
correct data. 
110  Lists  of  approved  authorities,  firms,  installations  and  equipment  in  the  field  of  technical  requirements  for 
inland navigation vessels. (cesni.eu) 

53 

 
 
as  “highly  relevant”  due  to  the  small  size  of  the  IWT  sector.  The  SME  test  has  been  therefore 
performed (see Annex 6).  

As explained in section 6.1.3, all policy options are expected to result in net costs savings for vessel 
operators and navigation software services providers. More specifically, for vessel operators PO-B 
would result in net costs savings estimated at EUR 100.6 million, expressed as present value over 
2025-2050  relative  to  the  baseline,  followed  by  PO-A  (EUR  40.2  million)  and  PO-C  (EUR  8.4 
million). It should however be noted that PO-C would also result in additional administrative costs, 
relate to the obligation of reporting the electronic voyage plan (PM5), estimated at EUR 27.1 per 
vessel journey. However, even PO-C results in overall net costs savings for vessel operators due to 
the  significant  energy  savings  entailed  by  PM5  and  costs  savings  entailed  by  other  measures 
included in this option. When considering the impact of each measure, as explained in section 3 of 
Annex 4, for vessel operators this will primarily materialise in time saved for planning voyages and 
improvements in navigation efficiency (as they will be warned of bottlenecks and thus adapt their 
speed), and administrative costs in case of PM5  (included in PO-C) as their reporting obligations 
will  increase.  Software  services  providers  would  benefit  of  costs  savings,  as  a  result  of  higher 
quality data to be used in their software which will reduce their efforts to collect this information, of 
EUR 8.4 million in PO-C, EUR 8.1 million in PO-B and EUR 4.4 million in PO-A, expressed as 
present value over 2025-2050 relative to the baseline. Considering the very large share of SMEs 
among  vessel  operators  and  software  services  providers,  most  of  these  net  costs  savings  are 
expected  to be  attributed  to them although  the  available data  did  not  allow  a  split of these  costs 
savings between the two groups of operators (i.e. SME and others).  

6.1.6 

Impact on the functioning of the internal market and competition 

All policy options are expected to have a positive impact on the functioning of the internal market. 
Improving the information exchange between the different actors in the IWT sector allows to deliver 
better inland transport services. By harmonising the provision of RIS between Member States, an 
important step is taken towards the completion of the single market as vessel operating in different 
parts of the EU will not be confronted with different operational requirements. Vessel operators that 
cross borders will also benefit from more standardised reporting requirements and high-quality of 
information.  Thus,  an  important  barrier  is  removed.  PO-A  would  lead  to  limited  impacts  on 
harmonisation, and thus on internal market, while PO-B and PO-C will benefit vessel operators to a 
larger extent as they contain more detailed harmonisation provisions.  Software services providers 
will  also  benefit  from  higher quality of underlying  data  which  will  help them in  developing and 
offering competitive products.  The better integration of IWT sector in the internal market will in 
turn increase its ability to compete for cross border carriage of goods.  

6.1.7 

Impact on competitiveness 

As explained in section 1, IWT is quite active in the transport of non-time sensitive goods (e.g. bulk 
or liquid cargo). To increase the competitiveness of intermodal inland waterways transport, focus is 
needed  on  incentivising  the  transport  of  goods  that  are  more  time  sensitive  (i.e.  typically  the 
container market). For this market segment, reliability is important and IWT would need to match 
the higher reliability standards of road transport, which benefits from a reduced number of actors 
(door-to-door services,  less  handling)  and higher  flexibility  (in  particular  compared to  “network” 
modes, like IWT and rail). 

Several policy measures are expected to have an impact on modal shift, away from road transport to 
intermodal inland waterway transport. In particular PM4 is expected to  increase the efficiency  in 
navigation,  as  improved  data  (e.g.  on  waiting  times  or  obstacles)  will  improve  navigation 

54 

 
performance.  PM14  will  have  a  similar  effect  through  improved  links  with  the  systems  of  other 
modes  (e.g.  the  estimated  time  of  arrival  will  be  available,  which  in  turn  will  contribute  to  the 
optimisation  of  the  logistics  chain).  This  will  lead  to  increased  performance,  predictability  and 
reliability of the intermodal IWT sector, increasing the potential to attract freight from other modes. 
The impact of PM4 and PM14 (both included in PO-B and PO-C) on modal shift has been assessed 
together, due to the synergies between the measures.  

No study has been identified that examines the issue of reliability in the IWT sector. However, a 
2019 TRT study111, examining the modal shift potential for rail, provides a good approximation for 
identifying  the  impact  of  improved  reliability  for  intermodal  IWT.  Like  IWT,  rail  is  also  a 
“network”  mode  (though  with  a  wider  network)  and  it  also  carries  both  time-sensitive  and  cost-
sensitive  goods.  The  study  found  that  the  lack  of  punctuality  was  the  most  important  reason 
provided by the surveyed logistics operators and freight forwarders for not choosing rail instead of 
road. It further estimated (through a stated preference survey) the impact of an increase in reliability 
in shifting freight away from road (i.e. the cross elasticity). Given the similarities between rail and 
IWT, the fact that both compete against road, and in the absence of further specific research, the 
results of the rail study are  used as a proxy for estimating the potential modal shift from road to 
IWT. In addition, sensitivity analysis has been performed and is presented in section 7.6.  

As explained above, based on the results of a stated preference survey run as part of the 2019 TRT 
study, a linear correlation between punctuality and modal shift potential has been identified. More 
specifically,  the  study  indicates  that  for  each  10%  increase  in  punctuality  a  6.1%  increase  in 
transport demand could be expected. To determine the impact on reliability for the inland waterway 
sector, information on average waiting times at locks has been collected in the context of the impact 
assessment  support  study112  and  the  impact  on  reliability  has  been  derived  based  on  desk-
research113. In the baseline scenario, the total travel time for freight inland waterways transport is 
estimated at 12 million hours in 2025, 12.19 million hours in 2030 and 12.42 million hours in 2050, 
while the waiting time at 0.54 million hours in 2025, 0.55 million hours in 2030 and 0.56 million 
hours  in 2050.  The  reliability of travel time  in inland shipping is  thus  estimated  at 95.5% in  the 
baseline scenario. Information on the position of the ship and the expected arrival time of ships can 
increase the reliability by a maximum of 4.5%. Drawing on the correlation between the increase in 
punctuality and transport demand from the TRT study, the model shift potential is estimated at 2.7% 
relative to the baseline. This modal shift potential is only applied to intermodal transport114, as not 
all goods transported by road may be suitable for transport by IWT, while the IWT network is much 
more  limited  compared  to  that  of  road.  Drawing  on  the  evolution  of  freight  IWT  activity  in  the 
baseline  scenario,  the  model  shift  potential  and  the  share  of  intermodal  transport  in  IWT,  the 
transport activity shifted from road to freight IWT in PO-B and PO-C is estimated at 0.35 billion 
tonne-kilometres (tkm) in 2026, 0.38 billion tkm in 2030 and 0.45 billion tkm in 2050. More details 
are provided in Annex 4 (section 4).  

Vessel  operators  suggested  that  measures  such  as  exchange  of  information  through  the  eFTI 
mechanism (PM7 in PO-A and PM8 in PO-B and PO-C) as well as links with ports (PM12 in PO-B 
and PM13 in PO-C) may also have a positive impact on increasing the competitiveness of the IWT 
sector. However, they impacts are expected to be more limited than those of PM4 and PM14. As no 

111 https://www.corridor-rhine-alpine.eu/files/downloads/others/Transport%20Market%20Study%202018.pdf  
112  An  average  waiting  time  per  lock  of  20  minutes  and  a  reliability  value  of  43  minutes  (i.e.  variance  of  23 
minutes) have been estimated. A barge passes an average number of 4 locks per voyage. 
113 IMA (2021) of the Department of Public Works.  
114 Based on Eurostat data, around 7.7% of inland waterway transport is intermodal container transport. 

55 

 
 
quantitative input was provided by stakeholders and considering their limited expected impact, no 
further analysis was undertaken. 

While the revision of the RIS Directive will make the EU inland waterway transport more efficient 
and  reliable,  including  positive  impacts  on  neighbouring  countries  such  as  Serbia  and  Ukraine 
which  are  already  voluntarily  applying  RIS  Directive,  the  initiative  has  no  impact  on  the 
international competitiveness of the sector.  

6.1.8 

Impacts on innovation 

The NAIADES III Action Plan indicates the need for the inland waterway transport sector to keep 
up with digital developments to improve the sector’s competitiveness and ensure that it becomes an 
active part of a broader multimodal chain115. Innovation in inland navigation is both necessary to 
maintain its modal share and to improve its performance.  

All  policy  options  are  expected  to  positively  affect  the  IWT  sector’s  capacity  to  innovate.  By 
providing  better  quality  RIS  data  they  will  lead  to  the  provision  of  more  accurate  services  and 
eventually set the basis upon which further digital applications can be developed (for example for 
planning and optimisation of navigation, avoidance of obstacles and warning of navigation hazards, 
etc.).  In  all  policy  options  the  introduction  of  cargo  information  through  eFTI  will  increase  the 
quantity  and  quality  of  information  available  in  the  eFTI  platforms,  which  then  could  feed  the 
development  of  business-to-business  applications.  In  addition,  in  PO-B  and  PO-C  the  increased 
links and exchange of information with other modes has the potential to improve multimodality and 
will allow developers of logistics and travel planning and cargo management applications to include 
IWT in their solutions.  

In the medium to long term, the information provided by RIS regarding navigation and the digital 
exchange  of  information  will  become  an  important  basis  for  the  development  and  operation  of 
automated  vessels  and  smart  shipping116.  As  the  availability  of  high-quality  data  is  an  essential 
prerequisite  for  the  use  automated  inland  vessels,  the  uptake  of  smart  shipping  is  related  to  the 
policy measures aiming to create high-level quality data (PM6 and PM10 in all policy options, and 
PM4  and  PM9  in PO-B  and PO-C). PO-A  is  expected to  have  a limited impact  on enabling the 
uptake  of  smart  shipping  as  it  will  only  promote  better  quality  RIS  data  through  provisions  for 
supplying data to the ERDMS (PM6) and faster development of technical specifications by CESNI 
(PM10).  In PO-B  and PO-C, the  new  technical  specifications  on  data  for  navigation  and voyage 
planning  (PM4)  and  the  information  exchange  through  the  RIS  COMEX  platform  (PM9)  will 

115 COM/2021/324 final  
116  Smart  shipping  is  based  on  the  concepts  of  automation  and  digitalisation  (see  Platina  3  Report  on 
requirements  towards  digital  and  automated  inland  navigation  tools  from  the  infrastructure  operator  and  user 
perspective  D4.3).  Smart  shipping  refers  to  the  largely  autonomous  operation  of  inland  vessels.  It  covers  not 
only on-board technologies, but also the design of ports and waterways so that, using data collected by sensors, a 
ship  can  manoeuvre  autonomously  or  prompt  the  crew  to  take  action  (see  Smart  Shipping:  comprehensive 
automation in the maritime sector | Maritime transport and seaports | Government.nl)116. Smart shipping is still in 
the  initiation  phase  (pilot  projects  and  research).  The  main  barrier  to  the  uptake  of  smart  shipping  is  IWT 
regulation (including crewing) which does not currently allow the commercial use of automated inland vessels. 
There  are  also  no  dedicated  automation  standards  available 
Inland  Navigation, 
https://repository.uantwerpen.be/docman/irua/d3e895/157179.pdf).  The  fact  that  smart  shipping  is  still  in  its 
initiation phase means that at this stage only very limited data is available for the quantification of the innovation 
impact of the proposed measures on smart shipping. Therefore, the assessment of the innovation impact of the 
relevant proposed measures is conducted on a qualitative basis. 

Innovative 

(see 

56 

 
 
further enable the uptake of smart shipping. Overall, based on the analysis above PO-B and PO-C 
are expected to have higher positive impacts on innovation in the IWT sector than PO-A.  

6.1.9  Digital by default  

All policy options will have a positive impact on the application of the ‘digital by default’ principle. 
PO-A  is  expected  to  have  a  more  limited  positive  impact  relative  to  the  baseline,  driven  by  the 
improved  quality  of  the  underlying  data  for  RIS  (PM6),  faster  development  of  technical 
specifications by CESNI (PM10) and by encouraging the use of eFTI for data exchange (PM7). The 
positive impact of PO-B is assessed to be higher due to the introduction of RIS COMEX as the main 
platform  for  exchange  of  RIS  information  (PM9),  a  platform  that  is  also  the  basis  for  the 
development  of  digital  applications  for  other  measures  under  consideration.  Furthermore,  by 
mandating the use of eFTI (PM8) and introducing better links with ports (PM12) and other modes 
(PM14), PO-B improves the interoperability  of  IWT through  digital solutions. PO-C  goes  a  step 
further, with higher positive impacts on digitalisation than PO-B and PO-A, as it requires electronic 
voyage  plan  reporting  (PM5)  and  the  exchange  of  cross-border  data  (PM15),  and  mandates 
electronic exchange with ports (PM13). 

6.1.10  Impacts on congestion 

As discussed in section 6.1.7, measures PM4 and PM14 (included in PO-B and PO-C) are expected 
to lead to higher use of freight IWT and a shift away from road transport, thus in turn reducing road 
congestion117.  The  reduction  in  the  external  costs  of  road  congestion  in  PO-B  and  PO-C  are 
estimated at EUR 4.7 million in 2030 and EUR 5.6 million in 2050 relative to the baseline (in 2022 
prices)118. Expressed as present value over 2025-2050, this is equivalent to EUR 86.8 million in PO-
B and PO-C. No impact on congestion is expected in PO-A. More details are provided in Annex 4 
(section 4).  

6.1.11  Territorial impacts 

As explained in section 1, the interconnected waterway network of 13,000 km covers 13 Member 
States (Austria, Belgium, Bulgaria, Czechia, Germany, France, Croatia, Hungary, Luxembourg, the 
Netherlands, Poland, Romania and Slovakia) serving over 250 TEN-T inland ports in the TEN-T 
network.  Thus,  the  initiative  and  the  analysis  is  limited  to  the  relevant  Member  States  and  their 
waterways.  

The inland waterways transport sector is small in terms of market size (EUR 7 billion of turnover in 
2020, compared to EUR 454 billion for road transport and EUR 61 billion for rail) and inland modal 
share  (6%  of  freight  inland  traffic,  compared  to  77%  for  road  transport  and  17%  for  rail).  In 
addition,  the  impacts  of  all  policy  options  in  terms  of  net  costs  savings  for  vessel  operators  are 
estimated at less than 0.1% of the annual turnover of the sector. As no significant impact is expected 
due to the initiative, a territorial impact assessment has not been performed. Nevertheless, it should 
be noted that the positive impacts due to the policy options are expected to be localised around the 
inland  ports  of  the  13  Member  States  concerned,  and  within  the  rivers  themselves.  The  positive 
impacts of the modal shift in terms of congestion, safety and environment will primarily materialise 

117 IWT does not suffer congestion. 
118  The  reduction  in  the  external  costs  of  road  congestion  are  estimated  based  on  the  reduction  in  the  road 
transport  activity  and  the  unit  values  from  the  2019  Handbook  on  the  external  costs  of  transport  (Source : 
Internalisation of transport external costs (europa.eu)) 

57 

 
 
in the areas from which traffic is shifted away from road. Their magnitude is however also very 
limited, due to the small size of the sector.  

6.2  Social impacts 

The social impacts are assessed in terms of impacts on safety and fundamental rights. 

6.2.1 

Impacts on safety 

In PO-B and PO-C, implementing new RIS technical specifications (PM4) and improving the links 
with the systems of other modes (PM14), induces higher use of IWT and a shift away from road 
transport (see section 6.1.7) that has an indirect positive impact on road safety. More specifically, 
the  reduction in the  road  freight transport  activity  relative to the baseline (by  0.38  billion tkm  in 
2030  and  0.45  billion  tkm  in  2050)  is  estimated  to  lead  to  a  reduction  in  the  external  costs  of 
accidents,  estimated  at  EUR  6.3  million  in  2030  and  EUR  7.5  million  in  2050119.  Expressed  as 
present  value  over  2025-2050,  PO-B  and  PO-C  are  projected  to  result  in  savings  in  the  external 
costs of accidents of EUR 115.8 million relative to the baseline. No significant impacts are expected 
in PO-A relative to the baseline.  

In the baseline scenario the number of accidents in IWT is projected to increase from 529 in 2015, 
to 535 in 2030 and 551 in 2050, driven by the increase in the transport activity. According to Intergo 
(2021)120, accidents in inland navigation are due to human error in 70 to 80% of the cases. Statistics 
published by Eurostat and Rijkswaterstaat indicate that most reported accidents involve grounding, 
collisions  with  infrastructure  or  collisions  with  other  ships.  Measures  that  aim  to  improve  the 
situational awareness of the vessel operators (PM4 in PO-B and PO-C, PM5 in PO-C and PM6 in 
PO-A,  PO-B  and  PO-C)  should  have  a  positive  impact  on  avoiding  accidents  in  IWT.  The 
evaluation indicated that water level messages concerning bridge passages can avoid collision with 
infrastructure, and messages related to traffic can help avoid collisions between ships. Given that up 
to date and accurate under keel clearance heights are only made available for a very limited number 
of bridges, providing such information is expected to have a positive impact on the safety in the 
IWT sector. However, the evaluation did not succeed in quantifying such benefits. In addition, the 
information provided during the stakeholder consultation on the impact assessment did not allow to 
identify  a  clear  indicator  that  could  be  used  to  reflect  the  impact  of  these  measures  on  avoiding 
accidents.  While  a  quantitative  assessment  was  not  possible,  the  impacts  of  PO-B  and  PO-C  on 
safety in the IWT sector are expected to be higher than those of PO-A.  

6.2.2 

Impacts on fundamental rights 

The  policy  options were  assessed to  determine if they  have  an impact on the  fundamental rights 
and/or equal treatment of EU citizens. The starting point of the assessment of the fundamental rights 
is the Charter of Fundamental Rights of the European Union121. All policy options were assessed 
having regard to the relevant EU instrument and it was concluded that they maintain full respect for 
human and fundamental rights, and none will have any negative impact thereon. Furthermore, none 

119  The  2019  Handbook  on  the  external  costs  of  transport  (Source:  https://op.europa.eu/en/publication-detail/-
/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1)  has  been  used  to  monetise  the  costs.  According  to  the 
Handbook,  the  external  cost of  a  fatality  in  2022 prices  is  estimated  at  EUR  3.9  million  and  that  of  a  serious 
injury at EUR 0.6 million. 
120 Intergo (2021), Human factors root causes of accidents in inland navigation: Organisational Aspects, retrieved 
from: Report phase 2b organisational aspects __final_2.02 Main report (inlandwaterwaytransport.eu) 
121 OJ C 326 of 26.10.2012 p.2 

58 

 
 
of the policy options mandate the exchange of personal data, but only provide more clarity (through 
PM16 and PM17) on the conditions under which the handling of personal information by national 
authorities is allowed (PM16), or define the technical aspects of how such an exchange should be 
done  through  RIS  if  appropriate  (PM17).  This  is  fully  in  line  with  applicable  legislation,  thus 
increasing legal clarity for users of RIS services.  

6.3  Environmental impacts 

The  environmental  impacts  are  assessed  in  terms  of  impacts  on  CO2  emissions,  air  pollution 
emissions, noise reduction and effects on habitats. More detailed information is provided in section 
4 of Annex 4 (see Table 71 to Table 76).  

CO2 emissions. As explained in section 6.1.7, in PO-B and PO-C, implementing new RIS technical 
specifications  (PM4)  and  improving  the  links  with  the  systems  of  other  modes  (PM14)  would 
result  in  higher  use  of  IWT  and  a  reduction  in  the  road  freight  transport  activity  relative  to  the 
baseline (by 0.38 billion tkm in 2030 and 0.45 billion tkm in 2050). This is expected to result in CO2 
emissions  savings  estimated  at  22.5  thousand  tonnes  in  2030  and  5.6  thousand  tonnes  in  2050 
relative to the baseline. PO-C is estimated to have further impact in reducing CO2 emissions relative 
to PO-B through the reduced energy use of IWT vessels, as mandating electronic voyage planning 
(PM5)  will  increase  the  situational  awareness  in  the  fairways  and  thus  lead  to  more  efficient 
navigation. PM5 is estimated to result in 22.7 thousand tonnes of CO2 emissions saved in 2030 and 
9 thousand tonnes saved in 2050. Thus, the highest reduction in CO2 emissions is estimated for PO-
C (45.2 thousand tonnes saved in 2030 and 14.5 thousand tonnes saved in 2050), followed by PO-B 
with 22.5  thousand  tonnes  saved  in 2030  and  5.6  thousand tonnes  saved  in  2050,  relative to  the 
baseline. Cumulatively,  over  2025-2050, CO2  emissions  savings  are  estimated at 832.1 thousand 
tonnes in PO-C and 389.1 thousand tonnes in PO-B relative to the baseline. No significant impact 
on  CO2  emissions  is  expected  for  PO-A.  Using  the  unit  costs  of  CO2  emissions  from  the  2019 
Handbook on external costs of transport, the reduction in the external costs of CO2 emissions for 
PO-C is estimated at EUR 5.4 million in 2030 and EUR 4.6 million in 2050, relative to the baseline, 
and for PO-B at EUR 2.7 million in 2030 and EUR 1.8 million in 2050 (see Table 7). Expressed as 
present value over 2025-2050, this is equivalent to EUR 105.2 million saved in PO-C and EUR 48.6 
million in PO-B. 

Air pollution. The drivers for the impacts on NOx and particulate matter (PM) emissions are the 
same as those for CO2 emissions. PO-B is however expected to result in a limited increase in the 
NOx and PM emissions relative to the baseline (for NOx: 19.7 tonnes in 2030 and 21.3 tonnes in 
2050, and for PM: 3.2 tonnes in 2030 and 1.6 tonnes in 2050), due to the modal shift from road 
transport to IWT. This is because in the baseline scenario road vehicles are projected to increase 
their performance in terms of air pollution emissions faster than the IWT vessels, thanks to the Euro 
standards. Cumulatively, over 2025-2050, PO-B would result in 603.2 additional tonnes of NOx and 
60.8 additional tonnes of PM emissions relative to the baseline. PO-C results in additional energy 
savings  relative  to  PO-B,  due  to  better  travel  information  and  adaptation  of  travel  speed  (PM5), 
which reduces air pollution. Overall, in terms of NOx emissions, PO-C results in 367.6 tonnes saved 
in 2030  and 129.5  tonnes saved  in  2050, while  in terms  of PM  emissions  it  results in  17  tonnes 
saved in 2030 and 6.3 tonnes saved in 2050 relative to the baseline. Cumulatively, over 2025-2050, 
PO-C would result in 6,552.3 tonnes of NOx saved and 338.8 tonnes of PM emissions saved.  

Using  the  unit  costs  of  air  pollution  emissions  from  the  2019  Handbook  on  external  costs  of 
transport, PO-B is estimated to result in an increase in the external costs of air pollution emissions 
estimated at EUR 0.7 million in 2030 and EUR 0.6 million in 2050, while PO-C would result in a 
reduction  in  external  costs  projected  at  EUR  9.4  million  in  2030  and  EUR  3.3  million  in  2050 

59 

 
relative to the baseline (see Table 7). Expressed as present value over 2025-2050, the increase in the 
external costs of air pollution in PO-B is estimated at EUR 13.1 million and the reduction in PO-C 
at EUR 127.6 million relative to the baseline. No significant impact on air pollution emissions is 
expected for PO-A. 

Noise  reduction.  Modal  shift  from  road  transport  to  IWT  in  PO-B  and  PO-C,  driven  by  the 
implementation of PM4 and PM14, is projected to reduce noise emissions along the European road 
network,  as  less  heavy  goods  vehicles  will  be  circulating  on  the  roads.  Drawing  on  the  2019 
Handbook on external costs of transport, the reduction in the external costs of noise emissions is 
estimated at EUR 2 million in 2030 and EUR 2.4 million in 2050, relative to the baseline (see Table 
7). Expressed as present value over 2025-2050, the savings in external costs are estimated at EUR 
36.6 million relative to the baseline in PO-B and PO-C. No significant impact on noise reduction is 
expected for PO-A. 

Habitats. Modal shift from road transport to IWT in PO-B and PO-C would contribute to improving 
habitat  quality  along  the  European  road  network,  by  reducing  the  disturbance  created  by  road 
transport crossing fragile natural areas. With an increase in waterborne transport, more disturbance 
of habitats is expected along the rivers. However, drawing on the 2019 Handbook on external costs 
of transport, the modal shift is projected to result in net gain. The external costs related to habitats 
are  estimated  to  reduce by  EUR  2 million in  2030 and  EUR  2.3 million in  2050,  relative  to the 
baseline (see Table 7). Expressed as present value over 2025-2050, this is equivalent to savings in 
external costs of EUR 36.2 million in PO-B and PO-C relative to the baseline. No significant impact 
on habitats is expected for PO-A.  

Table 7: Impact on external costs of CO2 emissions, air pollution emissions, noise and habitats relative to 
the baseline in 2030, 2040 and 2050 (in million EUR, 2022 prices) 

CO2 emissions 

PM5 
PM4&PM14 

Air pollution 

PM5 
PM4&PM14 

Noise 

PM4&PM14 

Habitats 

PM4&PM14 

PO-A 
2040 

2050 

2030 

Difference to the Baseline 
PO-B 
2040 

2050 

2030 

0.0 

0.0 

0.0 

-2.7 

-3.1 

-1.8 

0.0 

0.0 

0.0 

-2.7 
0.7 

-3.1 
0.9 

-1.8 
0.6 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.7 
-2.0 
-2.0 
-2.0 
-2.0 
-5.9 

0.9 
-2.2 
-2.2 
-2.1 
-2.1 
-6.6 

0.6 
-2.4 
-2.4 
-2.3 
-2.3 
-5.9 

PO-C 
2040 

2030 

2050 

-5.4 
-2.7 
-2.7 
-9.4 
-10.2 
0.7 
-2.0 
-2.0 
-2.0 
-2.0 
-18.7 

-7.1 
-3.9 
-3.1 
-6.0 
-6.8 
0.9 
-2.2 
-2.2 
-2.1 
-2.1 
-17.4 

-4.6 
-2.9 
-1.8 
-3.3 
-4.0 
0.6 
-2.4 
-2.4 
-2.3 
-2.3 
-12.7 

Total impact on external 
costs 
Source: Ramboll et al. (2024), impact assessment support study; Note: negative values refer to a reduction in 
external costs and positive values to an increase relative to the baseline.  

0.0 

0.0 

0.0 

PO-B and PO-C are consistent with the environmental objectives of the European Green Deal and 
the European Climate Law122, while PO-A has no significant impact in this respect. PO-B and PO-
C  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.  

122 Regulation (EU) 2021/1119 

60 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
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  8  provides  the  links  between  policy 
objectives and assessment criteria.  

Table 8: Links between objectives and assessment criteria 
General objective 

Specific objectives 

Assessment criteria  

Provide an effective 
framework for the 
deployment and use of 
harmonised River 
Information Services in 
the EU, that enables 
improvements in the 
competitiveness and 
safety of the sector, and 
its contribution towards 
the European Green 
Deal objectives 

SO1 - Ensure improved RIS data 
availability, and harmonised 
standards 

SO2 - Facilitate the integration of 
IWT into the multimodal chain 

SO3  -  Ensure  higher  uptake  and 
digital 
interoperability 
solutions, 
data 
and 
protection concerns 

of 
address 

Source: European Commission 

Expected  increase  in  harmonisation  of  RIS 
between Member States 

in 

IWT 

increase 

operation 

Expected 
performance 
Expected  increase  in  exchanges  with  other 
transport modes 
Expected  simplification  of  the  process  for  RIS 
data exchange 
Expected uptake of digital solutions  

Each  of  the  policy  options  addresses  the  problems  identified,  their  drivers  and  the  general  and 
specific objectives, though the effectiveness in addressing the objectives varies between the options. 

The specific criteria for assessing the extent to which the objectives are addressed were developed 
internally and approved by the Interservice Steering Group. To the extent possible, they focus on 
output variables that are quantified.  

For  SO1  (Ensure  improved  RIS  data  availability,  and  harmonised  standards),  the  following 
criterion is included: 

-  Expected  increase  in  harmonisation  of  RIS  between  Member  States.  The  increase  in 
harmonisation has been established as a clear requirement. Due to the lack of data it was not 
possible to assign a quantitative indicator (e.g. the number of discrepancies per Member State, 
per technical specification). As such, the impact on harmonisation is assessed qualitatively.  

For SO2  (Facilitate the  integration  of  IWT  into  the  multimodal  chain), the  following  criteria  are 
used: 

-  Expected increase in IWT operation performance. The expected increase in the IWT operation 
performance due to a more efficient data exchange environment is assessed through indicators 
such as modal shift away from road and CO2 emissions savings. 

-  Expected increase in exchanges with other transport modes. This criterion relates directly to the 

connection with other modes and it was only possible to assess it in a qualitative way.  

For  SO3  (Ensure  higher  uptake  and  interoperability  of  digital  solutions,  and  address  data 
protection concerns), the criteria used are:  

-  Expected  simplification  of  the  process  for  RIS  data  exchange.  This  criterion  relates  to  how 
61 

 
  
information  will  be  exchanged  within  the  RIS  environment  as  a  whole  and  is  assessed 
qualitatively. 

-  Expected  uptake  of  digital  solutions.  This  criterion  looks  at  the  impact  on  the  level  of 
digitalisation and the use of digital applications by the IWT sector, and is assessed qualitatively.  

Regarding  SO1  (Ensure  improved  RIS  data  availability,  and  harmonised  standards),  PO-A 
effectively  contributes  to  increasing  the  harmonisation  of  RIS,  as  both  national  authorities  and 
vessel  operators  will  benefit  from  clear  guidelines  that  will  help  reduce  discrepancies.  Higher 
quality and updated data will also be made available to RIS users through the ERDMS. Should data 
not be consistent, harmonised or simply not available, RIS users will have the opportunity to signal 
this to the national authorities through a clear mechanism. National authorities should take action to 
rectify  the  problem,  thus  improving  the  monitoring  of  implementation  and  the  consistency  of 
application. The nomination of CESNI as the development body for technical specifications should 
allow for faster updates, which would allow RIS users to benefit from improved information and 
services. PO-B is assessed to be more effective than PO-A because the introduction of RIS COMEX 
as the main data exchange platform will ensure a common platform for all users, who now have to 
work  with  separate  systems  for  different  Member  States.  In  addition,  PO-B  will  provide  vessel 
operators with a new category of data, which will assist them in navigation and voyage planning. 
PO-C  attains  a  slightly  higher  level  of  harmonisation  than  PO-B,  as  it  introduces  a  performance 
monitoring framework specifically aiming to identify harmonisation gaps. The requirement to share 
traffic and transport management information cross-border by the Member States directly will also 
reduce the harmonisation challenges that vessel operators face, as they will only need to report once 
instead of whenever they cross a border.  

Regarding SO2 (Facilitate the integration of IWT into the multimodal chain), in terms of expected 
impact on the operational performance of IWT, PO-A will have a positive but limited impact as the 
guidelines  will  help  reduce  differences  in  implementation  between  Member  States,  which  will 
facilitate operations for vessel operators. PO-B is assessed to lead to a moderate positive impact on 
the operational performance of IWT mainly as a result of the links with the other transport modes 
and the new technical specifications on navigation and voyage planning, resulting in an increase in 
the freight volumes shifted from road transport to IWT (by 0.38 billion tkm in 2030 and 0.45 billion 
tkm in 2050) with benefits in terms of reduced CO2 emissions (389.1 thousand tonnes of CO2 saved 
cumulatively over 2025-2050, relative to the baseline). PO-C is expected to have a stronger impact 
on operational performance of IWT relative to PO-B, as in addition to modal shift (by 0.38 billion 
tkm in 2030 and 0.45 billion tkm in 2050), the increased navigation performance through electronic 
voyage plan reporting will lead to reduced energy needs. PO-C thus results in 832.1 thousand tonnes 
of  CO2  saved  cumulatively  over  2025-2050,  relative  to  the  baseline.  Finally,  as  regards  the 
exchanges with other modes of transport, the impact of PO-A is considered positive but limited as 
PO-A only foresees a voluntary exchange of required cargo information through the eFTI platforms. 
PO-B  has  a  moderate  positive  impact,  as  it  makes  the  eFTI  link  mandatory,  develops  technical 
specifications for links with the systems of other modes (e.g. EMSWe) and with inland ports, and it 
aligns the scope of the Directive with that of the TEN-T network. While PO-C takes things one step 
further, by mandating the data exchange with ports, the overall positive impact is still considered as 
moderate  because  further  steps  (and  initiatives)  will  need  to  be  undertaken  by  other  modes  of 
transport.  

Regarding SO3 (Ensure a higher uptake and interoperability of digital solutions, and address data 
protection  concerns),  in  PO-A  the  regular  updates  of  technical  specifications  (through  CESNI) 
should simplify the process of exchanging data through RIS as users will operate under the most up 
to  date  technical  specifications.  PO-B  will  have  a  strong  positive  impact  as  RIS  COMEX,  by 

62 

 
acting  as  a  one-stop-shop  solution,  will  simplify  the  process  through  which  RIS  users  exchange 
information. Similarly, PO-C will have a strong positive impact in addressing SO2 as the addition of 
electronic  voyage  plan  reporting,  introduces  a  new  digital  solution  for  traffic  and  transport 
management,  while  the  introduction  of  specific  forms  for  personal  data  exchange  would  further 
simplify reporting for vessel operators. With regard to the expected uptake of digital solutions by the 
sector, PO-A is expected to have a positive but limited impact by providing a basic level of update 
of technical specifications and ERDMS information and a voluntary eFTI platform use. In PO-B 
introducing  the  RIS  COMEX  as  the  main  platform  would  have  a  moderate  positive  impact,  as 
exchanges will be done digitally instead of using other means (like radio, as is sometimes now the 
case  for  reporting).  Furthermore,  use  of  eFTI  becomes  a  requirement  for  reporting  of  dangerous 
goods information; thus all vessel operators will need to apply it. The links with other modes and 
inland  ports  increase  the  digital  options  available  for  RIS  users  and  allow  those  users  that  see 
benefits for their operational needs to make use of them. PO-C will slightly increase the uptake of 
digital  solutions  relative  to  PO-B  by  introducing  two  mandatory  elements,  namely,  the  required 
reporting  of  voyage  plans,  and  the  requirement  to  share  information  with  inland  ports.  Both 
measures, by design, will increase the use of digital solutions. 

Risks related to implementation and enforcement requirements  

In  terms  of  overall  risks  relating  to  implementation  and  enforcement,  the  non-harmonised 
implementation was identified by the evaluation as a challenge. This challenge arises due to the lack 
of  clearly  defined  data  to  be  exchanged  between  transport  modes,  different  interpretation  of 
standards on voyage planning, etc.  

Three  measures  were  developed  to  address  it  (namely  PM1,  PM2  and  PM3).  Through  RIS 
guidelines (PM1), the Commission will provide clear guidance on the technical specifications and 
how they should be applied. This is expected to increase the common understanding and application 
in PO-A. The complaint handling mechanism (PM2) in PO-A and PO-B will be an important tool 
which  will  provide  a  bottom-up  way  to  identify  these  inconsistencies  and  to  signal  them  to  the 
appropriate  authorities  for  action.  Member  State  authorities  will  benefit  of  transparency  on  the 
issues identified and will be required by a functionally independent body to address them. This is 
expected to lead to a quick rectification of the issue. The relevant authorities will also need to inform 
the Commission on the number and type of complaints (including their outcome), which will allow 
to  better  monitor  the  overall  implementation  of  the  Directive,  but  also  the  performance  of  the 
complaint  mechanism  itself.  The  Performance  Measurement  Framework  (PM3)  is  an  alternative 
approach to PM2, included in PO-C, that is based on top-down monitoring. In this case, national 
authorities  will  be  required  to  collect  and  report  on  a  yearly  basis  to  the  Commission  a  set  of 
indicators  related  to  the  performance  of  RIS  on  their  territory.  Through  this  Performance 
Measurement Framework, the Commission will have an overall picture of the implementation in 
each Member State and will be able to take action as required.  

Thus, PO-C follows a more traditional approach for ensuring implementation and enforcement, with 
the disadvantage that is it heavily reliant on the collection and reporting of indicators. Even when 
not considering possible gaps or inconsistencies in the reported information, one has to factor in a 
natural time-delay from the moment the problem occurs, to the moment it is reported, assessed and 
finally acted upon. On the other hand, PO-B, with the inclusion of the complaint mechanism, has 
the advantage that problems will be signalled to the authorities sooner, and Member States will be 
able to act upon them faster, if possible, at their level, or be reported to the Commission for further 
action if it is of a more general or fundamental nature. Finally, PO-A would have a more positive 
outcome as it would combine the complaint mechanism with interpretative guidelines, thus adding 
an extra layer of clarity and guidance on how technical specifications should be applied.  

63 

 
Another relevant challenge that was identified by the evaluation is the long duration in setting and 
updating  the  technical  specifications  (which  could  take  around  10  years).  Late  development  or 
update  of  technical  specifications  could  increase  the  risk  related  to  the  implementation  and 
enforcement,  as  well  as  delay  the  introduction  of  new  technology  solution  to  IWT,  which  could 
bring operational benefits and other benefits (e.g. the development and use of application via tablets 
or other technical devices by the skippers or the authorities). The involvement of CESNI for RIS 
(PM10,  included  in  PO-A,  PO-B  and  PO-C)  is  expected  to  speed  up  the  process  of  adoption  of 
technical  specifications.  With  CESNI  planning  and  leading  the  work,  it  was  possible  to  develop 
technical specifications for these Directives on average every 2 years, which is a big improvement 
compared to the current RIS setting. PM10 is supported by all stakeholder groups, it proved it can 
deliver, and it ensures control of the work by the Commission. As PM10 is applied in the same way 
to all policy options, it has no impact on their comparison.  

7.2  Efficiency 

Efficiency  concerns  the  ‘extent  to  which  objectives  can  be  achieved  for  a  given  cost  (cost 
effectiveness)’.  In  all  policy  options,  the  benefits  outweigh  the  increase  in  costs,  relative  to  the 
baseline. The estimates of costs and benefits are summarised in Table 9. 

