Under Regulation 34A of The Railways and Other Guided Transport Systems Regulations 2006 (ROGS), the Secretary of State for Transport is required to review the regulations at least every five years and to publish the results in a Post Implementation Review (PIR).
The purpose of a PIR is to assess the effectiveness of regulations after they have been in operation for a period of time. They are used across government to make sure regulations are meeting their original objectives and identify whether they could be improved in some way. The level of consultation and evidence gathering required for a PIR must be proportionate to the impact of the regulations being tested.
As of 2026, ORR has conducted three reviews of ROGS on behalf of the Secretary of State for Transport.
Third PIR of ROGS Collapse accordion Open accordion
In 2025, ORR carried out the third PIR of ROGS, on behalf of the Secretary of State for Transport. The focus of the review was whether ROGS (and the supporting Common Safety Methods) continues to be effective at achieving its objectives, in the context of the UK exiting the EU, wider rail reforms and the creation of Great British Railways.
Working closely with the Department for Transport (DfT), we conducted targeted consultation with key rail organisations and affected parties. In addition to seeking feedback on the effectiveness of key requirements under ROGS, we heard from stakeholders about how well the regulations worked for new and future technological changes in rail safety, including the use of artificial intelligence. We also took advice on how ROGS could be adjusted to fit the new rail landscape under the UK Government’s programme of rail reform.
Conclusions
The PIR found that ROGS continues to provide a good framework for railway safety, is working well and is continuing to meet its objectives.
The PIR report includes 11 recommendations for ORR and the Department for Transport, focused on addressing unintended consequences, enabling innovation and reducing the administrative burden of ROGS – all whilst maintaining high safety standards for Britain’s rail network.
These include two proposed amendments to ROGS, which will be taken forward by the Department for Transport:
- Removing the requirement for mainline operators to submit annual safety reports to ORR;
- Streamlining the safety certificate application and renewal process by consolidating Part A and Part B of the safety certificate;
The PIR report also recommended that the Department for Transport consult on the case for amending ROGS to require the integration of human and organisational factors (HOF) into the safety management system for domestic rail operators.
Additionally, ORR has been tasked with updating our suite of guidance and resources on ROGS and CSMREA to:
- Highlight how existing legal duties under ROGS and CSMREA apply to the safe development and deployment of digital technology, including AI;
- Provide greater clarity for entities in charge of maintenance (ECMs) on the post-Brexit regulatory framework in Great Britain, including duties, co-operation, and certification requirements.
ORR has begun the work of making the recommended updates, with amended ORR guidance and resources due to be published by the end of 2026.
Previous reviews Collapse accordion Open accordion
Since the introduction of Regulation 34A of ROGS in 2011, ORR has carried out two PIRs of ROGS:
- 2021 PIR of ROGS (second)
- 2016 PIR of ROGS (first)
Both of these reviews concluded that ROGS were working well, continued to meet their original objectives and had not led to significant unintended consequences. Each review identified minor regulatory changes and recommended improvements to ORR’s guidance on ROGS.