Overview of operator
3.1 SWR is one of the largest train operators in the country, serving South West London, southern England, and the Isle of Wight. It provides for dense commuter flows alongside regional and leisure travel, with Vauxhall, Wimbledon, Woking and Southampton Central among the 187 stations it manages. Waterloo and Clapham Junction, both managed by Network Rail, are major stations served by SWR and where SWR is responsible for delivering assistance for all its services.
3.2 During April 2024 to March 2025, SWR handled 165.6 million passenger journeys and recorded delivery of 177,451 assists (79,520 pre-booked and 97,931 turn up and go (TUAG)). In terms of pre-booked assists, this represented a 21% increase on the previous year. It employed 5,497 full-time equivalent staff as of 31 March 2025.
3.3 On 25 May 2025, SWR transferred into public ownership, as part of DfT Operator Limited. It was therefore under different management during the time period when the operator’s Delivery performance was assessed.
3.4 Key statistics for all operators can be viewed on the ORR data portal.
Evidence of capability
Monitoring and reporting
3.5 SWR has access to a good variety of data sources to assess passenger assistance performance, for both booked and TUAG assists, including data from the central industry passenger assistance system, mystery shopping, complaints and feedback from users of the service.
3.6 Earlier this year, SWR commissioned an external review of its assistance delivery which, amongst other recommendations, highlighted a lack of passenger assistance performance review meetings to discuss this data. While we welcome that SWR took the initiative to commission a review, at the point we commenced our assessment no actions had been taken in response to the review’s findings and this weakness had not been addressed; more detailed monitoring and reporting remained limited to a broader station improvements workstream. This workstream appears to be an effective vehicle for delivering station-level improvements, but it is only in this workstream that key metrics which provide internal accountability for journeys where assistance is not provided appear to be discussed although these are not disaggregated to the station level.
3.7 The periodic and quarterly reports we have seen for senior managers, leaders and stakeholders are less insightful, focusing on a small number of metrics that either have limited value (such as assistance complaints as proportion of total complaints) or exclude key context and information. For example, its reliability metrics exclude certain ‘incomplete’ assists, such as those where the customer could not be located, which may limit the accuracy of performance reporting. We saw no evidence of reporting setting out where assistance performance needs significant attention, such as at stations with significant additional demand.
3.8 Overall, we are concerned SWR’s historic approach to monitoring and reporting lacks appropriate analysis, insight and transparency, and as a result decision-makers may be missing meaningful insights into true passenger assistance performance and so opportunities to improve.
3.9 On a more positive note, as our assessment has progressed SWR has shown a welcome appetite for and commitment to making better use of passenger assistance data to develop more meaningful insights and improvements. We welcome its plans do more in this area, building upon the findings of its external review.
Risks and mitigations
3.10 We received no evidence that SWR maintains an active risk or issue register for passenger assistance. SWR’s own external review also highlighted this as a critical gap and we saw no evidence that steps had been taken to address the issue. We consider this a key failure of governance.
3.11 This failure is compounded by the historic underutilisation of its own passenger assistance data, as referenced in our assessment of SWR’s monitoring and reporting. As a result, while specific issues affecting disabled passengers identified via complaints or mystery shopping may be mitigated, and peak demand planned for by station managers, long-standing risks that are well known to station staff and management remain unresolved. Examples include handovers at Waterloo between SWR and Transport for London, and high demand from cruise ship passengers at Southampton Central. It is perhaps indicative that we were told that SWR has in the past been unable to make a successful business case to address the risks at Southampton Central, though we understand proposals are now being considered to address this.
3.12 More positively, frontline staff appear confident in their roles and responsibilities. In addition, although not driven by a structured assessment of risks to assistance, SWR has recently introduced initiatives that have the potential to improve assistance delivery, such as enhancing lift reliability, greater use of the passenger assistance staff mobile application, and assisted boarding points.