Table 9: Summary of costs and benefits of policy options  – net present value for 2025-2050 compared to 
the baseline (in million EUR, in 2022 prices) 

Difference to the Baseline 
PO-B 

PO-C 

PO-A 

Vessel operators 
Administrative costs 
Adjustment costs savings 
Administrative costs savings 
Software providers 
Adjustment costs savings 
National authorities 
Adjustment costs 
Administrative costs 
Administrative cost savings 
European Commission 
Adjustment costs 
External costs savings 
Reduction in external costs of CO2 emissions 
Reduction in external costs of air pollution emissions 
Reduction in external costs of noise emissions 
Reduction in external costs of habitats 
Reduction in external costs of congestion 
Reduction in external costs of accidents 
Total costs 
Total benefits 
Net benefits 
Benefits to costs ratio 
Source: Ramboll et al. (2024), impact assessment support study. 

0.0 
29.6 
10.7 

4.4 

5.6 
34.9 
11.4 

0.5 

41.0 
56.1 
15.1 
1.4 

0.0 
72.1 
28.5 

8.1 

18.3 
75.3 
30.6 

0.0 

48.6 

-13.1 
36.6 
36.2 
86.8 
115.8 
93.6 
450.4 
356.7 
4.8 

367.5 
324.0 
51.9 

8.4 

28.2 
104.3 
37.4 

0.0 

105.2 

127.6 
36.6 
36.2 
86.8 
115.8 
499.9 
930.0 
430.1 
1.9 

The  major  cost  elements  of  the  policy  options  are  related  to  administrative  costs  for  public 
authorities (in all policy options) and for vessel operators (in PO-C), and adjustment costs for public 
authorities  (in  all  policy  options).  PO-C  shows  the  highest  total  costs  estimated  at  EUR  499.9 
million, followed by PO-B (EUR 93.6 million) and PO-A (EUR 41 million), expressed as present 

64 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
value relative to the baseline. PO-C is also estimated to result in the highest total benefits, estimated 
at EUR 930 million expressed as present value over 2025-2050 relative to the baseline, followed by 
PO-B (EUR 450.4 million) and PO-A (EUR 56.1 million).  

Overall, all policy options result in net benefits relative to the baseline. PO-C shows the highest net 
benefits, estimated at EUR 430.1 million expressed as present value over 2025-2050, followed by 
PO-B  (EUR 356.7  million)  and  PO-A  (EUR 15.1  million).  On  the  other  hand,  PO-B  shows  the 
highest  benefits  to  costs  ratio  among  the options  (4.8),  followed by  PO-C  (1.9)  and PO-A  (1.4). 
Thus, PO-B is assessed to be the most efficient among the policy options.  

7.3  Coherence 

Internal coherence. The internal coherence assesses how well the various provisions of the revised 
Directive fit together and work in a coordinated manner to achieve its objectives. It should be noted 
that this does not only concern the Directive itself, but also its accompanying secondary legislation 
(implementing acts) as well as interpretative guidelines.  

Although all three policy options address the identified problem, they do so in different ways. All 
policy  options  foresee  that  the  required  technical  details  will  be  introduced  through  secondary 
legislation, and they all entrust the development of the technical specifications to CESNI. All policy 
options aim to improve the quality of RIS data by mandating the provision of required information 
to  the  ERDMS.  In  addition,  PO-A  addresses  the  problem  by  providing  more  flexibility  to  the 
Member States, as specific guidance will be provided through interpretative guidelines, aiming to 
reduce the existing fragmentation in the application of the provisions of the Directive. Furthermore, 
it encourages the use of eFTI but does not mandate it. Other than that, it introduces a harmonised 
complaint mechanism  and provides more  clarity  for exchange  of personal data. PO-B  and PO-C 
propose  amendments  to  the  Directive  for  all  aspects  that  require  further  harmonisation  and  thus 
ensure a higher degree of internal coherence than PO-A. PO-B follows a more targeted approach in 
the amendments proposed to the Directive, focusing on the improvement of the performance of the 
Directive and introducing a concrete structure for the provision of RIS (through COMEX), while 
allowing for improved links with other modes. PO-C envisages introducing further elements (such 
as mandating electronic voyage reporting and mandating cross border exchange of data). All policy 
options contain measures to improve the monitoring of the performance of RIS, and clarify cases of 
handling of personal data, with PO-C containing more detailed provisions due to its wider focus.  

External coherence. The external coherence concentrates on the compliance of the Directive with 
key EU policy objectives and international legislation. All policy options have links to several EU 
instruments.  PO-B  and  PO-C  are  consistent  with  the  European  Green  Deal,  SSMS  and  the 
NAIADES  III  Communication  as  they  contribute  to  modal  shift  and  the  reduction  of  CO2 
emissions. By aiming to improve digital applications in IWT and aligning the scope of application 
to that of the TEN-T waterways, PO-B and PO-C are also coherent with the TEN-T policy, which 
among its priorities deals with information and communication technology, such as implementing 
telematics  applications  (including  RIS),  as  well  as  with  multimodal  aspects,  such  as  connecting 
inland  port  infrastructure  to  rail  freight  and  road  transport  infrastructure.  In  addition,  the  CEF 
programme, under the TEN-T is providing funding for the development of RIS. The approach used 
in  all  the  policy  options  in  this  regard  is  not  to  duplicate  or  develop  overlapping  tools  and 
functionalities, but to enable and enhance links with those tools (through exchange of appropriate 
information), thus making best use of existing systems. 

Furthermore, the AFIR is mandating On Shore Power Systems (OPS) in inland ports for allowing 
vessels to connect to electricity and not polluting the air by turning their engines at quays. It also 

65 

 
requires Member States to create plans to provide other clean energy sources in the future. Through 
PM12 (in PO-B) and PM13 (in PO-C) skippers will, among others, be provided with information if 
and when OPS installations are available for use in the port of their destination. They thus both work 
complementary in supporting the greening of IWT fleet. The eFTI Regulation established a legal 
framework that allows economic operators to share information with enforcement authorities in an 
electronic  format  (i.e.  for  the  transport  of  goods  by  road,  rail,  inland  waterways  and  air  in  the 
Union). All policy options are coherent with eFTI, as through PM7 and PM8 they introduce eFTI as 
the platform for exchange of cargo information. 

Likewise,  PO-B  and  PO-C  are  coherent  with  SDG  9  on  industry,  innovation,  and  infrastructure 
(specifically  9.1  “Develop  quality,  reliable,  sustainable  and  resilient  infrastructure,  including 
regional and transborder infrastructure, to support economic development and human well-being, 
with a focus on affordable and equitable access for all”), as it promotes the shift of freight from road 
to inland waterways. They are also coherent with SDG 13 (“Take urgent action to combat climate 
change and its impacts”), as they lead to a decrease in CO2 emissions. 

Finally, the Directive does not make any provision on safety and traffic management on rivers that 
would  fall  exclusively  under  the  responsibility  of  Member  States  or  are  developed  by  the  River 
Commissions (Police Regulations).  

7.4  Subsidiarity and proportionality 

As highlighted in section 3 there is a clear need for EU action on the problem identified, and its 
drivers.  The current Directive  has not  attained  full  harmonisation  of RIS  and experience  with  its 
implementation shows challenges with the timely introduction of technical specifications and with 
monitoring.  Furthermore,  the  Directive  needs  to  become  fit  for  today’s  challenges  related  to 
digitalisation, intermodality and sustainability. Member States individually are not able to tackle the 
problem identified. To avoid a fragmented legal framework, there is a need for EU action. All policy 
options  ensure  a  certain  degree  of  harmonisation  of  the  legal  framework,  in  full  respect  of  the 
subsidiarity  principle.  All  policy  options  designate  CESNI  as  the  body  responsible  for  the 
development  of  new  technical  specifications,  which  will  involve  Member  States  and  sectoral 
experts,  and  improve  collaboration  with  the  River  Commissions.  Furthermore,  PO-A  and  PO-B 
place  the  identification  and  eventual  solution  of  problems  in  the  implementation  of  RIS  at  the 
national level, and thus closer to the user than in PO-C.  

All  policy  options  are  assessed  to  be  proportionate  as  action  at  EU  level  is  limited  to  what  is 
necessary to achieve an improvement in the overall level of River Information Services offered to 
RIS users, through improved exchanges of better-quality information. PO-A and PO-B contribute to 
such improvement  without imposing any cost for businesses and entailing only some adjustment 
and  administrative  costs  for  national  public  administrations.  On  the  other  hand,  PO-C  results  in 
administrative costs for vessel operators  (mostly SMEs)  due to the requirement on the electronic 
voyage plan reporting. This specific measure results in additional administrative costs of EUR 367.5 
million for vessel operators, expressed as present value over 2025-2050. It however also results in 
adjustment  cost  savings  for  vessel  operators  (EUR  248.7  million)  due  to  the  reduced  fuel 
consumption.  PO-B appears as the option providing the most balanced approach as it achieves a 
higher degree of harmonisation than PO-A, does not entail additional administrative or adjustment 
costs for businesses, but only costs savings. In this respect it is considered to be a more balanced 
option and thus more proportionate than either PO-A or PO-C.  

66 

 
7.5  Summary of the comparison of policy options 

Table  10  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 
less 
effective/efficient/coherent/ proportionate than the baseline). 

the  baseline) 

(much 

than 

'---' 

to 

Table  10: Comparison  of  options  in  terms  of  effectiveness,  efficiency,  coherence,  subsidiarity  and 
proportionality relative to the baseline 
Criteria 
Effectiveness 
Efficiency 
Coherence 
Subsidiarity and proportionality 
Source: European Commission 

PO-C 
+++ 
++ 
+++ 
++ 

PO-A 
+ 
+ 
++ 
++ 

PO-B 
++ 
+++ 
+++ 
+++ 

7.6  Sensitivity analysis 

As explained in section 6.1.7, sensitivity analysis has been performed in relation to the impacts of 
the policy options on the modal shift from road to IWT. Subsequently, the impacts on external costs 
and the efficiency of the policy options is assessed. More specifically, for the sensitivity analysis it is 
assumed that each 10% increase in punctuality would result in:  

-  4.1% increase in transport demand (low case); 

-  8.1% increase in transport demand (high case).  

This is further compared with the central case estimate (6.1% increase in transport demand). 

The impacts on the traffic shifted from road to IWT transport for the low case, central case and high 
case are presented in Table 11 below.  

Table 11: Impact on freight inland waterways transport activity in the low case, central case and high case 
relative to the baseline  

2026 

2030 

2040 

2050 

Shift  from  road  to  freight  IWT  activity  relative  to  the 
baseline (Gtkm) 
Low case 
Central case 
High case 

Source: European Commission 

0.24 
0.35 
0.47 

0.25 
0.38 
0.50 

0.28 
0.41 
0.55 

0.30 
0.45 
0.59 

Table 12 further presents the impacts on external costs of transport in the low case, central case and 
high case, due to shift from road to inland waterways traffic.  

Table 12: External costs savings by policy option in the low case, central case and high case, expressed as 
present value over 2025-2050 compared to the baseline (in million EUR, in 2022 prices)  

Difference to the Baseline 
PO-B 

PO-C 

PO-A 

Total external costs savings - low case 

Reduction in external costs of CO2 emissions 
Reduction in external costs of air pollution emissions 
Reduction in external costs of noise emissions 

67 

209.1 
32.7 
-8.8 
24.6 

406.3 
89.2 
131.9 
24.6 

 
  
  
  
  
  
 
  
  
  
  
  
Difference to the Baseline 
PO-B 

PO-C 

PO-A 

Reduction in external costs of habitats 
Reduction in external costs of congestion 
Reduction in external costs of accidents 
Total external costs savings - central case 

Reduction in external costs of CO2 emissions 
Reduction in external costs of air pollution emissions 
Reduction in external costs of noise emissions 
Reduction in external costs of habitats 
Reduction in external costs of congestion 
Reduction in external costs of accidents 
Total external costs savings - high case 

Reduction in external costs of CO2 emissions 
Reduction in external costs of air pollution emissions 
Reduction in external costs of noise emissions 
Reduction in external costs of habitats 
Reduction in external costs of congestion 
Reduction in external costs of accidents 

Source: European Commission 

24.4 
58.3 
77.9 
311.0 
48.6 
-13.1 
36.6 
36.2 
86.8 
115.8 
413.0 
64.5 
-17.3 
48.6 
48.1 
115.2 
153.8 

24.4 
58.3 
77.9 
508.3 
105.2 
127.6 
36.6 
36.2 
86.8 
115.8 
610.3 
121.1 
123.4 
48.6 
48.1 
115.2 
153.8 

Finally, Table 13 presents the impacts on total benefits, net benefits and benefits to costs ratio by 
policy  option  in  the  low  case,  central  case  and  high  case.  It  shows  that  all  policy  options  are 
expected to result in net benefits under the three cases considered. It also shows that the ranking of 
the policy options is not expected to change in the low case and high case relative to the central case 
estimates.  

Table 13: Summary of costs and benefits of the policy options in the low case, central case and high case, 
expressed as present value over 2025-2050 compared to the baseline (in million EUR, in 2022 prices) 
Difference to the Baseline 
PO-B 

PO-A 

PO-C 

Total costs 
Total benefits 
Low case 
Central case 
High case 
Net benefits 
Low case 
Central case 
High case 

Benefits to costs ratio 

Low case 
Central case 
High case 

Source: European Commission 

41.0 

56.1 
56.1 
56.1 

15.1 
15.1 
15.1 

1.4 
1.4 
1.4 

93.6 

499.9 

348.4 
450.4 
552.3 

254.8 
356.7 
458.7 

3.7 
4.8 
5.9 

828.0 
930.0 
1,032.0 

328.1 
430.1 
532.1 

1.7 
1.9 
2.1 

68 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
8  PREFERRED OPTION 

8.1 

Identification of the preferred policy option and stakeholders views 

Even  though  all  policy  options  are  in  line  with  the  general  objective  and  include  measures  that 
address  all  specific  objectives  and  problem  drivers,  they  vary  when  assessed  in  terms  of 
effectiveness, efficiency, coherence, subsidiarity and proportionality.  

First, there is a difference in their effectiveness. As explained in section 7.1 and Table 10, PO-C is 
the  most  effective  in  addressing  all  the  specific  objectives.  With  regard  to  efficiency,  PO-C  only 
ranks second (after PO-B) with a benefit to cost ratio of 1.9 (relative to 4.8 in PO-B). PO-C shows 
the highest net benefits, and at the same time entails the highest level of costs. The total costs of PO-
C are  434% higher  than those  of PO-B, while  the  total  benefits  are only 107% higher for PO-C 
compared to PO-B. The higher costs of PO-C are linked to the mandatory measures (primarily PM5 
on the reporting requirements for voyage plans, and to a lesser extent PM13 and PM17) that entail 
administrative costs for vessel operators (due to PM5) and administrative and adjustment costs for 
national administrations (due to PM13 and PM17).  

PO-B is assessed to be less effective than PO-C in addressing the specific objectives. However, the 
specific objectives are addressed in a more progressive and efficient way, entailing a higher benefit 
to  cost  ratio  than  PO-C  (4.8  versus  1.9),  and  allowing  a  smooth  transition  for  authorities  and 
operators (due to fewer mandatory measures). Measures under PO-B are also easier and quicker to 
implement and closer to the user than those in PO-C.  

PO-A is the least effective in addressing the specific objectives, and shows the lowest benefit to cost 
ratio among the options.  

In  relation  to  internal  coherence,  PO-B  and  PO-C  propose  amendments  to  the  Directive  for  all 
aspects that require further harmonisation and thus ensure a higher degree of internal coherence than 
PO-A. In relation to the external coherence with other instruments and policies, all policy options 
are coherent with several EU instruments (see section 7.3 and Table 10). PO-B and PO-C show a 
higher degree of external coherence than PO-A as they directly align the scope of the Directive with 
that  of  the  TEN-T  Regulation.  They  support  multimodality  and  the  greening  of  the  sector,  in 
particular by increasing links with other modes and leading to modal shift away from road. They 
also  both  increase  digitalisation  in  the  sector  by  introducing  and  mandating  the  use  of  digital 
applications in RIS.  

All policy options ensure a certain degree of harmonisation of the legal framework, in full respect of 
the subsidiarity principle. However, PO-A and PO-B place the identification and eventual solution 
of problems in the implementation of RIS at the national level, and thus closer to the user than in 
PO-C. All policy options are assessed to be proportionate as action at EU level is limited to what is 
necessary to achieve an improvement in the overall level of River Information Services offered to 
RIS users, through improved exchanges of better quality information. PO-B appears however as the 
option providing the most balanced approach as it achieves a higher degree of harmonisation than 
PO-A without additional costs for businesses and only some adjustment and administrative costs for 
national  public  administrations.  On  the  other  hand,  although  achieving  a  higher  degree  of 
harmonisation  than  PO-B,  PO-C  results  in  additional  administrative  costs  for  vessel  operators 
(mostly  SMEs)  due  to  the  requirement  on  the  electronic  voyage  plan  reporting,  and  it  is  thus 
assessed to be less proportionate than PO-B. 

In conclusion the analysis points at PO-B as the preferred policy option, since it brings the best 
balance  between  the  objectives  that  must  be  achieved  and  shows  the  best  benefits  to  costs  ratio 
69 

 
among the policy options. It ensures the proportionality of the intervention and is fully in line with 
the subsidiarity principle. In addition, it does not introduce burdens for the private sector.  

The level of ambition of the preferred policy option is considered appropriate as it modernises the 
RIS Directive bringing it up to speed with digital developments, addresses all identified problem 
drivers,  improves  the  position  of  IWT  in  the  logistics  chain  and  contributes  to  improving  its 
environmental performance. Moreover, it attains these results by making use of and increasing links 
with existing solutions and initiatives, thus avoiding duplication of efforts. In terms of preparing the 
IWT sector for future developments  such as smart shipping and automation, the preferred policy 
option establishes a central platform for RIS exchanges, which can provide the basis upon which 
new functionalities and services may be developed in the future.  

Stakeholders  widely  supported  the  involvement  of  CESNI  in  the  development  and  adoption  of 
technical  specifications.  Stakeholders  were  also  in  agreement  that  RIS  COMEX  provides  an 
important  basis.  A  small  number  of  RIS  experts  expressed  the  view  that  the  Directive  was 
sufficiently broad, and focus should rather be placed on implementation and on the introduction of 
guidelines. However, the majority of stakeholders across all groups envisaged the need for further 
adaptations to the Directive.  

Differences  in  opinions  appeared  in  particular  between  Member  State  authorities  and  vessel 
operators in terms of the costs and benefits of the complaint mechanism (Member States tended to 
be against) and of electronic voyage reporting (vessel operators tended to be against). The links with 
eFTI triggered some discussions, with some Member State autorities considering that they need to 
become mandatory, and vessel operators being more sceptical (while some saw this as a potential 
opening for business-to-business applications). Last but not least, there was a clear concern from the 
side of vessel operators (and in particular those representing SMEs) about the use of personal data 
(thought there did not appear to be a clear understanding of what would qualify as “personal data"). 
Some vessel operators went beyond the issue of personal data, expressing the view that they need to 
be  in  clear  control  of  what  information  is  shared,  including  business  information.  Member  State 
authorities saw potential in exchanging personal data but it became apparent that some clarity on the 
conditions  under  which  exchange  is  possible  is  required,  as  some  of  them  pointed  to  potential 
conflicts with national legislation.  

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 ‘A Europe fit for the Digital Age’. It has a REFIT dimension in terms 
of simplifying and harmonising the information exchange through RIS. The initiative will reduce 
administrative burden for vessel operators by reducing the need for re-registering cargo information 
and reporting cargo information to ports. The preferred policy option (PO-B) is estimated to result in 
administrative  costs  savings  of  EUR  28.5  million,  expressed  as  present  value  over  2025-2050 
relative to the baseline scenario.  

Currently, vessel operators need to consult sever websites in different Member States to obtain the 
information they need in order to plan their voyage. In addition, differences in the application of the 
provisions  of  the  Directive  by  the  Member  States  means  that  the  information  required  is  not 
provided in a harmonised way. The preferred policy option will reduce this burden by introducing a 
one-stop-shop platform for exchange of RIS information (RIS COMEX). Other measures foreseen 
as part of PO-B will also reduce the time spent by vessel operators in planning their voyage (new 
technical specifications on data for navigation and voyage planning, provisions for supplying data 
to the ERDMS, new technical specifications for the exchange of information relating to IWT ports, 

70 

 
a  harmonised  complaint  mechanism  in  Member  States).  This  is  expected  to  result  in  adjustment 
costs savings for vessel operators, estimated at EUR 72.1 million expressed as present value over 
2025-2050,  relative  to  the  baseline  scenario.  In  addition,  RIS  software  services  providers  would 
benefit of access to more and better-quality data with adjustment costs savings estimated at EUR 8.1 
million, expressed as present value over 2025-2050 relative to the baseline scenario.  

Finally,  in  the  preferred  policy  option  (PO-B)  no  reporting  obligations  arise  for  businesses.  For 
national  public  administrations,  reporting  obligations  arise  due  to  measure  PM6.  However,  as 
explained in section 6.1.4, the costs savings for vessel operators and software service providers due 
to PM6 outweigh the administrative costs for national public administrations. 

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

PO-B is expected to lead to administrative costs savings for vessel operators, by reducing the need 
for re-registering cargo information and reporting cargo information to ports, estimated at EUR 1.6 
million  per  year  relative  to  the  baseline.  These  administrative  costs  savings  are  driven  by  the 
exchange  of  cargo-related  information  through  the  eFTI  mechanism  (EUR  0.6  million)123,  the 
exchange  of  information  through  the  RIS  COMEX  platform  (EUR  0.2  million)124,  the  new 
technical specifications for the exchange of information with IWT ports (EUR 0.5 million)125 and 
legal clarity for personal data (EUR 0.3 million)126. There are no administrative costs for businesses 
under PO-B. 

In addition, in PO-B the adjustment costs savings for vessel operators are estimated at EUR 72.1 
million and those for software services providers at EUR 8.1 million, expressed as present value 
over 2025-2050 relative to the baseline. 

9  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

The initiative will be implemented in parallel with other initiatives under the European Green Deal 
and the SSMS. Taking those into account in the baseline, in particular for the multimodality aspects, 
the share of the IWT activity is  expected to roughly  remain stable over time. The environmental 
performance of IWT (especially in terms of CO2 emissions) is expected to improve due to the large-
scale uptake of renewable and low carbon fuels, namely e-fuels, biofuels and electricity. Safety is 
expected to stay within the same levels in the baseline. 

123 For the purpose of the application of the ‘one in, one out’ approach, the average reduction in the number of 
repeated  notifications  over  2026-2035  (simple  average)  has  been  estimated  at  88,397  per  year  relative  to  the 
baseline  and  the  average  costs  saved  per  repeated  notification  at  EUR  6.5.  Thus,  the  average  annual 
administrative costs savings (simple average)  for vessel operators are estimated at EUR  0.6 million relative to 
the baseline. 
124 For the purpose of the application of the ‘one in, one out’ approach, the average reduction in the number of 
repeated  notifications  over  2026-2035  (simple  average)  has  been  estimated  at  34,448  per  year  relative  to  the 
baseline  and  the  average  costs  saved  per  repeated  notification  at  EUR  6.5.  Thus,  the  average  annual 
administrative costs savings  (simple average) for vessel operators are estimated at EUR 0.2 million relative  to 
the baseline. 
125 For the purpose of the application of the ‘one in, one out’ approach, the average reduction in the number of 
resubmitted cargo reports over 2026-2035 (simple average) has been estimated at 114,006 per year relative to the 
baseline and the average costs saved per resubmission at EUR 4.4. Thus, the average annual administrative costs 
savings for vessel operators are estimated at EUR 0.5 million relative to the baseline. 
126 For the purpose of the application of the ‘one in, one out’ approach, the average reduction in the number of 
resubmitted cargo reports over 2026-2035 (simple average) has been estimated at 72,799 per year relative to the 
baseline and the average costs saved per resubmission at EUR 4.4. Thus, the average annual administrative costs 
savings (simple average) for vessel operators are estimated at EUR 0.3 million relative to the baseline. 

71 

 
 
The  initiative  is  expected  to  complement  these  developments  by  updating  and  modernising  the 
framework under which RIS is provided in the EU. This would allow more efficient exchange of 
information among RIS users and access to better quality information, which in turn should lead to 
improved  operational  performance,  greater  integration  in  the  multimodal  chain  and  a  more 
harmonised IWT market. 

The  measures  under  this  initiative  have  links  with  other  initiatives,  such  as  eFTI,  which  has 
introduced an environment for the voluntary handling of cargo information, EMSWe, which  is a 
single  window  for  reporting  in  the  maritime  sector,  and  the  TEN-T  which  defines  the  important 
multimodal corridors in the EU. It also has links with AFIR which aims to provide green charging 
infrastructure  for  vessels.  Furthermore,  it  has  links  with  the  CEF  funded  RIS  COMEX  project, 
developed by the Member States to improve the functionality of RIS. 

The initiative will be successful if it brings an improvement in the overall RIS framework, in terms 
of the number, quality and way river information services are provided to all users, that results in an 
a visible progress of IWT performance. This would in turn improve the competitiveness and safety 
of the sector and its contribution towards the EGD objectives.  

The level of progress needs to be seen, however, in the context of the size of the IWT sector, the 
geographic and other characteristics (described in section 1), and the overall nature and aim of this 
initiative. 

Ultimately, a successful scenario is one where there is an increase of information exchnaged through 
digital means, where IWT has established links with other modes of transport, which would lead to 
a growing modal share of IWT and an increased number of river information services. This should 
also translate into a better environmental performance of the EU transport system.  

The Commission will monitor the actual impacts of the legislation through different actions and a 
set of indicators allowing to measure progress in reaching the specific objectives. The monitoring 
actions will include the regular collection of publicly available information as well as information 
from  RIS  COMEX  and  the  complaint  mechanism.  In  addition,  the  existing  Commission  expert 
groups on DINA and NAIDES will be used as platforms to collect ad hoc feedback and information 
from the Member States and other stakeholders. The Commission may also encourage and support 
the  exchange  of  best  practices  among  Member  States.  In  developing  technical  specifications, 
CESNI will also develop specific technical indicators to be monitored which will then become part 
of the secondary legal acts.  

The  overall  success  of  the  initiative,  given  its  overall  objectives,  cannot  be  assessed  based  on  a 
single indicator but rather on the attainment of the operational objectives. To measure the progress 
and the actual effects of the initiative, a list of operational objectives and indicators for assessing the 
progress towards them have been identified and are detailed Table 14.  

Table 14: Operational objectives and indicators for monitoring progress 
Operational objectives 
Improve quality of RIS 

Possible Indicators 
Data  availability  in  ERDMS  and  frequency  of  update  by 
Member States 
Data  availability  in  RIS  Index  and  frequency  of  update  by 
Member States 
Number  and  type  of  complaints  received  by  national 
complaint handling bodies  
Number  of  corrective  actions  taken  and  average  time  to 
resolve complaints per year 
Frequency of introduction of technical specifications 

72 

 
Operational objectives 
Improve exchange of data 

Improve uptake of digital solutions 

Improving performance of the IWT sector  

Improving logistics links 

Source: European Commission 

Possible Indicators 
Number of exchanges with eFTI 
Number of exchanges with EMSWe 
Number of exchanges with inland ports 
Number of RIS COMEX users 
Data availability in RIS COMEX 
Data availability in national platforms that participate in RIS 
COMEX 
Number of other systems linked with RIS COMEX 
Average waiting times at key points in the network 
Average time spent in reporting and voyage planning 
Average time spent in processing reports 
Tonne-kilometres (tkm) and passenger kilometres (pkm) 
transported by IWT 
Estimated emission levels 
Volume of intermodal operations 
Modal share of IWT transport 
Tonnes of goods transported 
Number of persons transported 
Number of companies 
Number of people employed in IWT 

The success of the RIS Directive can be measured against operational objectives as follows: 

•  The success in improving the quality of the RIS can be assessed based on the availability and 
quality of information using harmonised technical specifications. This can be measured through 
the availability and completeness of  up-to-date data, which can be collected  from the relevant 
databases. The number of complaints submitted by RIS users to the Member States is also an 
important indicator to show the level of harmonisation attained. DINA and NAIADES experts 
will also be consulted for relevant input, and CESNI will be requested to further develop specific 
technical indicators to be monitored. 

•  The  success  in  improving  the  exchange  of  RIS  data  within  the  IWT  sector  and  with  other 
transport  modes  can  be  assessed  based  on  the  use  of  RIS  COMEX  and  the  information 
exchanged with other systems. Specific and technical indicators can be further developed with 
the  assistance  of  CESNI  and  NAIADES  and  DINA  experts  and  will  be  collected  from  these 
systems and national authorities. 

•  The  success  in  increasing  the  uptake  of  digital  solutions  can  be  monitored  though  the  yearly 
number of RIS COMEX users, the type and volume of information exchanged, and the number 
of systems linked (e.g. with ports). This information will be collected though the RIS COMEX 
and from the national authorities. 

•  The  success  in  improving  the  performance  of  RIS  can  also  be  measured  in  terms  of  average 
waiting  times  at  locks  and  other  points  along  the  river,  average  time  spent  in  reporting  and 
voyage planning (vessel operators) and handling of reports (for national public authorities), etc. 
This information can be collected from the national authorities and River Commissions, as well 
as  from  vessel  operators  and  sectoral  organisations  (ad  hoc  studies).  In  addition,  the 
environmental  performance  could  be  monitored  through  transport  activity  shifted  from  road 
transport to IWT and the associated reduction in emissions.  

•  The success of improving IWT position in the logistics chain can be measured by monitoring the 
increase  in  the  volume  of  intermodal  operations  (containerised  and  non-containerised),  the 
increase  in  the  number  of  vessel  operators  that  are  involved  in  intermodal  operations  and  the 
development in the modal split indicators. The information will be gathered from the sectoral 

73 

 
organisations,  official  statistics  on  volumes  of  operations  by  transport  mode  and  changes  in 
modal shares of freight transport.  

Regarding the sources for the information to be collected (when, by whom), it should be noted that 
use will be made of publicly available or already collected data (e.g. modal share, volumes of goods 
transported) for several indicators. There are indicators relating to specific measures (e.g. exchanges 
through COMEX) which are technical indicators and are part of the design of each policy measure 
and  will  be  refined  as  the  technical  specifications  are  developed  in  the  secondary  acts.  For 
improving the quality of RIS, information on ERDMS and RIS index can be obtained directly and at 
any time from these systems by the Commission. The information on the complaint mechanism will 
be reported by the competent authorities on a yearly basis. RIS COMEX usage data will provide 
information that will be used for a number of indicators, such as the exchange of data within IWT 
and  with  other  modes,  and  the  uptake  of  digital  solution.  Relevant  standards  for  statistics  to  be 
collected  by  the  platform  will  be  introduced  by  secondary  legislation  and  can  be  compiled  and 
reported on a yearly basis by the platform. For improving the performance of RIS, information will 
be reported by national authorities on a yearly basis from statistics on e.g. waiting times at locks. 
Information from vessel operators (e.g. average time for voyage planning) will be obtained through 
ad-hoc studies. General statistics (e.g. tonne-kilometres) will be obtained from Eurostat on a yearly 
basis.  Eurostat  will  also  be  the  source  for  the  improvement  of  logistics  performance  and 
supplemented in this case by sectoral statistics as available. 

The initiative will provide a legal framework for the development of more detailed rules, procedures 
and  templates,  which  will  be  laid  down  in  secondary  legislation.  Therefore,  the  implementation 
period  should  reflect  the  entry  into  effect  of  these  acts.  Five  years  after  the  end  of  the 
implementation date of all the relevant legislation (including the adoption and entry into effect of the 
necessary  implementing  and  delegated  acts),  the  Commission  services  should  carry  out  an 
evaluation to verify to what extent the objectives of the initiative have been reached. 

74 

 
  
 
 
ANNEX 1: PROCEDURAL INFORMATION 

1. 

LEAD DG, DECIDE PLANNING/CWP REFERENCES 

The  lead  DG  is  the  Directorate-General  for  Mobility  and  Transport  DG  MOVE,  Unit  D3: 
Ports and Inland Waterways 

DECIDE reference number: PLAN/2021/11060 

Item 5 in Annex II to Commission Work Programme 2023: A Union standing firm and united 
127. 

2. 

ORGANISATION AND TIMING 

The impact assessment follows the ex-post evaluation Directive 2005/44/EC on Harmonised 
River Information Services (RIS)128. 

The impact assessment started in 2022, with the inception impact assessment published on 3 
August 2021129.  

The impact assessment on a possible review of the RIS Directive was coordinated by an Inter-
Service  Steering  Group  (ISSG).  The  Commission  Services  participating  in  the  ISSG  were: 
Secretariat-General, Legal Service, DG Communications Networks, Content and Technology, 
DG Informatics, DG for Energy, DG Environment, the Joint Research Centre, DG Justice and 
Consumers, DG Regional and Urban Policy, DG Research and Innovation, and the European 
Climate, Infrastructure and Environment Executive Agency (CINEA). 

The Inter-Service Steering Group met 6 times: on 16 September 2021, 3 March 2022, 4 June 
2022,  12  September  2022,  30  January  2023,  and  14th  of  July  2023.  It  was  consulted 
throughout  the  different  steps  of  the  impact  assessment  process:  notably  on  all  stakeholder 
consultation  materials  and  deliverables  from  the  external  contractor  and  on  the  draft  Staff 
Working Document. 

3. 

CONSULTATION OF THE RSB 

The draft report was submitted to the Regulatory Scutiny Board on 30 August 2023. The RSB 
issued  a  positive  opinion  with  reservations  on  28  September  2023.  The  comments  received 
from  the  Board  have  been  addressed  in  the  revised  version  of  the  impact  assessment  as 
detailed in the table below. 

Table 15: Modifications of the impact assessment report in response to RSB comments 

What to improve 
(1) The  report should better explain the magnitude of the 
problems. The problem definition should better distinguish 
the  individual  problems  and  their  links  with  the  problem 

Modifications to the impact assessment 
Section 1 has been expanded (including the addition of 
graphs)  to  better  explain  the  specific  context  and 
characteristics of the IWT and RIS. 

127 COM(2022) 548 final 
128 SWD(2021) 50 final 
129 
revision-of-EU-rules_en  

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13135-River-information-services-

75 

 
 
and 

analysis 

consequences.  The 

drivers 
should 
demonstrate, with more evidence, the urgency for the EU 
to  act,  reflecting  the  views  of  the  most  affected  Member 
States.  It  should  set  out  the  main  bottlenecks  that  have 
been  delaying 
the  new 
standards.  The  report  should  also  differentiate  between 
problems affecting specific Member States, regions, local 
authorities,  private  entities,  or  particular  EU  areas.  It 
should  better  elaborate  whether  there  are  particular 
concerns 
or 
data 
safety, 
environmental and territorial concerns. 

implementation  of 

protection, 

regarding 

timely 

genuine 

options, 

(2) The policy options section should bring out clearly the 
available 
alternative 
presenting 
approaches  and  bringing  out  the  relevant  policy  choices. 
The presentation of the options should better explain how 
the policy measures would work in practice and which are 
the  most  important  ones  in  ensuring  the  success  of  the 
initiative.  It  should  also  explain  what  would  be  the 
responsibility  of  each  actor,  i.e.  Member  States,  regional 
authorities, private entities, etc. The option description and 
analysis  should  use  a  simpler  language,  making  it  less 
technical  and  more  accessible  for  the  non  specialist 
readers. 
(3)  The  analysis  should  be  clearer  on  how  different 
estimates were calculated, where they come from and how 
robust  and  complete  their  assessment  is.  It  should  better 
assess  the  reliability  of  estimates  on  environmental  and 
social  impacts  which  appear  to  be  attributed  to  increased 
punctuality,  given  that  these  drive  the  benefit-cost  ratio. 
The report should be more explicit as to how this initiative 
would  increase  punctuality  under  each  option,  given  that 
the study estimates cited as basis for the calculations were 
based  on  figures  for  railway  and  it  is  unclear  to  which 
extent these can be used in the present context. 

76 

information 

to  provide:  more 

The description of the problem in section 2.1 has been 
and 
improved 
clarifications on data limitations, how stakeholders are 
affected,  importance  of  challenges,  and  consequences 
of  the  problem  in  terms  of  safety  and  environment. 
Section 2.2 on problem drivers has been strengthened 
information,  where  available,  on 
with 
further 
consequences 
the  Member  States,  main 
for 
bottlenecks,  personal  data  aspects  and  the  views  of 
stakeholders.  Section  2.3  has  been  strengthened  by 
including  the  views  of  stakeholders.  Overall,  the 
wording has been fine tuned, to improve the clarity of 
the text. 

The  necessity  of  EU  action  has  been  further  clarified 
in section 3.2. 

The  specific  objectives  in  section  4.2  have  been 
simplified, to make it easier to assess their attainment.  
A table providing an overview of discarded measures 
has  been  included  in  section  5.2.1,  while  a  non-
technical  description  of  the  different  measures  is 
included  in  section  5.2.3,  along  with  the  expected 
importance of the measures. 

Section 5.2.4 on the policy options has been redrafted 
in a less technical way, to improve clarity. 

Sections  6.1.1  to  6.1.3  have  been  revised,  to  better 
explain  the  link  with  Annex  4  in  which  the  detailed 
calculations  are  provided.  Section  6.1.4  has  been 
added  on  the  new  reporting  obligations.  The  analysis 
of the impacts on SMEs in section 6.1.5 and in Annex 
6  has  been  expanded  to  include  more  detailed 
information.  A  new  section  on  territorial  impacts 
(section 6.1.10) has been added.  

the 
Further  explanations  have  been  added  on 
reliability of the calculations for modal shift (and thus 
for environmental and social impacts) in section 6.1.7. 
In  addition,  sensitivity  analysis  has  been  performed 
and added in section 7.6, including the  environmental 
and  social  impacts,  as  well  as  the  impacts  on  the 
benefits to costs ratio.  

The  effectiveness  section  (section  7.1)  has  been  re-
drafted,  to  take  into  account  of  the  revised  specific 
objectives. The description has been simplified for the 
non-technical  reader.  Section  7.3  on  coherence  has 
been  expanded  to  include  further  details  on  the 
coherence with specific relevant initiatives. 

Section  8.1  has  been  strengthened  to  include  further 
elaboration on the effectiveness of the preferred policy 
option  in  comparison  with  the  other  policy  options, 
and  the  result  of  the  cost-benefit  analysis  has  been 
highlighted. 

 
  
  
 
 
 
 
  
(4)  The  report  should  better  explain  what  the  initiative 
aims  to  accomplish  exactly.  To  achieve  this,  the  general 
and specific objectives should be better structured, split in 
order  to  fit  with  the  problem  drivers  and  expressed  in 
SMARTer  terms  to  ensure  better  measurement  and 
monitoring  of  effectiveness  and  ultimately  success  of  the 
EU action. 

