Background 

5.1    Northern performed poorly for reliability in our 2023 to 2024 survey. Eighteen percent of respondents reported they received none of the assistance they booked at Northern stations.

5.2    In July 2024 we engaged Northern setting out our concerns. We asked for analysis of what caused recent failed assists and the steps being taken to improve performance. Northern’s response did not reassure us that it understood its own performance, the causes of its failings, or that it had robust plans in place to secure improvements.

Improvement plan

5.3    In September 2024, we requested an improvement plan to demonstrate Northern was taking the necessary steps to comply with its ATP commitments. 

5.4    Northern submitted its plan on 4 November 2024 and we accepted it on 5 December 2024, following a thorough review. 

5.5    Northern gathered insight from a range of sources to inform its plan, covering both passenger and staff perspectives. Sources included customer complaints, mystery shopping exercises, post-travel surveys, insight from the Northern Accessibility User Group and data from the passenger assistance staff app. Northern set out 21 actions across five key themes to address the issues it identified were driving poor assistance outcomes.

5.6    The five themes were: 

• Policy and processes: to ensure consistency across the network
• Human factors: to ensure colleagues had the capability to deliver the service
• Disruption: to empower colleagues to adapt and respond to challenges caused by disruption
• Technology: to support consistency in service delivery and enable insight into quality performance
• Information: to ensure easy access to the information needed by customers and colleagues

5.7    Some of the actions that had the potential to have the highest impact and were therefore considered high priority included: 

• Producing an assistance policy specifically for Northern to underpin all other changes;
• Producing Passenger Assistance procedure guidance for key roles and bespoke for types of location (e.g. large station, small station and conductors);
• Reviewing the staffing model for assistance at the ten stations that provided the highest volumes of assists, starting with Leeds station;
• Establishing a new team dedicated to remotely supporting passengers who require assistance, including during their journey, using phone and WhatsApp;
• Piloting additional staff training on communication between boarding and alighting stations;
• Trialling a new process that enables passengers at unstaffed stations who have not pre-booked assistance to alert conductors to their presence;
• Working with staff and staff representatives to progress rollout of the passenger assistance staff app; and
• Ensuring that all reports of failed assistance are recorded, investigated and the root cause identified.

Progress to date

5.8    We reviewed progress via regular fortnightly meetings and carried out full reviews of progress against all actions in January 2025 and April 2025. 

5.9    Northern’s engagement throughout the process has been constructive. It has been receptive to ORR’s input and promptly provided any additional information or context requested by ORR on an ad-hoc basis.

5.10    Northern made good progress early on and generally delivered against the timescales in the plan. Any actions that slipped past their original delivery deadline were generally delayed no longer than a month and the reasons behind delays were always made clear and were reasonable. As such, at no point have we been concerned about the pace of Northern’s implementation. 

5.11    All actions are now complete. 

Current status

5.12    As all actions have now been delivered, we are monitoring passenger outcomes to establish what improvements to passenger assistance reliability the plan has secured. While we are mindful that it can take time for actions to translate to direct benefits for passengers, Northern’s staggered delivery dates means many actions have been in place for several months already. 

5.13    Northern is reporting to us on its progress quarterly. Its reports draw on data from Northern’s new failed assistance investigation process (currently Northern contact all passengers who have had a journey marked as incomplete in the passenger assist staff app and that it has contact details for), mystery shopping exercises (around 70 mystery shops are completed every four weeks), customer complaints data, and outputs from the passenger assistance staff app. Alongside, we are also continuing to monitor the responses to our own passenger survey.

Disability awareness training 

5.14    We introduced a new approach to monitoring compliance with disability awareness training requirements in April 2025, with all operators reporting key metrics to us every quarter. We received Northern’s first submission in August 2025, which reported that Northern had around 800 station and revenue protection staff that had not received disability awareness training. Disability awareness training for passenger-facing staff, with defined outcomes, has been a requirement of our ATP Guidance since 2021. Northern’s improvement plan had included delivery of some targeted staff training but had not identified or addressed this wider training need.

5.15    We requested a full recovery plan, setting out how Northern would ensure that station staff were able to meet the training outcomes set out in our ATP Guidance. The key elements of our request included: 

• A detailed description of how training would be delivered including, for example, which content would be delivered through face-to-face training sessions or e-learning, and who would deliver face-to-face training.
• A description of how disabled people had been involved in the development of course content and material, and how staff will hear from disabled people about their lived experience of using the railway.
• Copies of all training material being used.
• A trajectory showing, week by week, the number of staff to receive training.
• Dates and locations of planned training activities.

5.16    Northern responded to the request constructively and submitted an ambitious plan to deliver all outstanding training over a four-week period and by 31 October 2025, using largely face to face sessions at stations by a team of Passenger Assist Champions and Team Leaders.

5.17    On 4 November 2025, Northern reported it had fulfilled the plan, and all training had been delivered. 

Next steps

5.18    It is approaching 12 months since ORR accepted Northern’s passenger assistance improvement plan. We continue to monitor performance for sustained improvement to the reliability of passenger assistance delivery. 

5.19    Separately, in relation to the 800 station and revenue protection staff that had not received disability awareness training, we are opening a formal investigation into whether Northern contravened, or is contravening, Condition 5 of its Station Licence and GB Statement of National Regulatory Provisions (SNRP): Passenger.  

5.20    The scope of the investigation will include the following:

• The timeframe over which staff who had not received required training were interacting with disabled passengers, and the scale and impact of the issue;
• The circumstances that led to staff not receiving training when required and how the issue remained unresolved and unreported during this timeframe; and
• How Northern can assure itself, its passengers and ORR that i) the recent training has been effective and is enabling staff to meet the required training outcomes and ii) a similar situation will not arise in future.

5.21    The outcomes of this formal investigation could ultimately result in a finding of breach of Northern’s Station Licence and GB SNRP: Passenger, and if appropriate, formal action.