Engagement
3.13 SWR’s accessibility panel meets quarterly, is independently chaired, and benefits from active member participation (including between meetings). However, members lack clarity on how their input influences decisions, and performance data is not shared with them.
3.14 Engagement with the operators SWR interacts with at the operational level appears generally positive but largely reactive, focusing on resolving complaints rather than proactively managing risks or improving services. Internally, SWR engages well with its guards and station managers; it also appears to take an active and collaborative role in cross-industry initiatives.
3.15 In summary, whilst we saw positive signs of engagement across a range of internal and external stakeholders, we saw little evidence of the sort of structured feedback loop mechanisms that would deliver continuous improvements and allow staff and stakeholders to see the results of their input.
Training
3.16 The written evidence we reviewed suggests that SWR has good oversight of the number of frontline staff receiving disability awareness training, both at induction and then a refresher within two years. While this evidence suggested most staff are receiving this refresher training online, awareness of this training amongst staff in focus groups was patchy with some suggesting they had not completed it for many years.
3.17 Whilst our assessment was underway, autism awareness training was being rolled out to all frontline staff. We welcome this positive initiative but are concerned that general awareness of passengers with specific needs was mixed, both in our focus groups and in our station visits, with some staff even questioning whether certain passengers required assistance. SWR has acknowledged this is an area that needs focus.
3.18 Unfortunately, SWR provided only limited evidence of updated training materials, but have assured us that induction training includes lived experience input. Feedback is collected from participants, but we found only limited evidence of how training outcomes are assessed or how feedback is used to improve materials. It is also unclear the extent to which training outcomes are monitored on an ongoing basis.
3.19 Overall, we consider that more needs to be done to ensure SWR’s disability awareness training is meeting the needs of staff and delivering the required outcomes. Non-visible disabilities are an area on which SWR should maintain its focus.
Next steps
3.20 Based on our assessment, we set out below our expectations of actions SWR should take to strengthen its capability to improve assistance delivery, building on the recommendations of its own external review.
Monitoring and reporting / risks and mitigations
1. Improve data categorisation, insight and ownership
SWR should enhance its use of existing data to generate more targeted insights at station and route level, with a particular focus the reliability of assistance. In particular, SWR should take action to reduce instances where customers are not found by staff and are therefore at risk of not receiving the assistance they need to travel. Its success metric should accurately reflect performance in this area. To support this process, we welcome the expansion of SWR’s mystery shopping programme; results should continue to be systematically analysed and used to inform service improvements.
2. Establish a formal risk register
SWR should develop and maintain a formal risk register that captures key risks associated with the delivery of passenger assistance services, along with appropriate mitigations. Each risk should be assigned a responsible owner and reviewed on a regular schedule. The register should be reviewed and updated frequently to reflect operational changes and emerging issues.
3. Enhance governance and reporting
Governance arrangements within SWR should be strengthened to ensure that passenger assistance performance is regularly reviewed and challenged at senior levels. Executive leadership should assure itself it has the right data analysis to carry out this assessment. This should be informed by the establishment of regular review meetings at working level, focused on passenger assistance. Insights from individual stations should be integrated into strategic decision-making processes to ensure that local challenges and successes inform broader delivery and are shared with industry.
Engagement / training
4. Strengthen feedback loops
SWR should make more effective use of its existing stakeholder engagement structures to gather and act on feedback related to passenger assistance. Feedback loops involving SWR’s accessibility panel, staff and external stakeholders must be reinforced, with clear evidence of how input is used to shape service delivery and training. The impact of feedback should be visible and measurable, helping to build trust and demonstrate responsiveness.
5. Strengthen training assurance
SWR must ensure robust tracking of both disability awareness training completion and effectiveness across all relevant staff groups. Training programmes should be reviewed to ensure inclusion of content that raises awareness of non-visible disabilities, ideally incorporating lived experience to deepen understanding. Completion of training should be linked to performance reviews to reinforce its importance, demonstrate understanding and ensure sustained behavioural change.