Section 9 has been reinforced and now discusses how 
success would look like in terms of  an improved RIS 
framework, linking the achievements of this initiative 
with  parallel  complementary  initiatives  focusing  on 
multimodality and environmental performance.  

4. 

EVIDENCE, SOURCES AND QUALITY 

The impact assessment is based on several sources, including: 

1.  The ex-post evaluation of the RIS Directive;  

2.  Stakeholder consultation activities (see Annex 2); 

3.  External  support  study  carried  out  by  an  independent  consultant  (Ramboll  Management 

Consulting, supported by Transport & Mobility Leuven and Panteia);  

4.  Commission experience in monitoring and implementing the Directive;  

5.  Commission  expert  groups  for  NAIADES  and  DINA  (Digital  Inland  Navigation)  The 
expert group meetings were held on 7th of July and 12th of December 2022.  

77 

 
 
 
 
 
 
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) 

1 

INTRODUCTION 

This  annex  provides  a  summary  of  the  outcomes  of  the  consultation  activities  which  have 
been  carried  out  for  the  review  of  RIS  Directive,  including  in  the  context  of  the  external 
support  study.  It  notes  the  range  of  stakeholders  consulted,  describes  the  main  consultation 
activities and provides a succinct analysis of their views and the main issues they raised.  

The  objective  of  the  consultation  activities  was  to  collect  information  and  opinions  of 
stakeholders  on  the  key  problems  and  associated  drivers,  definition  of  relevant  policy 
objectives  linked  to  those  problem  areas  and  the  identification,  definition  and  screening  of 
policy  measures  that  could  eventually  be  incorporated  into  policy  options  for  this  impact 
assessment as well as gather information and opinions on their likely impacts. A consultation 
strategy, covering the stakeholder consultation activities, has been developed and further fine-
tuned throughout the different phases of impact assessment process. 

The main consultation activities included: 

-  Consultation  on  the  Inception  Impact  Assessment  (IIA)  was  conducted  by  the  European 
Commission  between  August  and  September  2021.  In  total  21  respondents  provided 
feedback. 

-  An  Open  Public  Consultation  (OPC),  which  was  available  in  all  EU  languages,  was 
conducted over the period 16 August 2022  - 22 November 2022. The OPC was aimed at 
gathering public opinion on the shortcomings and challenges in the implementation of the 
RIS Directive, and the possible ways in which the Directive could be revised. In total, 13 
responses were received. 

-  29 interviews were organised in the context of the impact assessment support study (during 
the period 25 October - 18 November 2022) with relevant stakeholders at the national level 
and  with  key  stakeholders  at  the  EU  level  particularly  to  support  and  refine  the  overall 
problem definition and possible policy options. 

-  2 targeted surveys covered two different parts of the impact assessment: (i) First survey - 
views on the identified problems and their assessment of the policy measures; (ii) Second 
survey  -  views  on  the  costs  and  benefits  of  each  of  the  proposed  policy  measure.  The 
respondents  were  asked  to  also  distribute  the  survey  to  other  relevant  authorities  or 
organisations that would be interested to complete the surveys. The survey was distributed 
to 229 stakeholders. In the first survey, there were 65 respondents, whereas in the second 
survey there  were 13 respondents.  Overall, the response rate for both  surveys  was  34 %. 
The first survey was launched on the 1st of August 2022 and has been closed on the 26th 
of August 2022. The second survey was launched on 24th November 2022 and was closed 
on 07th February 2023.  

-  2  meetings  were  organised  with  experts  from  the  Commission  expert  group  on  inland 
waterway  transport  (NAIADES  implementation  group)  and  the  expert  group  on  digital 
inland  navigation  (DINA  expert  group).  The  aim  of  the  meetings  was  to  gather  and 
validate  expert  views  on  the  problem  drivers  and  on  the  list  of  proposed  measures.  The 
meetings were held on 7th of July and 12th of December 2022.  

-  Additional  consultation  activities  as  part  of  the  consultation  strategy,  included  a  two-day 
targeted workshop organised on 26 and 27 January 2023 (to facilitate the participation of 
vessel operator representatives). The aim was to collect the feedback of RIS users on the 
potential  costs  or  expected  benefits  stemming  from  the  proposed  policy  measures.  The 

78 

 
workshop  was  co-organised  with  one  of  the  professional  associations  at  the  European 
Level (IWT Platform) and attended by staff of enterprises providing inland navigation and 
logistics ICT, representatives of networks of private businesses, members of the shipping 
sector  associations  and  non-profit  organisations  for  innovation  in  the  inland  navigation 
industry.  

The  information  collected  from  stakeholders  was  key  in  identifying  the  problem  and  its 
drivers,  in  refining  the  design  of  the  Policy  Options  (POs)  as  well  as  in  assessing  their 
economic,  social  and  environmental  impacts.  Findings  from  the  stakeholder  consultation 
complemented the desk research carried out in the context of the impact assessment support 
study. 

2  METHODOLOGY 

The  remainder  of  the  annex  presents  the  main  findings  from  the  analysis  of  stakeholder 
contributions to the consultation process. They are structured around the main elements of the 
intervention  logic,  namely  problems  and  their  drivers,  key  policy  objectives  as  well  as  key 
needs and possible aspects of policy design.  

A  mixed  methods  approach  combining  online  surveys,  targeted  and  follow  up  interviews, 
expert  meetings  and  stakeholder  workshops  has  been  adopted  to  conduct  the  targeted 
stakeholder  consultation  activities,  which  have  taken  place  gradually  throughout  the  impact 
assessment process. This allowed to capture and fill in data gaps and provide evidence for the 
impact assessment. Interviews and meetings have been held mostly by videoconference.  

2.1 

 Feedback on the Inception Impact Assessment 

The consultation on the  Inception Impact Assessment (IIA) was conducted by the European 
Commission  in  August  2021.  The  IIA  was  open  to  stakeholders  and  the  general  public  to 
comment and provide feedback.  

In total, 21 responses were received, originating from 11 countries, with the largest response 
rate  originating  from  the  Netherlands  (4  out  of  21).  The  main  stakeholders  which  provided 
feedback were public authorities and business associations. 

Figure 13: Overview of respondents to the inception impact assessment (N=21) 

Source: Ramboll et al. (2024), impact assessment support study 

As regards the replies provided, the following was noted:  

79 

 
 
•  Regarding the context, the problem definition and the subsidiarity check, the respondents 
largely  welcomed  and  supported  the  need  for  the  revision  of  the  RIS  Directive  and 
considered  it  very  timely  considering  the  evolution  of  RIS.  They  acknowledged  the 
definition of the problem, mentioning clearly that full harmonisation and interoperability of 
RIS  has  not  been  achieved  due  to  fragmented  implementation.  Respondents  from  public 
authorities  mainly  mentioned  problems  of  cross-border  inefficiencies  and  data  protection 
as  the  relevant  ones,  as  well  as  inefficient  processes  for  adopting  RIS  technical 
specifications. The respondents from the business sector  emphasized that too much focus 
was placed on the needs of authorities, without the necessary level of involvement of the 
sector  players  and  that  the  revision  of  the  Directive  needs  to  be  oriented  towards 
decreasing the administrative burden for the operators.  

•  Regarding the objectives and the policy options, the respondents welcomed the identified 
objectives  and  policy  options,  especially  the  part  on  facilitating  interfaces  with  other 
transport modes (in particular maritime). Public authorities considered as very relevant the 
measure ensuring the efficiency and effectiveness of the processes and organisation design 
for the adoption of RIS technical specifications, enabling the sector to take up innovation 
in a timely way. The corresponding role of CESNI in that regard was clearly referenced by 
the respondents from public authorities, but also from the business sector.  

•  In terms of preliminary assessment of expected impacts, only two respondents commented. 
One respondent mentioned that the impacts listed in the document are valid, whereas some 
of them might need further checks. The other commented on the likely social impacts and 
raised  doubt  regarding  the  ability  of  skippers  to  adapt  to  new  digital  processes  and 
requirements that are going to be imposed on small and medium sized barge owners. 

2.2  Open Public Consultation  

An  Open  Public  Consultation  was  designed  and  implemented  by  the  Commission  over  the 
period  16  August  2022  -  22  November  2022,  to  support  the  gathering  of  evidence  for  the 
impact  assessment  process.  The  public  consultation  aimed  to  gather  public  opinion  on  the 
shortcomings  and  challenges  in  the  implementation  of  the  RIS  Directive  and  the  possible 
ways in which the Directive could be revised. Out of the 13 responses received, 6 were from 
public authorities, 3 from business associations and 2 from company/business organisations. 
In  terms  of  geographical  distribution  of  the  respondents,  the  largest  response  rate  was  from 
respondents in Belgium (3), followed by Austria and France (2 respectively). 

Excluding  the  reply  from  the  EU  and  a  business  association  which  did  not  provide  this 
information, the breakdown of the size of the organisations/companies is presented in Figure 
14. 

Figure 14: OPC replies - breakdown of organisation size 

Source: Open Public Consultation 

80 

 
 
Within  the  Open  Public  Questionnaire,  the  respondents  were  requested  to  provide  feedback 
on 4 main areas:  

•  problem drivers and the baseline; 

•   expected  development  of  the  inland  waterway  sector  if  the  legal  framework  of  RIS 

remains unchanged;  

•  areas where a revision of the RIS Directive would have the highest impact; 

•  priority areas of a possible revision of the RIS directive. 

Regarding feedback on problem drivers and baseline, respondents were asked to provide their 
views  on  the  importance  of  specific  challenges  in  the  implementation  of  the  River 
Information Services (RIS) in Europe. The answers are provided in Figure 15. 

Figure 15: Importance of challenges in the implementation of River Information Services (RIS) in Europe 

Source: Open Public Consultation 

With  regard  to  missing  and  non-harmonised  RIS  information  hampering  efficient  and  safe 
navigation,  12  of  the  13  respondents  consider  this  as  a  very  important  challenge,  and  1  as 
somewhat  important.  Delayed  introduction  of  technical  specifications  for  River  Information 
Services  is  considered  as  a  very  important  challenge  by  10  of  the  13  respondents  and  as 
somewhat  important  by  the  other  3.  Of  the  13  respondents,  9  consider  as  a  very  important 
challenge that River Information Services do not support the integration of inland waterway 
transport  in  the  multimodal  supply  chains,  while  2  consider  it  as  somewhat  important  and 
further  2  as  not  important  at  all.  As  far  as  missing  relevant  information  and  efficient 
monitoring to reduce the negative externalities of transport, including through modal shift, 7 
out  of 13 respondents  consider this as a very important  challenge, 5 out  of 13 as somewhat 
important,  while  1  respondent  did  not  know.  Electronic  data  issues  including  exchange  of 
information  (including  cross-border)  and  reporting,  were  considered  as  very  important 
challenges by 10 out of 13 respondents, and the rest 3 considered it as somewhat important. 
Personal  data  protection  concerns  by  the  inland  waterway  operators  were  viewed  as  a  very 
important  challenge  by  8  out  of  13  respondents,  as  somewhat  important  by  3  out  of  13 
respondents,  and  as  not  important  by  the  rest  (2).  In  addition,  5  out  of  13  respondents 
indicated  an  additional  challenge.  Of  those,  2  out  of  5  considered  it  a  very  important 
challenge (which was further defined by 1 out of 2 as relating to data protection of movement 
of  ships  and  by  the  other  as  relating  to  the  standardisation  of  information),  further  2  out  5 
indicated as a non important challenge (further defined as the imprecision of minimum data 

81 

 
 
requirements  concerning  navigation  and  voyage  planning),  and  1  out  of  5  respondents 
indicated “do not know” as an answer. 

Regarding the expected development of the inland waterway sector if the legal framework of 
RIS remains unchanged, respondents were asked to provide their views on how they expect 
the inland waterway sector to develop, if the legal framework of RIS remains unchanged. The 
answers are provided in Figure 16. 

Figure 16: Development of inland waterway sector if the legal framework remains unchanged  

Source: Open Public Consultation 

If the legal  framework remains unchanged, 5 out  of 13 respondents  believe this will have a 
strong  negative  development  in  terms  of  the  implementation  of  the  RIS  technical 
specifications, 4 out of 13 believe it will have a somewhat negative development, 2 out of 13 
believe it will have a somewhat positive development, 1 out of 13 strongly positive and 1 out 
of  13  respondents  believes  that  things  will  remain  unchanged.  Regarding  the  digital 
transformation  of  the  sector,  6  out  of  13  respondents  anticipate  a  strongly  negative 
development, 5 out of 13 a somewhat negative development, 2 out of 13 a somewhat positive 
development and 1 out of 13 respondents believes that things will remain unchanged. On the 
issue  of  the  environmental  performance  of  the  inland  waterway  sector,  6  out  of  13 
respondents  expect  no  changes,  4  out  of  13  somewhat  negative  developments,  2  out  of  13 
somewhat  positive  and  one  respondent  indicated  no  knowledge.  In  relation  to  safety  of 
navigation 6 out of 13 respondents anticipate somewhat negative developments, 4 out of 13 
that the situation will not change, 2 out of 13 that it will be somewhat positive and 1 out of 13 
that it will become strongly negative. On the integration of inland waterway transport into the 
multimodal  supply  chain,  7  out  of  13  expect  a  strong  negative  development,  4  out  of  13  a 
somewhat  negative  development  and  of  the  remaining,  1  considers  no  change  and  1  a 
somewhat  positive  development.  Regarding  the  efficient  use  of  RIS,  8  out  of  13  expect  a 
somewhat negative development, 2 out of 13 a strongly negative, 2 out of 13 that things will 
remain unchanged and 1 out of 13 a strongly positive development. As far as developments in 
the internal market  are  concerned, 9 out of 13  respondents  expect  no  change, 3 out of 13 a 
somewhat negative development and 1 out of 13 a somewhat positive development. 

Regarding  areas  where  a  revision  of  the  RIS  Directive  would  have  the  highest  impact, 
participants were asked about the area where a possible revision of the RIS Directive should 
have the highest impact. The answers are presented in Figure 17. 

82 

 
 
Figure 17: Areas where a revision of the RIS Directive would have the highest impact 

Source: Open Public Consultation 

Of the respondents, 8 out of 13 indicated the integration with other transport modes, 3 out of 
13 the efficiency of inland waterway operations, and 1 out of 13 safety. In addition, 1 out of 
13  respondents  indicated  another  area  of  impact  which  was  further  described  as 
standardisation  of  information.  Regarding  priority  areas  of  a  possible  revision  of  the  RIS 
directive, the replies are presented in Figure 18. 

Figure 18: Priority areas of a possible revision of the RIS directive 

Source: Open Public Consultation 

From the replies of the participants, 9 out of 13 indicated the provision of a clear legal basis 
for the processing of personal data as a high priority, 3 out of 13 as a low priority and 1 out of 
13 as no need to take action. On the alignment of the scope of RIS to  other relevant  policy 
fields, 8 out of 13 indicated this as a high priority, 3 out of 13 as low priority, 1 out of 13 as 
no need to  take  action and 1 out  of 13 indicated do not  know. Regarding the facilitation of 
interfaces with other modes of transport, 9 out of 13 considered this a high priority and 4 out 
13 as low priority. 11 out of 13 respondents consider that a possible revision should mandate 
links  between  RIS  and  other  information  services  as  high  priority  and  2  out  of  13  as  low 
priority.  Improvement  of  monitoring  of  RIS  implementation  and  complaint  handling  was 
considered a high priority by 6 out of 13 respondents, as low priority by 6 out of 13 and 1 out 
of 13 did not know. Speeding up the adoption of RIS technical specifications was seen as high 
priority  by  8  out  of  12  respondents,  as  low  by  3  out  of  12  and  1  out  of  13  did  not  know. 
Reducing  cross  border  information  gaps  and  reporting  requirements,  is  considered  as  high 
priority by 11 out of 13 respondents and as low priority by 2 out of 13. As regards introducing 
provisions on reporting of voyages / cargo / persons-on-board, including voyage plans, 11 out 
of  12  respondents  considered  this  a  high  priority  and  1  out  of  12  as  low  priority.  As  high 
priority is the increase of harmonisation of information provided through RIS, including new 
technical  specifications  seen by 12 out  of 13 respondents,  while 1 out  13 sees  this  as a low 
83 

 
 
 
priority.  Mandating  the  exchange  of  information  between  all  actors  is  considered  as  a  high 
priority by 12 out of 13 respondents and as a low priority by 1 out of 13. 

2.3 

Interviews, surveys and targeted consultations  

Overall,  29  interviews  were  conducted  with  relevant  stakeholders  at  the  national  level  and 
with key stakeholders at the EU level. The interview programme followed the results of the 
first survey. The interviews aimed to provide an opportunity for respondents to go into more 
details.  The  results  fed  into  the  assessment  of  impacts.  Despite  efforts  to  reach  out  to 
stakeholders, only 22% of those approached agreed to participate in interviews.  

Table 16: Overview of interviews  

Stakeholder group 

Stakeholder type 

No. of proposed 
interviews 

No. of 
interviews 

Public bodies: 
International level 

Shipping Regulation / Technical 
Certification Authority 

Public bodies: European 
level 

River Commissions 

Other RIS related bodies 

Public bodies: National 
level 

Port Authorities 

National RIS authorities 

Calamity abatement support / agencies 

Private sector companies 
/ representative 
organisations 

Professional Associations (European 
level) representing IWT operators and 
port operators 

Professional Associations (national level) 
and the IWT operators, navigation 
personnel and port operators they 
represent.  

Developers of RIS 

Total 

Response rate 

2 

2 

1 

2 

15 

1 

3 

12 

2 

40 

1 

3 

2 

0 

10 

1 

6 

3 

3 

29 

22% 

Source: Ramboll et al. (2024), impact assessment support study 

Due  to  the  low  response  rate  to  the  interviews,  a  two  days  targeted  back-to-back  workshop 
was organised in order to obtain targeted feedback from RIS users, in particular skippers who 
broadly  represent  SMEs.  Representatives  of  staff  of  enterprises  providing  inland  navigation 
services,  logistics  and  ICT,  representatives  of  networks  of  private  businesses  (skippers)  and 
members  of  the  shipping  sector  associations  (representing  skippers)  and  non-profit 
organisations  for  innovation  in  the  inland  navigation  industry,  were  invited  to  discuss 
estimates of potential costs or expected benefits stemming from the proposed policy measures 
to  update  the  RIS  Directive.  In  total,  10  out  of  the  35  persons  invited  took  part  in  the 
workshops. 

84 

 
  
Furthermore, online surveys were paramount in reaching out to the relevant stakeholders and 
collecting  their  views  and  opinions  on  the  identified  problems  and  their  assessment  of  the 
policy  measures,  as  well  as  the  costs  and  benefits  of  each  of  the  policy  measures.  The  first 
survey was structured and presented on the following key areas: problem and problem drivers, 
situation  under  the  current  RIS  Directive,  and  feedback  on  the  draft  policy  measures.  The 
survey was distributed to 229 stakeholders,  of which 65 have completed  it. Out of these  65 
respondents, in terms of the geographical scope of the countries where the stakeholders work 
in,  the  highest  number  of  stakeholders’  replies  were  received  from  the  Netherlands  (22 
respondents), followed by Germany (11 respondents), Belgium (7 respondents) and Austria (5 
respondents).  8  stakeholders  responded  that  they  work  in  more  than  one  country,  with  2 
stakeholders  working  in  the  Netherlands,  Belgium  and  Germany;  1  working  in  the 
Netherlands,  Germany,  Hungary,  Slovakia,  Belgium,  Austria  and  Serbia;  2  working  in  an 
international  organisation,  1  in  the  Sava  Commission,  1  internationally  between  the 
Netherlands, France, Germany and Belgium, and 1 across Europe. 

Furthermore,  regarding  the  stakeholder  categories  of  the  respondents,  the  majority  of  the 
respondents were either inland waterway transport or RIS users (31 respondents) or national 
level public bodies (15 respondents).  

The  second  survey  focused  on  the  potential  costs  and  benefits  for  the  stakeholders  of  the 
proposed  policy  measures  in  terms  of  economic,  environmental,  and  social  impacts.  The 
survey  was  distributed  to  229  stakeholders,  of  which  13  have  completed  it.  As  regards  the 
geographical  scope,  the  highest  number  of  stakeholders  work  primarily  in  Germany  (3 
respondents),  followed  by  Austria  (2  respondents).  In  addition,  two  stakeholders  responded 
that  they  work  in  more  than  one  country,  with  1  stakeholder  working  for  an  international 
organisation  whose  headquarter  is  in  France,  and  1  working  across  Europe.  In  terms  of  the 
stakeholder categories of the respondents, the majority of the respondents were either national 
level public bodies (3 respondents) or inland waterway transport or RIS users (3 respondents). 
1 stakeholder chose “other type of professional association” and responded as a IWT operator 
for fleet and ports; whilst 1 stakeholder chose “other” and responded as a RIS operator. 

With  regard  to  the  2  meetings  organised  with  experts  of  the  Commission  expert  group  on 
inland waterway transport (NAIADES implementation group) and the expert group on digital 
inland navigation (DINA expert group), the following key elements were gathered: 

During the 1st meeting, which was attended by 26 participants, the discussions focused on the 
draft problems, draft problem drivers and draft policy measures. The results of the analysis of 
the  inputs  regarding  the  problem  drivers  showed  that  the  opinion  that  prevailed  among  the 
participants  was  that  if  no  revisions  were  made  to  the  RIS  Directive  (i.e.  the  baseline 
scenario),  problem  drivers  are  likely  to  persist.  Similarly,  the  findings  on  the  expected 
development of the draft problem showed a similar pattern, with majority of votes saying that 
the  situation  will  stay  relatively  the  same.  In  relation  to  the  policy  measures,  the  measures 
which  the  participants  ranked  the  highest  according  to  their  relevance/importance  in 
addressing  a  given  problem  driver,  were  the  measures  related  to  increasing  the  level  of 
harmonisation  of  RIS  by  providing  guidelines  for  competent  authorities;  introducing 
provision for supplying data to the ERDMS and its operation; strengthening requirements by 
adding new standards for navigation and voyage planning (RIS INDEX).  

During  the  2nd  meeting,  which  was  attended  by  18  participants,  participants  were  asked  to 
rank the 17 measures from the least costly to the most costly to implement, while the second 

85 

 
exercise  asked  them  to  rank  these  from  the  least  beneficial  for  RIS  users  to  the  most 
beneficial.  

As  a  general  comment  on  the  assumptions  for  the  parameters  substantiating  the  policy 
measures,  experts stressed that the types of assumptions greatly depended on the actors that 
provided them. On the complaint mechanism, experts stressed that complaints and the costs 
thereof  are  not  linked  to  objects  but  rather  to  RIS-related  problems.  A  few  experts  also 
reckoned that the assumptions for the costs and impacts of the complaint mechanism were too 
wide as they included a wide scope of information linked to very different parameters. It was 
also suggested that a complaint mechanism should not be operated at the Member State-level, 
but rather at the corridor-level. For what concerns the performance measurement framework, 
it was stressed by the experts that its costs would greatly change depending on what the key 
indicators  chosen  for  framework  are  and  on  whether  the  framework  is  based  on  a  Member 
State-  or  corridor-level,  suggesting  a  strong  preference  for  the  latter.  Other  important 
takeaways  from  the  discussions  related  to  the  involvement  of  CESNI  in  adopting  RIS 
standards, which was welcomed by the experts as it is expected to increase  the swiftness of 
the  adoption  of  RIS  technical  standards;  support  was  given  to  the  need  to  clarify  the 
management of data, possibly allowing barge owners to autonomously decide who they share 
their  data  with.  Also,  the  area  which  was  emphasized  as  important  was  the  protection  of 
company data and the need of RIS-users for Member States to ensure that the illegal use of 
AIS  data  is  fought  against,  as  this  data  may  disclose  contractual  relationships  and  sensitive 
commercial information. 

3 

 ANALYSIS OF THE STAKEHOLDER CONSULTATION 

The  remainder  of  the  annex  presents  the  main  findings  from  the  analysis  of  stakeholder 
contributions to the consultation process. They are structured around the main elements of the 
intervention logic, including the problem areas and their drivers, the policy objectives as well 
as the key aspects of the design of possible policy measures. The impact assessment support 
study130 contains the detailed presentation of findings from the targeted consultation activities. 

3.1  Problem areas and policy objectives  

The  impact  assessment  identified  one  main  overarching  problem  to  be  addressed  through  a 
revision of the RIS Directive. As part of the interviews, stakeholders were asked to identify 
what  they  see  as  being  the  main  problem  to  be  addressed  through  a  revision  of  the  RIS 
Directive. Overall, the most salient topic was the difference in the level of implementation of 
RIS  across  Member  States  and  the  problems  that  subsequently  arise  in  relation  to 
harmonisation.  This  was  raised  by  3  out  of  10  national  RIS  authorities,  2  out  of  3  River 
Commissions,  1  out  of  6  professional  association  at  the  EU  level,  1  out  of  3  professional 
association  at  the  national  level  and  1  out  of  3  developers  of  RIS.  In  particular,  the  lack  of 
harmonised  information  was  noted  to  bring  about  legal  and  organisational  challenges,  often 
stemming from lack of efficient communication between stakeholders.  

Based on the feedback from interviews and the evaluation findings, the overall problem was 
defined as: “slow and fragmented deployment of River Information Services that hamper the 
competitiveness  and  safety  of  the  sector,  and  its  contribution  towards  the  European  Green 

130  Rambol  et  al.  (2023),  Impact  Assessment  support  study  for  the  revision  of  Directive  2005/44/EC  on 
Harmonised River Information Services (RIS). 

86 

 
 
Deal objectives”. As seen in Figure 19, 40 out of 59 respondents considered that the problem 
will somewhat or considerably worsen in the absence of EU level action.  

Figure  19:  How  do  you  expect  the  problem  (slow  and  fragmented  deployment  of  River  Information 
Services  that  hamper  the  competitiveness  and  safety  of  the  sector,  and  its  contribution  towards  the 
European Green Deal objectives) to develop in the future? (n=59) 

Source: First Survey 

Based on the input from stakeholders, a series of problem drivers were developed to explain 
the main factors that contribute to  the slow and fragmented deployment  of RIS that hamper 
the  competitiveness  and  safety  of  the  sector.  The  main  source  of  stakeholder  input  for  the 
problem drivers stemmed from the first expert groups meeting and the first survey. Figure 20 
and  accompanying  text  provide  a  summary  of  the  responses  provided,  showing  that  the 
stakeholders  largely  confirm  the  identified  problem  drivers,  and  provide  an  indication  as  to 
their importance. 

Figure 20: Responses from the first survey to the question “In your view, are the problem  drivers listed 
below problems which the IWT/ RIS sector currently faces?” (n=65) 

Source: First survey 

There  is  no  significant  difference  between  the  opinions  of  the  stakeholders  on  the  problem 
drivers.  The  majority  of  the  stakeholders  considered  all  problem  drivers  to  be  relevant. 
Problem  driver  3  (Information  Services  do  not  support  the  integration  of  inland  waterways 
transport  into  multimodal  supply  chains)  was  found  to  be  an  issue  by  slightly  fewer 
stakeholders, 15 out of 56 stakeholders stating that it is not a current problem driver. Inland 
waterway transport/RIS users were consistent in their views across the different drivers, about 
half of them considered them to be “definitely a current problem driver”. For problem driver 

87 

 
 
 
3, the most responses considering it “definitely a current problem driver” were from national 
public bodies.  

Figure 21: Responses from the first survey and the DINA/NAIADES expert group meeting to the question 
“If the current RIS Directive is not revised, how do you expect the following problem drivers to develop in 
the future?” (Survey, n=59; Expert group meeting, n=26) 

Source: First survey and DINA/NAIADES expert group meeting 

In  terms  of  stakeholder  differences  across  the  problem  drivers  during  the  first  survey,  the 
majority who responded “the problem will get considerably worse” for problem driver 5 were 
inland  waterway  transport/RIS  users  (9  out  of  13  respondents),  while  for  problem  drivers  3 
and  4  the  majority  were  inland  waterway  transport/RIS  users  (7  respondents  for  problem 
driver  3  and  7  respondents  for  problem  driver  4)  and  national  level  public  bodies  (6 
respondents for problem driver 3 and 5 respondents for problem driver 4). Approximately half 
of  the  stakeholders  who  responded  “the  problem  will  get  considerably  worse”  for  problem 
driver  2  were  inland  waterway  transport/RIS  users  (6  out  of  13  respondents).  For  problem 
driver  1  there  were  no  significant  differences  between  the  stakeholder  groups  in  the  survey 
responses,  however  in  the  expert  group  meeting,  one  national  authority  noted  that  the  non-
harmonisation  aspect  may  be  missing  within  the  EuRIS  portal,  but  it  is  dependent  on  the 
Member  States.  However,  this  view  was  disputed  by  one  navigation  authority  which  noted 
that  in  some  countries  it  takes  a  long  time  for  the  information  to  be  updated  (weeks  or 
months), which poses a big problem. One representative of a national authority expressed the 
view that “although the EuURIS portal as part of the RIS COMEX platform, provides a way 
to distribute and collect information, it does not solve the problem”. 

3.2  Potential policy measures 

The stakeholder views on the list of policy measures are described in this section. Each policy 
measure was discussed in connection with one or more of the problem drivers. As part of the 
first  survey  stakeholders  were  asked  about  the  extent  to  which  they  believed  that  the 
individual measures could address each of the identified problem drivers.  

Under  problem  driver  1,  the  measures  for  the  provisions  of  guidelines  for  competent 
authorities and the addition of new standards gathered support across all stakeholder groups. 
For the measures on the requirement of electronic voyage planning reporting, introduction of 
provisions  for  supplying  data  to  the  ERDMS  and  its  operation,  private  sector  organisations 
generally  were  less  in  favour.  This  was  also  true  of  the  introduction  of  a  new  Performance 

88 

 
 
Measurement  Framework,  and  complaint  mechanism,  of  which 
level 
organisations  also  were  less  in  favour.  The  requirement  of  electronic  voyage  reporting  also 
gathered more negative views from IWT and RIS users, as well as participants from the first 
expert group meeting.  

international 

Under  problem  driver  2,  the  measure  for  the  inclusion  of  CESNI  in  the  development  and 
adoption  of  technical  specifications  by  revising  the  governance  structure  and  adoption 
procedure for technical specifications of the RIS Directive was broadly supported across each 
consultation  method,  with  private  sector  companies  however  being  split  on  the  degree  to 
which it could bring about positive change.  

Under problem driver 3, for the measures of encouraging and requiring electronic voyage plan 
reporting,  there  was  general  support  across  stakeholder  groups,  with  the  exception  of 
international level public bodies and private sector companies. Private sector companies were 
also  less  in  favour  of  the  measure  to  add  new  standards  on  data  for  navigation  and  voyage 
planning,  revise  the  RIS  guidelines  as  well  as  the  introduction  of  provisions  for  supplying 
data  to  the  ERDMS  and  its  operation,  which  was  also  not  supported  by  national  RIS 
authorities. For the measure of linking RIS requirements with those of the TEN-T Regulation, 
there was general support across stakeholder groups with the exception of international level 
public bodies and private sector companies.  

Under problem driver 4, for the measure on information exchange through eFTI and EMSWe 
mechanisms,  despite  agreement  between  national  level  public  bodies  and  representative 
organisations,  a  more  negative  opinion  was  provided  by  IWT/RIS  users  and  international 
level organisations. Similarly, international level organisations and private organisations were 
also  less in  favour of the measures for the  encouragement of information exchange through 
the  RIS  COMEX  platform  and  a  centralised  system  for  RIS  data  exchange  by  the 
Commission.  

Finally,  under  problem  driver  5,  all  of  the  measures  proposed  were  positively  received  by 
stakeholders with the exception of international organisations which generally held the view 
that the measures would only address the problem to a small or to no extent. 

Figure 22 to Figure 26 below show to what extent participants in the DINA/NAIADES expert 
group  meetings  considered  that  different  draft  policy  measures  would  address  the  various 
identified problem drivers. 

89 

 
Figure  22:  To  what  extent  do  you  believe  the 
individual  measures  below  could  help  to  address 
problem driver 1? (n=49) 

Figure  23:  To  what  extent  do  you  believe  the  individual 
measures  below  could  help  to  address  problem  driver  2? 
(n=48) 

Figure  24:  To  what  extent  do  you  believe  the 
individual  measures  below  could  help  to  address 
problem driver 3? (n=48) 

Figure  25:  To  what  extent  do  you  believe  the  individual 
measures  below  could  help  to  address  problem  driver  4? 
(n=48) 

Figure  26:  To  what  extent do  you  believe  the  individual  measures  below  could  help  to  address  problem 
driver 5? (n=46) 

Source: DINA/NAIADES expert group meeting 

90 

 
 
 
 
 
 
 
3.3  Differences among stakeholder groups and integration of consultation results 

While the number of stakeholders consulted differs significantly across the different levels of 
governance, a concerted effort was made to consult all relevant stakeholder groups. While all 
groups  were  contacted,  there  was  a  limited  response  from  IWT  skippers  and  barge  owners 
thus limiting their contribution in the triangulation of results.  

The Open Public Consultation had a low response rate, while in the case of the interviews, the 
main stakeholder group targeted was that of national RIS authorities. In terms of geographical 
coverage,  overall,  there  was  noticeable  bias  with  stakeholders  from  the  Netherlands, 
Germany,  Austria  and  Belgium.  This  bias  was  however  to  be  expected,  given  the  main 
transport/ river routes across Europe, as well as the most prominent stakeholders being EU or 
International associations/ organisations.  

With  regards  to  the  surveys  and  interviews  a  slight  bias  towards  greater  representation  of 
IWT/  RIS  users  was  found  in  the  overall  sample  size  compared  to  other  groups.  This  was 
however judged positively as the majority of those respondents indicated to work for SMEs. 
No weightings were applied in relation in the different sample sizes, but rather the data was 
triangulated, and biases were taken into account in the presentation of results. 

From  the  different  activities  described  above,  triangulation  of  the  data  uncovered  that  the 
stakeholder views were largely divided across two broad points of view: 1) keep the RIS in its 
current  form,  but  reinforce  implementation  across  Member  States,  and  2)  revise  the  RIS 
Directive and focus on greater implementation. Another diverging sets of views could be seen 
in  the  area  of  sharing  of  data  where  the  public  authorities  were  much  more  in  favour  of 
sharing  of  relevant  data,  while  the  operators  and  business  associations  were  against  data 
sharing as well as managing the data on a central level. These differing views were found in 
each  of  the  consultation  activities  and  have  been  taken  into  account  and  adequately 
represented in the analysis. 

91 

 
 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

1. 

PRACTICAL IMPLICATIONS OF THE INITIATIVE 

The  revision  of  the  Directive  on  River  Information  Services  (RIS)  aims  at  providing  a 
framework  for  harmonised  and  updated  RIS  that  will  enable  improvements  in  the 
competitiveness  and  safety  of  the  sector,  and  its  contribution  towards  the  European  Green 
Deal objectives.  

The preferred policy option will improve the performance of RIS, provide for more and better 
quality  data  exchange,  through  a  clear  structure.  It  will  support  enhanced  participation  in 
intermodal operations and will bring legal clarity on the exchange for cross border operations.  

The preferred policy option will promote digitalisation in the sector, improve links with other 
systems  and  tackle  the  identified  challenges.  In  this  respect  the  preferred  policy  option  sets 
the basis and acts as an enabler for further developments to improve operational performance, 
intermodality, competitiveness and sustainability. The  main stakeholder groups affected are: 
national  public  authorities,  vessel  operators,  RIS  software  services  providers  and  the 
European Commission.  

The national public authorities will initially bear some upfront  adjustment  costs related to 
the  setting  up  of  the  complaint  handling  mechanism,  as  well  as  for  necessary  software  and 
hardware  to  improve  the  RIS  Index  and  RIS  COMEX,  as  well  as  links  with  other  modes 
(eFTI,  EMSWe)  and  inland  ports.  National  public  authorities  will  also  bear  recurrent 
administrative  costs  for  maintenance  and  update  of  the  above-mentioned  systems.  On  the 
other hand, they will benefit from administrative cost savings through electronic processing of 
cargo information (instead of paper cargo reports) and the phase out of national platforms that 
would be gradually replaced by RIS COMEX.  

Vessel  operators  will  benefit  from  better  quality  information  and  reduced  efforts  to  collect 
the  necessary  information  to  plan  their  voyage,  which  will  bring  adjustment  costs  savings. 
They  will  also  benefit  from  administrative  cost  savings,  as  less  efforts  will  be  required  to 
prepare  and  resubmit  reports  as  these  will  be  done  with  harmonised  and  standardised  tools, 
like the one-stop-shop RIS COMEX, the eFTI platforms, and with inland ports.  

Software services providers will benefit of adjustment costs savings due to improved access 
to better quality information, which will reduce the costs of their software applications.  

The  society  at  large  will  benefit  from  a  reduction  in  the  external  costs  of  CO2  emissions, 
accidents, congestion, noise and habitats.  

2. 

SUMMARY OF COSTS AND BENEFITS 

I. Overview of Benefits (total for all provisions) – Preferred Option (PO-B) 

Description 

Adjustment costs savings 
for vessel operators, 
expressed as present value 
over 2025-2050 relative to 
the baseline 

Amount 

Direct benefits 

EUR 72.1 million 

92 

Comments 

Recurrent  adjustment  costs  savings  for 
vessel  operators  due 
to  better  quality 
information  and  reduced  efforts  to  collect 
the  necessary  information  to  plan  their 
voyage. 

 
I. Overview of Benefits (total for all provisions) – Preferred Option (PO-B) 

Description 

Administrative costs 
savings for vessel operators, 
expressed as present value 
over 2025-2050 relative to 
the baseline 

Amount 

EUR 28.5 million 

Comments 

Recurrent  administrative  costs  savings  for 
vessel  operators,  due  to  reducing  the  need 
for  re-registering  cargo  information  and 
reporting cargo information to ports. These 
administrative  costs  savings  are  driven  by 
the  exchange  of  cargo-related  information 
through the eFTI mechanism, the exchange 
of  information  through  the  RIS  COMEX 
platform,  the  new  technical  specifications 
for  the  exchange  of  information  with  IWT 
ports and legal clarity for personal data. 

