The package aims to support more sustainable rail and multimodal travel across Europe while improving the passenger experience. According to ECTAA, the measures could improve consumers’ access to rail services and encourage a more integrated European mobility market.
The association said the proposed Rail Ticketing Regulation could allow independent travel intermediaries to access rail content under fair, reasonable and non-discriminatory (FRAND) conditions. ECTAA noted that equal access to rail content could increase transparency, consumer choice and innovation in rail distribution.
ECTAA stated that consumers increasingly expect to compare and combine travel options across different rail operators, transport modes and ancillary services through a single platform. It added that better access to rail content is essential for building an integrated European mobility market.
However, the association also identified several concerns regarding the legislative proposals.
ECTAA argued that FRAND principles should not apply only to rail transport. It said similar anti-competitive practices are increasingly visible in air transport and other mobility sectors. The association referred to the recent Ryanair antitrust case in Italy as an example of dominant carriers imposing unfair commercial conditions on independent distributors.
“Ensuring fair access to rail content is an important and welcome step for consumers and independent travel distributors alike. However, the same market failures exist in air transport and should be addressed consistently. FRAND principles should apply whenever dominant operators impose unfair conditions on weaker market participants, regardless of the transport mode,” said Eric Drésin, Secretary General of ECTAA.
ECTAA also expressed concern about provisions requiring dominant railway undertakings to open their retail platforms to competing rail services in order to increase the visibility of new market entrants.
The association stated that while increased competition between rail operators could improve prices and service quality, the measures could also strengthen the market power of incumbent operators by turning their platforms into primary gateways for rail distribution.
According to ECTAA, this could accelerate market concentration by reinforcing the direct distribution power of dominant operators while weakening independent travel intermediaries that provide impartial comparison tools and transparency across multiple operators and transport modes.
The association warned that regulatory frameworks indirectly favouring vertically integrated dominant operators could reduce distribution diversity and undermine innovation over the longer term.
“We are concerned that some of the proposed measures could unintentionally create ‘super competitors’, to the detriment of independent travel intermediaries that cannot compete with the brand recognition and customer reach of dominant transport operators,” said Eric Drésin.
ECTAA also commented on the proposed MDMS Regulation, which aims to address the market power of certain MDMS providers in their relationships with transport operators.
The association stated that similar safeguards are not foreseen for dominant transport operators outside the rail sector. It added that this appears disproportionate given the higher concentration levels in transport markets, while the distribution market remains fragmented and largely composed of small and medium-sized enterprises.
ECTAA called on co-legislators to conduct a detailed assessment of the competitive impact of the legislative proposals and to avoid measures that could weaken independent distribution channels or further strengthen dominant market positions.
Tags: European Commission Eric Drésin, ECTAA
