ORR review of train operators’ revenue protection practices –
Response from the RMT
Introduction
The National Union of Rail, Maritime and Transport Workers (RMT) is Britain’s largest specialist transport union and has more than 80,000 members from almost every sector of the transport industry including thousands of members working across the railway in roles that involve revenue protection and ticket examination duties.
We note with concern that trade unions are not listed by ORR as one of the bodies that it will be gathering evidence from as part of this review. It is vital that the views of the frontline workers who undertake revenue protection duties on a daily basis are properly considered during this review, and we would welcome the opportunity to engage further with the ORR and Government on this matter.
Executive summary
Rail workers whose roles involve revenue protection on-board trains and at stations are dedicated individuals who work hard to ensure that revenue is not lost from the publicly funded rail network.
Whilst most passengers are genuine fare-payers, there are those who deliberately and routinely seek to evade fares and this causes significant lost revenue to the public purse. It is therefore right that the rail industry seeks to recoup this lost revenue and deter fare evasion. RMT believes that there should be a consistent approach the rail sector to dealing with fare evasion and sufficient staff to properly tackle the problem.
It is clear that as a result of the privatised and fragmented structure of the railway, it is harder than it should be for many passengers to navigate the complex ticketing system, and the reforms introduced by the Government via Great British Railways (GBR) must address this. This would also make it easier to identify and address examples of deliberate fare evasion.
The presence of staff at stations and on-trains is vital to tackling and deterring fare evasion, but decades of policies under privatisation have sought to de-staff stations and trains and diminish dedicated revenue protection teams. This has made fare evasion easier and unaddressed in many areas on the rail network.
An increased presence of staff, coupled with a consistent and proportionate approach to revenue protection across GBR will help to address fare evasion, make staff safer and help
passengers to feel that the system is fair. This would also align with the Government’s goal of providing value for money.
RMT Revenue Protection member survey
RMT has thousands of members across the rail network in Britain whose roles involve some element of revenue protection. This includes revenue protection inspectors/officers, on-board staff such as guards, ticket examiners and train managers and station staff including those on gatelines. To help inform our response to the ORR’s review, we surveyed our members involved in revenue protection to ask for their views.
From our survey of around 4000 members working across the train operating companies covered by the review, it was clear there is significant variance in the experiences of the staff who undertake revenue protection which reflects the differing approaches taken by operators.
In terms of their company’s approach to enforcement and prosecution:
• Whilst the majority of respondents said they did not feel under pressure from management to report cases of fare evasion for prosecution, nearly 20% said they did.
• 40% of members said they thought their company took a proportional approach to prosecutions for non-compliance with ticketing rules. 25% thought they did not, and the remainder were not sure.
• Respondents were split 50-50 on whether they felt their company takes a proportionate approach to revenue protection and enforcement overall.
“Thecompanyprefertoreportpeopleforprosecutionratherthanissuepenaltyfares becausetheymakemoremoneyfromprosecutions.”
“Themanageralwayssaysmyprosecutionandpenaltyfaresarewellbelowthedepot averageandIcoulddobetter.”
Conversely, there were members who felt their company did not prioritise revenue protection sufficiently:
“Thegeneralideais‘don’tdelaytrainsforrevenueissues’”
“Theapproachneedstobefartougheronthoseintentionalindividualsovernoncomplianceofticketingrules”
“Thereisthesensethatthecompanywillneverbackyouupforenforcingticketingrules”.
There were members who felt their operator takes a proportional approach: “Weareneverputunderanypressuretomakedecisions.However,weareencouragedto ensurethatallcustomersaretreatedfairly,especiallyfromthepointofviewofthose customerswhoarefollowingtherules.”
“Ithinkmymanagementareverygoodattrustingmyprofessionalviewofasituationas towhetherprosecutionisappropriate.”
There was a strong view from members that there are insufficient staff employed to undertake revenue protection duties, and also a lack of presence from the British Transport Police (BTP):
“Thereisaninsufficientamountofrevenueprotectionofficersacrosssuchabusy network.”
“Foryearswehavehaemorrhagedrevenuebygettingridofstationticketinspectingstaff atentrancesandexitsofstations.”