Adjustment costs savings 
for RIS software services 
providers, expressed as 
present value over 2025-
2050 relative to the baseline 

Administrative costs 
savings for national public 
authorities, expressed as 
present value over 2025-
2050 relative to the baseline 

Reduction in external costs 
of CO2 emissions, expressed 
as present value over 2025-
2050 relative to the baseline 

Reduction in external costs 
of noise emissions, 
expressed as present value 
over 2025-2050 relative to 
the baseline 

Reduction in external costs 
of habitats, expressed as 
present value over 2025-
2050 relative to the baseline 

Reduction in external costs 
of road congestion, 
expressed as present value 
over 2025-2050 relative to 
the baseline 

Reduction in external costs 
of road accidents (fatalities 

EUR 8.1 million 

EUR 30.6 million 

Indirect benefits 

EUR 48.6 million 

EUR 36.6 million 

EUR 36.2 million 

EUR 86.8 million 

EUR 115.8 million 

93 

Recurrent adjustment costs savings for RIS 
to 
software 
improved 
quality 
information, which will reduce the costs of 
their software applications. 

providers 
to 

services 
access 

better 

due 

public 

authorities 

Recurrent  administrative  costs  savings  for 
national 
through 
electronic  processing  of  cargo  information 
(instead  of  paper  cargo  reports)  and  the 
phase  out  of  national  platforms  that  would 
be gradually replaced by RIS COMEX. 

Indirect  benefit  to  society  at  large,  due  to 
the tonnes of CO2 emissions saved, enabled 
by the higher use of IWT and the shift away 
from  road  transport.  The  reduction  in  the 
is 
external  costs  of  CO2  emissions 
estimated  at  EUR  48.6  million,  expressed 
as  present  value  over 
the  2025-2050 
horizon relative to the baseline. 

Indirect benefit to  society at large, enabled 
by the higher use of IWT and the shift away 
from  road  transport.  The  reduction  in  the 
external  costs  of  noise  emissions 
is 
estimated  at  EUR  36.6  million,  expressed 
as  present  value  over 
the  2025-2050 
horizon relative to the baseline. 

Indirect benefit to  society at large, enabled 
by the higher use of IWT and the shift away 
from  road  transport.  The  reduction  in  the 
external  costs  of  habitats  is  estimated  at 
EUR  36.2  million,  expressed  as  present 
value  over  the  2025-2050  horizon  relative 
to the baseline. 

Indirect benefit to  society at large, enabled 
by the higher use of IWT and the shift away 
from  road  transport.  The  reduction  in  the 
external  costs  of 
is 
estimated  at  EUR  86.8  million,  expressed 
as  present  value  over 
the  2025-2050 
horizon relative to the baseline. 

road  congestion 

Indirect  benefit  to  society  at  large,  due  to 
injuries  avoided, 
the 

lives  saved  and 

 
I. Overview of Benefits (total for all provisions) – Preferred Option (PO-B) 

Description 

Amount 

Comments 

and injuries), expressed as 
present value over 2025-
2050 relative to the baseline 

enabled  by  the  higher  use  of  IWT  and  the 
shift  away  from  road  transport  and  thus  a 
reduction  in  the  road  freight  transport 
the  baseline.  The 
activity 
reduction  in  the  external  costs  of  road 
accidents 
is  estimated  at  EUR  115.8 
million, expressed as present value over the 
2025-2050 horizon relative to the baseline. 

relative 

to 

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

Administrative costs 
savings for vessel operators 
- average per year131 
relative to the baseline 

EUR 1.6 million on average per year 

Recurrent  administrative  costs  savings  for 
vessel  operators,  due  to  reducing  the  need 
for  re-registering  cargo  information  and 
reporting  cargo  information  to  ports.  They 
are  estimated  at  EUR  1.6  million  per  year 
on average relative to the baseline, and they 
are driven by: the exchange of cargo-related 
information  through  the  eFTI  mechanism 
the  exchange  of 
(EUR  0.6  million), 
the  RIS  COMEX 
information 
through 
platform  (EUR  0.2  million), 
the  new 
standards  and  technical  specifications  for 
the  exchange  of  information  with  IWT 
ports (EUR 0.5 million) and legal clarity for 
personal data (EUR 0.3 million). 

II. Overview of costs – Preferred option (PO-B) 

Citizens/Consumers 

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

Direct adjustment costs, 
expressed as present value 
over 2025-2050 relative to the 
baseline 

Direct administrative costs, 
expressed as present value 
over 2025-2050 relative to the 
baseline 

Direct regulatory fees and 
charges 

Direct enforcement costs 

Indirect costs 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

For national 
public 
administrations: 
EUR 18.3 
million 

- 

For national 
public 
administrations: 
EUR 75.3 
million 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

Costs related to the ‘one in, one out’ approach 

131 As explained in section 8.3, this is calculated as simple average over 2026-2035. 

94 

 
 
 
 
 
II. Overview of costs – Preferred option (PO-B) 

Direct adjustment 
costs  

Total  

Indirect 
adjustment costs 

Administrative 
costs (for 
offsetting) 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

3. 

RELEVANT SUSTAINABLE DEVELOPMENT GOALS 

III. Overview of relevant Sustainable Development Goals – Preferred Option (PO-B) 
Relevant SDG 

Expected progress towards the Goal 

Comments 

389.1 thousand tonnes of CO2 emissions saved 
cumulatively over the period 2025-2050. 

Shift of freight transport from road to inland 
waterways by 0.38 billion tonnes-kilometres in 
2030 and 0.45 billion tonnes-kilometres in 2050 
relative to the baseline. 

The  decrease  in  emissions  is  due  to  the 
modal  shift  of  freight  from  road  to  inland 
waterway transport. 

Indicator  9.1.2  “Passenger  and 
volumes, by mode of transport” is used. 

freight 

SDG 13 (“Take urgent 
action to combat climate 
change and its impacts”) 

SDG 9 (“on industry, 
innovation and 
infrastructure”), specifically 
9.1 “Develop quality, 
reliable, sustainable and 
resilient infrastructure, 
including regional and 
transborder infrastructure, to 
support economic 
development and human 
well-being, with a focus on 
affordable and equitable 
access for all” 

95 

 
 
 
 
 
 
 
 
 
 
 
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  Staff  Working  Document  accompanying 
the REPowerEU package132, the impact assessments underpinning the “Fit for 55” package133, 
the impact assessments accompanying the 2030 Climate Target Plan134 and the Staff Working 
Document accompanying the Sustainable and Smart Mobility Strategy135, the Commission’s 
proposal  for  a  Long  Term  Strategy136  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 Rambol et al. in the context of the impact assessment support study137. The tool 
draws on the Standard Cost Model for the assessment of the costs and costs savings and also 
includes an assessment of the environmental and social impacts. The excel-based tool builds 
extensively on data from Eurostat, the CCNR, and the analysis of stakeholders' feedback. The 
proposed  measures  which  involve  the  amendment  of  the  Directive  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 
2025-2050 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; 

132 https://ec.europa.eu/commission/presscorner/detail/en/IP_22_3131 
133 Delivering the European Green Deal | European Commission (europa.eu) 
134 SWD(2020)176 final. 
135 EUR-Lex – 52020SC0331 – EN – EUR-Lex (europa.eu)  
136 Source: 2050 long-term strategy (europa.eu)  
137 The  analysis in this section is based on  the Rambol et al. (2023), Impact Assessment support study for the 
revision of Directive 2005/44/EC on Harmonised River Information Services (RIS). 

96 

 
 
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 model 
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 TREMOVE138 
modelling community. Part of the model (e.g. the utility nested tree) was built following the 
TREMOVE  model.139  Other  parts,  like  the  component  on  fuel  consumption  and  emissions, 
follow the COPERT model. 

Data inputs 

The  main  inputs  to  the  PRIMES-TREMOVE  model,  such  as  for  activity  and  energy 
consumption, come from the EUROSTAT database and from the Statistical Pocketbook "EU 
transport  in  figures”140.  Excise  taxes  are  derived  from  the  DG  TAXUD  excise  duty  tables. 
Other data come from different sources such as research projects (e.g. TRACCS project) and 
reports. In the context of this exercise, the PRIMES-TREMOVE transport model is calibrated 
to  2005,  2010  and  2015  historical  data.  Available  data  on  2020  market  shares  of  different 
powertrain types have also been taken into account. 

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)141.  The  same  assumptions  have  been  used  in  the  policy  scenarios 

138 Source : https ://www.tmleuven.be/en/navigation/TREMOVE  
139 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. 
140 Source : https ://ec.europa.eu/transport/facts-fundings/statistics_en 
141 EU Reference Scenario 2020 (europa.eu) 

97 

 
 
underpinning the impact assessments accompanying the “Fit for 55” package142 and the Staff 
Working Document accompanying the REPowerEU package143. 

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  Eurostat144  are  used  to  estimate  the  evolution  of  the  European 
population,  which  is  expected  to  change  little  in  total  number  in  the  coming  decades.  The 
GDP growth projections are from the Ageing Report 2021145 by the Directorate General for 
Economic  and  Financial  Affairs,  which  are  based  on  the  same  population  growth 
assumptions. 

Table 17: 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 

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 

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 

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 

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% 

1.1% 

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% 

142 Policy scenarios for delivering the European Green Deal (europa.eu) 
143 https://ec.europa.eu/commission/presscorner/detail/en/IP_22_3131 
144 EUROPOP2019 population projections : Eurostat – Data Explorer (europa.eu)  
145 The 2021 Ageing Report : Underlying assumptions and projection methodologies  The 2021 Ageing Report: 
Underlying Assumptions and Projection Methodologies | European Commission (europa.eu) 

98 

 
 
  
 
Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

Population 

GDP growth 

2020 

0.63 

0.51 

17.40 

37.94 

10.29 

19.28 

5.46 

2.10 

47.32 

10.32 

2025 

0.66 

0.56 

17.75 

37.57 

10.22 

18.51 

5.47 

2.11 

48.31 

10.75 

2030 

0.69 

0.59 

17.97 

37.02 

10.09 

17.81 

5.44 

2.11 

48.75 

11.10 

2020-‘25 

2026-‘30 

1.7% 

2.7% 

0.7% 

2.1% 

0.8% 

2.7% 

1.1% 

2.1% 

0.9% 

1.4% 

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 
policy  options  of  this  impact  assessment,  that  draw  on  the  modelling  underpinning  the 
REPowerEU package146.  

transport  modelling 

Table 18: 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 

146 SWD(2022)230 final. 

99 

 
 
  
 
Reference  Scenario  2020147.  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  2021148  and  the  initiatives  of  the 
RePowerEU package proposed by the Commission on 18 May 2022149. The baseline scenario 
assumes  no  further  EU  level  intervention  beyond  the  current  RIS  Directive.  The  effects  of 
projects  such  as  RIS  COMEX  are  however  expected  to  continue  over  time  in  the  baseline 
scenario,  as  the  continuation  of  the  project  RIS  COMEX  2  was  recently  selected  for  CEF 
funding. In addition, the baseline scenario accounts  for the proposed revision  of the TEN-T 
Regulation150.  

The baseline also incorporates foresight megatrends151 and developments captured in the 2022 
Strategic  Foresight  Report152.  Among  others,  it  captures  the  trend  of  increasing  demand  for 
transport as population and living standards grow as well as the links between the digital and 
green  transition.  In  particular,  the  projected  transport  activity  draws  on  the  long-term 
population projections from Eurostat and GDP growth from the Ageing Report 2021153 by the 
Directorate General for Economic and Financial Affairs. 

2.2.  Baseline scenario results 

Evolution of transport performance 

In the Baseline scenario, EU transport activity is projected to grow post-2020, following the 
recovery from the COVID pandemic. Road transport would maintain its dominant role within 
the EU by 2050. Rail transport activity is projected to grow significantly faster than for road, 
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. Freight rail traffic would increase by 42% by 
2030  relative  to  2015  (96%  for  2015-2050).  Freight  inland  waterways  activity  represented 
147  billion  tonne-kilometres  (tkm)  in  2015,  going  down  to  132  billion  tkm  in  2020154. 
Following  the  post-COVID  recovery,  the  freight  inland  waterways  activity  is  projected  to 
increase  to  178  billion  tkm  in  2030  (21%  increase  relative  to  2015)  and  212  billion  tkm  in 
2050 (44% increase for 2015-2050)155. 

147 EU Reference Scenario 2020 (europa.eu) 
148 https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal/delivering-european-green-
deal_en 
149 https://ec.europa.eu/commission/presscorner/detail/en/IP_22_3131 
150 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=COM%3A2021%3A812%3AFIN 
151 https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en#explore  
152 COM(2022) 289 final of 29 June 2022. 
153 The 2021 Ageing Report : Underlying assumptions and projection methodologies  
154 Source: EU transport in figures. Statistical pocketbook 2022 (europa.eu) 
155  PRIMES-TREMOVE  model  provides  the  projections  for  inland  waterways  and  domestic  maritime  at 
aggregate  level.  No  split  is  available  between  the  two.  This  is  due  to  the  fact  that  energy  balances  do  not 
distinguish  between  the  two  modes  (their  energy  use  is  provided  together).  In  order  to  derive  the  transport 
activity  for  freight  inland  waterways,  the  share  of  inland  waterways  activity  in  total  inland  waterways  and 

100 

 
 
 
Table 19: Projected inland waterways activity at EU level in the baseline scenario (in billion tkm/pkm) 

IWT freight (billion tkm) 
IWT passenger (billion pkm) 

2015 

147 
0.5 

2020 

132 
0.04 

2030 

173 
0.6 

2040 

195 
0.7 

2050 

212 
0.7 

Source: Ramboll et al. (2024), impact assessment support study  

The projected evolution of freight inland waterways activity by Member State is provided in 
Table 20. The highest shares of the freight inland waterways activity post-2030 are projected 
in  Germany  (around  40%  of  the  total),  the  Netherlands  (around  30%),  Romania  (around 
11%),  Belgium  (around  7%)  and  France  (around  5%).  The  other  Member  States  would 
provide less than 5% of the freight inland waterways activity from 2030 onwards. 

Table 20: Projected inland waterways activity by Member State in the baseline scenario (in billion tkm) 

2015 
55.32 
DE 
48.54 
NL 
13.17 
RO 
10.43 
BE 
8.52 
FR 
5.60 
BG 
1.81 
AT 
1.82 
HU 
0.88 
HR 
0.74 
SK 
0.24 
LU 
0.13 
FI 
0.06 
IT 
0.00 
SE 
0.09 
PL 
0.03 
CZ 
EU 
147.35 
Source: Ramboll et al. (2024), impact assessment support study  

2020 
46.34 
45.17 
13.64 
7.39 
6.99 
6.26 
1.61 
2.00 
0.90 
0.83 
0.20 
0.13 
0.12 
0.08 
0.08 
0.02 
131.74 

2030 
69.94 
54.13 
19.32 
12.27 
8.30 
6.33 
2.41 
2.53 
1.12 
1.00 
0.27 
0.16 
0.15 
0.10 
0.15 
0.04 
178.21 

2040 
76.77 
58.06 
21.26 
13.59 
8.61 
7.29 
2.55 
3.11 
1.33 
1.08 
0.33 
0.18 
0.16 
0.12 
0.21 
0.04 
194.69 

2050 
85.29 
61.99 
23.57 
14.54 
8.74 
7.95 
2.59 
3.40 
1.46 
1.15 
0.36 
0.20 
0.16 
0.13 
0.24 
0.05 
211.82 

The  passenger  segment  of  IWTs  is  expected  to  increase  as  well  (see  Table  19),  with  the 
number  of  passenger-kilometres  projected  to  increase  by  36%  by  2030  compared  to  2015 
(53%  increase  for  2015-2050)156.  The  number  of  passengers  on  cruise  vessels  for  the 
historical  period  is  based  on  data  from  CCNR157.  The  activity  in  terms  of  passenger-
kilometres  has  been  derived  assuming  an  average  sailing  distance  per  passenger  in  inland 
navigation of 350 kilometres. 

Despite  the  increase  in  terms  of  transport  volumes,  the  modal  share  of  freight  IWT  in  land 
transport158 is projected to decrease from 6.8% in 2015, to 6.5% in 2025 and 6.3% in 2030. 
Post-2030, the modal share of freight IWT is projected to remain relatively stable over time, 
at 6.2% of land transport activity. The decrease in the market share of IWT relative to 2015 is 

domestic  maritime  activity  from  Eurostat  has  been  used.  Post-2020,  the  share  of  inland  waterways  activity  is 
assumed to remain constant over time at its 2020 levels, in line with historical developments. 
156  For  the  projection  period,  the  passenger  IWT  activity  is  assumed  to  grow  in  line  with  that  of  inland 
waterways and domestic maritime activity from the PRIMES-TREMOVE model, while also taking into account 
the increasing share of passenger IWT between 2015 and 2019. 
157 Source: https://www.ccr-zkr.org/files/documents/om/om20_II_en.pdf  
158 Excluding pipeline transport.  

101 

 
 
 
 
due to the specific type of goods transported by inland navigation, i.e. petroleum products and 
coal  that  are  expected  to  decrease  their  share  over  time  driven  by  the  energy  transition,  but 
also due to the higher growth in the rail transport activity. Although growth is expected in the 
container segment, this growth is only projected to counterbalance the decrease in fossil fuels 
trade  post-2030.  As  regards  passenger  transport,  the  modal  share  of  IWT  only  represents 
around 0.01% of land transport activity and is projected to remain relatively stable over time 
following the post-COVID recovery. 

The  number  of  passenger  vessel  journeys  is  derived  based  on  the  projected  evolution  of 
activity in passenger-kilometres, assuming an average sailing distance per passenger in inland 
navigation of 350 kilometres and an average capacity of vessels of 150 passengers159. In the 
baseline scenario, the number of passenger vessel journeys is projected to increase from 8,867 
in  2015  to  12,043  in  2030  and  13,572  in  2050  following  the  recovery  from  the  COVID-19 
pandemic (see Table 21).  

The  total  number  of  freight  vessels  journeys  is  estimated  as  the  total  number  of  tonnes 
transported  by  IWT  divided  by  the  number  of  tonnes  transported  per  journey.  The  total 
number of tonnes transported is projected to grow roughly in line with the transport activity in 
tonne  kilometres  (from  545  million  tonnes  in  2015  to  690  million  tonnes  in  2030  and  813 
million tonnes in 2050), while the number of tonnes per journey  would continue to increase 
but at a slower pace than in the past160. For 2015 the total number of freight vessels journeys 
was estimated at 682,120, going down to 588,721 in 2020. Around 60% of vessels journeys 
took  place  within  the  Netherlands.  Post-2020,  the  number  of  freight  vessels  journeys  is 
projected to go up to 717,838 in 2030 (5% increase for 2015-2030) and 731,234 in 2050 (7% 
increase for 2015-2050), following the recovery from the COVID-19 pandemic.  

Around  40%  of  the  freight  vessels  journeys  take  place  within  one  country,  with  the  rest 
crossing on average 1.3 borders per journey. This means that in many cases these are journeys 
between neighbouring countries (e.g. the Netherlands-Belgium or the Netherlands-Germany) 
and to a much lesser extent journeys that pass through three or more countries (e.g. Belgium-
the  Netherlands-Germany  or  Ukraine-Romania-Bulgaria).  The  share  of  border  crossings  in 
the number of vessel journeys is  assumed to  remain constant  over time (at  around 60%),  in 
line  with  the  historical  developments.  Thus,  the  total  number  of  freight  border  crossings  is 
projected  to  go  up  from  427,947  in  2015  to  432,442  in  2030  and  440,512  in  2050.  For 
passenger vessels journeys, the share of border crossings is much higher (around 90%) and is 
assumed  to  remain  constant  over  time.  The  total  number  of  border  crossings  for  passenger 
IWT is projected to increase from 8,344 in 2015 to 10,882 in 2030 and 12,264 in 2050 (see 
Table 21). 

Table 21: Projected evolution of vessel journeys and border crossings in the baseline scenario 

2015 

2020 

2030 

2040 

2050 

Number  of  vessel 
journeys 
Freight  
Passenger  

Number  of  border 

682,120 
8,867 

588,721 
827 

717,838 
12,043 

721,589 
12,940 

731,234 
13,572 

159 Cruise Ship Passenger Capacity | CruiseMapper 
160 From 799 tonnes per journey in 2015 and 859 tonnes per journey in 2020 to 961 tonnes per journey in 2030 
and 1,111 tonnes per journey in 2050. 

102 

 
 
 
 
 
 
 
 
 
 
 
 
 
crossings 

Freight  
Passenger  

2015 

2020 

2030 

2040 

2050 

427,947 
8,344 

354,659 
747 

432,442 
10,882 

434,702 
11,693 

440,512 
12,264 

Source: Ramboll et al. (2024), impact assessment support study  

In  terms  of  vessels-kilometres,  the  freight  inland  waterways  activity  is  projected  to  remain 
relatively  constant  over  time  (from  184  million  vessels-kilometres  in  2015  to  185  million 
vessels-kilometres  in  2030  and  191  million  vessels-kilometres  in  2050).  This  is  despite  the 
growing number of tonnes transported, and can be explained by the increase in the number of 
tonnes  per  journey,  as  mentioned  above161.  For  passenger  IWT,  the  activity  is  projected  to 
increase from 3.1 million vessels-kilometres in 2015 to 4.2 million vessels-kilometres in 2030 
and 4.8 million vessels-kilometres in 2050.  

Evolution of the fleet 

The number of cargo vessels has decreased significantly between 2003 and 2020162. In 2003, 
there were 13,385 ships in the EU, but by 2020 their number has fallen to 10,332, a decline of 
23%. The number of cargo vessels decreased because of scale enlargement (larger quantities 
per ship) and better functioning of the transport market (liberalisation). As the same time, the 
size  of  vessels  is  increasing,  making  up  for  the  reduction  in  carrying  capacity,  which 
according  to  Eurostat  decreases  only  by  3%.  The  overall  downward  trend  in  the  number  of 
cargo vessels is expected to reverse by 2030 (12,371 cargo vessels), driven by the increase in 
activity  and  the  slower  increase  in  the  capacity  of  ships  compared  to  the  past,  and  it  is 
expected to  remain relatively stable until 2050 (12,223 cargo vessels) due to the increase in 
the  productivity  per  vessel163.  On  the  other  hand,  the  number  of  passenger  vessels  had 
increased  from  approximately  160  ships  in  2004  to  405  ships  in  2021.  When  the  day-tour 
ships  and  smaller  cycle  holiday  ships  are  counted,  around  2,553  passenger  ships  were 
estimated  to  operate  in  the  EU  in  2015164.  The  number  of  passenger  vessels  is  projected  to 
follow the increase in the number of passengers (3,467 vessels projected in 2030 and 3,908 in 
2050). It should however be noted that the majority of these vessels are small or very small. 
In  contrast  to  cargo  vessels,  no  further  growth  in  scale  or  productivity  is  expected  for 
passenger shipping. 

Table 22: Projected evolution of the fleet in the baseline scenario 

2015 

2020 

2030 

2040 

2050 

Freight  
Passenger  
Total fleet 

11,792 
2,553 
14,345 

10,332 
2,942 
13,274 

12,371 
3,467 
15,838 

12,270 
3,726 
15,996 

12,223 
3,908 
16,131 

161 From 799 tonnes per journey in 2015 and 859 tonnes per journey in 2020 to 961 tonnes per journey in 2030 
and 1,111 tonnes per journey in 2050. 
162 The year 2003 was chosen for the comparison because of data availability on the number of ships in both the 
Rhine, Danube and other river basins.  
163 This is assumed at 1.5% per year per ship/barge. This increase is justified by both technical and operational 
developments: for instance Smart And Autonomous Shipping which may result into a larger share of the fleet 
being able to sale 24/7 (in spite of labour shortages in the sector), increased attention to good navigational status 
of waterways (including 24/7 operation of bridges and locks on the major waterways) and scale enlargement in 
IWT of both companies (larger number of vessels per company) and vessels (larger load capacities for vessels), 
although at slower pace than in the past. 
164 Prominent (2017) 

103 

 
 
 
 
Source: Ramboll et al. (2024), impact assessment support study  

Evolution of energy use, CO2 and air pollutant emissions  

The  evolution  of  energy  consumption  and  emissions  draws  on  the  PRIMES-TREMOVE 
model  projections,  while  accounting  for  the  share  of  inland  waterways  transport  in  inland 
waterways and domestic maritime activity. Energy use in freight IWT is projected to remain 
relatively stable by 2030 to its 2015 levels, despite the increase in activity, and to decrease to 
895  ktoe165  by  2050  (11%  decrease  for  2015-2050),  thanks  to  the  uptake  of  more  fuel-
efficient technologies including electrification. For passenger vessels, energy consumption is 
projected to increase by 11% by 2030 (132 ktoe), driven by the strong growth in activity, and 
only to slightly decrease by 2050 relative to its 2015 levels (112 ktoe). Overall, considering 
both  passenger and freight,  energy use in  inland  waterways transport is  projected to remain 
relatively  stable  by  2030  compared  to  its  2015  levels  and  to  go  down  by  10%  by  2050, 
relative to 2015.  

In  the  baseline  scenario,  CO2  emissions  from  inland  waterways  transport  are  projected  to 
decrease much faster than the energy use (21% decrease for 2015-2030 and 67% decrease for 
2015-2050).  This  is  because  of  the  large  scale  uptake  of  renewable  and  low  carbon  fuels, 
namely  e-fuels,  biofuels  and  electricity.  In  this  context,  it  should  be  noted  that  the  baseline 
scenario  assumes  the  implementation  of  the  European  Climate  Law  to  which  all  sectors, 
including the inland waterways sector, need to contribute.  

In terms of NOx emissions a similar trend is expected. NOx emissions are projected to reduce 
from  73  ktons  in  2015  to  just  below  20  ktons  in  2050.  The  amount  of  particulate  matter 
emitted by inland navigation is also expected to reduce, from 3.8 ktons in 2015 to 1 kton in 
2050.  This  is  due  to  both  electrification  and  the  fact  that  the  ships  that  continue  to  operate 
with internal combustion engines are becoming cleaner. In this context, it should be noted that 
since 2020 new combustion engines are considerably cleaner, thanks to the implementation of 
non-road mobile machinery (NRMM) Regulation166 (NRMM Stage 5). 

Table 23: Projected evolution of energy use, CO2 and air pollutant emissions in the baseline  

2015 

2020 

2030 

2040 

2050 

Energy use (ktoe) 

Freight  

Passenger  

CO2 emissions (ktons) 

Freight  

Passenger  

NOx emissions (ktons) 

Freight  

Passenger  

PM emissions (ktons PM2.5) 

Freight  

Passenger  

1,124 

1,006 

119 

3,476 

3,109 

366 

73 

65 

8 

3.8 

3.4 

0.4 

828 

818 

10 

2,416 

2,387 

29 

49 

49 

1 

2.6 

2.5 

0.0 

1,129 

997 

132 

2,745 

2,424 

321 

47 

41 

5 

2.4 

2.2 

0.3 

1,060 

938 

122 

2,182 

1,930 

251 

32 

28 

4 

1.6 

1.5 

0.2 

1,007 

895 

112 

1,084 

963 

121 

18 

16 

2 

1.0 

0.8 

0.1 

165 The tonne of oil equivalent (toe) is a unit of energy defined as the amount of energy released by burning one 
tonne of crude oil. 
166 Regulation (EU) 2016/1628. 

104 

 
 
 
Source:  Ramboll  et  al.  (2024),  impact  assessment  support  study;  Note:  PM  stands  for  particulate  matter 
emissions.  

Evolution of the number of accidents  

There  is  little  consistent  data  on  safety  in  the  inland  navigation  sector,  with  available  data 
coming  from  Eurostat  and  national  databases  for  Bulgaria,  Czechia,  Germany,  Croatia, 
Hungary,  the  Netherlands,  Austria,  Poland  and  Romania.  In  the  baseline  scenario,  the 
projected evolution of the number of accidents is linked to the evolution of activity expressed 
in  terms  of  vessel-kilometres.  The  number  of  accidents  per  vessel-kilometres  is  assumed  to 
remain constant over time. Thus, the number of accidents is projected to slightly increase to 
535 in 2030 and 551 in 2050 in the baseline scenario. 

Table 24: Projected evolution of the number of accidents in the baseline scenario 

Freight and passenger 

2015 

2020 

2030 

2040 

2050 

529 

433 

535 

539 

551 

Source: Ramboll et al. (2024), impact assessment support study  

3.  Impacts of policy measure in terms of costs and cost savings 

This  section  explains  the  inputs  used  and  provides  the  assessment  of  costs  of  the  policy 
measures  included  in  the  policy  options.  The  estimates  take  into  account  the  synergies 
between the policy measures included in the policy options. The estimation of the costs draws 
on  the  impact  assessment  support  study167,  including  input  collected  through  desk  research 
and stakeholder interviews during the impact assessment process. 

PM1: Increase the harmonisation of RIS through guidelines  

Under this measure, the European Commission,  supported by CESNI (European Committee 
for drawing up standards in the field of inland navigation), would develop a set of guidelines 
that  will  support  Member  States  and  stakeholders  in  better  interpreting  and  applying  the 
existing technical specifications168. This would increase the level of harmonisation of RIS by 
removing  different  interpretations  or  incomplete  application  of  the  technical  specifications 
and will help to improve the quality of the information provided to the users through RIS, and 
help the sector to identify required information more easily.  

167 Ramboll et al. (2024), Impact assessment support study. 
168 These guidelines are not the same with the “RIS Guidelines” as mentioned in Annex II of the Directive, and 
which  form  an  integral  part  of  the  standards,  originating  from  the  work  of  PIANC,  and  which  are  in  force 
through Commission Regulation (EC) No 414/2007.  

105 

 
 
 
Adjustment costs for the European Commission  

The development of the guidelines will proceed in two steps169. A study will be carried out to 
compile  the  required  elements  and  propose  several  options  for  the  establishment  of  the 
technical specifications. In a second stage, an expert group will use the findings of the study 
to draft the guidelines. 

The one-off costs of the study are estimated at EUR 400,000. The average cost for a two-day 
workshop  hosted  by  European  Commission  (EC),  where  participants  are  reimbursed  by  the 
EC, is around EUR 30,000. Two of such in-person workshops may be required as well as two 
online  meetings.  Compensation  for  the  experts  contributing  to  the  online  meetings  is 
estimated  at  EUR  5,000  for  each  meeting.  Therefore,  the  one-off  adjustment  costs  for  the 
European Commission are estimated at EUR 0.47 million. 

Adjustment costs savings for navigation software service providers  

The guidelines are expected to facilitate the work of navigation software service providers by 
reducing  current  inefficiencies,  such  as  the  ones  caused  by  data  inconsistencies  between 
Member  States.  The  improvement  in  the  quality  of  the  information  provided  through  RIS 
under  this  measure  is  expected  to  lead  to  time  savings  for  software  service  providers  for 
introducing the data into their systems and thus to a reduction in their operation costs. In the 
baseline scenario, the average cost for software service providers for introducing the data into 
their systems is estimated at EUR 452 per year, per vessel (in 2022 prices)170. Considering the 
evolution  of  the  fleet  provided  in  section  2.2  of  Annex  4,  in  the  baseline  scenario  the  total 
costs for navigation software service providers for introducing the data into their systems are 
estimated at EUR 6.9 million in 2025, EUR 7.2 million in 2030 and EUR 7.3 million in 2050. 
According  to  feedback  provided  by  the  RIS  software  service  providers  during  the  second 
stakeholder survey171, PM1 would allow to reduce the average cost per vessel by 1% relative 
to the baseline (i.e. EUR 4.52 saved per vessel) from 2026 onwards. The recurrent adjustment 
costs savings for navigation  software service providers for 2030, 2040 and  2050, relative to 
the baseline, are provided in Table 25. Expressed as present value over 2025-2050, they are 
estimated at EUR 1.25 million relative to the baseline (in 2022 prices)172. 

Table  25:  Recurrent  adjustment  costs  savings  for  navigation  software  service  providers  due  to  PM1 
relative to the baseline (in EUR, in 2022 prices) 

Number of vessels 

Average  costs  savings  for  navigation  software  service 
providers per vessel (in EUR) 

2030 

2040 

2050 

15,838 

4.52 

15,996 

4.52 

16,131 

4.52 

169 Note that CESNI is financed by the Commission through a grant agreement. Therefore, these funds would be 
transferred  from  the  Commission  to  CESNI,  which  would  be  in  charge  of  the  actual  development  of  the 
guidelines.  
170  Ludden,  V.  et  al.,  (2020):  Study  supporting  the  evaluation  of  Directive  2005/44/EC  on  Harmonised  River 
Information Services  (RIS).  Ramboll,  University  of  Antwerp  and  DLA  Piper.  The  average  cost  in  the  study  is 
expressed in 2019 prices. For the purpose of this impact assessment, it has been transformed in 2022 prices using 
the  harmonised  consumer  price  index  for  Belgium  from  Eurostat  because  the  two  navigation  software  service 
providers that serve around 90% of the market are based in Belgium.  
171  The  feedback  has  been  provided  by  the  two  navigation  software  service  providers,  based  in  Belgium,  that 
serve around 90% of the market. 
172  Part  of  these  costs  savings  benefiting  software  provides  may  be  passed  through  to  the  vessel  operators, 
although it is not possible to assess the share of the costs savings passed through. 

106 

 
 
 
Adjustment  costs  savings  for  navigation  software  service 
providers (in EUR) 
Source: Ramboll et al. (2024), impact assessment support study  

Adjustment costs savings for vessel operators  

2030 

2040 

2050 

71,552 

72,266 

72,876 

The guidelines are also expected to benefit vessel operators by facilitating their trip planning. 
When travelling  across the management areas of several  RIS authorities, it  will be easier to 
compare  and  interpret  the  data.  In  the  baseline  scenario,  the  time  required  for  preparing  an 
international trip is estimated at 15 minutes, according to the survey undertaken in the context 
of this impact assessment.  Based on discussions with training institutes in inland navigation 
(and  validated  by  the  sector  in  the  targeted  workshop),  trip  preparation  time  is  expected  to 
decrease  by  2.5  minutes  relative  to  the  baseline  from  2026  onwards  thanks  to  PM1.  The 
recurrent adjustment costs savings for vessel operators are derived based on the time saved for 
the  preparation  of  a  trip,  the  labour  cost  per  hour  (EUR  26.7  per  hour173)  and  the  projected 
number  of  border  crossings,  and  are  provided  in  Table  26.  Expressed  as  present  value  over 
2025-2050, they are estimated at EUR 8.61 million relative to the baseline (in 2022 prices). 

Table 26: Recurrent adjustment costs savings for vessels operators due to PM1 relative to the baseline (in 
EUR, in 2022 prices) 

Number of border crossings per year 

Adjustment costs savings for vessel operators (in EUR) 

Source: Ramboll et al. (2024), impact assessment support study  

2030 

2040 

2050 

443,324 

493,057 

446,395 

496,472 

452,776 

503,570 

PM2: Introduce a harmonised complaint mechanism (in Member States)  

Under this  measure,  Member States  would need to  designate a (existing or new)  competent 
governmental  body  to  directly  handle  complaints  filed  by  RIS  users.  This  body  should  be 
independent from RIS related authorities and would have the role to verify the complaints and 
request corrective action (e.g. correct wrong, outdated or non-standardised data). This would 
improve the overall quality of data (by identifying for example mistakes in the databases), and 
point  to  areas  and  instances  where  RIS  users  believe  that  the  Directive  is  not  properly 
implemented.  Each  Member  State  will  be  responsible  for  addressing  problems  in  their 
waterways,  and  a  specific  provision  will  be  included  that  collaboration  with  neighbouring 
Member  States  should  be  undertaken  if  the  complaint  has  a  cross-border  element.  The 
functioning  of  this  mechanism  requires  that  each  Member  State  will  assign  appropriate 
resources depending on the expected number of complaints. 

Administrative costs for national public authorities 

Recurrent  administrative  costs  are  expected  due  to  PM2,  related  to  staff  for  managing  the 
complaints (e.g. sending them to the right person and coordinating the whole process). Based 
on  the  network  usage  (expressed  in  tonne-kilometres)  and  the  size  of  the  network  (i.e.  the 
number of entries in RIS index from EU-RIS portal is used as a proxy) in each Member State, 
and  using  as  reference  value  the  costs  for  the  Netherlands  (EUR  150,000)  provided  by  the 

173 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 

107 

 
 
 
 
Dutch  Ministry  of  Infrastructure  and  Water  Management  (Rijkswaterstaat),  the  recurrent 
administrative costs to run the complaint mechanisms for all 13 European RIS-authorities are 
estimated at EUR 0.92 million per year from 2026 onwards relative to the baseline (in 2022 
prices). Expressed as present value over 2025-2050, they are estimated at EUR 16.02 million 
relative to the baseline (in 2022 prices). 

Table  27:  Recurrent  administrative  costs  for  national  public  authorities  due  to  PM2  relative  to  the 
baseline (in EUR, in 2022 prices) 

Usage (projected billion tkm 
in 2025) 

Number of entries in RIS 
index from EU-RIS portal 

Administrative costs (in EUR) 

BE 
BG 
CZ 
DE 
FR 
HR 
LU 
HU 
NL 
AT 
PL* 
RO 
SK 
Total 
Source: Ramboll et al. (2024), impact assessment support study; Note: * estimated RIS index.  

18,279 
5,082 
4,704 
65,760 
120,623 
5,634 
412 
4,531 
29,184 
4,705 
2,235 
2,414 
2,056 
265,619 

11.5 
5.8 
0.0 
63.2 
7.9 
1.0 
0.3 
2.3 
51.9 
2.2 
0.1 
17.3 
1.0 
 164  

 63,624  
 21,370  
 12,135  
 260,217  
 321,363  
 15,969  
 1,437  
 14,958  
 150,000  
 15,215  
 5,896  
 31,126  
 6,672  
919,984 

Adjustment costs for national public authorities 

In addition, introducing a complaints procedure would involve one-off investment costs to set 
the  system.  Based  on  the  experience  of  EMSA  when  setting  up  the  e-certificate  registry174, 
these costs are estimated to be three times the recurrent annual costs for running the complaint 
mechanism or EUR 2.76 million in 2025. 

Adjustment cost savings for navigation software service providers 

The  introduction  of  a  complaints  mechanism  per  country  will  facilitate  the  communication 
between  navigation  software  service  providers  and  authorities  and  lead  to  time  savings  for 
navigation  software  service  providers.  For  instance,  navigation  software  service  providers 
often  struggle  to  find  the  appropriate  contact  within  RIS  authorities,  preventing  an  efficient 
exchange  of  information  when  they  identify  incorrect  data.  The  complaints  procedure  will 
lead  to  easier  contacts  with  authorities,  enabling  a  faster  (bottom  up)  handling  of  technical 
issues  in  the  provision  of  RIS  services  and  compliance  with  technical  specifications.  As 
explained under PM1, in the baseline scenario, the average cost for software service providers 
for  introducing  the  data  into  their  systems  is  estimated  at  EUR  452  per  year,  per  vessel  (in 
2022 prices)175. According to feedback provided by the RIS software service providers during 

174  European  Maritime  Safety  Agency  (EMSA).  European  Union.  Available  at:  https://european-
union.europa.eu/institutions-law-budget/institutions-and-bodies/institutions-and-bodies-profiles/emsa_en  
175  Ludden,  V.  et  al.,  (2020):  Study  supporting  the  evaluation  of  Directive  2005/44/EC  on  Harmonised  River 
Information Services  (RIS).  Ramboll,  University  of  Antwerp  and  DLA  Piper.  The  average  cost  in  the  study  is 
expressed in 2019 prices. For the purpose of this impact assessment, it has been transformed in 2022 prices using 

108 

 
 
 
 
the second stakeholder survey176, PM2 would allow to reduce the average cost per vessel by 
0.5%  relative  to  the  baseline  (i.e.  EUR  2.26  saved  per  vessel)  from  2026  onwards.  The 
recurrent  adjustment  costs  savings  for  navigation  software  service  providers  for  2030,  2040 
and 2050, relative to the baseline, are provided in Table 28. Expressed as present value over 
2025-2050, they are estimated at EUR 0.63 million relative to the baseline (in 2022 prices)177. 

