Proposed modifications to the complaints handling obligations in rail operator licences

Consultation status
Conclusions published
Date of publication

Notice of statutory consultations on changes to modify the Complaints Handling obligations in the rail licences and Statement of National Regulatory Provisions (SNRPs).

On 20 October (see dropdown menu below) we published two statutory consultations setting out our proposals to modify the Complaints Handling condition in licences and SNRPs in two distinct ways: 

  1. Changes regarding licence holders’ complaints handling obligations; and
  2. Changes regarding licence holders’ membership of the relevant Alternative Dispute Resolution (ADR) scheme

Regarding the changes proposed under 1 above, all relevant licence/SNRP holders have given their written consent to the amended licence condition being incorporated into their respective licences/SNRPs. 

We have therefore issued a notice of modification to the complaints handling licence condition which sets out the modifications to licences and SNRPs listed in Schedules 1, 2, 3 and 4 of the notice. These changes will take effect from 1 April 2023.

The principal effect of these changes is that licence and SNRP holders will be required to establish and thereafter comply with a procedure for handling complaints that complies with ORR’s Complaints Code of Practice.

We will issue the outcome of the second consultation on changes regarding licence holders' membership of the relevant Alternative Dispute Resolution (ADR) scheme in due course. For now, the current requirements on ADR membership remain unchanged. 

October 2022 consultation

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Date of publication: 20 October 2022
Closing date: 21 November 2022

We recently published our conclusions to ORR’s Complaints Code of Practice consultation and conclusions on our future Rail Ombudsman operating model as part of the process for ORR to take on sponsorship of the Rail Ombudsman.

We are now publishing two statutory consultations seeking licence holders’ and SNRP holders’ consent to amend their licences to give effect to these policy conclusions. 

These statutory consultations set out our proposals to modify the Complaints Handling condition, and the reasons for these proposed modifications, in licences and SNRPs in two distinct ways: 

  1. Changes regarding licence holders’ complaints handling obligations; and
  2. Changes regarding licence holders’ membership of the relevant Alternative Dispute Resolution (ADR) scheme

We have published individual notices and response forms for Network Rail Infrastructure Ltd, London Underground Ltd, and Eurostar International Ltd. Other licence and SNRP holders should refer to the first notice and response form shown below. 

Please note that each notice covers the 2 changes listed above.  This is to allow responses (including consents, representations or objections) to be provided in a single document for each licence. We hope this will be more convenient for our stakeholders.  

These notices are also being sent to relevant licence and SNRP holders directly via post.

Responses should be emailed to by 5pm on 21 November 2022.

Publishing your response

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

Should you wish for any information that you provide to be treated as confidential, please be aware that this may be subject to publication, or release to other parties or to disclosure, in accordance with the access to information regimes. These regimes are primarily 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.

Under the FOIA, there is a statutory code of practice with which public authorities must comply and which deals, amongst other things, with obligations of confidence. In view of this, if you are seeking confidentiality for information you are providing, please explain why. If we receive a request for disclosure of the information, we will take full account of your explanation, 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.

If you are seeking to make a response in confidence, we would also be grateful if you would annex any confidential information, or provide a non-confidential summary, so that we can publish the non-confidential aspects of your response.

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 Data Protection Act 2018.


In responding to this consultation you consent to us:

  • handling your personal data for the purposes of this consultation;
  • publishing your response on our website (unless you have indicated to us that you wish for your response to be treated as confidential as set out above.)

Your consent to either of the above can be withdrawn at any time. Further information about how we handle your personal data and your rights is set out in our privacy notice.

Format of responses

So that we are able to apply web standards to content on our website, we would prefer that you email us your response either in Microsoft Word format or OpenDocument Text (.odt) format. ODT files have a fully open format and do not rely on any specific piece of software.

If you send us a PDF document, please:

  • create it directly from an electronic word-processed file using PDF creation software (rather than as a scanned image of a printout); and
  • ensure that the PDF's security method is set to no security in the document properties.