“Thereisashortageofrevenuesupportstaff(whohavelegalpowersbeyondthoseofmy grade).Therefore,whenpassengersrefusetopurchaseaticketfortravelwhileonboard, theseniorconductorortrainmanagerhasnobackupforenforcement.Thisissueisnow exacerbatedbytheBTPdeclaringthattheywillnotattendtocallsfromtraincrewto assistwithafaredodger.”
“WehaveVERYfewrevenueinspectors.”
“Moreon-boardrevenueprotectionwouldincreasepayingcustomers’confidencethat everyoneisbeingtreatedfairly,andactasadeterrentforthoseseekingtoevadefares.”
• The vast majority of members said they are able to use their discretion when deciding how to deal with cases of non-compliance, although over half said they would like more discretion, for instance when customers appear to have made a genuine mistake.
“Ourdecisionsofdiscretionareneverquestioned”
“Ialwaysofferdiscretionandhelpcustomersintimeswheregenuinemistakeshavebeen made”
“Itwouldbegreattobeabletousediscretionopenlyandforanycircumstancesas necessary.Thiswouldreduceconfrontation/unnecessaryprosecutionsandimprove customerrelations”
“Alotofouroptionshavebeentakenaway,forexamplewecannolongerexcesspeople whoforgettheirRailcard”
“IwouldlikemorediscretionbutwhilstIamtargetedonmyperformanceitcan’thappen”
• Members overwhelmingly (88%) cited the Trainline as the most common point of sale for ticketing problems, followed by other online ticketing platforms (53%) and TVMs (38%).
“Sellingsplitticketscombiningadvanceandopenticketscausingconfusion”
“Trainlinesalescanbedeceitful:forexample,passengerbuysopenreturnbutreceiveda
QRcodeforadayticket.Anotherexamplewouldbethesaleofasplitticketwiththefirst partbeingoff-peakandthesecondadvancetickethourslaterwhichwouldtechnically meanthepassengerwouldneedtowaitforhoursatthesaidsplitstationforthesecond tickettobevalid.”
“Trainlinehasareputationforsellingincorrecttickets.”
“Trainlineappcanalsoselladiscountedrailcardticketwithouteventhepresenceofa railcard”
“Quiteoftenpassengersinputtheywanttobuyanopenreturn,tocomebackanyday withinamonth,andTrainlinesellsthemadayreturn.”
“Trainlineseemstobeabigissue,theyseemtosellticketswithouttellingthecustomer theterms,it’sallinthesmallprintwhichcanbehardtounderstand,plustheyseemto sellticketswhichsaytheyareopenreturnbutinfacttheyaren’tandtheysellticketsto trainswhichdon’texist.”
“Ifthere’severaticketproblemyoucanalmostguaranteethatit’sbeensoldbyTrainline, especiallyregardingsplittickets:whereachangeoftrainisinvolvedbutnot communicatedtothepassenger:splitticketswherepartofthejourneyisadvanceand otherpartflexible:returnticketsusingdifferenttraincompaniesandnotobvioustothe passenger.”
“Toooftenthirdpartyretailersletthecustomerdown.Ithenbecomethetargetoftheir frustration.TheissuelieswiththelikeofTrainline,who,bythewayarebyfartheworst thirdpartyretailer.”
“Around95%ofticketingissuesstemfromtheTrainlinealone”
• Over 80% of members said that the National Rail Conditions of Travel and railcard T&Cs are not well communicated to passengers.
• Nearly 60% said they do not think their company’s revenue protection policy is well communicated to passengers.
“Ifboughtataticketofficethenstaffwillexplain,butifTVMoronlinenotenough informationgiven.”
“Ticketingistoocomplicated,simplifytickets,clearcommunicationtothetravellingpublic, anddon’tallowthirdpartiestosellincorrecttickets.”
“Ifinditverycommonthatpeopledonotunderstandtherestrictionsthatapplytotheir railcards.Mostcommonwouldbeminimumfaresandthenumberofpassengersrequired fortherailcardtobevalid.”
“Manydon’treadthetermsandconditionsoftheirtickets.Thereshouldbeawayof checkingthatthepassengerholdsavalidrailcardbeforebeingabletopurchasea discountedticket.”