Table  28:  Recurrent  adjustment  costs  savings  for  navigation  software  service  providers  due  to  PM2 
relative to the baseline (in EUR, in 2022 prices) 

Number of vessels 

Average  costs  savings  for  navigation  software  service 
providers per vessel (in EUR) 
Adjustment  costs  savings  for  navigation  software  service 
providers (in EUR) 
Source: Ramboll et al. (2024), impact assessment support study  

Adjustment cost savings for vessel operators 

2030 

2040 

2050 

15,838 

2.26 

15,996 

2.26 

16,131 

2.26 

35,776 

36,133 

36,438 

In addition, the filing of complaints by vessel operators is expected to lead to improvements 
in  RIS  data.  In  the  baseline  scenario  the  time  required  for  preparing  an  international  trip  is 
estimated  at  15  minutes  and  that  for  a  domestic  trip  at  10  minutes,  according  to  the  survey 
undertaken  in  the  context  of  this  impact  assessment.  Based  on  discussions  with  training 
institutes  in  inland  navigation  (and  validated  by  the  sector  in  the  targeted  workshop),  trip 
preparation time is expected to decrease by 8% due to PM2 (1.2 minutes for international trips 
and 0.8 minutes for domestic trips) relative to the baseline from 2026 onwards. The recurrent 
adjustment  costs  savings  for  vessel  operators  are  derived  based  on  the  time  saved  for  the 
preparation  of  a  trip,  the  labour  cost  per  hour  (EUR  26.7  per  hour178)  and  the  projected 
number  of  domestic  trips  and  border  crossings,  and  are  provided  in  Table  29.  Expressed  as 
present value over 2025-2050, they are estimated at EUR 6.16 million relative to the baseline 
(in 2022 prices).  

Table 29: Recurrent adjustment costs savings for vessels operators due to PM2 relative to the baseline (in 
EUR, in 2022 prices) 

Number of domestic trips per year 

Number of border crossings per year 

Adjustment costs savings for vessel operators (in EUR) 

Source: Ramboll et al. (2024), impact assessment support study  

2030 

2040 

2050 

286,557 

443,324 

352,763 

288,134 

446,395 

355,056 

292,030 

452,776 

360,048 

the  harmonised  consumer  price  index  for  Belgium  from  Eurostat  because  the  two  navigation  software  service 
providers that serve around 90% of the market are based in Belgium.  
176  The  feedback  has  been  provided  by  the  two  navigation  software  service  providers,  based  in  Belgium,  that 
serve around 90% of the market. 
177  Part  of  these  costs  savings  benefiting  software  provides  may  be  passed  through  to  the  vessel  operators, 
although it is not possible to assess the share of the costs savings passed through. 
178 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 

109 

 
 
 
 
Administrative cost savings for vessel operators 

Vessel  operators  that  may  lodge  a  complaint  would  benefit  of  administrative  costs  savings 
relative  to  the  baseline  due  to  the  use  of  a  structured  mechanism.  However,  these  costs 
savings are expected to be limited and are not further estimated. 

PM3: Introduce a new Performance Measurement Framework  

This measure aims to improve the monitoring of the implementation of the RIS Directive, by 
requiring Members States and relevant authorities to report to the Commission, on a regular 
basis,  on  key  performance  indicators  (e.g.  the  number  of  shipping  messages  issued  in 
accordance with standards and interpretations from the most recent RIS encoding guide, and 
the  number  of  electronic  cargo  reports  received  in  relation  to  the  number  of  voyages). This 
should partly address the issue of lack of available data identified by the evaluation. The key 
performance indicators will be developed by the European Commission with the assistance of 
CESNI.  Member  States  will  have  to  undertake  the  collection  of  the  required  data.  Having 
better  information,  the  European  Commission  will  be  able  to  follow  more  closely  the 
provision of RIS and identify cases where RIS implementation is fragmented. Based on this it 
will be  requesting the responsible Member State to  undertake corrective  action.  As a result, 
RIS users are expected benefit from improved harmonised RIS services.  

Adjustment costs for the European Commission  

Setting up the structure of the new performance measurement framework will be done in the 
context of the existing  working groups, for example CESNI and PIANC.  They will identify 
the data necessary for the new framework and set up the terms of reference. This task can be 
considered  within  the  mandate  of  those  working  groups  and,  therefore  will  not  lead  to 
additional costs relative to the baseline.  

Administrative costs for national public authorities 

National public authorities will face recurrent administrative costs to collect and process the 
data  and  report  it  to  the  Commission  on  an  annual  basis.  Based  on  two  interviews  with 
national authorities, it is estimated that each of the 13 Member States using inland waterways 
for commercial purposes would spend EUR 50,000 per year. Thus, total administrative costs 
for  national  public  authorities  are  estimated  at  EUR  650,000  per  year  from  2025  onwards. 
Expressed as present value over 2025-2050, they are estimated at EUR 11.97 million relative 
to the baseline.  

Adjustment cost savings for navigation software service providers 

The new Performance Measurement Framework will allow to monitor the implementation of 
the Directive  and, ultimately, collect  more  accurate information. As explained  above, in  the 
baseline scenario, the average cost for software service providers for introducing the data into 
their systems is estimated at EUR 452 per year, per vessel (in 2022 prices)179. According to 

179  Ludden,  V.  et  al.,  (2020):  Study  supporting  the  evaluation  of  Directive  2005/44/EC  on  Harmonised  River 
Information Services  (RIS).  Ramboll,  University  of  Antwerp  and  DLA  Piper.  The  average  cost  in  the  study  is 
expressed in 2019 prices. For the purpose of this impact assessment, it has been transformed in 2022 prices using 
the  harmonised  consumer  price  index  for  Belgium  from  Eurostat  because  the  two  navigation  software  service 
providers that serve around 90% of the market are based in Belgium.  

110 

 
 
feedback  provided  by  the  RIS  software  service  providers  during  the  second  stakeholder 
survey180,  PM3  would  allow  to  reduce  the  average  cost  per  vessel  by  0.25%  relative  to  the 
baseline (i.e. EUR 1.13 saved per vessel) from 2026 onwards. The recurrent adjustment costs 
savings  for  navigation  software  service  providers  for  2030,  2040  and  2050,  relative  to  the 
baseline,  are  provided  in  Table  30.  Expressed  as  present  value  over  2025-2050,  they  are 
estimated at EUR 0.31 million relative to the baseline (in 2022 prices)181. 

Table  30:  Recurrent  adjustment  costs  savings  for  navigation  software  service  providers  due  to  PM3 
relative to the baseline (in EUR, in 2022 prices) 

Number of vessels 

Average  costs  savings  for  navigation  software  service 
providers per vessel (in EUR) 
Adjustment  costs  savings  for  navigation  software  service 
providers (in EUR) 
Source: Ramboll et al. (2024), impact assessment support study  

Adjustment cost savings for vessel operators 

2030 

2040 

2050 

15,838 

1.13 

15,996 

1.13 

16,131 

1.13 

17,888 

18,066 

18,219 

The new Performance Measurement Framework will allow to monitor the implementation of 
the  Directive  and,  ultimately,  collect  more  accurate  information.  Consequently,  vessel 
operators  will  save  resources  when  preparing  their  journeys.  As  explained  above,  in  the 
baseline  scenario,  the  time  required  for  preparing  an  international  trip  is  estimated  at  15 
minutes and that for a domestic trip at 10 minutes, according to the survey undertaken in the 
context of this impact assessment. The vessel operators that responded to the survey estimated 
that the time spent on planning trips will decrease by 4% on average due to PM3 relative to 
the baseline (approximately 0.6 minutes for each international trip and  0.4 minutes for each 
domestic  trip)  from  2026  onwards.  The  recurrent  adjustment  costs  savings  for  vessel 
operators are derived based on the time saved for the preparation of a trip, the labour cost per 
hour (EUR 26.7 per hour182) and the projected number of domestic trips and border crossings 
and are provided in Table 31. Expressed as present value over 2025-2050, they are estimated 
at EUR 3.08 million relative to the baseline (in 2022 prices). 

Table 31: Recurrent adjustment costs savings for vessels operators due to PM3 relative to the baseline (in 
EUR, in 2022 prices) 

Number of domestic trips per year 

Number of border crossings per year 

Adjustment costs savings for vessel operators (in EUR) 

Source: Ramboll et al. (2024), impact assessment support study  

2030 

2040 

2050 

286,557 

443,324 

176,381 

288,134 

446,395 

177,528 

292,030 

452,776 

180,024 

180  The  feedback  has  been  provided  by  the  two  navigation  software  service  providers,  based  in  Belgium,  that 
serve around 90% of the market. 
181  Part  of  these  costs  savings  benefiting  software  provides  may  be  passed  through  to  the  vessel  operators, 
although it is not possible to assess the share of the costs savings passed through. 
182 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 

111 

 
 
 
 
PM4:  Strengthen  requirements  for  RIS 
specifications on data for navigation and voyage planning (RIS Index)  

technical  specifications  by  adding  new 

This measure aims to strengthen the requirements of Annex I of the current RIS Directive by 
introducing  new  technical  specifications  (‘standards’)  on  data  for  navigation  and  voyage 
planning (‘RIS Index’), and strengthen provisions under Article 4, paragraph 3, for the supply 
of such data by the Member States. This will improve the quality of the basic data provided in 
RIS and will  benefit in  particular skippers who  will have better  and up-to-date information, 
reducing the time needed to plan their voyage.  This measure also introduces new additional 
requirements  into  the  RIS  Directive  that  require  Member  States  to  ensure  that  information 
relating to the efficiency of navigation (e.g. current and expected waiting times at bridges and 
locks)  is  shared.  This  information  will  assist  vessel  operators  during  navigation.  Member 
States  will  need  to  undertake  digital  hardware  and  software  updates  in  order  to  provide  the 
required  information.  The  detailed  technical  specifications  that  will  be  required  will  be 
adopted  at  a  later  stage,  through  secondary  legislation.  This  measure  will  also  facilitate  the 
adoption of ‘smart shipping’183 systems for the automation of navigation. 

Adjustment costs for national public authorities 

To enable more efficient navigation a series of data including for instance clearance heights at 
bridges, information on fairway profiles and digitisation of vessel traffic signs will have to be 
collected.  Moreover,  the  system  should  also  include  information  on  the  real-time  traffic 
situation,  such  as  current  and  expected  waiting  times  at  locks.  Obtaining  and  sharing  these 
data requires investment in both digital hardware and software (to monitor and report on the 
information  mentioned  above).  Based  on  interviews  with  Rijkswaterstaat  this  measure  is 
estimated  to  lead  to  one-off  adjustment  costs  of  EUR  500,000  in  the  Netherlands  alone. 
Considering  each  country’s  share  of  the  network  in  terms  of  length  and  infrastructure 
elements  such  as  locks  and  bridges  (i.e.  using  as  proxy  the  number  of  entries  in  RIS  index 
from EU-RIS portal), these costs have been extrapolated for the other twelve Member States. 
For the 13 Member States, total one-off adjustment costs are estimated at EUR 4.55 million. 
The breakdown by Member State is provided in Table 32.  

Table 32: One-off adjustment costs for national public authorities due to PM4 relative to the baseline (in 
EUR, in 2022 prices) 

Number of entries in RIS index from EU-
RIS portal 

One-off adjustment costs (in EUR) 

BE 
BG 
CZ 
DE 
FR 
HR 
LU 
HU 

18,279 
5,082 
4,704 
65,760 
120,623 
5,634 
412 
4,531 

313,168 
87,068 
80,592 
1,126,645 
2,066,595 
96,525 
7,059 
77,628 

183  ‘Smart  shipping’  is  a  general  term  referring  to  different  technologies  to  facilitate  navigation.  CCNR  has 
classify  them  in  five  levels:  Level  1.Steering  assistance,  Level  2.Partial  automation  (steering  and  propulsion, 
designed  to  reduce  fuel  consumption),  Level  3.Conditional  automation  (including  collision  avoidance),  Level 
4.High  automation  (context-specific  automation  of  all  dynamic  navigation  tasks),  Level  5.Full  automation 
(unconditional  automation of all  dynamic  navigation  tasks).  In  addition,  Level  0 refers  to  no  automation  even 
when warning and intervention systems such as radars assist the helmsman. 

112 

 
 
 
Number of entries in RIS index from EU-
RIS portal 

One-off adjustment costs (in EUR) 

NL 
AT 
PL* 
RO 
SK 
Total 
Source: Ramboll et al. (2024), impact assessment support study; Note: * estimated RIS index.  

29,184 
4,705 
2,235 
2,414 
2,056 
265,619 

500,000 
80,609 
38,292 
41,358 
35,225 
4,550,764 

Administrative costs for national public authorities 

Both the hardware and software  used for the exchange of the collected  data  will  need to  be 
updated and maintained on a regular basis. The annual maintenance costs are assumed to be 
25% of the investment costs, based on the DINA study184. Thus, the recurrent administrative 
costs  for  national  public  authorities  are  estimated  at  EUR  1.14  million  per  year  from  2026 
onwards.  The  breakdown  by  Member  State  is  provided  in  Table  33.  Expressed  as  present 
value  over  2025-2050,  they  are  estimated  at  EUR  19.81  million  relative  to  the  baseline  (in 
2022 prices).  

Table  33:  Recurrent  administrative  costs  for  national  public  authorities  due  to  PM4  relative  to  the 
baseline (in EUR, in 2022 prices) 

Administrative costs (in EUR) 

BE 
BG 
CZ 
DE 
FR 
HR 
LU 
HU 
NL 
AT 
PL 
RO 
SK 
Total 
Source: Ramboll et al. (2024), impact assessment support study  

78,292 
21,767 
20,148 
281,661 
516,649 
24,131 
1,765 
19,407 
125,000 
20,152 
9,573 
10,340 
8,806 
1,137,691 

Adjustment cost savings for navigation software service providers 

Navigation software service providers are currently building their own smart software to offer 
added value to their customers. For instance, including more data via AIS stations at bridges 
on  waterways  with  variable  water  levels  (free  flowing  rivers)  can  improve  the  service.  As 
explained above, in the baseline scenario, the average cost for software service providers for 
introducing the data into their systems is estimated at EUR 452 per year, per vessel (in 2022 
prices)185. Based on feedback from software services providers in the context of stakeholders’ 

184 European Commission (2017): Digital inland waterway areas. Towards a digital inland waterway area and 
digital multimodal nodes. Final report. According to the study, the maintenance of digital tools e.g. as a result of 
service  level  agreements  and  license  fees,  represents  approximately  20%  of  the  initial  technology  investment. 
Another 5% is attributed to the governance of the required standards and the coordination of the implementation. 

113 

 
 
 
 
consultation,  PM4  would  allow  to  reduce  the  average  cost  per  vessel  by  2%  relative  to  the 
baseline (i.e. EUR 9.04 saved per vessel) from 2026 onwards. The recurrent adjustment costs 
savings  for  navigation  software  service  providers  for  2030,  2040  and  2050,  relative  to  the 
baseline,  are  provided  in  Table  34.  Expressed  as  present  value  over  2025-2050,  they  are 
estimated at EUR 2.5 million relative to the baseline (in 2022 prices)186.  

Table  34:  Recurrent  adjustment  costs  savings  for  navigation  software  service  providers  due  to  PM4 
relative to the baseline (in EUR, in 2022 prices) 

Number of vessels 

Average  costs  savings  for  navigation  software  service 
providers per vessel (in EUR) 
Adjustment  costs  savings  for  navigation  software  service 
providers (in EUR) 
Source: Ramboll et al. (2024), impact assessment support study  

Adjustment cost savings for vessel operators  

2030 

2040 

2050 

15,838 

9.04 

15,996 

9.04 

16,131 

9.04 

143,104 

144,532 

145,751 

PM4 would make new data available for vessel operators including longer and more accurate 
water  level  predictions,  current  and  predicted  underpass  heights  at  bridges  and  current  and 
predicted waiting  times at  locks.  Based on  feedback from vessel  operators  in  the context of 
the stakeholders’ consultation, the time needed for voyage planning can be reduced by 15% 
due to PM4 relative to the baseline. This corresponds to 1.5 minutes saved for each domestic 
voyage and 2.25 minutes saved for each international trip from 2026 onwards. The recurrent 
adjustment  costs  savings  for  vessel  operators  are  derived  based  on  the  time  saved  for  the 
preparation  of  a  trip,  the  labour  cost  per  hour  (EUR  26.7  per  hour187)  and  the  projected 
number of domestic voyages and border crossings and are provided in Table 35. Expressed as 
present  value  over  2025-2050,  they  are  estimated  at  EUR  11.09  million  relative  to  the 
baseline (in 2022 prices). 

Table 35: Recurrent adjustment costs savings for vessels operators due to PM4 relative to the baseline (in 
EUR, in 2022 prices) 

Number of domestic voyages 

Number of border crossings per year 

Adjustment costs savings for vessel operators (in EUR) 

Source: Ramboll et al. (2024), impact assessment support study  

PM5: Require electronic voyage plan reporting 

2030 

2040 

2050 

286,557 

443,324 

634,973 

288,134 

446,395 

639,100 

292,030 

452,776 

648,087 

While PM4 deals with information provided by the Member States to vessel operators, PM5 
focuses on requiring vessel operators and skippers to report their voyage plan  (ERIVOY) to 

185  Ludden,  V.  et  al.,  (2020):  Study  supporting  the  evaluation  of  Directive  2005/44/EC  on  Harmonised  River 
Information Services  (RIS).  Ramboll,  University  of  Antwerp  and  DLA  Piper.  The  average  cost  in  the  study  is 
expressed in 2019 prices. For the purpose of this impact assessment, it has been transformed in 2022 prices using 
the  harmonised  consumer  price  index  for  Belgium  from  Eurostat  because  the  two  navigation  software  service 
providers that serve around 90% of the market are based in Belgium.  
186  Part  of  these  costs  savings  benefiting  software  provides  may  be  passed  through  to  the  vessel  operators, 
although it is not possible to assess the share of the costs savings passed through. 
187 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 

114 

 
 
 
 
competent authorities at the start of their journey and update this with any further changes to 
their  estimated  time  of  arrival.  This  would  allow  authorities  to  provide  (more  accurate) 
feedback  on  estimated  waiting  times  at  locks  and  advised  navigation  speeds.  Optimising 
vessel  speed  would  lead  to  fuel  savings  and  thus  lower  emissions  and  operation  costs.  In 
addition,  inland  ports  and  traffic  managers  at  locks  and  bridges  can  better  channel  traffic, 
reducing delays and increasing efficiency.  

Adjustment costs for national public authorities 

The standards for ERIVOY messages have already been implemented by the software service 
providers. National public authorities would need to develop a software that can process and 
convert the voyage plan notification message (ERIVOY) from inland waterway operators into 
accurate  lock  predictions.  The  Dutch  Directorate  General  for  Public  Works  and  Water 
Management (Rijkswaterstaat) estimated the one-off investment costs for the development of 
such software at EUR 500,000. Based on the network usage (expressed in tonne-kilometres) 
and  the  size  of  the  network  (i.e.  the  number  of  entries  in  RIS  index  from  EU-RIS  portal  is 
used as a proxy) in each Member State, and using as reference value the investment costs for 
the  Netherlands  (EUR  500,000),  the  one-off  adjustment  costs  for  all  13  European  RIS-
authorities are estimated at EUR 3.07 million in 2025 relative to the baseline (in 2022 prices). 

Table 36: One-off adjustment costs for national public authorities due to PM5 relative to the baseline (in 
EUR, in 2022 prices) 

Usage (projected billion tkm 
in 2025) 

Number of entries in RIS 
index from EU-RIS portal 

One-off adjustment costs (in 
EUR) 

BE 
BG 
CZ 
DE 
FR 
HR 
LU 
HU 
NL 
AT 
PL* 
RO 
SK 
Total 
Source: Ramboll et al. (2024), impact assessment support study; Note: * estimated RIS index.  

18,279 
5,082 
4,704 
65,760 
120,623 
5,634 
412 
4,531 
29,184 
4,705 
2,235 
2,414 
2,056 
265,619 

11.5 
5.8 
0.0 
63.2 
7.9 
1.0 
0.3 
2.3 
51.9 
2.2 
0.1 
17.3 
1.0 
 164  

212,080 
71,235 
40,449 
867,391 
1,071,211 
53,230 
4,791 
49,860 
500,000 
50,717 
19,655 
103,755 
22,239 
3,066,613 

Administrative costs for national public authorities 

The implementation of a new software implies maintenance costs for software and hardware. 
The annual maintenance costs are assumed to be 25% of the investment  costs, based on the 
DINA  study188.  Thus,  the  recurrent  administrative  costs  for  national  public  authorities  are 
estimated at EUR 0.77 million per year from 2026 onwards. The breakdown by Member State 

188 European Commission (2017): Digital inland waterway areas. Towards a digital inland waterway area and 
digital multimodal nodes. Final report. According to the study, the maintenance of digital tools e.g. as a result of 
service  level  agreements  and  license  fees,  represents  approximately  20%  of  the  initial  technology  investment. 
Another 5% is attributed to the governance of the required standards and the coordination of the implementation. 

115 

 
 
 
is  provided  in  Table  37.  Expressed  as  present  value  over  2025-2050,  they  are  estimated  at 
EUR 13.35 million relative to the baseline (in 2022 prices).  

Table  37:  Recurrent  administrative  costs  for  national  public  authorities  due  to  PM5  relative  to  the 
baseline (in EUR, in 2022 prices) 

Administrative costs (in EUR) 

BE 
BG 
CZ 
DE 
FR 
HR 
LU 
HU 
NL 
AT 
PL 
RO 
SK 
Total 
Source: Ramboll et al. (2024), impact assessment support study  

Administrative costs for vessel operators 

53,020 
17,809 
10,112 
216,848 
267,803 
13,308 
1,198 
12,465 
125,000 
12,679 
4,914 
25,939 
5,560 
766,653 

The  mandatory  voyage  plan  reporting  for  inland  navigation  would  lead  to  recurrent 
administrative  costs  for  vessel  operators.  The  analysis  assumes  that  the  ERIVOY  messages 
would be added to the ERINOT messages189.  

Based on replies by inland skippers in the context of stakeholders’ consultation, preparing and 
communicating  a voyage plan will take 34 minutes for the first notification and 14 minutes 
for follow-up notifications. For freight IWT, the number of first notifications per year is equal 
to the projected number of voyages. For deriving the number of follow-up notifications, it is 
assumed  that  barges  are  deployed  an  average  of  5.5  days  per  week  and  the  average  voyage 
duration is 5 days. Hence, each voyage includes one loading day, three sailing days and one 
unloading day. This means that each voyage entails one initial notification and two follow-up 
notifications.  For  passenger  IWT,  similarly  to  freight,  the  number  of  first  notifications  per 
year  is  equal  to  the  projected  number  of  voyages.  For  calculating  the  number  of  follow-up 
notifications for passenger IWT, 214 sailing days per year have been assumed (April-October 
period).  The  number  of  initial  and  follow-up  notifications  for  freight  and  passenger  IWT  is 
provided in Table 38. The total recurrent administrative costs for vessel operators have been 
derived considering the labour cost per hour (EUR 26.7 per hour190), the number of initial and 
follow-up notifications and the time for preparing the first and follow-up notifications and are 
provided in Table 38. Expressed as present value over 2025-2050, they are estimated at EUR 

189 The electronic cargo report (ERINOT) report contains information on origin and destination of the voyage, 
the  amount  and  type  of  cargo  and  the  number  of  persons  on  board.  This  can  optionally  include  an  ETA  at 
destination. An ERIVOY message is much more comprehensive. 
190 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 

116 

 
 
 
367.5  million  (EUR  86.26  million  for  passenger  IWT  and  EUR  281.25  million  for  freight 
IWT). 

Table  38:  Recurrent  administrative  costs  for  vessels  operators  due  to  PM5  relative  to  the  baseline  (in 
EUR, in 2022 prices) 

Number of first notifications 

Passenger 
Freight 

Number of follow-up notifications 

Passenger 
Freight 

Recurrent administrative costs (in million 
EUR) 

Passenger 
Freight 

2025 
718,186 
11,567 
706,619 
1,377,507 
670,888 
706,619 

19.3 
4.3 
15.0 

2030 
729,880 
12,043 
717,838 
1,416,312 
698,475 
717,838 

19.7 
4.5 
15.3 

2040 
734,529 
12,940 
721,589 
1,472,098 
750,508 
721,589 

20.2 
4.8 
15.3 

2050 
744,806 
13,572 
731,234 
1,518,409 
787,175 
731,234 

20.6 
5.1 
15.5 

Source: Ramboll et al. (2024), impact assessment support study  

Adjustment costs savings for vessel operators 

Operation costs savings for vessel operators are expected due to PM5 through reduced speed 
of ships and less manoeuvring movements (e.g. braking the ship, mooring at waiting jetties, 
leaving and entering the lock). These savings are mainly related to the crossing of locks and 
adaptation of the speed in the proximity of a lock (i.e. the last hour). The adjustment of speed 
in the proximity of a lock (i.e. during the last hour) is estimated to lead to 5% savings in fuel 
consumption  relative  to  the  baseline  from  2026  onwards.  Based  on  statistics  for  the 
Netherlands, vessels cross on average 4 locks per trip. Also considering the total number of 
voyages and  a consumption  of  60  litres per hour of sailing,  savings  are estimated  at  around 
0.89% of total energy consumption. The energy savings in ktoe and the recurrent adjustment 
costs savings (fuel savings) relative to the baseline for 2030, 2040  and 2050 are provided in 
Table  39191.  Expressed  as  present  value  over  2025-2050  they  are  estimated  at  EUR  248.72 
million.  

Table 39: Recurrent adjustment costs savings for vessels operators due to PM5 relative to the baseline (in 
EUR, in 2022 prices) 

Energy savings (ktoe) 
Adjustment costs savings (million EUR) 
Source: Ramboll et al. (2024), impact assessment support study  

2030 
9.3 
15.0 

2040 
8.8 
14.4 

2050 
8.3 
15.2 

PM6: Introduce provisions for supplying data to the ERDMS and its operation 

Under this measure, Member States would  need to provide information required by the RIS 
Directive  to  the  European  Reference  Data  Management  System  (ERDMS),  which  contains 
regularly updated data necessary for the provision of RIS, and is owned and operated by the 
European  Commission  (DG  MOVE).  Integration  of  the  RIS-data  in  ERDMS  with  RIS 
COMEX is foreseen, and data should be aligned. This measure mostly affects RIS users and 
navigation  software  service  providers  and  would  make  it  easier  for  navigation  software 

191  The  projected  average  energy  prices  per  toe  from  the  baseline  scenario  developed  with  the  PRIMES-
TREMOVE model have been used to estimate the adjustment costs savings. These average  prices per toe take 
into account the projected development of the fuel mix, including biofuels, electricity and e-fuels.  

117 

 
  
  
 
service providers to collect the right data and pass it on to the industry. Member States will 
have to undertake efforts to ensure that the required information is provided and up-to-date.  

Administrative costs for national public authorities 

No  additional  investment  costs  are  expected  due  to  PM6  relative  to  the  baseline.  Member 
States  already  have  access  to  a  reference  database  containing  all  RIS  objects.  However,  the 
level of accuracy of this data vary across Member States.  

At  present,  there  are  no  obligations  regarding  reference  data.  Some  RIS  authorities  still 
provide  outdated  or  even  incorrect  data  about  objects  on  the  European  waterways  network. 
PM6 would require Member States to periodically update their data. Thus, PM6 is expected to 
lead  to  recurrent  administrative  costs  for  national  public  authorities  relative  to  the  baseline. 
Based  on  the  feedback  received  during  the  stakeholders’  consultation,  for  the  Netherlands 
PM6 is estimated to require additional 1.5 full time equivalents (FTE) relative to the baseline. 
This has been extrapolated to the other Member States based on the size of their network (i.e. 
the number of entries in RIS index from EU-RIS portal is used as a proxy) in relation to that 
of the Netherlands. Assuming 240 working days per year and 7.3 hours of work per day on 
average192, and using the tariff per hour for non-manual workers (ISCO 8 - Plant and machine 
operators  and  assemblers)  from  Eurostat  Structure  of  earnings  survey,  the  recurrent 
administrative costs for national public authorities are estimated at EUR 0.66 million per year 
relative to the baseline from 2025 onwards. Expressed as present value over 2025-2050, they 
are estimated at EUR 12.18 million. 

Table  40:  Recurrent  administrative  costs  for  national  public  authorities  due  to  PM6  relative  to  the 
baseline (in EUR, in 2022 prices) 

Number of entries in 
RIS index from EU-RIS 
portal 

Additional number of FTEs  

Administrative costs (in EUR) 

BE 
BG 
CZ 
DE 
FR 
HR 
LU 
HU 
NL 
AT 
PL* 
RO 
SK 
Total 
Source: Ramboll et al. (2024), impact assessment support study; Note: * estimated RIS index.  

18,279 
5,082 
4,704 
65,760 
120,623 
5,634 
412 
4,531 
29,184 
4,705 
2,235 
2,414 
2,056 
265,619 

0.94 
0.26 
0.24 
3.38 
6.20 
0.29 
0.02 
0.23 
1.50 
0.24 
0.11 
0.12 
0.11 

51,390 
2,123 
5,326 
175,907 
318,739 
4,537 
1,013 
3,578 
80,758 
12,505 
1,859 
1,574 
2,198 
661,507 

Adjustment cost savings for navigation software service providers 

Software service providers carry out quality checks on the data and correct erroneous data if 
necessary,  when  receiving  complaints.  Obliging  RIS  authorities  to  periodically  update  the 

192 Hours of work - annual statistics - Statistics Explained (europa.eu) 

118 

 
 
 
 
data, the number of errors is expected to decrease. This would also reduce the efforts required 
for  navigation  software  service  providers  to  obtain  correct  data.  As  explained  above,  in  the 
baseline scenario, the average cost for software service providers for introducing the data into 
their  systems  is  estimated  at  EUR  452  per  year,  per  vessel  (in  2022  prices)193.  Based  on 
feedback from software services providers in the context of stakeholders’ consultation, PM6 
would  allow  to  reduce  the  average  cost  per  vessel  by  2%  relative  to  the  baseline  (i.e.  EUR 
9.04  saved  per  vessel)  from  2026  onwards.  The  recurrent  adjustment  costs  savings  for 
navigation  software  service  providers  for  2030,  2040  and  2050,  relative  to  the  baseline,  are 
provided in Table 41. Expressed as present value over 2025-2050, they are estimated at EUR 
2.5 million relative to the baseline (in 2022 prices)194.  

Table  41:  Recurrent  adjustment  costs  savings  for  navigation  software  service  providers  due  to  PM6 
relative to the baseline (in EUR, in 2022 prices) 

Number of vessels 

Average  costs  savings  for  navigation  software  service 
providers per vessel (in EUR) 
Adjustment  costs  savings  for  navigation  software  service 
providers (in EUR) 
Source: Ramboll et al. (2024), impact assessment support study  

Adjustment cost savings for vessel operators  

2030 

2040 

2050 

15,838 

9.04 

15,996 

9.04 

16,131 

9.04 

143,104 

144,532 

145,751 

Based on feedback from vessel operators in the context of the stakeholders’ consultation, the 
time needed for voyage planning can be reduced by 20% due to PM6 relative to the baseline. 
This corresponds to 2 minutes saved for each domestic voyage and 3 minutes saved for each 
international  trip  from  2026  onwards.  The  recurrent  adjustment  costs  savings  for  vessel 
operators are derived based on the time saved for the preparation of a trip, the labour cost per 
hour (EUR 26.7 per hour195) and the projected number of domestic trips and border crossings, 
and are provided in Table 42. Expressed as present value over 2025-2050, they are estimated 
at EUR 14.79 million relative to the baseline (in 2022 prices). 

Table 42: Recurrent adjustment costs savings for vessels operators due to PM6 relative to the baseline (in 
EUR, in 2022 prices) 

Number of domestic voyages 

Number of border crossings per year 

Adjustment costs savings for vessel operators (in EUR) 

Source: Ramboll et al. (2024), impact assessment support study  

2030 

2040 

2050 

286,557 

443,324 

846,631 

288,134 

446,395 

852,133 

292,030 

452,776 

864,116 

193  Ludden,  V.  et  al.,  (2020):  Study  supporting  the  evaluation  of  Directive  2005/44/EC  on  Harmonised  River 
Information Services  (RIS).  Ramboll,  University  of  Antwerp  and  DLA  Piper.  The  average  cost  in  the  study  is 
expressed in 2019 prices. For the purpose of this impact assessment, it has been transformed in 2022 prices using 
the  harmonised  consumer  price  index  for  Belgium  from  Eurostat  because  the  two  navigation  software  service 
providers that serve around 90% of the market are based in Belgium.  
194  Part  of  these  costs  savings  benefiting  software  provides  may  be  passed  through  to  the  vessel  operators, 
although it is not possible to assess the share of the costs savings passed through. 
195 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 

119 

 
 
 
 
PM7: Encourage cargo-related information exchange through the eFTI mechanism  

This measure will require that technical specifications are developed so that RIS cargo related 
information  (i.e.  electronic  ship  reports  )  can  be  shared  on  a  voluntary  basis  through  the 
electronic freight transport information (eFTI) platforms. This includes both authority to ship 
and  authority  to  authority  information. The  standards  will  be  developed  but  not  made 
obligatory for use. The mandatory reporting requirements for specific ships would still apply 
(i.e.  ships  transporting  dangerous  goods).  The  Member  States  will  need  to  develop  the 
capacity to receive and process information through eFTI. 

Adjustment costs for national public authorities 

PM7  will  require  national  public  authorities  to  adapt  existing  data  flows  so  that  RIS  cargo-
related  information  is  linked  with  eFTI.  There  are  currently  five  systems  in  place:  BICS 
(Netherlands), eRIBa (Belgium), VELI (France), NAMIB (Germany), and CEERIS  (Rest of 
Europe). Based on feedback from RIS authorities, the investment costs for adjusting each of 
these  systems  are  estimated  at  EUR  250,000  per  system.  Thus,  the  total  one-off  adjustment 
costs are estimated at EUR 1.25 million in 2025 relative to the baseline.  

Administrative cost savings for vessel operators 

PM7  would  lead  to  recurrent  administrative  costs  savings  for  inland  shipping  skippers. 
Interviews with waterway managers during the stakeholders’ consultation have revealed that 
incorrect  reference information,  such as  regarding the loading/unloading  location, coding  of 
the cargo or hull information, is the cause of errors in data exchange. These errors force the 
skippers to re-register upon a border crossing. Repeated notifications are estimated to occur in 
20% of international trips in the Rhine catchment area and in all international trips (100%) in 
the Danube catchment area. Taking into account the number of trips in both catchment areas, 
it is estimated that 30% of all cross-border trips require repeated notifications. Based on the 
interviews and stakeholders’ survey, repeated notifications take around 15 minutes per vessel 
operator.  PM7  is  expected  to  reduce  the  share  of  repeated  notifications  by  10  percentage 
points relative to the baseline from 2026 onwards. Considering the labour cost per hour (EUR 
26.7 per hour196), the administrative cost savings for vessels operators due to PM7 relative to 
the baseline are provided in  Table 43. Expressed as present  value over  2025-2050, they are 
estimated at EUR 5.01 million relative to the baseline. 

Table 43: Recurrent administrative costs savings for vessels operators due to PM7 relative to the baseline 
(in EUR, in 2022 prices) 

Number of border crossings requiring repeated notifications in the 
baseline 
Reduction in the number of repeated notifications due to PM7 
relative to the baseline 
Administrative costs savings for vessel operators due to PM7 (in 
EUR) 

Source: Ramboll et al. (2024), impact assessment support study  

2030 
132,997 

2040 
133,918 

2050 
135,833 

44,332 

44,639 

45,278 

286,792 

288,778 

292,912 

196 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 

120 

 
  
 
Administrative cost savings for national public authorities 

The information exchange through the eFTI mechanism leads to the replacement of the paper 
cargo  reports  with  the  electronic  reports.  The  number  of  paper  cargo  reports  is  assumed  to 
grow  in  line  with  the  transport  activity  in  the  baseline  scenario.  According  to  the  estimates 
provided  by  the  Dutch  authorities  during  the  interviews,  a  total  elimination  of  the  paper 
reports would lead to a reduction in the effort required equivalent to  8 full time equivalents 
(FTE) relative to the baseline. Considering the voluntary system in PM7, a 50% reduction in 
the  paper  cargo  reports  is  assumed,  equivalent  to  4  FTEs  saved  relative  to  the  baseline  in 
2026.  This  is  extrapolated  to  the  other  Member  States  based  on  their  respective  transport 
activity (expressed in tkm) relative to that of the Netherlands. In addition, the growth in the 
number of paper cargo reports over time is  also  taken into account. Assuming 240 working 
days per year and 7.3 hours of work per day on average197, and using the tariff per hour for 
non-manual  workers  (ISCO  8  -  Plant  and  machine  operators  and  assemblers)  from  Eurostat 
Structure  of  earnings  survey,  the  recurrent  administrative  costs  savings  for  national  public 
authorities  are  provided  in  Table  44.  Expressed  as  present  value  over  2025-2050,  they  are 
estimated at EUR 11.45 million relative to the baseline.  

