Where things go wrong, we want passengers to feel confident that they will be compensated for delays, can easily complain and that their complaints will be addressed. We want operators to use learnings from all complaints to drive continuous improvement in passengers’ experiences of rail.

Meeting minimum expectations

Operators report data on their performance in handling complaints and delay repay claims to us every month. We monitor this data to identify where we need to intervene to protect passengers.

This year, performance has been generally good. The industry average over the year has seen 97% of complaints responded to within 20 working days, which is our minimum requirement, and 73% responded to within 10 working days. Similarly, 99% of delay repay claims were processed within 20 working days. No individual operator has performed substantially worse than the average during the year.

We want to see operators self-reporting compliance risks and issues to us, as it provides assurance both that they understand their own performance and that they are proactively taking steps to come back into compliance. Several operators have alerted us to short term compliance issues during the year, together with their plans and timescales for recovery. This is welcome and means that we can make an early judgement about whether or when there is a need for further regulatory engagement, proportionate to the risks to passengers.

Continuous improvement

Operators should always be looking to improve their handling of complaints and delay repay claims, and they report to us annually on how they are doing that. 

To share good practice, in October 2025 we published a short summary of the steps that operators are taking to improve their complaints handling and delay repay claims processes.

The complaints continuous improvement reports demonstrated some good practice but there are areas that operators need to focus on to underpin a continuous improvement culture, including how they assess the experiences of the complaints process and the impact of improvements. 

For the first time this year, all operators were required to specifically consider disabled passengers’ experiences in their complaints continuous improvement reports. Some good practice examples that ORR encourage to be rolled out more widely include: 

• Examining the top complaint categories associated with accessibility, including passenger assistance, to establish any recurring issues.
• Setting up specialised teams to handle complaints about passenger assistance.
• Collecting information on passengers’ requirements/preferences in handling their complaint.
• Improving access and ways to communicate complaints, for example accessible webforms and use of accessibility services like SignLive and Aira. In addition, providing an Easy Read version of guidance on making a complaint.

On delay repay, we asked operators to focus on raising awareness of the scheme in innovative ways to maximise the number of passengers who know they can claim for delays, and to identify and address recurring issues that are driving passenger complaints about delay repay.

Our priorities for April 2026 to March 2027

We will:

• Assess the continuous improvements reports that operators are required to produce each year on their delay repay and complaints handling processes.
• Monitor operator performance using the data they report to us each month and our ongoing survey of passenger satisfaction with complaints handling, intervening where necessary.
• Continue to challenge industry to fully utilise the insight and learning that is generated through complaints handling.