Briefing: What the Railways Bill means for the role of ORR

Annex A: the legal process for GBR appeals

A flowchart summarising the process for GBR appeals under the Bill and ORR's powers. If ORR upholds an appeal, the options available to it depends on the type of decision being appealed. For all types of decision, ORR can remit the matter back to GBR (potentially with directions as to its reconsideration). Some decisions can also be quashed in whole or in part. In the specific circumstances where GBR has committed an error of law, and there was only one lawful decision that it could have made if not for that error, ORR may substitute its own decision in place of GBR’s decision.

Published: 16 June 2026

Page last updated: 16 June 2026

Revision history

Version 1.2: Revisions to various sections for clarity and to update based on developments since first publication. Addition of appeals process flowchart in Annex A, 16 June 2026.

Version 1.1: minor updates to terminology and "Next steps", 16 January 2026.

Version 1.0: first published 20 November 2025.

Briefing: What the Railways Bill means for the role of ORR

Annex A: the legal process for GBR appeals

Revision history

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