Table 44: Recurrent administrative costs savings for national public authorities due to PM7 relative to the 
baseline (in EUR, in 2022 prices) 

BE 
BG 
CZ 
DE 
FR 
HR 
LU 
HU 
NL 
AT 
PL 
RO 
SK 
Total 
Source: Ramboll et al. (2024), impact assessment support study  

2030 
51,247 
3,926 
60 
277,928 
32,572 
1,341 
997 
2,965 
222,516 
9,523 
183 
18,712 
1,596 
623,566 

2040 
56,765 
4,522 
72 
305,078 
33,811 
1,590 
1,214 
3,655 
238,676 
10,068 
261 
20,591 
1,716 
678,018 

2050 
60,735 
4,933 
82 
338,957 
34,329 
1,751 
1,315 
3,988 
254,861 
10,229 
293 
22,821 
1,825 
736,120 

PM8: Mandate cargo-related information to be exchange through the eFTI mechanism  

This measure goes beyond PM7 in that it will mandate that all RIS cargo related information 
(i.e.  electronic  ship  reports  )  are  shared  through  the  electronic  freight  transport  information 
(eFTI)  platforms,  for  exchanges  between  authority  /  authority  and  authority  /  ship.  This 
should  lead  to  higher  benefits  than  PM7  as  more  vessel  operators  will  report  cargo 
information in this way. 

Adjustment costs for national public authorities 

PM8  will  require  national  public  authorities  to  adapt  existing  data  flows so  that  RIS  cargo-
related  information  is  linked  with  eFTI.  There  are  currently  five  systems  in  place:  BICS 

197 Hours of work - annual statistics - Statistics Explained (europa.eu) 

121 

 
 
 
(Netherlands), eRIBa (Belgium), VELI (France), NAMIB (Germany), and CEERIS (Rest of 
Europe). Based on feedback from RIS authorities, the investment costs for adjusting each of 
these  systems  are  estimated  at  EUR  250,000  per  system.  Thus,  the  total  one-off  adjustment 
costs are estimated at EUR 1.25 million in 2025 relative to the baseline.  

Administrative cost savings for vessel operators 

Similarly,  to  PM7,  PM8  would  lead  to  recurrent  administrative  costs  savings  for  inland 
shipping skippers. Interviews with waterway managers during the stakeholders’ consultation 
have  revealed  that  incorrect  reference  information,  such  as  regarding  the  loading/unloading 
location,  coding  of  the  cargo  or  hull  information,  is  the  cause  of  errors  in  data  exchange. 
These errors  force the skippers  to  re-register upon a border crossing.  Repeated notifications 
are  estimated  to  occur  in  20%  of  international  trips  in  the  Rhine  catchment  area  and  in  all 
international trips (100%) in the Danube catchment area. Taking into account the number of 
trips in both catchment areas, it is estimated that 30% of all cross-border trips require repeated 
notifications.  Based  on  the  interviews  and  stakeholders’  survey,  repeated  notifications  take 
around  15  minutes  per  vessel  operator.  PM8  is  expected  to  reduce  the  share  of  repeated 
notifications by 20 percentage points relative to the baseline from 2026 onwards. Considering 
the labour cost  per hour  (EUR 26.7 per hour198), the administrative  cost  savings for vessels 
operators due to PM8 relative to the baseline are provided in Table 45. Expressed as present 
value over 2025-2050, they are estimated at EUR 10.01 million relative to the baseline.  

Table 45: Recurrent administrative costs savings for vessels operators due to PM8 relative to the baseline 
(in EUR, in 2022 prices) 

Number of border crossings requiring repeated notifications in the 
baseline 
Reduction in the number of repeated notifications due to PM8 
relative to the baseline 
Administrative costs savings for vessel operators due to PM8 (in 
EUR) 

Source: Ramboll et al. (2024), impact assessment support study  

2030 
132,997 

2040 
133,918 

2050 
135,833 

88,617 

89,230 

90,506 

573,281 

577,246 

585,501 

For the purpose of the application of the ‘one in, one out’ approach, the average reduction in 
the  number  of  repeated  notifications  over  2026-2035  has  been  estimated  at  88,397  per  year 
relative  to  the  baseline  and  the  average  costs  saved  per  repeated  notification  at  EUR  6.5. 
Thus,  the  average  annual  administrative  costs  savings  for  vessel  operators  are  estimated  at 
EUR 0.57 million relative to the baseline.  

Administrative cost savings for national public authorities 

As explained for PM7, the introduction of the exchange of information will reduce the need to 
handle  paper  cargo  reports.  Making  it  compulsory  will  fully  eliminate  the  paper  reports. 
According  to  the  estimates  provided  by  the  Dutch  authorities  during  the  interviews,  a  total 
elimination  of  the  paper  reports  would  lead  to  a  reduction  in  the  effort  equivalent  to  8  full 
time  equivalents  (FTE)  relative  to  the  baseline  in  2026.  This  is  extrapolated  to  the  other 
Member States based on their respective transport activity (expressed in tkm) relative to that 

198 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 

122 

 
  
 
of the Netherlands. In addition, the growth in the number of paper cargo reports over time is 
also taken into account. Assuming 240 working days per year and 7.3 hours of work per day 
on  average199,  and  using  the  tariff  per  hour  for  non-manual  workers  (ISCO  8  -  Plant  and 
machine operators and assemblers) from Eurostat Structure of earnings survey, the recurrent 
administrative  costs  savings  for  national  public  authorities  are  provided  in  Table  46. 
Expressed as present value over 2025-2050, they are estimated at EUR 22.89 million relative 
to the baseline.  

Table 46: Recurrent administrative costs savings for national public authorities due to PM8 relative to the 
baseline (in EUR, in 2022 prices) 

BE 
BG 
CZ 
DE 
FR 
HR 
LU 
HU 
NL 
AT 
PL 
RO 
SK 
Total 
Source: Ramboll et al. (2024), impact assessment support study  

2030 
102,495 
7,852 
121 
555,856 
65,143 
2,683 
1,994 
5,929 
445,031 
19,046 
366 
37,424 
3,192 
1,247,133 

2040 
113,529 
9,043 
144 
610,155 
67,622 
3,181 
2,428 
7,309 
477,352 
20,137 
522 
41,182 
3,431 
1,356,036 

PM9: Require information exchange through a RIS platform  

2050 
121,470 
9,866 
165 
677,913 
68,658 
3,503 
2,630 
7,976 
509,722 
20,458 
587 
45,643 
3,650 
1,472,240 

This  measure  envisages  the  use  of  a  single  digital  platform  for  the  exchange  of  RIS 
information.  Given  the  existence  of  RIS  COMEX  and  to  avoid  duplication  of  efforts,  this 
measure  would  require  Member  States  to  exchange  information  through  the  RIS  COMEX 
platform. RIS COMEX was a CEF funded multi-beneficiary project aiming at the definition, 
specification, implementation and sustainable operation of Corridor RIS Services. Following 
the  project  conclusion  in  2022,  the  13  participating  Member  States200  of  the  connected 
European  Inland  Waterway  Network  and  their  authorities  continue  the  use  of  the  system 
under  a  separate  European  Corridor  Management  Agreement201.  The  result  of  the  RIS 
COMEX project is thus currently used on a voluntary basis by the Member States that apply 
RIS,  as  a  one  stop  shop  of  exchange  of  data.  For  example,  through  the  EuRIS  -  European 
River  Information  Services  platform  (www.eurisportal.eu)  waterway  users  can  plan  their 
travel  and  arrival  times  across  Europe  in  one  environment,  without  the  need  to  consult 
numerous websites and information sources (especially when crossing borders). The project is 
entering  a  second  phase  (RIS  COMEX  2)  as  in  June  2023  it  was  selected  for  CEF  funding 
with Poland joining as a partner. This indicates the interest of the Member States to continue 
with this platform as a basis for RIS. RIS COMEX 2 shall continue the work of the first stage 

199 Hours of work - annual statistics - Statistics Explained (europa.eu) 
200  The  current  partnership  consists  of  the  following  countries:  Austria,  Belgium,  Bulgaria,  Croatia,  Czechia 
France, Germany, Hungary, Luxembourg, the Netherlands, Romania, Serbia and Slovakia. 
201 The agreement defines the governance structure, financing, sharing of costs, and other elements such as the 
"Partnership Coordinator" who manages the platform. 

123 

 
 
 
(RIS  COMEX)  by  extending  the  quantity  and  quality  of  the  related  services  and  provided 
data,  by  extending  the  geographical  scope  to  additional  waterways  and  even  to  additional 
countries  (Poland),  as  well  as  by  focusing  on  interconnections  and  integrations  of  existing 
systems and services.  

PM9 will mandate the use of RIS COMEX202, ensuring that a common structure is in place - 
one  where  all  additional  functionalities  will  be  built  upon.  In  this  respect,  PM9  will  be  the 
basic element for implementing the exchange of RIS information and works in combination 
with other measures of this initiative (e.g. PM4, PM6, PM8, PM12, PM14). By mandating the 
use  of  RIS  COMEX,  efficient  use  of  EU  funds  is  ensured,  as  the  development  was  already 
supported  under  CEF,  and  duplication  of  efforts  (e.g.  by  developing  another  system)  is 
avoided.  

Adjustment costs for national public authorities 

One-off investment costs for national public authorities are expected due to PM9. They cover 
those  countries  that  were  not  part  of  the  initial  RIS  COMEX  project  (e.g.  Italy,  Spain, 
Portugal)  and  who  will  need  to  develop  the  necessary  digital  applications.  They  also  cover 
elements  in  RIS  COMEX  that  will  need  to  be  updated/completed  (for  example,  the  inland 
waters  of  a  maritime  character  in  Germany  are  missing).  The  one-off  adjustment  costs  for 
national public authorities are estimated at EUR 3.5 million in 2025 relative to the baseline. 

Administrative costs savings for national public authorities 

The ultimate aim of PM9 is to replace the national platforms that currently coexist. This can 
only happen if the functionality of RIS COMEX is equivalent to that of the national platforms 
and  can  also  serve  a  broader  purpose,  such  as  providing  information  on  waterways 
exclusively  navigable  for  recreational  navigation.  When  this  is  achieved,  it  is  expected  that 
the  existing  national  platforms  would  be  phased  out.  PM9  would  thus  lead  to  recurrent 
administrative  costs  savings  estimated  at  EUR  500,000  per  year  from  2030  onwards. 
Expressed as present value over 2025-2050, they are estimated at EUR 7.71 million relative to 
the baseline.  

Adjustment cost savings for navigation software service providers 

Using RIS COMEX as a central platform will benefit navigation software providers, as they 
can  obtain  information  from  a  central  place,  instead  of  referring  to  various  individual 
platforms of the European RIS authorities. As explained above, in the baseline scenario, the 
average  cost  for  software  service  providers  for  introducing  the  data  into  their  systems  is 
estimated  at  EUR  452  per  year,  per  vessel  (in  2022  prices)203.  Based  on  feedback  from 
software services providers in the context of stakeholders’ consultation, PM9 would allow to 
reduce  the  average  cost  per  vessel  by  1%  relative  to  the  baseline  (i.e.  EUR  4.52  saved  per 
vessel)  from  2026  onwards.  The  recurrent  adjustment  costs  savings  for  navigation  software 

202 While RIS COMEX has resulted in different applications, this measure uses the term RIS COMEX to refer to 
the overall results of the project as applied by the EU Member States. 
203  Ludden,  V.  et  al.,  (2020):  Study  supporting  the  evaluation  of  Directive  2005/44/EC  on  Harmonised  River 
Information Services  (RIS).  Ramboll,  University  of  Antwerp  and  DLA  Piper.  The  average  cost  in  the  study  is 
expressed in 2019 prices. For the purpose of this impact assessment, it has been transformed in 2022 prices using 
the  harmonised  consumer  price  index  for  Belgium  from  Eurostat  because  the  two  navigation  software  service 
providers that serve around 90% of the market are based in Belgium.  

124 

 
 
service providers for 2030, 2040 and 2050, relative to the baseline, are provided in Table 47. 
Expressed as present value over 2025-2050, they are estimated at EUR 1.25 million relative to 
the baseline (in 2022 prices)204.  

Table  47:  Recurrent  adjustment  costs  savings  for  navigation  software  service  providers  due  to  PM9 
relative to the baseline (in EUR, in 2022 prices) 

Number of vessels 

Average  costs  savings  for  navigation  software  service 
providers per vessel (in EUR) 
Adjustment  costs  savings  for  navigation  software  service 
providers (in EUR) 
Source: Ramboll et al. (2024), impact assessment support study  

Adjustment cost savings for vessel operators 

2030 

2040 

2050 

15,838 

4.52 

15,996 

4.52 

16,131 

4.52 

71,552 

72,266 

72,876 

PM9 is expected to lead to significant recurrent adjustment costs savings for vessel operators 
for  voyage  planning.  While  several  national  RIS  portals  had  to  be  consulted  by  a  vessel 
operator  for  voyage  planning  in  the  baseline,  all  relevant  information  is  now  offered  by  a 
single portal within RIS COMEX (EuRIS portal). In the baseline scenario the time required 
for preparing an international trip is estimated at 15 minutes. In PM9, a 50% reduction in the 
time  required  for  preparing  an  international  voyage  is  assumed  (7.5  minutes)  from  2026 
onwards relative to  the  baseline, based on stakeholders’ feedback.  The  recurrent  adjustment 
costs savings for vessel operators are derived based on the time saved for the preparation of a 
trip,  the  labour  cost  per  hour  (EUR  26.7  per  hour205)  and  the  projected  number  of  border 
crossings and are provided in Table 48. Expressed as present value over 2025-2050, they are 
estimated at EUR 37.16 million relative to the baseline (in 2022 prices).  

Table 48: Recurrent adjustment costs savings for vessels operators due to PM9 relative to the baseline (in 
million EUR, in 2022 prices) 

Number of border crossings per year 

Adjustment  costs  savings  for  vessel  operators  (in  million 
EUR) 
Source: Ramboll et al. (2024), impact assessment support study  

Administrative cost savings for vessel operators 

2030 

2040 

2050 

443,324 

446,395 

452,776 

1.48 

1.49 

1.51 

CEERIS  was  developed  under  the  RIS  COMEX  banner.  This  tool  should  enable  vessel 
operators on the Danube to benefit of a one-stop-shop application for electronic reporting of 
cargo  and  voyage  data.  When  the  use  of  RIS  COMEX,  including  thus  the  CEERIS  tool, 
becomes  mandatory,  vessel  operators  on  the  Danube  will  benefit  from  a  single  electronic 
notification  of  cargo  data.  Based  on  the  interviews  and  stakeholders’  survey,  repeated 
notifications take around 15 minutes per vessel operator. PM9 is expected to reduce the share 
of repeated notifications by 8 percentage points relative to the baseline from 2026 onwards. 

204  Part  of  these  costs  savings  benefiting  software  provides  may  be  passed  through  to  the  vessel  operators, 
although it is not possible to assess the share of the costs savings passed through. 
205 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 

125 

 
 
 
 
Considering the labour cost per hour (EUR 26.7 per hour206), the administrative cost savings 
for vessels operators due to PM9 relative to the baseline are provided in Table 49. Expressed 
as  present  value  over  2025-2050,  they  are  estimated  at  EUR  3.9  million  relative  to  the 
baseline.  

Table 49: Recurrent administrative costs savings for vessels operators due to PM9 relative to the baseline 
(in EUR, in 2022 prices) 

Number of border crossings requiring repeated notifications in the 
baseline 
Reduction in the number of repeated notifications due to PM9 
relative to the baseline 
Administrative costs savings for vessel operators due to PM9 (in 
EUR) 

Source: Ramboll et al. (2024), impact assessment support study  

2030 
132,997 

2040 
133,918 

2050 
135,833 

34,534 

34,773 

35,271 

223,407 

224,953 

228,175 

For the purpose of the application of the ‘one in, one out’ approach, the average reduction in 
the  number  of  repeated  notifications  over  2026-2035  has  been  estimated  at  34,448  per  year 
relative  to  the  baseline  and  the  average  costs  saved  per  repeated  notification  at  EUR  6.5. 
Thus,  the  average  annual  administrative  costs  savings  for  vessel  operators  are  estimated  at 
EUR 0.22 million relative to the baseline.  

PM10: Involve CESNI in the development and adoption of technical specifications  

To ensure faster development of technical specifications, this measure will designate CESNI 
(the European Committee for drawing up standards  in  the  field  of inland  navigation) as the 
relevant  body  for  developing  RIS  related  technical  specifications. CESNI  has  already  been 
designated  in  this  role  in  Directive  (EU)  2016/1629  on  Technical  Requirements  for  inland 
waterway  vessels  and  Directive  (EU)  2017/2397  on  professional  qualifications  in  inland 
navigation. 

Adjustment costs for national public authorities / European Commission 

There  is  already  a  CESNI  working  group  responsible  for  RIS  technical  specifications. 
Therefore,  PM10  can  be  understood  as  formalising  a  mandate  to  CESNI207  for  the 
development  of  the  technical  specifications.  In  this  context,  this  is  a  task  that  can  be 
considered within the mandate of the working group and, therefore it is not expected to lead 
to additional costs relative to the baseline even if the work programme should be adapted.  

Adjustment cost savings for vessel operators 

Vessel operators might benefit from faster application of technical specifications fostered by 
stronger engagement of CESNI. This is, however, hard to quantify and the magnitude of the 
effect is expected to be limited.  

206 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 
207  Note  that  CESNI  is  financed  by  the  Commission  through  a  grant  agreement.  Therefore,  the  funds  are 
transferred from the Commission to CESNI. 

126 

 
  
 
PM11: Link the RIS requirements with those of the TEN-T Regulation  

This  measure  would  seek  at  aligning  the  scope  of  the  RIS  Directive  with  the  scope  of  the 
TEN-T  Regulation.  Currently,  all  interconnected  waterways  of  CEMT  class  IV  and  higher 
(which refers to the size of the vessel they can accommodate) are within the scope of the RIS 
Directive. Member States may decide to include further waterways in this scope (for example 
Italy,  Spain  and  Portugal).  This  scope  does  not  match  the  TEN-T  network,  which  with  its 
current proposed revision will not refer any more to CEMT classification but will be based on 
the characteristics of the waterways themselves.  

Under PM11,  the scope  of the RIS Directive is aligned with  that of the  TEN-T Regulation, 
which corresponds to the waterways of international importance. The waterways currently in 
the scope of the RIS Directive have a length of 14,400 km while the waterways under TEN-T 
have  a  length  of  13,000  km.  As  a  consequence,  up  to  1,400  km  of  waterways  would 
potentially not be covered by the RIS provisions. Under this measure, Member States would 
still be able to voluntarily extend the RIS requirements to other parts of their network beyond 
what is in the TEN-T network.  

The majority of these waterways appear to be in the Netherlands, which already applies RIS. 
During  the  interviews  the  Dutch  authorities  indicated  that  they  already  now  compile 
information outside the scope of the current RIS Directive. As the majority of the 1,400 km 
that would fall out of scope of the new Directive are within the Netherlands, it is assumed that 
they  will  remain  in  the  network  on  a  voluntary  basis.  Furthermore,  given  the  international 
nature of IWT traffic, it is unlikely that a vessel operator operating in the Dutch network will 
not (even partly) enter waterways covered under RIS, and would thus be confronted with the 
requirements of the Directive. Moreover, for waterways that are currently voluntarily in RIS 
(e.g. in Italy, Spain and Portugal) and are currently in the TEN-T network, their participation 
will become obligatory.  

Therefore, it is assumed that the change of scope brought  by this measure will not lead to a 
net change in the kilometres coverage, and thus no further economic impacts are considered. 

PM12:  Develop  new  technical  specifications  for  the  exchange  of  information  related  to 
IWT ports 

Data related to ports is not easily available to vessel operators (for example, the dimensions of 
bridges over port basins and operating times). This is the case even in RIS COMEX, where 
for example port basins along the German Rhine are missing (this includes important ports for 
inland  navigation  such  as  Duisburg,  Dusseldorf,  Neuss,  Mannheim  and  Karlsruhe).  As  this 
information  is  missing,  skippers  have  to  look  up  the  required  information  independently  on 
port  authority  websites.  This  leads  to  extra  time  for  voyage  preparations.  In  addition, 
information is not exchanged with the ports. Thus, the ports do not always have the vessels' 
cargo and voyage information and this information has to be reported again at the ports.  

The  aim  of  this  measure  is  to  develop  new  technical  specifications  for  the  exchange  of 
information  to  and  from  IWT  ports.  These  technical  specifications  will  be  developed  by 
CESNI and be introduced through a secondary legislation at a later stage. PM12 will provide 
real  time  information  for  transhipment  capacity,  berths,  etc.  It  will  also  provide  real  time 
information  on  the  availability  of  alternative  fuels  (at  least  the  infrastructure  that  the 

127 

 
Alternative  Fuels  Infrastructure  Regulation208  requires),  which  might  increase  the  uptake  of 
clean  technologies  by  vessels  and  the  utilisation  of  the  infrastructure  in  the  ports209.  In 
addition, port infrastructure will be better mapped in many areas where it is currently labelled 
as empty or as “caution areas” on maps. Overall, PM12 would lead to better data quality for 
all, leading to simpler travel planning. Under PM12, data exchange with IWT ports would be 
voluntary, but if RIS users do share data, the technical specifications will need to be applied. 

Adjustments costs for national public authorities (ports) 

While  vessel  operators  would  be  able  to  use  this  feature  on  a  voluntary  basis  through  RIS, 
implementation of the new technical specifications and technical specifications at port level is 
required for making it possible. It was assumed that all 54 core ports of the European TEN-T 
network for which no RIS data is available would implement the new technical specifications. 
The DINA study210 estimates at EUR 25,000 the investment cost per port (in 2017 prices) for 
developing information systems. This is equivalent to EUR 29,197 in 2022 prices. Applying 
this cost to the 54 ports, the total one-off adjustment costs for national public authorities are 
estimated at EUR 1.58 million relative to the baseline (in 2022 prices). 

Administrative costs for national public authorities (ports) 

Once  the  systems  are  established,  national  authorities  are  expected  to  incur  recurrent 
administrative costs for managing and maintaining the data. According to the DINA study211 
these represent around 25% of the one-off investment costs212. Thus, the administrative costs 
for national authorities are estimated at EUR 394,159 per year from 2026 onwards relative to 
the  baseline.  Expressed  as  present  value  over  2025-2050,  they  are  estimated  at  EUR  6.86 
million relative to the baseline (in 2022 prices). 

Adjustment costs savings for navigation software services providers 

Navigation software services providers currently encounter lots of difficulties to collect data 
on  inland  ports.  If  all  inland  ports  provided  reference  data  and  keep  this  data  updated,  this 
would  lead  to  time  savings  for  navigation  software  suppliers.  As  explained  above,  in  the 
baseline scenario, the average cost for software service providers for introducing the data into 
their  systems  is  estimated  at  EUR  452  per  year,  per  vessel  (in  2022  prices)213.  Based  on 
feedback from software services providers in the context of stakeholders’ consultation, PM12 

208 Regulation (EU) 2023/1804. 
209 To be noted that AFIR provides a minimum requirement for inland ports in the TEN-T Network to invest in 
on-shore  power  supply  connection.  Such  ports  may  decide  to  provide  infrastructure  beyond  these  minimum 
requirements. 
210  European  Commission  (2017),  Digital  inland  waterway  areas. Towards  a  digital  inland  waterway  area  and 
digital multimodal nodes. Final report. 
211  European  Commission  (2017),  Digital  inland  waterway  areas. Towards  a  digital  inland  waterway  area  and 
digital multimodal nodes. Final report. 
212 According to the study, the maintenance of digital tools e.g. as a result of service level agreements and license 
fees,  represents  approximately  20%  of  the  initial  technology  investment.  Another  5%  is  attributed  to  the 
governance of the required standards and the coordination of the implementation. 
213  Ludden,  V.  et  al.,  (2020):  Study  supporting  the  evaluation  of  Directive  2005/44/EC  on  Harmonised  River 
Information Services  (RIS).  Ramboll,  University  of  Antwerp  and  DLA  Piper.  The  average  cost  in  the  study  is 
expressed in 2019 prices. For the purpose of this impact assessment, it has been transformed in 2022 prices using 
the  harmonised  consumer  price  index  for  Belgium  from  Eurostat  because  the  two  navigation  software  service 
providers that serve around 90% of the market are based in Belgium.  

128 

 
 
would allow to reduce the average cost per vessel by 0.75% relative to the baseline (i.e. EUR 
3.39  saved  per  vessel)  from  2026  onwards.  The  recurrent  adjustment  costs  savings  for 
navigation  software  service  providers  for  2030,  2040  and  2050,  relative  to  the  baseline,  are 
provided in Table 50. Expressed as present value over 2025-2050, they are estimated at EUR 
0.94 million relative to the baseline (in 2022 prices)214.  

Table  50:  Recurrent  adjustment  costs  savings  for  navigation  software  service  providers  due  to  PM12 
relative to the baseline (in EUR, in 2022 prices) 

Number of vessels 
Average  costs  savings  for  navigation  software  service 
providers per vessel (in EUR) 
Adjustment  costs  savings  for  navigation  software  service 
providers (in EUR) 
Source: Ramboll et al. (2024), impact assessment support study  

Adjustment costs savings for vessel operators 

2030 

2040 

2050 

15,838 
3.39 

15,996 
3.39 

16,131 
3.39 

53,664 

54,199 

54,657 

For trip preparation, an average of 5 minutes per port call is assumed in the baseline. In the 
process, important information should be retrieved, such as how deep the port is in relation to 
the depth  of the channel, as well as where berths are and where loading/unloading can take 
place.  Other  relevant  questions  are  whether  there  is  shore  power  available  in  the  port  and 
whether  the  vessel  can  be  turned  around  in  the  port.  Finally,  other  relevant  questions  are 
whether bridges in the harbour need to be considered, how high they are when closed and if 
the bridges can be opened, how these openings can be requested and what the operating times 
are. This wide amount of information is difficult to obtain now.  

The  new  technical  specification  and  specification  about  ports  will  facilitate  the  voyage 
preparation  and  planning  for  the  ports’  section.  Given  that  there  are  54  core  network  ports 
(along the Rhine and Danube) for which data is not yet provided (out of a total of 262 ports) 
and  considering  that  half  of  the  trips  start/end  in  a  port,  PM12  could  reduce  the  time  for 
voyage  planning  by  21%  per  port  call  (1  minute  saved)  relative  to  the  baseline  from  2026 
onwards. Considering the labour cost per hour (EUR 26.7 per hour215), the adjustment costs 
savings for vessels operators due to PM12 relative to the baseline are provided in Table 51. 
Expressed as present value over 2025-2050, they are estimated at EUR 2.92 million relative to 
the baseline.  

Table 51: Recurrent adjustment costs savings for vessels operators due to PM12 relative to the baseline (in 
EUR, in 2022 prices) 

Number of port calls 
Adjustment costs savings for vessel operators (in EUR) 
Source: Ramboll et al. (2024), impact assessment support study  

2030 
364,940 
167,309 

2040 
367,264 
168,375 

2050 
372,403 
170,731 

214  Part  of  these  costs  savings  benefiting  software  provides  may  be  passed  through  to  the  vessel  operators, 
although it is not possible to assess the share of the costs savings passed through. 
215 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 

129 

 
 
  
 
 
 
Administrative costs savings for vessel operators 

Currently, (electronic) cargo reports are not passed on to inland ports. This means that vessel 
operators  have  to  report  again  when  entering  a  port.  PM12  would  remove  the  need  of 
reporting  again  to  the  ports.  If  ports  would  start  applying  these  standards,  reports  could  be 
forwarded, and part of the administrative burden could be alleviated.  

Administrative costs savings are expected for  all 83216 core TEN-T network ports. The time 
for preparing and (re)submitting the reports is estimated at 10 minutes in the baseline. Taking 
into  account  that  half  of  the  trips  start/end  in  a  port,  PM12  could  reduce  the  number  of 
resubmitted cargo reports by 31% relative to the baseline from 2026 onwards. Considering the 
labour  cost  per  hour  (EUR  26.7  per  hour217),  the  administrative  costs  savings  for  vessels 
operators due to PM12 relative to the baseline are provided in Table 52. Expressed as present 
value over 2025-2050, they are estimated at EUR 8.88 million relative to the baseline.  

Table 52: Recurrent administrative costs savings for vessels operators due to PM12 relative to the baseline 
(in EUR, in 2022 prices) 

Reduction in the number of resubmitted cargo reports due to PM12 
relative to the baseline  
Administrative costs savings for vessel operators due to PM12 (in 
EUR) 
Source: Ramboll et al. (2024), impact assessment support study  

2030 
114,302 

2040 
115,030 

2050 
116,639 

508,499 

511,738 

518,898 

For the purpose of the application of the ‘one in, one out’ approach, the average reduction in 
the number of resubmitted cargo reports over 2026-2035 has been  estimated at  114,006 per 
year relative to the baseline and the average costs saved per resubmission at EUR 4.4. Thus, 
the average annual administrative costs savings for vessel operators are estimated at EUR 0.5 
million relative to the baseline.  

PM13:  Require  the  exchange  of  information  with  IWT  ports  according  to  new  technical 
specifications 

In  contrast  to  PM12,  where  the  exchange  of  information  is  voluntary,  this  measure  will 
require  that  the  exchange  of  certain  data  (transhipment  capacity,  availability  of  alternative 
fuels,  availability  of  berths,  etc.)  between  vessels  and  IWT  ports  uses  the  new  technical 
specification. These will be developed through a secondary legislation. 

Adjustment costs for national public authorities (ports) 

In PM13, both core and comprehensive ports of the TEN-T network will have to implement 
the  technical  specifications.  In  total,  there  are  54  core  TEN-T  network  ports  and  115 
comprehensive TEN-T network ports for which no RIS data is available. The DINA study218 
estimates  at  EUR  25,000  the  investment  cost  per  port  (in  2017  prices)  for  developing 

216 This goes beyond the 54 ports that do not provide data. It is assumed that the core inland ports, due to their 
importance will be the ones to voluntarily take up this measure.  
217 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 
218  European  Commission  (2017),  Digital  inland  waterway  areas. Towards  a  digital  inland  waterway  area  and 
digital multimodal nodes. Final report. 

130 

 
  
 
information systems. This is equivalent to EUR 29,197 in 2022 prices. Applying this cost to 
the 169 ports, the total one-off adjustment costs for national public authorities are estimated at 
EUR 4.93 million relative to the baseline (in 2022 prices). 

Administrative costs for national public authorities (ports) 

Once  the  systems  are  established,  national  authorities  are  expected  to  incur  recurrent 
administrative costs for managing and maintaining the data. According to the DINA study219 
these represent around 25% of the one-off investment costs220. Thus, the administrative costs 
for  national  authorities  are  estimated  at  EUR  1.23  million  per  year  from  2026  onwards 
relative  to  the  baseline.  Expressed  as  present  value  over  2025-2050,  they  are  estimated  at 
EUR 21.48 million relative to the baseline (in 2022 prices). 

Adjustment cost savings for navigation software service providers 

As in PM12, if all inland ports provided reference data and keep this data updated, this would 
lead  to  time  savings  for  navigation  software  suppliers.  Based  on  feedback  received  in  the 
context  of  stakeholders’  consultation,  the  mandatory  provision  of  reference  data  by  all  182 
inland ports of the comprehensive  TEN-T network, in  addition to  the 83 core TEN-T ports, 
would allow to reduce the average cost per vessel by 1.25% relative to the baseline (i.e. EUR 
5.65 saved per vessel) from 2026 onwards. As explained above, in the baseline scenario, the 
average  cost  for  software  service  providers  for  introducing  the  data  into  their  systems  is 
estimated at EUR 452 per year, per vessel (in 2022 prices)221. The recurrent adjustment costs 
savings  for  navigation  software  service  providers  for  2030,  2040  and  2050,  relative  to  the 
baseline,  are  provided  in  Table  53.  Expressed  as  present  value  over  2025-2050,  they  are 
estimated at EUR 1.56 million relative to the baseline (in 2022 prices)222.  

Table  53:  Recurrent  adjustment  costs  savings  for  navigation  software  service  providers  due  to  PM13 
relative to the baseline (in EUR, in 2022 prices) 

Number of vessels 
Average  costs  savings  for  navigation  software  service 
providers per vessel (in EUR) 
Adjustment  costs  savings  for  navigation  software  service 
providers (in EUR) 
Source: Ramboll et al. (2024), impact assessment support study  

2030 

2040 

2050 

15,838 
5.65 

15,996 
5.65 

16,131 
5.65 

89,440 

90,332 

91,095 

219  European  Commission  (2017),  Digital  inland  waterway  areas. Towards  a  digital  inland  waterway  area  and 
digital multimodal nodes. Final report. 
220 According to the study, the maintenance of digital tools e.g. as a result of service level agreements and license 
fees,  represents  approximately  20%  of  the  initial  technology  investment.  Another  5%  is  attributed  to  the 
governance of the required standards and the coordination of the implementation. 
221  Ludden,  V.  et  al.,  (2020):  Study  supporting  the  evaluation  of  Directive  2005/44/EC  on  Harmonised  River 
Information Services  (RIS).  Ramboll,  University  of  Antwerp  and  DLA  Piper.  The  average  cost  in  the  study  is 
expressed in 2019 prices. For the purpose of this impact assessment, it has been transformed in 2022 prices using 
the  harmonised  consumer  price  index  for  Belgium  from  Eurostat  because  the  two  navigation  software  service 
providers that serve around 90% of the market are based in Belgium.  
222  Part  of  these  costs  savings  benefiting  software  provides  may  be  passed  through  to  the  vessel  operators, 
although it is not possible to assess the share of the costs savings passed through. 

131 

 
 
 
 
 
Adjustment cost savings for vessel operators 

PM13 is expected to lead to recurrent adjustment costs savings for vessel operators for the trip 
preparation.  In  the  baseline,  an  average  of  5  minutes  per  port  call  is  assumed  for  trip 
preparation for the ports’ section. There are currently 262 ports in the TEN-T network (core 
plus comprehensive network). A total of 93 inland ports already provide RIS data while 169 
inland  ports  do  not  provide  RIS  data  (54  from  the  core  network  and  115  from  the 
comprehensive  network).  Under  PM13,  all  those  169  inland  ports  will  have  to  report  RIS 
data. Given that half of the trips start/end in a port, PM13 could reduce the time for voyage 
planning by 65% per port call (3.2 minutes saved) relative to the baseline from 2026 onwards. 
Considering the labour cost per hour (EUR 26.7 per hour223), the adjustment costs savings for 
vessels operators due to PM13 relative to the baseline are provided in Table 54. Expressed as 
present value over 2025-2050, they are estimated at EUR 9.14 million relative to the baseline.  

Table 54: Recurrent adjustment costs savings for vessels operators due to PM13 relative to the baseline (in 
EUR, in 2022 prices) 

Number of port calls 
Adjustment costs savings for vessel operators (in EUR) 
Source: Ramboll et al. (2024), impact assessment support study  

Administrative cost savings for vessel operators 

2030 
364,940 
523,616 

2040 
367,264 
526,951 

2050 
372,403 
534,324 

Under PM13, all 262 inland ports from the core and comprehensive TEN-T network will be 
automatically receiving the (electronic) cargo reports and therefore, vessel operators will not 
have  to  resubmit  them.  Considering  the  labour  cost  per  hour  (EUR  26.7  per  hour224),  the 
administrative  costs  savings  for  vessels  operators  due  to  PM13  relative  to  the  baseline  are 
provided in Table 55. Expressed as present value over 2025-2050, they are estimated at EUR 
28.35 million relative to the baseline.  

Table 55: Recurrent administrative costs savings for vessels operators due to PM13 relative to the baseline 
(in EUR, in 2022 prices) 

Reduction in the number of resubmitted cargo reports due to PM13 
relative to the baseline  
Administrative costs savings for vessel operators due to PM13 (in 
EUR) 
Source: Ramboll et al. (2024), impact assessment support study  

2030 
364,940 

2040 
367,264 

2050 
372,403 

1,623,521 

1,633,861 

1,656,721 

For the purpose of the application of the ‘one in, one out’ approach, the average reduction in 
the number of resubmitted cargo reports over 2026-2035 has been  estimated at  363,996 per 
year relative to the baseline and the average costs saved per resubmission at EUR 4.4. Thus, 
the average annual administrative costs savings for vessel operators are estimated at EUR 1.6 
million relative to the baseline.  

223 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 
224 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 

132 

 
  
  
 
PM14:  Improve  the  harmonisation  between  RIS  and  the  information  services  for  other 
modes of transport (e.g. maritime)  

Currently  the  RIS  Directive  envisages  continuity  with  other  modal  traffic  management 
services,  in  particular  with  maritime.  However,  no  further  details  are  included,  or  technical 
specifications  have  been  developed  along  these  lines.  Therefore,  this  measure  aims  to 
strengthen the interoperability of RIS with other modes of transport. To do so, this measure 
does not aim to create new or duplicate existing systems, but will include a clear requirement 
in  the  Directive  to  create  links  with  systems  of  other  modes  like  EMSWe225.  In  addition,  a 
common  data  exchange  mechanism  (such  as  application  programming  interfaces)  should  be 
developed to  enable both systems  to  access  the  data functionality  of one another.  Technical 
specifications  to  implement  these  links  and  ensure  compatibility  between  systems  will  be 
developed at a second stage through CESNI and introduced through secondary legislation.  

Adjustment costs for national public authorities 

IT investments by the national public authorities will be needed to integrate RIS information 
systems with information systems of other modes. The IT investment costs are assumed to be 
similar  to  that  of  the  CoRISma  project226.  Expressed  in  2022  prices,  the  one-off  adjustment 
costs for the national public authorities are estimated at EUR 3.14 million.  

Administrative costs for national public authorities 

The annual maintenance costs are assumed to be 25% of the IT investment costs, based on the 
DINA  study227.  Thus,  the  recurrent  administrative  costs  for  national  public  authorities  are 
estimated at EUR 0.79 million per year from 2026 onwards. Expressed as present value over 
2025-2050, they are estimated at EUR 13.68 million. 

Adjustment cost savings for navigation software service providers  

PM14 will result into maritime charts (ECDIS) and inland charts (Inland ECDIS) being better 
aligned  and  thus  to  time  savings  for  software  service  providers.  As  explained  above,  in  the 
baseline scenario the average cost for software service providers for introducing the data into 
their systems is estimated at EUR 452 per year, per vessel (in 2022 prices)228. According to 
feedback  provided  by  the  RIS  software  service  providers  during  the  second  stakeholder 

225 European Maritime Single Window environment, established by Regulation (EU) 2019/1239. 
226 CoRISMa was a TEN-T project running between January 2014 and December 2015. CoRISma studied and 
defined the next steps in the development of River Information Services: RIS enabled Corridor Management on 
inland waterways aiming at mutually sharing information services among waterway authorities but also sharing 
those with waterway users and logistic partners in order to optimise the use of inland navigation corridors within 
the  network  of  European  waterways.  The  European  Commission  contributed  EUR  1,083,204  to  the  CoRISma 
project with a co-financing rate of 41% (expressed in 2014 prices). 
227 European Commission (2017): Digital inland waterway areas. Towards a digital inland waterway area and 
digital multimodal nodes. Final report. According to the study, the maintenance of digital tools e.g. as a result of 
service  level  agreements  and  license  fees,  represents  approximately  20%  of  the  initial  technology  investment. 
Another 5% is attributed to the governance of the required standards and the coordination of the implementation. 
228  Ludden,  V.  et  al.,  (2020):  Study  supporting  the  evaluation  of  Directive  2005/44/EC  on  Harmonised  River 
Information Services  (RIS).  Ramboll,  University  of  Antwerp  and  DLA  Piper.  The  average  cost  in  the  study  is 
expressed in 2019 prices. For the purpose of this impact assessment, it has been transformed in 2022 prices using 
the  harmonised  consumer  price  index  for  Belgium  from  Eurostat  because  the  two  navigation  software  service 
providers that serve around 90% of the market are based in Belgium.  

