Approval of Accessible Travel Policies (ATPs) for new franchises or new operators


All licensed operators must have an Accessible Travel Policy (ATP) to comply with their operating licence.

Guidance on ATPs

Our guidance forms the basis of ORR's review and approval of operators ATP. Operators should satisfy themselves that they meet all of the standards and criteria in this guidance.

The ‘Accessible Travel Policy’ condition of passenger and station operator licences requires licence holders to:

Establish and thereafter comply with:

  1. a statement of policy; and
  2. a detailed body of arrangements, procedures, services and other benefits to be implemented or provided by the licence holder designed to protect the interests of people who are disabled in their use of trains of which the licence holder is the operator pursuant to this licence and to facilitate such use (together ‘the Accessible Travel Policy’).

As per the licence condition, we can require licence holders to submit their ATP for review on an annual basis, and where evidence emerges that they are not being implemented appropriately or where we consider a material change has been made without approval.

Approval of ATPs

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New operators must obtain approval for their Accessible Travel Policy prior to a licence being granted. Drafts should be submitted to the ORR as early as possible for initial comment and at least ten weeks before the intended start of operations. ORR will aim to approve the documents at least two weeks prior to the start of operations.

The approval process takes approximately three months to complete and includes a four week consultation with the Disabled Persons Transport Advisory Committee, Transport Focus and/or London TravelWatch.

Once we have given our approval to an ATP we will publish a decision letter summarising areas of good practice and innovation, alongside a copy of the final ATP.

Review of ATPs

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Accessible Travel Policies must be reviewed by operators annually from the date of approval, or more frequently to ensure that they are as up-to-date as possible where there is a change in policy or procedure. ORR can also require the licence holder to carry out a review of the ATP or any part of it or the manner in which it has been implemented, with a view to determining whether any change should be made to it.

Operators must submit their ATP to the ORR for review at least six weeks before the anniversary of the date on which the ATP was initially approved. If the operator is proposing significant or material changes to their ATP, ORR will undertake a review and approve the revised ATP. Significant or material changes are where policy or procedure changes may have a significant impact, positive or negative, on a number of passengers. ORR will issue an approval letter to the operator, to which will be annexed a copy of the approved ATP. This will also be published on our website.

If the proposed changes are not material or significant, the operator must confirm this to ORR with a brief summary of the proposed changes. In these circumstances, ORR will not need to undertake a formal review and approve the changes.

Further information

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Following publication of the revised ATP guidance, operators must submit their ATPs to ORR by the end of 2019 in accordance with the schedule of ATP submissions below. Until we approve its ATP, an operator is obliged to comply with the commitments set out in its approved Disabled People’s Protection Policy.

We also require licence holders to provide us with a core set of data, in order to demonstrate that they are complying with their obligations to disabled passengers and managing their DPPP in accordance with published policies and procedures.

ATP submissions

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Week commencing Licence holder
10 June 2019 East Midlands Railway (new franchise)
16 September 2019 Scotrail
30 September 2019 TfL Rail
30 September 2019 Caledonian Sleeper
30 September 2019 Great Western Railway
30 September 2019 Network Rail
21 October 2019 Northern
21 October 2019 Hull Trains
21 October 2019 Heathrow Express
21 October 2019 London North Eastern Railway
21 October 2019 West Midland Trains
11 November 2019 Chiltern Railways
11 November 2019 Greater Anglia
11 November 2019 Transport for Wales Rail
11 November 2019 Cross Country
11 November 2019 Grand Central
02 December 2019 Southern, GTR
02 December 2019 South Western Railway
02 December 2019 TransPennine Express
02 December 2019 Merseyrail
16 December 2019 London Overground
16 December 2019 c2c
16 December 2019 London Underground