Consultation on a framework for determining redress for booked assistance not provided

In October 2025, the Office of Rail and Road (ORR) published its response to a consultation on Accessible Travel Policy (ATP) Guidance redress requirements. This introduced a requirement for operators to determine redress on a case-by-case basis where booked passenger assistance has not been provided.  All operators’ ATPs have now been reviewed and updated to reflect this new requirement.

As part of its consultation response, ORR committed to undertake further work to explore wider issues raised during the consultation. These included whether additional guidance or a framework may be needed to support the determination of appropriate redress, as well as questions relating to scope, ownership of claims, and the handling of redress.

This consultation forms part of that programme of work. It seeks views on a proposed framework to support operators in determining appropriate redress where booked passenger assistance has not been provided.

The proposed framework (published alongside this consultation) was developed in concert with stakeholders, including Transport Focus, the Rail Ombudsman and train operators, and discussed at ORR’s Consumer Expert Panel and Accessible Travel Stakeholder Forum. It is designed to support:

• Consistent, fair, proportionate, and transparent redress decisions.
• Recognition of the impacts experienced by disabled passengers.
• Flexibility to reflect individual circumstances.
• Alignment with ATP Guidance and Ombudsman principles.
• Improved monitoring, learning, and confidence in the passenger assistance system.

The framework sets out the considerations operators may take into account when determining redress. It does not introduce prescriptive or enforceable requirements, replace existing regulatory obligations, or prescribe specific outcomes or levels of redress. The framework is not part of the ATP Guidance. We continue to consider that ORR is not best placed to issue guidance on financial compensation levels in the absence of legislation, and that claims should be considered on a case-by-case basis.

The proposed framework is not exhaustive. Operators may consider other relevant factors where appropriate.  It also sets out the expectation for how redress claims are handled, including that operators’ redress processes should align with the Complaints Code of Practice. 

Wider issues

Other issues raised—such as those relating to the scope of redress and the ownership of claims—are closely linked to wider questions about industry structure and accountability. These issues are not addressed in this consultation. We will explore how we could take them forward as part of further work alongside the development of Great British Railways (GBR).

Passenger Assistance plays a critical role in enabling disabled and older passengers to travel safely and independently. Where assistance is not delivered as booked, the impacts on passengers can be significant, including disruption to journeys, safety risks, and loss of confidence in the rail network.

Operators are required, as a condition of their operating licence, to establish and comply with an ATP, setting out what they will do to help disabled people use the railway. Our ATP Guidance requires operators to commit to providing appropriate redress to passengers where assistance has been booked but has not been provided as confirmed by the operator, due to a failure of the assistance service.

Redress refers to the steps taken by an operator to put things right for a passenger where booked assistance has not been delivered as booked.

Redress may take different forms depending on the circumstances of the case. This may include:

• financial redress, for example to reflect the seriousness of the incident or to reimburse costs; and
• non-financial redress, such as apologies, explanations, or actions to address underlying issues.

Non-financial remedies may play an important role in providing reassurance and rebuilding confidence where failures have occurred.

The accompanying document sets out a proposed framework to support operators in determining redress, in cases where assistance has not been provided as booked or agreed, and an operator has already determined that this is the case.

This section provides a high-level overview of the proposed framework, which is published in full alongside this consultation.

The framework brings together:

• core expectations guiding decision-making; and
• key considerations relating to:
  • the nature of the failure;
  • the impact on the passenger; and
  • the operator’s response.

These considerations include:

• the extent and nature of the failure;
• the impact on the passenger’s journey;
• personal and emotional impacts;
• the passenger’s dependency on assistance;
• operator conduct and communication; and
• whether the failure reflects repeated or structural issues.

The framework also sets out the expectation that operators will handle redress claims in a way that reflects the principles and processes set out in the Complaints Code of Practice (COP), including those relating to timeliness, accessibility, communication and transparency.

Operators should continue to comply with ATP-specific requirements relating to redress, including those concerning the ownership and transfer of claims, which differ from the requirements in the Complaints COP.

While ATP requirements on redress apply to failures of booked assistance, assistance failures may also occur when Turn Up and Go assistance has been agreed. Operators should ensure that such cases are appropriately considered through their complaints processes. In doing so, they may wish to consider the factors set out in this framework.

ORR and Transport Focus are undertaking further work to better understand industry practices and passenger experience of TUAG assistance.

The proposed framework is designed to advance equality of opportunity for older and disabled people by increasing the consistency, fairness, proportionality, and transparency of redress claim outcomes. We do not consider it impacts on other groups with protected characteristics.

ORR is not proposing a change in the requirement to provide redress; we are consulting on a new framework to help operators to meet their existing obligations to do so. We welcome comments on how the framework may be used to go further in advancing equality of opportunity for and reducing discrimination against groups with protected characteristics under the Equality Act. We will publish a full impact assessment alongside the final framework.

We plan to publish all responses to this consultation on our website.

If you want any information in your response to be treated as confidential, please state this clearly and explain the reasons why, for us to consider. If your response does contain information you would like to be treated as confidential, please include it separately where possible or provide a summary that does not contain confidential details so that we can publish the non-confidential parts.

Please be aware that all information sent to us may still be subject to disclosure in accordance with the information access rights granted by the Freedom of Information Act 2000 (FOIA), the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 (DPA) and the Environmental Information Regulations 2004 (EIR).

If we receive a request for the disclosure of information you have sent us that we have not published, we will aim to contact you so that we can take your views into account, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on ORR.

Use of your personal data

The legal basis for processing your personal data is that it is necessary for the performance of a task carried out in the exercise of an official function vested in ORR.

Any personal data you provide to us will be used for the purposes of this consultation and will be handled in accordance with our privacy notice which sets out how we comply with the UK GDPR and the DPA.

We will publish your consultation response, withholding or redacting confidential information where appropriate. We will not publish your personal data.

ORR staff may have access to your information for the duration of the consultation process. This will be no longer than a year’s duration and all information submitted in response to a consultation which has not been published on our website, will be deleted.

Artificial Intelligence (AI)

We may use AI to analyse consultation responses and identify key themes. Your name and contact details will be removed prior to the use of AI. The data will not be used to train or improve third party AI models and will remain under the control of ORR.