133 

 
 
survey229, PM14 would allow to reduce the average cost per vessel by 0.25% relative to the 
baseline (i.e. EUR 1.13 saved per vessel) from 2026 onwards. The recurrent adjustment costs 
savings  for  navigation  software  service  providers  for  2030,  2040  and  2050,  relative  to  the 
baseline,  are  provided  in  Table  56.  Expressed  as  present  value  over  2025-2050,  they  are 
estimated at EUR 0.31 million relative to the baseline (in 2022 prices)230. 

Table  56:  Recurrent  adjustment  costs  savings  for  navigation  software  service  providers  due  to  PM14 
relative to the baseline (in EUR, in 2022 prices) 

Number of vessels 

Average  costs  savings  for  navigation  software  service 
providers per vessel (in EUR) 
Adjustment  costs  savings  for  navigation  software  service 
providers (in EUR) 
Source: Ramboll et al. (2024), impact assessment support study  

2030 

2040 

2050 

15,838 

1.13 

15,996 

1.13 

16,131 

1.13 

17,888 

18,066 

18,219 

PM15:  Require  sharing  of  all  necessary  cross-border  data  for  traffic  management  and 
transport management by Member States 

Currently  not  all  information  provided  by  vessel  operators  to  authorities  is  shared  with  the 
authorities  of  other  Member  States,  which  creates  a  challenge  when  crossing  borders  as  in 
many  cases  the  information  needs  to  be  retransmitted.  As  an  illustrative  example,  cargo 
reports are not always transmitted to the next country in the journey, which then is not aware 
that a vessel with dangerous cargo is approaching its area. For example, this does not happen 
at  the  borders  between  the  Netherlands  and  Wallonia,  France  and  Wallonia,  France  and 
Luxembourg,  Austria  and  Germany,  and  all  other  borders  in  the  Danube  area  except  of  the 
Austrian-Slovakian border.  

This  measure  would  require  Member  States  to  share  cross-border  all  necessary  data  that  is 
required  for  traffic  and  transport  management.  This  includes  for  example  information 
provided by vessel operators regarding the cargo, the position of the vessel, ERI information, 
but  also  the  exchange  of  information  between  authorities  such  as  changes  in  the  navigation 
parameters,  limitations  of  traffic,  speed,  etc.  This  way  PM15  aims  at  facilitating  the 
international exchange of RIS-related data making the planning of journeys more accurate and 
faster.  Under  this  measure,  all  the  data  authorities  require  would  be  submitted  once  the 
journey starts and then re-shared by the authorities, as well as information generated during 
the journey.  

This  measure  does  not  deal  with  exchanges  not  made  due  to  personal  data  concerns,  while 
they are handled by measures PM16 and PM17. 

Adjustment costs for national public authorities 

The one-off adjustment costs (i.e. investment costs to develop the necessary digital tools that 
will allow the exchange between the national authorities) for national public authorities due to 

229  The  feedback  has  been  provided  by  the  two  navigation  software  service  providers,  based  in  Belgium,  that 
serve around 90% of the market. 
230  Part  of  these  costs  savings  benefiting  software  provides  may  be  passed  through  to  the  vessel  operators, 
although it is not possible to assess the share of the costs savings passed through. 

134 

 
 
 
PM15 are estimated at EUR 5 million in 2025 relative to the baseline. The estimate is based 
on comparable projects in the rail freight sector (ELETA and its successor EDICT231).  

Administrative cost savings for national public authorities 

PM15  is  expected  to  reduce  the  staff  required  at  borders.  Based  on  different  sources 
summarised in Table 57, it has been estimated that around 87,420 vessels cross borders where 
a control in established. Based on the interviews during the stakeholders’ consultation, border 
officers spend on average 5 minutes for these controls on each side of the border. Considering 
the labour cost per hour (EUR 26.7 per hour232), the administrative costs savings for national 
public authorities are estimated at EUR 388,908 per year  from 2026 onwards relative to the 
baseline. Expressed as present value over 2025-2050, they are estimated at EUR 6.77 million 
relative to the baseline (in 2022 prices). 

Table 57: Border crossings and controls 

Border 

Location 

Source 

 Number 
of vessels 

Lanaye 
French border, Meuse 
French border, Escaut 
Grevenmacher lock 
Aschach lock 
Gabcikovo lock 

NL <-> BE 
BE <-> FR 
BE <-> FR 
FR <-> LU 
DE <-> AT 
SK <-> HU 
HU <-> HR 
HR <-> RS 
RS <-> RO 
DE <-> CZ 
DE <-> PL 
Total 
Source: Ramboll et al. (2024), Impact assessment support study 

Iron Gate I 
Locks Usti Nad Labem 
Schiffshebewerk Niederfinow 

Voies Hydrauliques Wallone233 
Voies Hydrauliques Wallone 
Voies Hydrauliques Wallone 
Lu Stat234 
Statistic.at235 
Common Danube Report 2018236 

Common Danube Report 2018 
Idnes.cz237 
Verkehrsbericht 2021238 

 13,718  
 1,040  
 7,555  
 4,828  
 3,939  
 13,361  
 13,361  
 13,361  
 13,363  
 1,000  
 1,894  
87,420 

231  ELETA:  Electronic  Exchange  of  ETA  Information;  EDICT:  Enhanced  Data  Interoperability  for  Combined 
Transport Stakeholders 
232 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 
233 http://voies-
hydrauliques.wallonie.be/opencms/opencms/fr/nav/navstat/navstat.do?path=tr&per=2022&vn=21&val=N&displ
ay=T&pas=A&col=CLA  
234 
https://lustat.statec.lu/vis?lc=en&fs[0]=Topics%2C1%7CEnterprises%23D%23%7CTransport%23D6%23&fs[1
]=Topics%2C2%7CEnterprises%23D%23%7CTransport%23D6%23%7CMaritime%20and%20fluvial%20trans
port%23D63%23&pg=0&fc=Topics&df[ds]=ds-
release&df[id]=DF_D6401&df[ag]=LU1&df[vs]=1.0&pd=2015%2C&dq=.A.&ly[rw]=SPECIFICATION%2C
DIRECTION&ly[cl]=TIME_PERIOD  
235 https://www.statistik.at/en/statistics/tourism-and-transport/freight-transport/freight-transport-on-inland-
waterways 
236 http://www.plovput.rs/file/danube-stream/common-danube-report-2018.pdf 
237 https://www.idnes.cz/bydleni/architektura/strekov.A120322_110822_architektura_web 
238 
https://www.gdws.wsv.bund.de/SharedDocs/Downloads/DE/Verkehrsberichte/Verkehrsbericht_2021.pdf?__blo
b=publicationFile&v=4 

135 

 
 
 
 
 
 
 
 
 
Administrative cost savings for vessel operators 

PM15  (included  in  POC)  will  eliminate  the  need  for  vessel  operators  to  resubmit  the 
electronic  cargo  reports  for  border  crossing  where  this  is  still  required  (i.e.  in  30%  of  the 
border  crossings  in  the  baseline).  Vessel  operators  would  only  have  to  report  their  voyage 
once  to  a  RIS  authority,  which  then  automatically  transfers  the  voyage  report  to  other  RIS 
authorities when the vessel enters the management area of the subsequent authority. However, 
considering the synergies with PM8 and PM9 (both included in POC), PM15 is expected to 
reduce the share of repeated notifications by 2 percentage points relative to the baseline from 
2026  onwards239.  Based  on  the  interviews  and  stakeholders’  survey,  repeated  notifications 
take around 15 minutes per vessel operator. Considering the labour cost per hour (EUR 26.7 
per hour240), the administrative cost savings for vessels operators due to PM15 relative to the 
baseline  are  provided  in  Table  58.  Expressed  as  present  value  over  2025-2050,  they  are 
estimated at EUR 1.11 million relative to the baseline.  

Table 58: Recurrent administrative costs savings for vessels operators due to PM15 relative to the baseline 
(in EUR, in 2022 prices) 

Number of border crossings requiring repeated notifications in the 
baseline 
Reduction in the number of repeated notifications due to PM15 
(considering the synergies with PM8 and PM9) relative to the 
baseline 
Administrative costs savings for vessel operators due to PM15 (in 
EUR) 

Source: Ramboll et al. (2024), impact assessment support study  

2030 
132,997 

2040 
133,918 

2050 
135,833 

9,846 

9,914 

10,056 

63,696 

64,136 

65,054 

PM16: Specify more clearly the cases for exchange of personal data   

Currently the main challenge regarding the personal data in RIS relates to the information on 
the  position  of  the  vessel  through  AIS  (Automatic  Identification  System).  As  explained  in 
problem driver 5, vessel operators (in particular SMEs) who also reside in the vessel, consider 
that  information  regarding  the  position  should  be  considered  personal  data.  Due  to  these 
concerns, and as it is not always clear on which basis the data is being processed and whether 
this  is  allowed,  authorities  are  reluctant  to  process  and  transmit  positioning  information  to 
other authorities. This in turn leads to resubmission of the information by the vessel operators 
to different national authorities or refusal to share information. 

Under this measure, the RIS Directive would provide more  clarity on the specific cases and 
legal basis where exchange of personal data would be justified (e.g. for reasons of safety, to 
streamline  the  process,  etc.).  This  would  provide  legal  clarity  both  for  Member  States  and 
other  stakeholders,  and  thus  allow  a  reduction  in  the  number  of  resubmissions.  The 
expectation is that if it is made clear in which cases AIS data can and cannot be shared, the 

239 As explained, in the baseline  scenario 30% of the border crossings require to resubmit the electronic cargo 
reports. PM8 reduces the share of repeated notifications by 20 percentage points relative to the baseline and PM9 
by another 8 percentage points. Therefore, the elimination of the need to resubmit the electronic cargo reports in 
PM15  (in  combination  with  PM8  and  PM9)  leads  to  a  reduction  in  the  share  of  repeated  notifications  by  2 
percentage points relative to the baseline.  
240 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 

136 

 
  
 
procedure  for  collecting  port  charges  will  become  simpler.  Barges  will  no  longer  have  to 
report  in  ports,  authorities  will  have  to  make  less  effort  to  identify  vessels.  Therefore, 
economic impacts are assessed for these two categories of stakeholders. 

This  measure  is  designed  to  work  in  complementarity  with  PM12,  PM13  and  PM15  as  it 
covers a specific case (personal data) that they do not. 

Adjustment costs for national public authorities (ports) 

For PM16 to be implemented, all TEN-T inland ports would have to develop an application 
where the position of the vessel  through AIS  can be used for port-related matters, such as 
berth  management  and  collection  of  port  fees241.  The  investment  costs  for  such  an 
application  are  estimated  at  EUR  5,839  per  port  (in  2022  prices)  as  identified  in  DINA 
study242. The total one-off adjustments costs for all 265 ports are thus estimated at EUR 1.55 
million in 2025 relative to the baseline. 

Administrative costs for national public authorities (ports) 

PM16 is also expected to lead to recurrent administrative costs for managing and maintaining 
the systems. Based on the DINA study they are assumed to be 25% of the investment costs, or 
EUR 1,460 per port. Thus, total recurrent administrative costs are estimated at EUR 386,860 
per year relative to  the baseline  from  2026 onwards. Expressed as present  value over 2025-
2050, they are estimated at EUR 6.74 million relative to the baseline.  

Administrative costs savings for vessel operators 

Making clear in which cases AIS data can and cannot be shared, the procedure for collecting 
port  charges  would  become  simpler.  Barges  would  no  longer  have  to  report  in  ports  and 
authorities would have to make less effort to identify vessels. Currently, there are 120 ports in 
Europe where port dues are levied, mainly located in the Netherlands and some on the Rhine 
and  Danube.  It  is  estimated  that  if  the  cases  for  data-sharing  would  be  better  clarified  the 
number of resubmitted reports to ports would decrease by 20% relative to the baseline from 
2026  onwards.  Considering  the  labour  cost  per  hour  (EUR  26.7  per  hour243),  the 
administrative  costs  savings  for  vessels  operators  due  to  PM16  relative  to  the  baseline  are 
provided in Table 59. Expressed as present value over 2025-2050, they are estimated at EUR 
5.67 million relative to the baseline.  

Table 59: Recurrent administrative costs savings for vessels operators due to PM16 relative to the baseline 
(in EUR, in 2022 prices) 

Number of port calls 
Reduction in the resubmission of electronic cargo reports to ports 
relative to the baseline  

2030 
364,940 
72,988 

2040 
367,264 
73,453 

2050 
372,403 
74,481 

241  This  application  is  considered  as  separate/has  other  functionality  to  those  under  PM12 and  PM13,  as  these 
last ones do not consider AIS among the information to be shared. 
242 European Commission (2017): Digital inland waterway areas. Towards a digital inland waterway area and 
digital multimodal nodes. Final report. 
243 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 

137 

 
  
 
Administrative costs savings for vessel operators due to PM16 (in 
EUR) 
Source: Ramboll et al. (2024), impact assessment support study  

2030 
324,704 

2040 
326,772 

2050 
331,344 

For the purpose of the application of the ‘one in, one out’ approach, the average reduction in 
the  number  of  resubmitted  cargo  reports  over  2026-2035  has  been  estimated  at  72,799  per 
year relative to the baseline and the average costs saved per resubmission at EUR 4.4. Thus, 
the  average  annual  administrative  costs  savings  for  vessel  operators  are  estimated  at  EUR 
0.32 million relative to the baseline.  

PM17: Develop templates and standards for the exchange of personal data 

This  measure  will  develop  and  mandate  new  standards  and  technical  specifications  for  the 
exchange  of  personal  information  when  this  is  required  by  national  or  international 
legislation.  This  measure  goes  beyond  measure  16,  in  that  it  will  not  only  clarify  the  cases 
when personal data can be exchanged, but will define the exact templates and standards to be 
followed when such an exchange can take place, in line with existing legal provisions. It will 
thus provide a further step of harmonisation. It would also provide information on why this is 
proportionate (i.e. on what is aimed to be achieved) and why it is the least intrusive way to 
exchange personal data to achieve its goals). 

Adjustment costs for national public authorities (ports) 

For PM17 to be implemented, all TEN-T inland ports would have to develop an application 
where  the  position  of  the  vessel  through  AIS  can  be  used  for  port-related  matters,  such  as 
berth management and collection of port fees244. The application would need to additionally 
accommodate  harmonised  features  (e.g.  templates  and  standards  to  be  followed)  relative  to 
PM16. The investment costs for such an application are estimated at EUR 10,219 per port (in 
2022  prices)  as  identified  in  DINA  study245.  The  total  one-off  adjustments  costs  for  all  265 
ports are thus estimated at EUR 2.71 million in 2025 relative to the baseline. 

Administrative costs for national public authorities (ports) 

PM17 is also expected to lead to recurrent administrative costs for managing and maintaining 
the systems. Based on the DINA study they are assumed to be 25% of the investment costs, or 
EUR 2,555 per port. Thus, total recurrent administrative costs are estimated at EUR 677,005 
per year relative to  the baseline  from  2026 onwards. Expressed as present  value over 2025-
2050, they are estimated at EUR 11.79 million relative to the baseline.  

Administrative cost savings for vessel operators 

By clarifying instances when AIS data can and cannot be shared, the procedure for collecting 
port charges would become simpler.  In Europe, port dues are levied in 120 ports, which are 
primarily  located  in  the  Netherlands,  but  some  also  along  the  Rhine  and  Danube.  It  is 
estimated that if the cases for data-sharing would be better clarified the number of resubmitted 

244  This  application  is  considered  as  separate/has  other  functionality  to  those  under  PM12 and  PM13,  as  these 
last ones do not consider AIS among the information to be shared. 
245 European Commission (2017): Digital inland waterway areas. Towards a digital inland waterway area and 
digital multimodal nodes. Final report. These investment costs are 75% higher than those in PM16. 

138 

 
  
 
reports  to  ports  would  decrease  by  30%  relative  to  the  baseline  from  2026  onwards. 
Considering the labour cost per hour (EUR 26.7 per hour246), the administrative costs savings 
for vessels operators due to PM17 relative to the baseline are provided in Table 60. Expressed 
as  present  value  over  2025-2050,  they  are  estimated  at  EUR  8.51  million  relative  to  the 
baseline.  

Table 60: Recurrent administrative costs savings for vessels operators due to PM17 relative to the baseline 
(in EUR, in 2022 prices) 

Number of port calls 
Reduction in the resubmission of electronic cargo reports 
relative to the baseline  
Administrative costs savings for vessel operators due to 
PM12 (in EUR) 
Source: Ramboll et al. (2024), impact assessment support study 

Summary of costs and costs savings 

2025 
359,093 

2030 
364,940 
109,482 

2040 
367,264 
110,179 

2050 
372,403 
111,721 

487,056 

490,158 

497,016 

Drawing on the detailed explanations by policy measure and stakeholder group above, Table 
61  to  Table  68  provide  a  summary  of  the  costs  and  costs  savings  by  policy  option,  policy 
measure and stakeholder group.  

Table 61: Recurrent  costs and costs savings for vessels operators  by policy option and measure  in 2030, 
2040 and 2050, relative to the baseline (in million EUR, in 2022 prices) 

PO-A 
2040 

2050 

2030 

Difference to the Baseline 
PO-B 
2040 

2050 

2030 

Administrative costs 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

PM5 

Adjustment costs savings 

PM1 
PM2 
PM3 
PM4 
PM5 
PM6 
PM9 
PM12 
PM13 

Administrative costs 
savings 
PM7 
PM8 
PM9 
PM12 
PM13 
PM15 
PM16 
PM17 

1.69 
0.49 
0.35 

1.70 
0.50 
0.36 

1.73 
0.50    
0.36 

0.85 

0.85 

0.86 

3.48 

3.50 

3.55 

0.35 

0.36 

0.36    

0.63 

0.64 

0.65 

0.85 
1.48 
0.17 

0.85 
1.49 
0.17 

0.86 
1.51 
0.17    

0.61 

0.62 

0.62 

1.63 

1.64 

1.66 

0.29 

0.29 

0.29    

0.57 
0.22 
0.51 

0.58 
0.22 
0.51 

0.59 
0.23 
0.52    

0.32 

0.33 

0.33 

0.32 

0.33 

0.33    

PO-C 
2040 
20.16 
20.16 
18.04 

2030 
19.74 
19.74 
18.70 

2050 
20.60 
20.60 
18.98 

0.18 
0.63 
15.04 
0.85 
1.48 

0.18 
0.64 
14.36 
0.85 
1.49 

0.18 
0.65 
15.24 
0.86 
1.51 

0.52 
2.97 

0.53 
2.99 

0.53 
3.03 

0.57 
0.22 

1.62 
0.06 

0.58 
0.22 

1.63 
0.06 

0.59 
0.23 

1.66 
0.07 

0.49 

0.49 

0.50 

246 Weighted average of the tariff per hour for non-manual workers (ISCO 8 - Plant and machine operators and 
assemblers) in the 13 Member State in the scope of RIS. It is based on Eurostat Structure of earnings survey and 
expressed in 2022 prices. 

139 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
PO-A 
2040 

2050 

2030 

Difference to the Baseline 
PO-B 
2040 

2050 

2030 

PO-C 
2040 

2030 

2050 

Net costs savings  
Source: Ramboll et al. (2024), impact assessment support study  

2.35 

2.32 

2.30 

5.11 

5.14 

5.22 

1.93 

0.88 

1.42 

Table 62: Recurrent costs and costs savings for vessels operators by policy option and measure, expressed 
as present value over 2025-2050, relative to the baseline (in million EUR, in 2022 prices) 

Difference to the Baseline 
PO-B 

PO-C 

PO-A 

Administrative costs 

PM5 

Adjustment costs savings 

PM1 
PM2 
PM3 
PM4 
PM5 
PM6 
PM9 
PM12 
PM13 

Administrative costs savings 

PM7 
PM8 
PM9 
PM12 
PM13 
PM15 
PM16 
PM17 

Net costs savings  

Source: Ramboll et al. (2024), impact assessment support study  

0.00 

29.56 

8.61    
6.16 

14.79 

10.68 

5.01    

0.00 

72.12 

6.16    

11.09 

14.79 
37.16 

2.92    

28.47 

10.02 
3.90 
8.88    

5.67 

40.24 

5.67    

100.59 

367.50 
367.50 
323.99 

3.08 
11.09 
248.72 
14.79 
37.16 

9.14 
51.89 

10.02 
3.90 

28.35 
1.11 

8.51 
8.37 

Table  63:  Adjustment  costs  savings  for  navigation  software  services  providers  by  policy  option  and 
measure in 2030, 2040 and 2050, relative to the baseline (in million EUR, in 2022 prices) 

PM1 
PM2 
PM3 
PM4 
PM6 
PM9 
PM12 
PM13 
PM14 

PO-A 
2040 

0.07 
0.04 

2030 

0.07 
0.04 

Difference to the Baseline 
PO-B 
2040 

2050 

2030 

2050 

0.07    
0.04 

0.04 

0.04 

0.04    

PO-C 
2040 

2030 

2050 

0.14 

0.14 

0.15 

0.14 
0.14 
0.07 
0.05 

0.02 
0.14 
0.14 
0.07 

0.09 
0.02 
0.48 

0.15 
0.15 
0.07 
0.05    

0.02 
0.47 

0.02 
0.14 
0.14 
0.07 

0.09 
0.02 
0.49 

0.02 
0.15 
0.15 
0.07 

0.09 
0.02 
0.49 

0.14 
0.14 
0.07 
0.05 

0.02 
0.47 

Total adjustment costs 
savings 
Source: Ramboll et al. (2024), impact assessment support study  

0.26 

0.25 

0.25 

0.02 
0.47 

140 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table  64:  Adjustment  costs  savings  for  navigation  software  services  providers  by  policy  option  and 
measure,  expressed  as  present  value  over  2025-2050,  relative  to  the  baseline  (in  million  EUR,  in  2022 
prices) 

Difference to the Baseline 
PO-B 

PO-C 

PO-A 

PM1 
PM2 
PM3 
PM4 
PM6 
PM9 
PM12 
PM13 
PM14 

1.25    
0.63 

2.50 

Total adjustment costs savings 
Source: Ramboll et al. (2024), impact assessment support study  

4.38 

0.63    

2.50 
2.50 
1.25 
0.94    

0.31 
8.13 

0.31 
2.50 
2.50 
1.25 

1.56 
0.31 
8.44 

Table 65: Recurrent costs and costs savings for national public authorities by policy option and measure 
in 2030, 2040 and 2050, relative to the baseline (in million EUR, in 2022 prices) 

Administrative costs 

PM2 
PM3 
PM4 
PM5 
PM6 
PM12 
PM13 
PM14 
PM16 
PM17 

PO-A 
2040 

1.97 
0.92 

2030 

1.97 
0.92 

2050 

1.97 
0.92 

0.66 

0.66 

0.66 

0.39 

0.39 

0.39 

Difference to the Baseline 
PO-B 
2040 

2050 

2030 

4.29 
0.92 

4.29 
0.92 

4.29 
0.92    

1.14 

1.14 

1.14 

0.66 
0.39 

0.79 
0.39 

0.66 
0.39 

0.79 
0.39 

0.66 
0.39    

0.79 
0.39    

PO-C 
2040 

2030 

2050 

5.91 

5.91 

5.91 

0.65 
1.14 
0.77 
0.66 

1.23 
0.79 

0.65 
1.14 
0.77 
0.66 

1.23 
0.79 

0.65 
1.14 
0.77 
0.66 

1.23 
0.79 

0.68 

0.68 

0.68 

0.62 
0.62 

Administrative cost 
savings 
PM7 
PM8 
PM9 
PM15 
Net costs  
Source: Ramboll et al. (2024), impact assessment support study  

0.74 
0.74    

0.68 
0.68 

1.23 

1.29 

1.34 

1.25 
0.50 

2.54 

1.75 

1.86 

1.97 

2.14 

2.24 

2.36 

1.36 
0.50 

1.47 
0.50 

2.43 

2.31 

1.25 
0.50 
0.39 
3.78 

1.36 
0.50 
0.39 
3.67 

1.47 
0.50 
0.39 
3.55 

Table 66: One-off adjustment costs for national public authorities by policy option and measure in 2025, 
relative to the baseline (in million EUR, in 2022 prices) 

PM2 
PM4 
PM5 
PM7 
PM8 
PM9 
PM12 
PM13 

Difference to the Baseline 
PO-B 

PO-C 

PO-A 

2.76 

1.25    

2.76    
4.55 

1.25 
3.50 
1.58    

4.55 
3.07 

1.25 
3.50 

4.93 

141 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Difference to the Baseline 
PO-B 

PO-C 

PO-A 

PM14 
PM15 
PM16 
PM17 

Total one-off adjustment costs  
Source: Ramboll et al. (2024), impact assessment support study  

3.14 

1.55    

18.33 

3.14 
5.00 

2.71 
28.15 

1.55 

5.56 

Table  67:  Recurrent  and  one-off  costs  and  costs  savings  for  national  public  authorities  by  policy  option 
and measure, expressed as present value over 2025-2050, relative to the baseline (in million EUR, in 2022 
prices) 

Difference to the Baseline 
PO-B 

PO-C 

PO-A 

Adjustment costs 

PM2 
PM4 
PM5 
PM7 
PM8 
PM9 
PM12 
PM13 
PM14 
PM15 
PM16 
PM17 

Administrative costs 

PM2 
PM3 
PM4 
PM5 
PM6 
PM12 
PM13 
PM14 
PM16 
PM17 

Administrative cost savings 

PM7 
PM8 
PM9 
PM15 
Net costs  
Source: Ramboll et al. (2024), impact assessment support study  

5.56 
2.76 

1.25    

1.55 

34.9 
16.02 

12.18 

6.74 

11.45 
11.45    

29.05 

18.33 

2.76    
4.55 

1.25 
3.50 
1.58    

3.14 

1.55    

75.3 
16.02    

19.81 

12.18 

6.86    

13.68 

6.74    

30.60 

22.89 
7.71 

63.02 

28.15 

4.55 
3.07 

1.25 
3.50 

4.93 
3.14 
5.00 

2.71 
104.3 

11.97 
19.81 
13.35 
12.18 

21.48 
13.68 

11.79 
37.37 

22.89 
7.71 
6.77 
95.04 

Table 68: One-off adjustment costs for the European Commission by policy option and measure in 2025, 
relative to the baseline (in million EUR, in 2022 prices) 

Difference to the Baseline 
PO-B 

PO-C 

PO-A 

PM1 

Total one-off adjustment costs  
Source: Ramboll et al. (2024), impact assessment support study  

0.47    
0.47 

0.00 

0.00 

142 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
4.  Impacts on modal shift and external costs 

As explained in section 1, IWT is quite active in the transport of non-time sensitive goods (e.g. bulk 
or liquid cargo). To increase the competitiveness of intermodal inland waterways transport, focus is 
needed  on  incentivising  the  transport  of  goods  that  are  more  time  sensitive  (i.e.  typically  the 
container market). For this market segment, reliability is important and IWT would need to match 
the higher reliability standards of road transport, which benefits from a reduced number of actors 
(door-to-door services,  less  handling)  and higher  flexibility  (in  particular  compared to  “network” 
modes, like IWT and rail). 

Several policy measures are expected to have an impact on modal shift, away from road transport to 
intermodal inland waterway transport. In particular PM4 is expected to increase the efficiency in 
navigation,  as  improved  data  (e.g.  on  waiting  times  or  obstacles)  will  improve  navigation 
performance.  PM14  will  have  a  similar  effect  through  improved  links  with  the  systems  of  other 
modes  (e.g.  the  estimated  time  of  arrival  will  be  available,  which  in  turn  will  contribute  to  the 
optimisation  of  the  logistics  chain).  This  will  lead  to  increased  performance,  predictability  and 
reliability of the intermodal IWT sector, increasing the potential to attract freight from other modes. 
The impact of PM4 and PM14 (both included in PO-B and PO-C) on modal shift has been assessed 
together, due to the synergies between the measures.  

No study has been identified that examines the issue of reliability in the IWT sector. However, a 
2019 TRT study247, examining the modal shift potential for rail, provides a good approximation for 
identifying  the  impact  of  improved  reliability  for  intermodal  IWT.  Like  IWT,  rail  is  also  a 
“network”  mode  (though  with  a  wider  network)  and  it  also  carries  both  time-sensitive  and  cost-
sensitive  goods.  The  study  found  that  the  lack  of  punctuality  was  the  most  important  reason 
provided by the surveyed logistics operators and freight forwarders for not choosing rail instead of 
road. It further estimated (through a stated preference survey) the impact of an increase in reliability 
in shifting freight away from road (i.e. the cross elasticity). Given the similarities between rail and 
IWT, the fact that both compete against road,  and in the absence of further specific research, the 
results of the rail study are used as a proxy for estimating the potential modal shift from road to 
IWT. In addition, sensitivity analysis has been performed and is presented in section 7.6.  

Based on the results of a stated preference survey run as part of a 2019 TRT study248, a linear 
correlation  between  punctuality  and  modal  shift  potential  has  been  identified.  More 
specifically, the study indicates that for each 10% increase in punctuality a 6.1% increase in 
transport  demand  could  be  expected.  To  determine  the  impact  on  reliability  for  the  inland 
waterway  sector,  information  on  average  waiting  times  at  locks  has  been  collected  in  the 
context of the impact assessment support study and the impact on reliability (90% value) has 
been derived based on desk-research249. 

Table 69: Average waiting times at locks and impact on reliability, in minutes 

Oranjesluizen 
Houtribsluizen 
Margrietsluis 
Gaarkeukensluis 
Oostersluis 

Average waiting time 
18 
18 
19 
16 
22 

90% value 
42 
38 
36 
32 
45 

247 https://www.corridor-rhine-alpine.eu/files/downloads/others/Transport%20Market%20Study%202018.pdf  
248 https://www.corridor-rhine-alpine.eu/files/downloads/others/Transport%20Market%20Study%202018.pdf 
249 IMA (2021) of the Department of Public Works.  

143 

 
 
 
Delden 
Grave 
Sint Andries 
Weurt 
Schijndel 
Hansweert 
Krammersluizen 
Kreekraksluizen 
Volkeraksluizen 
Average 
Source: Ramboll et al. (2024), impact assessment support study  

Average waiting time 
32 
21 
21 
16 
20 
14 
25 
20 
24 
20 

90% value 
82 
42 
45 
36 
41 
30 
53 
45 
40 
43 

The table shows an average waiting time per lock of 20 minutes and a reliability value of 43 
minutes (i.e. variance of 23 minutes). Moreover, a barge passes an average number of 4 locks 
per  voyage250,251.  In  the  baseline  scenario,  the  total  travel  time  for  freight  inland  waterways 
transport  is  estimated  at  12  million  hours  in  2025,  12.19  million  hours  in  2030  and  12.42 
million  hours  in  2050,  while  the  waiting  time  at  0.54  million  hours  in  2025,  0.55  million 
hours in 2030 and 0.56 million hours in 2050. Based on this, the reliability of travel time in 
inland shipping is estimated at 95.5% in the baseline scenario. Information on the position of 
the ship and the expected arrival time of ships can increase the reliability by a maximum of 
4.5%. Drawing on the correlation between the increase in punctuality and transport demand 
from  the  TRT  study,  the  model  shift  potential  is  estimated  at  2.7%  relative  to  the  baseline. 
This  modal  shift  potential  is  only  applied  to  intermodal  transport252,  as  not  all  goods 
transported  by  road  may  be  suitable  for  transport  by  IWT,  while  the  IWT  network  is  much 
limited  compared  to  that  of  road.  Drawing  on  the  evolution  of  freight  IWT  activity  in  the 
baseline scenario, the model shift potential and the share of intermodal transport in IWT, the 
transport activity shifted from  road to  freight  IWT is  estimated at  0.35 billion  tkm in  2026, 
0.38 billion tkm in 2030 and 0.45 billion tkm in 2050. 

Table 70: Impact on freight inland waterways transport activity relative to the baseline 

2026  

2030  

2040  

2050  

Freight IWT activity in the baseline scenario 
(Gtkm) 
Travel time in the baseline (million hours) 
Waiting time in the baseline (million hours) 
Reliability  

167.0 
12.04 
0.54 
95.5% 

Effect of more reliable travel planning 
Modal shift potential 
Shift from road to freight IWT activity 
relative to the baseline (Gtkm) 
Source: Ramboll et al. (2024), impact assessment support study  

4.5% 
2.7% 

0.35 

178.2 
12.19 
0.55 
95.5% 

4.5% 
2.7% 

194.7 
12.26 
0.55 
95.5% 

4.5% 
2.7% 

211.8 
12.42 
0.56 
95.5% 

4.5% 
2.7% 

0.38 

0.41 

0.45 

Environmental impacts and external costs 

The CO2 emissions  reductions are  driven by the  combined effect of PM4 and PM14 on the 
shift from road to inland waterways transport, and by the energy savings in PM5. To calculate 
the  CO2  emissions  reductions  due  PM4  and  PM14,  the  changes  in  the  transport  activity 
relative to the baseline and the CO2 emissions intensity for freight inland waterways transport 

250 Rijkswaterstaat's Basic Travel File (2019), including around 375,000 trips.  
251 At trip level, the variance is estimated at 47 minutes. 
252 Based on Eurostat data, around 7.7% of inland waterway transport is intermodal container transport. 

144 

 
 
  
 
and road transport (expressed in tCO2 per tkm) have been used. The CO2 emissions intensity 
draws on the baseline scenario developed with the PRIMES-TREMOVE model. It should be 
noted that the CO2 intensity for both road transport and IWT reduces significantly over time 
in  the  baseline  scenario,  driven  by  improvements  in  energy  efficiency  and  the  uptake  of 
renewable  and  low  carbon  fuels.  For  PM5,  the  CO2  emissions  savings  have  been  derived 
based  on  the  energy  savings  and  the  CO2  intensity  expressed  in  tCO2  per  ktoe  from  the 
baseline  scenario  developed  with  the  PRIMES-TREMOVE  model.  The  reduction  in  the 
external costs of CO2 emissions has been calculated based on the CO2 emissions savings and 
the unit costs from the 2019 Handbook on external costs of transport. 

A similar approach has been used for air pollutant emissions. 

Table 71: Impact on CO2 emissions relative to the baseline in 2030, 2040 and 2050 (kt of CO2) 

PO-A 
2040 

2030 

2050 

Difference to the Baseline 
PO-B 
2040 

2050 

2030 

CO2 emissions (kt) 

0.0 

0.0 

0.0 

-22.5 

-14.3 

-5.6 

PM5 
PM4&PM14 

-22.5 
Source: Ramboll et al. (2024), impact assessment support study  

-14.3 

-5.6 

PO-C 
2040 

-32.3 
-18.0 
-14.3 

2030 

-45.2 
-22.7 
-22.5 

2050 

-14.5 
-9.0 
-5.6 

Table 72: Cumulative impact on CO2 emissions for 2025-2050 relative to the baseline (kt of CO2) 

CO2 emissions (kt) 

PM5 
PM4&PM14 

Difference to the Baseline 
PO-B 

PO-C 

PO-A 

0.0 

-389.1 

-389.1 

-832.1 
-443.0 
-389.1 

Source: Ramboll et al. (2024), impact assessment support study  

Table 73: Impact on air pollutant emissions relative to the baseline in 2030, 2040 and 2050 (tonnes) 

PO-A 
2040 

2050 

2030 

Difference to the Baseline 
PO-B 
2040 

2050 

2030 

PM emissions (in tonnes) 

0.0 

0.0 

0.0 

3.2 

2.5 

1.6 

PM5 
PM4&PM14 

NOx emissions (in tonnes) 

0.0 

0.0 

0.0 

PM5 
PM4&PM14 

3.2 
19.7 

2.5 
29.2 

1.6 
21.3 

19.7 

29.2 

21.3 

Source: Ramboll et al. (2024), impact assessment support study  

PO-C 
2040 
-11.1 
-13.6 
2.5 
-231.5 
-260.7 
29.2 

2030 
-17.0 
-20.3 
3.2 
-367.6 
-387.3 
19.7 

2050 

-6.3 
-7.9 
1.6 
-129.5 
-150.8 
21.3 

Table 74: Cumulative impact on air pollutant emissions for 2025-2050 relative to the baseline (tonnes) 

PM emissions (in tonnes) 

PM5 
PM4&PM14 

NOx emissions (in tonnes) 

PM5 
PM4&PM14 

Difference to the Baseline 
PO-B 

PO-C 

PO-A 

0.0 

0.0 

60.8 

60.8 
603.2 

603.2 

-338.8 
-399.6 
60.8 
-6552.3 
-7,155.5 
603.2 

Source: Ramboll et al. (2024), impact assessment support study  

145 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 75: Impact on external costs of CO2 emissions, air pollution emissions, noise and habitats relative to 
the baseline in 2030, 2040 and 2050 (in million EUR, 2022 prices) 

CO2 emissions 

PM5 
PM4&PM14 

Air pollution 

PM5 
PM4&PM14 

Noise 

PM4&PM14 

Habitats 

PO-A 
2040 

2050 

2030 

Difference to the Baseline 
PO-B 
2040 

2050 

2030 

0.0 

0.0 

0.0 

-2.7 

-3.1 

-1.8 

0.0 

0.0 

0.0 

-2.7 
0.7 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

-3.1 
0.9 

0.9 
-2.2 
-2.2 
-2.1 
-2.1 
-6.6 

-1.8 
0.6 

0.6 
-2.4 
-2.4 
-2.3 
-2.3 
-5.9 

0.7 
-2.0 
-2.0 
-2.0 
-2.0 
-5.9 

PO-C 
2040 

2030 

2050 

-5.4 
-2.7 
-2.7 
-9.4 
-10.2 
0.7 
-2.0 
-2.0 
-2.0 
-2.0 
-18.7 

-7.1 
-3.9 
-3.1 
-6.0 
-6.8 
0.9 
-2.2 
-2.2 
-2.1 
-2.1 
-17.4 

-4.6 
-2.9 
-1.8 
-3.3 
-4.0 
0.6 
-2.4 
-2.4 
-2.3 
-2.3 
-12.7 

PM4&PM14 
Total reduction in 
external costs 
Source: Ramboll et al. (2024), impact assessment support study  

0.0 

0.0 

0.0 

Table 76: Impact on external costs of CO2 emissions, air pollution emissions, noise and habitats relative to 
the baseline – expressed as present value over 2025-2050 (in million EUR, 2022 prices) 

PO-A 

Difference to the Baseline 
PO-B 

PO-C 

CO2 emissions 

PM5 
PM4&PM14 

Air pollution 

PM5 
PM4&PM14 

Noise 

PM4&PM14 

Habitats 

PM4&PM14 

Total reduction in external costs 

Source: Ramboll et al. (2024), impact assessment support study  

External costs of congestion  

0.0 

0.0 

0.0 

0.0 

0.0 

-48.6 

-48.6 
13.1 

13.1 
-36.6 
-36.6 
-36.2 
-36.2 
-108.4 

-105.2 
-56.6 
-48.6 
-127.6 
-140.7 
13.1 
-36.6 
-36.6 
-36.2 
-36.2 
-305.7 

The  reduction  in  the  external  costs  of  road  congestion  has  been  calculated  based  on  the 
reduction  in  the  road  transport  activity  and  the  unit  costs  of  congestion  from  the  2019 
Handbook on external costs of transport253.  

