Provides ORR’s emerging thinking and seeks stakeholder views on licence modifications which may be necessary or desirable in the context of rail reform.
Who should respond to this consultation?
This consultation will be of interest to:
- Railway licence holders who are expected to remain outside of Great British Railways (GBR)
- Owning groups
- Funders and specifiers of train services, stations, depots
- Devolved governments and devolved authorities
We also welcome views from other interested parties such as:
- Passenger and industry representatives
- Freight customers and other users of the services of companies licensed to operate railway assets
- Other rail stakeholders
Background
The Government intends to establish Great British Railways (GBR) as the railway’s integrated directing mind as well as the operator of the vast majority of infrastructure and most passenger trains and stations. GBR is expected to operate under a railway licence issued by the Secretary of State and enforced by ORR. Alongside GBR, a significant number of other “non GBR” operators of trains, stations, depots and networks will continue to hold licences issued, managed and enforced by ORR. This discussion document sets out ORR’s emerging thinking on how these non GBR licences may need to be modified to support rail reform.
This discussion document seeks feedback on ORR’s proposed approach to considering and making changes to non GBR licences. It represents the first stage of our engagement and is intended to inform further policy development. Feedback will help shape ORR’s formal policy consultation, which is expected to take place alongside the Department for Transport (DfT) consultation on the GBR licence in Autumn 2026. Subject to the passage of the Railways Bill, this would be followed by a statutory consultation on specific licence modifications, with the aim of notifying all non-GBR licence holders of the outcome of the statutory process ahead of GBR Day 1, when GBR’s licence becomes operational.
This document represents the first stage of our engagement on non GBR licence modifications. Responses will inform the development of our policy approach and the design of the subsequent formal consultation.
This document does not seek views on underlying Government policy. Stakeholders should engage with the relevant consultation processes on the substance of those specific policy proposals, including the content of the GBR licence (led by DfT) or the proposed Retail Code of Practice (led by ORR). Outcomes from those processes will inform ORR’s approach to non GBR licence modifications.
How to submit your response
ORR welcomes responses to this discussion document by 18 September 2026.
Responses should be submitted via ORR’s online form. Respondents may respond to individual questions and/or provide general comments and are not required to answer all questions. Responses may also be submitted by email to strategyandreform@orr.gov.uk.
ORR intends to publish responses to this discussion document and we may also share responses with DfT. Please let us know if you would prefer your response to be anonymous or if there is any sensitive information you wish to be redacted.
Publishing your response Collapse accordion Open accordion
We plan to publish all responses to this consultation on our website. We may also share responses with the Department for Transport.
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.