Table 77: Impact on external costs of congestion relative to the baseline in 2030, 2040 and 2050 (in million 
EUR, 2022 prices) 

PO-A 
2040 

2030 

2050 

Difference to the Baseline 
PO-B 
2040 

2050 

2030 

Congestion 

-4.7 
-4.7 
Source: Ramboll et al. (2024), impact assessment support study  

PM4&PM14 

0.0 

0.0 

0.0 

-5.1 
-5.1 

-5.6 
-5.6 

PO-C 
2040 

-5.1 
-5.1 

2030 

-4.7 
-4.7 

2050 

-5.6 
-5.6 

253 Internalisation of transport external costs (europa.eu) 

146 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
Table 78: Impact on external costs of congestion relative to the baseline – expressed as present value over 
2025-2050 (in million EUR, 2022 prices) 

Congestion 

PM4&PM14 

PO-A 

Difference to the Baseline 
PO-B 

PO-C 

0.0 

-86.8 
-86.8 

-86.8 
-86.8 

Source: Ramboll et al. (2024), impact assessment support study  

External costs of accidents 

The reduction in the external costs of accidents has been calculated based on the reduction in 
the  road  transport  activity  and  the  unit  costs  per  fatality  and  serious  injury  from  the  2019 
Handbook on external costs of transport. According to the Handbook, the external cost of a 
fatality in 2022 prices is estimated at EUR 3.9 million and that of a serious injury at EUR 0.6 
million. 

Table 79: Impact on external costs of accidents relative to the baseline in 2030, 2040 and 2050 (in million 
EUR, 2022 prices) 

Difference to the Baseline 

PO-A 
2040 

2030 

2050 

2030 

Accidents (Road) 
PM4&PM14 

-6.3 
-6.3 
Source: Ramboll et al. (2024), impact assessment support study  

0.0 

0.0 

0.0 

PO-B 
2040 

2050 

2030 

PO-C 
2040 

-6.9 
-6.9 

-7.5 
-7.5 

-6.3 
-6.3 

-6.9 
-6.9 

2050 

-7.5 
-7.5 

Table 80: Impact on external costs of accidents relative to the baseline – expressed as present value over 
2025-2050 (in million EUR, 2022 prices) 

Accidents (Road) 
PM4&PM14 

Difference to the Baseline 

PO-A 

PO-B 

PO-C 

0.0 

-115.8 
-115.8 

-115.8 
-115.8 

Source: Ramboll et al. (2024), impact assessment support study  

147 

 
  
  
  
  
  
  
  
  
ANNEX 5: COMPETITIVENESS CHECK 

1. 

OVERVIEW OF IMPACTS ON COMPETITIVENESS  

Dimensions of competitiveness 

Impact of the initiative 
(++ / + / 0 / - / -- / n.a.) 

References to sub-sections of 
the main report or annexes 

Cost and price competitiveness 

Capacity to innovate 

International competitiveness 

SME competitiveness 

+ 

+ 

0 

+ 

Sections  6.1.3  and  6.1.7,  and  Annex 
4 

Sections 6.1.8 and 6.1.9  

Section 6.1.7  

Section 6.1.5 and Annex 6 

2. 

SYNTHETIC ASSESSMENT 

2.1. Cost and price competitiveness 

The  preferred  policy  option  will  bring  improvements  in  the  operational  efficiency  of  inland 
waterway operations, including the efficiency of vessel operators. These are mainly a result of 
measures  enabling  better  planning  of  operations  and  a  reduction  in  the  resubmissions  of 
reports (PM2, PM4, PM6, PM9, PM16), as well as of measures enabling better exchange of 
cargo  information  through  eFTI  and  with  inland  ports  (PM8  and  PM12).  As  indicated  in 
section 6.1.3, administrative costs savings for vessel operators are estimated at EUR 28.5 million in 
PO-B,  expressed  as  present  value  over  2025-2050  relative  to  the  baseline,  and  adjustment  cost 
savings  at  EUR  72.1  million.  Overall,  the  preferred policy option  results  in  net  costs  savings  for 
vessel operators estimated at EUR 100.6 million. 

In addition, providers of RIS software services are expected to benefit of costs savings thanks 
to access to more and better-quality data. As indicated in section 6.1.3, the adjustment costs 
savings  for  RIS  software  services  providers  are  estimated  at  EUR  8.1  million  in  PO-B, 
expressed as present value over 2025-2050 relative to the baseline. 

As explained in section 6.1.7, the competitiveness of the IWT is expected to improve relative 
to the road transport sector in PO-B. The transport activity shifted from road to freight IWT in 
PO-B and PO-C is estimated at 0.35 billion tonne-kilometres (tkm) in 2026, 0.38 billion tkm 
in 2030 and 0.45 billion tkm in 2050. 

2.2. International competitiveness 

While  the  revision  of  the  RIS  Directive  will  make  the  EU  inland  waterway  transport  more 
efficient and reliable, including positive impacts on neighbouring countries such as Serbia and 
Ukraine which are already voluntarily applying RIS Directive, the initiative has no impact on 
the international competitiveness of the sector.  

2.3. Capacity to innovate 

The preferred policy option  will  positively  affect the  IWT sector’s  capacity to  innovate. By 
providing  better quality RIS data  it will lead to the provision  of  more  accurate services and 

148 

 
 
 
 
 
eventually set the basis upon which further digital applications can be developed (for example 
for planning and optimisation of navigation, avoidance of obstacles and warning of navigation 
hazards,  etc.).  In  addition,  PO-B  will  have  a  positive  impact  on  digitalisation  by  promoting 
the electronic exchange of data. The increased links and exchange of information with other 
modes has the potential to improve multimodality and will allow developers of logistics and 
travel  planning  and  cargo  management  applications  to  include  IWT  in  their  solutions.  The 
introduction  of  cargo  information  through  eFTI  will  increase  the  quantity  and  quality  of 
information  available  in  the  eFTI  platforms,  which  then  could  feed  the  development  of 
business-to-business  applications.  In  the  medium  to  long  term,  the  information  provided  by 
RIS regarding navigation and the digital exchange of information will become an important 
basis for the development and operation of automated vessels. 

2.4. SME competitiveness  

Given  that  SMEs  constitute  a  very  large  share  of  both  vessel  operators  and  RIS  software 
services providers, the assessment in section 2.1 of Annex 5 (cost and price competitiveness) 
is also relevant for SMEs. In particular, most of net costs savings are expected to be attributed to 
SMEs  although  the  available  data  did  not  allow  a  split  of  these  costs  savings  between  the  two 
groups  of  operators  (i.e.  SME  and  others).  Hence,  the  preferred  policy  option  has  a  positive 
impact  on  competitiveness  of  SMEs,  in  particular  those  engaged  in  cross-border  as  well  as 
intermodal  operations,  by  improving  their  operational  efficiency  and  facilitating  their 
inclusion in the logistics chain. 

149 

 
 
 
ANNEX 6: SME TEST 

Step (1) of SME test (identification of affected businesses). According to Eurostat, around 5,500 IWT 
freight transport companies are active in Europe (EU plus Bosnia-Herzegovina, Serbia and Switzerland), 
employing  more  than  23,000  persons.  In  addition,  there  are  around  4,000  passenger  companies  which 
employ  around  14,000  persons.  While  no  data  is  available  at  EU  level  for  the  number  of  Small  and 
Medium  Enterprises  (SMEs)  within  the  IWT  sector,  one  characteristic  of  the  IWT  sector  is  the  high 
number of SMEs. According to the CCNR, the majority of companies in Western Europe are small family 
owned operating one or two vessels254, while companies in the Danube region are bigger as they derive 
from previously state-owned enterprises255.  

Software  services  providers  for  RIS  applications  are  highly  specialised  and  serve  a  niche  market. 
According to Article 7 of the RIS Directive, RIS equipment including software needs to be type approved. 
The  Directive  requires  that  Member  State  authorities  responsible  for  type-approval  are  notified  to  the 
Commission, however there is no concrete information as to the actual number of the software providers 
that  have  been  approved.  CESNI  provides  a  list  of  around  20  companies  as  providers  for  ECDIS  and 
inland AIS256, while a Member State expert estimated the potential number to be up to 50 companies. A 
review of the information  related to these companies, based on their public  websites, indicates that the 
majority of them are small companies employing less than 250 employees.  

Step (2) of SME test (consultation of SME stakeholders). SMEs constitute a significant share of the 
stakeholders involved in the consultation activities. In the first stakeholder survey, of the 37 respondents 
identified as “inland waterway transport/RIS user”, 7 indicated they work alone, 23 in a company of less 
than 20 people, 3 in a company between 10 and 50 people, 2 in a company between 50 and 250 people 
and  only  2  in  a  company  above  250  people.  Regarding  the  RIS  software  or  systems  developers,  their 
participation to the overall stakeholder consultation was more limited, with 3 representatives taking part in 
interviews and the same number responding to the first stakeholder survey.  

The second survey had a much smaller response rate, but even so of the 5 respondents identified as “inland 
waterway  transport/RIS  user”,  3  were  from  companies  of  less  than  250  people.  The  Open  Public 
Consultation  had  a  limited  response  rate  (only  13  replies),  and  of  the  2  identified  as  “skippers/barge 
owners” one indicated working for a company with less than 10 people and 1 for a company with less than 
50  people.  In  addition,  2  of  the  11  associations  interviewed  during  the  stakeholder  consultation  were 
representing barge owners and skippers (also representing SMEs) and were also participating in the two 
DINA/NAIADES expert group meeting organised. Furthermore, two back-to-back workshops specifically 
focused  on  RIS  users  and  in  particular  skippers,  where  4  out  of  10  participants  represented  SMEs  or 
associations of companies which include SMEs.  

Despite the low response rate during the consultation process, the multiple and targeted approaches used 
are assessed to have identified adequately the specific needs and challenges for SMEs.  

254 Indicatively for 2017, the number of companies employing less than 10 persons represented 97% in the Netherlands, 
96% in France and 82% in Germany. 
255  CCNR  (2020)  Marker  Report  2014-2019,  Main  features  and  trends  of  the  European  Inland  Waterway  Transport 
Sector, Market-report-2014-2019_Web_BD.pdf (inland-navigation-market.org)  
256  Lists  of  approved  authorities,  firms,  installations  and  equipment  in  the  field  of  technical  requirements  for  inland 
navigation vessels. (cesni.eu) 

150 

 
 
 
Step (3) of SME test (assessment of the impacts on SMEs). As explained in section 6.1.3, all policy 
options are expected to result in net costs savings for vessel operators and navigation software services 
providers. More  specifically,  for  vessel operators PO-B would  result  in  net  costs savings  estimated  at 
EUR 100.6 million, expressed as present value over 2025-2050 relative to the baseline, followed by PO-A 
(EUR 40.2 million) and PO-C (EUR 8.4 million). It should however be noted that PO-C would also result 
in additional administrative costs, despite the overall net costs savings. 

When considering the impact of each measure, as explained in section 3 of Annex 4, for vessel operators 
this  will  primarily  materialise  in  time  saving  for  planning  of  voyages  and  improvements  in  navigation 
efficiency, and administrative costs in case of PM5 (included in PO-C). The detailed calculations of the 
costs savings for each measure (and costs for PM5) are provided in section 3 of Annex 4. Below, more 
explanations are provided on the drivers of the costs savings or costs (in case of PM5) for vessel operators 
in each policy measure. 

More specifically: 

•  Vessel operators  will  be faced  with less  discrepancies  in  the information they receive  from national 
authorities  as  a  result  of  the  interpretative  guidelines  (PM1).  This  will  reduce  the  time  required  to 
compare  and  interpret  information  from  different  authorities  and  thus  to  plan  their  voyage,  as  they 
should now have more clarity on e.g. when a lock is fully closed in both directions or partially closed in 
one of the directions of navigation.  

•  The  complaint  handling  mechanism  (PM2)  will  provide  vessel  operators  full  clarity  on  the  relevant 
competent authority in each Member State for handling RIS related complaints. Costs for submitting 
such  complaints  are  estimated  to  be  negligible  as  they  can  be  done  through  an  online  form.  By 
reporting  problems  (e.g.  wrong  data,  standard  inconsistencies)  they  will  benefit  of  an  overall 
improvement in the quality of RIS, which translates in better quality information and time savings for 
voyage planning. On the other hand, the Performance Measurement Framework (PM3) will not require 
action from  the  side of  vessel  operators  and  provide  benefits in terms  of improved RIS  services,  as 
potential problems with the implementation of RIS are reduced.  

•  The strengthened requirements for RIS technical specifications (PM4) will also lead to a reduction in 
the  voyage  planning  time,  as  vessel  operators  will  receive  better  quality  information  regarding  e.g. 
water level predictions, current and predicted underpass heights at bridges and current and predicted 
waiting times at locks. In addition, due to the increase in efficiency of navigation, vessel operators will 
experience an increase in freight volumes (that will be shifted away from road transport).  

•  The requirement to vessel operators and skippers to report their voyage plan (ERIVOY) to competent 
authorities at the start of their journey, and update this with further changes to their estimated time of 
arrival (PM5), will increase the time spent in preparing and reporting on the voyage plan and follow up 
notifications, thus creating an administrative burden. On the other hand, this will improve navigation 
efficiency and result in energy savings.  

•  Updated and more accurate ERDMS data (PM6) will improve the quality of the necessary information 

for voyage planning, thus reducing the time required for its preparation.  

•  In  PM7  and  PM8,  an  eFTI  platform  will  be  developed  for  vessel  operators  to  inform  the  national 
authorities  about  dangerous  goods  they  may  carry.  Should  they  choose  to  do  so  on  voluntary  basis 
(PM7), or be required to do so (PM8) they will only need to upload the information once on eFTI, and 
then report to the authorities through ERI only the relevant link. This once-only principle will reduce 

151 

 
mistakes  in  reporting  regarding  e.g.  the  loading/unloading  location,  coding  of  the  cargo  or  hull 
information, which can force the skippers to re-register upon a border crossing.  

•  The use of RIS COMEX (PM9), as the main platform for RIS exchanges, will be an important change 
for vessel operators, as they will benefit of a single platform of interaction instead of several portals and 
systems, reducing the time for voyage planning and notifications.  

•  The involvement of CESNI in the development of technical specifications will have only an indirect 
impact on vessel operators, as the development and rollout of necessary technical specifications will be 
more frequent compared to the situation today.  

•  The change of scope of RIS, to bring the focus on the TEN-T waterways (PM11), will not have direct 
impacts on vessel operators as the overall area of application of RIS is hardly expected to change.  

•  The  exchange  of  information  with  inland  ports  (either  voluntary  under  PM12  or  mandatory  under 
PM13) will benefit vessel operators through improved and updated information regarding the situation 
in  their  inland  port  of  destination  (e.g.  access  constraints  on  opening  of  bridges,  the  availability  of 
berths,  the  availability  of  clean  fuels  at  the  time  of  arrival).  This  will  facilitate  the  planning  of  the 
voyage and reduce the need of (re)submitting reports. 

•  The  exchange  of  information  with  other  modes  (PM14)  will  benefit  vessel  operators  by  better 
integrating them into the  logistics  chain.  Vessel operators  are  expected  to  experience an increase  in 
freight volumes, that will be shifted away from road transport.  

•  In PM15, vessel operators will benefit of reduced reporting (e.g. for the cargo report)257, as when a 
border is crossed the information will be exchanged between the authorities and not resubmitted by the 
vessel operator.  

•  In PM16 and PM17, by making clear in which cases AIS data can and cannot be shared, the procedure 
for  collecting  port  charges  would  become  simpler  and  reduce  the  number  of  resubmissions.  The 
difference between PM16 and PM17 is limited for vessel operators, as PM17 only further defines the 
exact templates and standards to be followed when such an exchange takes place, in line with existing 
legal provisions.  

Software  services  providers  would  benefit  of  costs  savings  of  EUR  8.4  million  in  PO-C,  EUR  8.1 
million in PO-B and EUR 4.4 million in PO-A, expressed as present value over 2025-2050 relative to the 
baseline. For software service providers, the main impact relates to the quality of the basic information that 
they can introduce in their software. Higher quality information will reduce the need for additional efforts 
to collect the required data and thus their costs. Several measures will provide updated and more accurate 
data  to  different  extent  (i.e.  the  interpretative  guidelines  (PM1),  the  complaint  mechanism  (PM2),  the 
Performance  Measurement  Framework  (PM3),  the  technical  specifications  for  navigation  and  voyage 
planning (PM4), updates to the ERDMS (PM6), RIS COMEX (PM9), the exchange of information with 
inland ports (PM12 and PM13) and the improved links with other modes (PM14)). The calculation of the 
costs savings by measure is provided in section 3 of Annex 4.  

257  As  currently  not  all  information  provided  by  vessel  operators  to  authorities  is  shared  with  the  authorities  of  other 
Member  States,  this  creates  a  challenge  when  crossing  borders  as  in  many  cases  the  information  needs  to  be 
retransmitted. 

152 

 
 
Considering the very large share of SMEs among vessel operators and software services providers, most 
of these net costs savings are expected to be attributed to them although the available data did not allow a 
split of these costs savings between the two groups of operators (i.e. SME and others). In addition, the 
increase in intermodal transport in PO-B and PO-C is expected to have a positive economic impact on the 
SMEs involved. 

Step  (4)  of  SME  test  (minimizing  negative  impacts  on  SMEs).  It  should  be  noted  that  a  key  issue 
highlighted by the respondents to the stakeholders’ consultation is the need to simplify the procedures they 
have  to  follow  during  navigation.  In  fact,  all  policy  options  aim  to  address  this  issue  (also  for  SMEs) 
through two important measures: (i) the provision of accurate and updated data to ERDMS (PM6 in PO-
A,  PO-B  and  PO-C),  (ii)  the  improvement  of  RIS  index  data  and  the  technical  specifications  for 
navigation  and  voyage  planning  (PM4  in  PO-B  and  PO-C).  As  a  result,  the  quality  of  information  for 
vessel voyage planning will improve and the process simplified. In addition, the development of standards 
by CESNI  (PM10  in PO-A, PO-B  and  PO-C)  will  ensure that  technical  specifications  are up-to-date, 
thus facilitating operations. Software services providers will benefit from better quality data which will 
reduce their efforts to develop their products. The introduction of a complaint mechanism (PM2 in PO-A 
and PO-B) will be an important tool for SMEs to report to relevant authorities the problems they identify 
in the network during their daily operations. Respondents identified as or contributing on behalf of SMEs 
vessel operators also pointed to the need to simplify and reduce the burden for reporting. PO-B and PO-C 
aim  to  facilitate  the  work  for  skippers  (and  by  extension  the  family-owned  SMEs)  in  this  regard.  By 
introducing requirement for the use of RIS COMEX as the main tool for exchange of information (PM9 in 
PO-B and PO-C), vessel operators will benefit of a one-stop-shop for the exchange of information with 
authorities. Importantly, this could develop into a platform for further development of digital applications. 
This  is  also  important  for  software  services  providers  who  will  adapt  their  products  for  one  platform 
instead  of  many  national  ones.  New  technical  specifications  for  exchanging  information  with  ports 
(PM12 in PO-B) would also facilitate the contact with ports and improve operations. The requirement for 
electronic  voyage  reporting  (PM5  in  PO-C)  also  aims  to  improve  navigation  conditions.  However, 
skippers  reported  concerns  on  the  efforts  required  by this  measure during the stakeholder  consultation. 
Last but not least, personal information is particularly important for those family-owned companies, for 
which the vessel is at the same time their home. PM16 and PM17 aim to address the legal uncertainty, 
without  increasing  obligations  or  intruding  in  fundamental  rights  (something  that  SME  representatives 
highlighted during the stakeholder consultation).  

153 

 
 
 
ANNEX 7: CONCLUSIONS OF THE EVALUATION 

The  links  between  the  conclusions  of  the  ex-post  evaluation  and  the  impact  assessment  are 
summarised in the table below. 

Main ex-post evaluation conclusions 

How it is covered in this IA 

Conclusions on effectiveness 

The  degree  of  harmonisation  differs  between  RIS 
technologies.  RIS  technologies  are  not  utilised  to  the  same 
extent  in  all  countries  and  river  corridors.  Monitoring  of  the 
implementation  of  the  Directive  is  weak.  There  is  no 
indication  of  a  modal  shift  towards  inland  navigation 
occurring as a result of the RIS Directive. 

Conclusions on efficiency 

Policy  measures  are  defined:  to  strengthen  the 
degree  of  harmonisation, 
to  further  align 
Member  States’  implementation  of  RIS,  to 
strengthen 
the 
implementation, and to improve the role of RIS 
in  supporting  the  integration  of  IWT  in  the 
multimodal chain. 

monitoring 

the 

of 

The findings show that there is potential for simplification, to 
address  the  slow  update  and  adoption  process  of  technical 
standards. 

Policy  measures  are  defined  to  simplify  the 
update and adoption of technical specifications. 

Conclusions on relevance 

The RIS Directive and its implementing acts are still relevant; 
however,  its  primary  focus  on  the  safety  of  navigation  is  no 
longer  sufficiently  aligned  with  the  sector’s  needs.  More 
specifically,  it  does  not  support  the  need  for  improving  the 
efficiency  of  inland  waterway  transport  and  its  integration 
into  the  multimodal  supply  chains.  In  addition,  it  does  not 
sufficiently  address  new  technological  challenges,  such  as 
automation  of  vessels,  and  the  further  digitalisation  of  the 
sector. 

Conclusions on coherence 

The  Directive  and  its  implementing  acts  form  a  consistent 
legal framework. Both internal coherence and coherence with 
other EU legislation is ensured. 

Conclusions on EU added value 

The rationale for public intervention at EU level through the 
RIS  Directive  is  rooted  in  the  cross-border,  international 
character  of  the  inland  waterway  transport  sector  and 
contributes  to  avoiding  fragmentation  between  different 
national  or  regional  (e.g.  between  the  River  Commissions) 
RIS implementation approaches. Stakeholders considered that 
the  same  benefits  could  not  have  been  achieved  by 
comparable  interventions  at  the  international,  regional  or 
national level.  However, higher benefits of digitalisation and 
data exchange are hindered by the  lack of full harmonisation 
of data provided across the Member States. 

Source: Ramboll et al. (2024), impact assessment support study 

Policy  measures  are  defined  to  increase  the 
IWT  multimodal  potential,  its  efficiency  and 
technological challenges. 

The  proposed  measures  are  coherent  with  the 
RIS Directive and with other EU legislation. 

Several  policy  measures  are  defined  to  further 
align  Member  States’  implementation  of  RIS, 
which  would  result  in  even  further  integration 
of RIS. 

154 

 
 
 
 
ANNEX 8: EFFECTIVENESS OF THE DIFFERENT POLICY OPTIONS 

This annex provides more detailed explanations on the assessment of effectiveness of the policy options, complementing the analysis in section 
7.1. 

Key impacts expected 

 

 

O 

✓ 

✓✓ 

✓✓✓ 

Strongly negative 

Negative 

No or negligible 
impact 

Positive 

Moderately positive  Strongly positive 

Unclear 

Specific policy objective 1: Ensure improved RIS data availability, and harmonised standards  

PO-A 

PO-B 

PO-C 

increase 

Expected 
in 
harmonisation  of  RIS 
between Member States 

Positive 
harmonisation of RIS.  

impact 

on 

increasing 

the 

Strong  positive  impact  on  increasing  the 
harmonisation of RIS.  

Strong  positive 
harmonisation of RIS. 

impact  on 

increasing 

the 

The  introduction  of  interpretative  guidelines 
for  the  implementation  of  RIS  (PM1)  is 
expected to reduce the problems and increase 
the level of harmonisation of RIS. The impact 
is  however  expected  to  be  limited  as  the 
guidelines  are  not  mandatory  and  may  not 
address all issues. This is supplemented by the 
(PM2) 
complaint 
through which vessel operators will be able to 
identify  areas  where harmonisation  is  lacking 
and signal this to the relevant authorities. It is 
expected  that  authorities  will  take  corrective 

handling  mechanism 

PO-B  shares  the  same  benefits  as  PO-A  in 
terms  of  improving  harmonisation  thanks  to 
the  complaint  handling  mechanism  (PM2), 
data  availability  in  ERDMS  (PM6),  and 
CESNI (PM10). In place of guidelines, PO-B 
is  strengthening  the  requirements  for  RIS 
index  and  introduces  technical  specifications 
for  navigation  and  voyage  planning  (PM4). 
An important step forward is  making the RIS 
COMEX  the  main  data  exchange  platform 
(PM9)  as  this  will  create  a  “one-stop-shop” 
solution  for  RIS  users  and  de-facto  increase 

155 

technical 

specifications 

PO-C  will  integrate  the  benefits  of  PO-A  and 
PO-B  and  in  addition,  by  requiring  electronic 
voyage  plan  reporting  (PM5)  and  setting  the 
it  will 
relevant 
strengthen  the  harmonised  implementation  as 
regards  this  information.  Unlike  PO-A  and 
PO-B,  PO-C  will  base  the  monitoring  of 
implementation  on  a  specific  performance 
monitoring  framework  (PM3)  that  will  be 
designed  to  collect  the  necessary  information 
(including  technical  data)  that  would  point  to 
to  be 
areas  where  harmonisation  needs 

 
 
 
 
 
action,  thus  further  increasing  harmonisation. 
Both  these  measures  are  expected  to  have  a 
limited  positive  impact  on  the  time  vessel 
in  preparing  a  voyage. 
operators  spend 
Furthermore,  requiring  Member  States 
to 
provide  regularly  data  to  the  ERDMS  (PM6) 
will  increase  the  quality  of  the  underlying 
information  provided 
the  users.  The 
nomination  of  CESNI  for  developing  RIS 
technical specifications (PM10) is expected to 
increase  the  rate  of  development  of  new 
technical  specifications  and  ensure  that  they 
are up-to-date.  

to 

harmonisation  as  interactions  will  now  take 
place  through  this  platform.  As  this  platform 
is  already  used  on  voluntary  basis  in  the 
baseline, the benefits compared to the baseline 
are expected to be limited. However, the legal 
certainty  that  comes  with  the  requirement for 
its  use  ensures  harmonisation  as  interaction 
with  national  systems  will  be  limited  if  not 
completely replaced. 

transport  management 

improved.  In  addition,  Member  States  will  be 
required  to  share  all  necessary  data  for  traffic 
cross-border 
and 
(PM15) 
the  need  for  re-
submissions  of  reports  to  different  national 
systems.  

thus  reducing 

Specific policy objective 2: Facilitate the integration of IWT into the multimodal chain 

Expected increase in IWT 
operation performance 

Positive impact on increasing IWT operational 
performance.  

Moderate  positive 
operational performance. 

impact  on 

increasing 

Strong 
positive 
operational performance.  

impact 

on 

increasing 

the  harmonisation  problems 

The  introduction  of  guidelines  (PM1)  will 
reduce 
in 
implementation  among  Member  States.  As  a 
results vessel operators will be faced with less 
information  and  procedures, 
inconsistent 
which  will 
their  operational 
performance and reduce efforts. 

facilitate 

PO-C  includes  the  same  benefits  as  PO-B.  In 
addition,  by  requiring  electronic  voyage  plan 
reporting  (PM5),  it  will  allow  competent 
authorities  to  better  manage  traffic  which  in 
turn will allow vessel operators to navigate  in 
a  more  efficient  manner  which  translates  in 
reduced  fuel  consumption.  Overall,  in  PO-C 
CO2  emissions  are  projected  to  decrease  by 
832.1 
tonnes  during  2025-2050 
(cumulatively), relative to the baseline.  

thousand 

to 

the 

and 

new 

Index 

improve 

PO-B  is  expected  to  increase  the  operational 
performance  of  IWT  as  the  strengthening  of 
RIS 
technical 
specifications  on  navigation  and  voyage 
planning  (PM4),  and  the  increased  links  with 
the  systems  of  other  modes  (PM14),  are 
expected 
the  planning  and 
efficiency of operations, which will ultimately 
lead  to  better  inclusion  of  inland  waterways 
transport 
logistics  chain.  These 
measures  are  estimated  to  lead  to  a  shift  of 
freight from road transport to IWT, estimated 
at  0.38  billion  tkm  in  2030  and  0.45  billion 
tkm  in  2050  relative  to  the  baseline.  As  a 
result,  CO2  emissions  are  projected 
to 
decrease  by  389.1  thousand  tonnes  during 
the 
2025-2050  (cumulatively),  relative 

into 

the 

to 

156 

 
 
  
 
 
 
 
increase 

in 
Expected 
exchanges  with  other 
transport modes 

Positive but limited impact on exchanges with 
other transport modes. 

Moderate  positive  impact  on  exchanges  with 
other transport modes. 

Strong  positive  impact  on  exchanges  with 
other transport modes. 

baseline.  

the 

In  PO-A  the  links  with  other  modes  are 
introduced  through  the  option  for  skippers  to 
submit 
information 
required  cargo 
(dangerous  goods)  though  an  eFTI  platform 
(PM7). This will allow authorities to consider 
transport 
this 
purposes.  To  the  extent  this  is  voluntary  and 
the potential for further use of this information 
is unknown this is expected to have a positive 
but limited impact.  

information  for 

intermodal 

requirement 

In  PO-B  the  links  for  data  exchanges  with 
other transport modes are improved. First, the 
use  of 
the  eFTI  platforms  becomes  a 
requirement for the exchange of the necessary 
cargo  information  (PM8).  In  addition,  PO-B 
introducing 
includes  a 
technical links with the systems used by other 
modes 
technical 
(PM14).  Furthermore, 
specifications for the exchange of information 
with  inland  ports  through  RIS  (PM12)  are 
introduced,  to  be  used  on  a  voluntary  basis. 
Finally,  harmonising  the  scope  of  RIS  with 
that of TEN-T (PM11) will provide a positive 
signal in terms of intermodality.  

for 

In  PO-C  the  links  for  exchanging  information 
with  other  modes  are  slightly  strengthened 
compared  with  PO-B,  as  the  exchange  of 
information  with  inland  ports  through  RIS  is 
mandatory  (PM13).  The  overall  impact  is 
however  considered  to  be  moderate  as  further 
steps  will  need  to  be  undertaken  by  other 
modes  (and  other  initiatives)  for  the  full 
impact to materialise. 

Specific policy objective 3: Ensure higher uptake and interoperability of digital solutions, and address data protection concerns. 

simplification 
Expected 
of  process  for  RIS  data 
exchange 

Positive  impact  on  the  simplification  of  the 
process for RIS data exchange 

Strong positive impact on the simplification of 
the process for RIS data exchange 

Strong positive impact on the simplification of 
the process for RIS data exchange 

PO-A  will  simplify  the  process  for  data 
exchange  as  through  the  use  of  updated 
technical specifications (PM10). Furthermore, 
by  clarifying  the  legal  basis  and  when  and 
how personal data can be handled by national 
administrations  (PM16)  will  result  in  further 
simplification of the process. 

PO-B  further  simplifies  the  process  of  data 
exchange, by introducing RIS-COMEX as the 
main  platform  (PM9),  as  now  RIS  users  will 
have  to  mainly  interact  with  one  platform 
instead of several national ones.  

157 

that 

In addition to PO-B, PO-C also harmonises the 
through  electronic 
voyage  plan  reporting 
means  (PM5)  which  should  facilitate  the 
processing of this information.  In  addition, by 
traffic 
requiring 
transport 
is  shared  cross-border 
management  data 
(PM15),  the  number  of  resubmissions  should 
be 
the 
reduced.  PO-C  also  envisages 
introduction  of  specific  forms  for  the  sharing 
of personal data (PM17) which would simplify 
the process. 

and 

 
 
 
 
Expected 
digital solutions 

uptake 

of 

Positive  but  limited  impact  on  the  uptake  of 
digital solutions. 

Moderate  positive  impact  on  the  uptake  of 
digital solutions. 

Moderate  positive  impact  on  the  uptake  of 
digital solutions. 

PO-A  will  have  a  positive  but  limited  impact 
on  the uptake  of digital  solutions.  The  use  of 
the  eFTI  platforms  for  the  exchange  of 
information  (PM7)  is  expected  to  provide  a 
simplified option to vessel operators. 

Source: European Commission 

as 

an 

In PO-B, the use of RIS COMEX (PM9) will 
the 
important  development 
be 
simplification  in  the  use  of  RIS  will  help 
vessel  operators  to  accept  digital  solutions. 
Furthermore,  as  reporting  dangerous  goods 
through eFTI (PM8) will become mandatory it 
will  de  facto  increase  the  use  of  digital 
systems. 
technical 
specifications  for  links  with  other  modes 
(PM14)  and  those  for  inlands  ports  (PM12) 
will  further 
the  digital  options 
increase 
available for RIS users. 

technical 

The 

PO-C  will  increase  the  uptake  of  digital 
solutions  relative  to  PO-B  by  introducing  two 
mandatory  elements,  namely,  the  required 
reporting  of  voyage  plans  (PM5),  and  the 
requirement  to  share  information  with  inland 
ports  (PM13).  Despite  these  measures,  the 
overall impact is still considered as moderate. 

158 

 
 
  
ANNEX 9: OVERVIEW OF RIS 

RIS  are  the  information  services  to  support  traffic  and  transport  management  in  inland 
navigation258.  RIS  aim  at  contributing  to  a  safe  and  efficient  transport  process  and  utilising  the 
inland waterways to their fullest extent. RIS are already in operation in manifold ways. RIS include 
interfaces with other transport modes on sea, roads and railways. Under the current legal framework, 
RIS does not include  business to  business  commercial  activities,  but  should be open to interface 
with  such  activities.  RIS  collect,  process,  assess  and  disseminate  fairway,  traffic  and  transport 
information so that they provide the following services:  

•  Fairway Information Services: Fairway259 information is one-way information: shore to ship 
or  shore  to  stakeholder’s  office  and  includes  geographical,  hydrological  and  administrative 
information related to the waterway infrastructure and fairways in the RIS area that is required by 
the RIS users to plan, execute and monitor a voyage. 

•  Traffic  Information Services: information  to support the safety  and  efficiency of traffic  and 

navigation on inland waterways. 

•  Traffic Management: operational service that supports traffic management processes in inland 

navigation. 

•  Calamity Abatement Support: operational service that facilitates the actions necessary to limit 

the consequences of a calamity (or accidents and incidents). 

•  Information  for  Transport  Logistics:  operational  service  that  supports  transport  logistic 

processes in inland navigation. 

•  Information  for  Law  Compliance:  facilitates  legal  compliance  for  the  waterway  users  and 

supports relevant agencies responsible for inland navigation law enforcement. 

•  Statistics: information on traffic  and transport  in  inland navigation that is  required  to support 

statistical processes. 

•  Waterway Charges and Harbour Dues:  information needed to facilitate the calculation and 

collection of waterway charges and harbour dues. 

The provision of RIS is based on four key technologies described below, and their relationship with 
the services is summarised below: 

•  Inland  Electronic  Chart  Display  and  Information  System  (Inland  ECDIS):  on-board 
computer system for the display of electronic inland navigation charts and additional information 
on the vessel’s  environment,  contributing to the  safety  and  efficiency  of  inland navigation  by 
reducing the workload of the skipper and increasing situational awareness.  

•  Notices  to  Skippers  (NtS):  The  Notices  to  Skippers  serve  to  communicate  information  from 
national and local fairway authorities regarding the waterway, such as the status of the inland 
waterway  infrastructure  (i.e.  bridges  and  locks),  failures  of  aids  to  navigation,  temporary 
blockages  of waterway  sections or  other types of infrastructure,  works,  water level  and water 
depth information, ice information and weather messages.  

•  Electronic Ship Reporting International  (ERI):  ERI  enables  electronic  data  interchange  for 

reporting purposes to and between competent authorities. 

258 Inland navigation relates to all types of inland  waterways such as rivers, canals, lakes, inland ports, etc. For 
simplicity,  the  terms  rivers  or  waterways  may  be  used  in  this  impact  assessment  report,  but  they  should  be 
understood as referring to the overall inland waterways. 
259 The fairway is the navigable channel in a body of water.  

160 

 
 
•  Vessel  Tracking  and  Tracing  System  (VTT):  VTT  supports  on-board  navigation,  Vessel 
Traffic  Management  (VTM)  from  shore,  calamity  abatement,  transport  management, 
enforcement and waterway dues and port infrastructure charges260.  

Figure 27: Relation between RIS and RIS key technologies 

Source: PIANC (2011) Guidelines and Recommendations for River Information Services 

Besides  the  RIS  key  technologies,  RIS  relies  on  basic  technologies  (such  as  radar  and 
radiotelephone services), which, for many decades, have been vital to navigation. 

The current RIS structure and its interconnection with other systems is summarised in Figure 28. 

260 This information exchange is supported by Inland AIS (Automatic Identification System), a broadcast system 
based on the transmission of very high frequency radio signals between shipborne AIS stations (mobile stations) 
and shore AIS stations. Each type of transmission is standardised to be transmitted and received by Inland AIS 
equipment. 

161 

 
 
 
 
Figure 28: RIS technologies and interconnections with other systems 

Source: European Commission (2017): Digital inland waterway areas. Towards a digital inland waterway area 
and digital multimodal nodes, Final report; Note: The dotted lines indicate mandatory 
systems/technologies/data exchanges which are widely implemented and used; the dotted lines indicate 
systems/technologies/data exchanges used by some actors 

162