• Over 70% of members thought there should be differing approaches to non-compliance with ticketing rules depending on the severity of the case.
“Deliberateandfrequentevasionoffaresmustbetreatedasaseverecasetoprovidea deterrence.”
“Ifthereareregularfareevaderswhogetawaywithexcusesandnotbuyingaticket,they aretheoneswhoneedtobedealtwithseriously.Thepersonwhomakesagenuine mistakeonce,probablybecausetheticketingsystemissocomplicated,shouldbegiven discretion.”
“Asmallfarewithanhonestmistakecanbeletoffwithawarning,whereasaggressive andabusivepassengers,purposelynon-compliantshouldbemetwithstiffconsequences e.g.finesandcriminalcharges.Failuretodosoallowsthesepeopletocontinuetheir actionswherestafffacephysicalandverbalabusewithoutjustice.”
“Alldeliberatefareevasionneedstobedealtwithseverelytostopitcontinuingtoget worseandworselikeitisatthemoment.It’sneverbeensobad.”
• 92% of members thought it would be better for staff and passengers if there were a consistent approach to revenue protection and enforcement across the railway.
“Yes,standardisationacrossTOCs.Buttreatingtheindividualpassengeronacasebycase basis.”
“Yes,oneteamwithsetstandardsacrosstheindustry,centrallyemployedwithallthe sametraining,equipmentandthesamestandards.”
“IthinkTOCsalldealwithticketirregularitiesdifferently.Someerringmoretowards customerservice,somemoretowardsenforcement.Weshouldalsobeabletoissue penaltyfarenoticesmoreconsistentlyacrossallTOCs.”
“Havingastandardisedapproachtorevenueprotectionwouldbethemostfairsystemfor passengers.”
“Bettercommunicationandconsistentenforcementwouldgohandinhandtomakeit betterforbothpassengersandstaff.”
• Our members overwhelmingly reported facing anti-social and/or abusive behaviour when undertaking revenue protection duties, with 96% saying that they experience this.
“Everysingleday.Beenassaulted3timesinthepast12monthsincludingbeingspaton, threatstokillandcontinualverbalabuseeverysingleday.”
“Gatelinestaffarecontinuallyabusedandthreatenedwithviolence.”
“ProlificoffendersoffareevasionandASBarewellawarethatthecompanyinstructsusto avoidanyescalationwhendealingwithfareevasion.Aggressivebehaviourisusedasa
tactictoavoidenforcement.”
“Iwasthreatenedtodaywithhavingmyheadbashedin.It’sextremelyregularlythatI’m verballyabusedorthreatenedinsomeway.”
“Ihavehad4middleageddrunkmensurroundandattempttointimidatemeasItold theirfemalefriendstheirticketswerenotvalid.WrongTOCandwrongtimeonadvance tickets.”
“Thelevelofviolencehasincreasedmassively.”
“Youcanreceivealotofabusethesedays.Ithasprogressivelygotworseoverthelast510years,BTPareoftenunhelpfulandwhilstTOCssaytheyhaveproceduresinplaceto protectpeople,rarelyisthereanythingthereinpractice.”
• The majority of our members said they were encouraged to report instances of abusive behaviour they experience at work, but over 80% said their employer does not have sufficient mechanisms in place to protect staff from anti-social and abusive behaviour when undertaking revenue inspection duties.
“Weveryoftengetlittleornohelpwithanti-socialbehaviour/peoplewhorefusetopayfor tickets.”
“Thereseemstobeaverymuch‘getoutthereandgetonwithit’attitudewithverylittle protectionfromtheBritishTransportPolice.”
“NoCCTVon-boardourtrainssothepolicewon’tgetinvolved.”
We set out in more detail below what RMT considers to be the main issues in the current approach to revenue protection and how these can be addressed and our members better protected as the railway transitions to GBR:
Complexities in the ticketing system
It is universally acknowledged that the UK’s rail ticketing system is highly complex. As a result of decades of privatisation and the resulting fragmentation, there are a myriad of fares with different conditions, there are operator specific tickets and there are often multiple fares available for a single journey. For instance, in our survey, members cited examples of a single route having three different operator specific fares.
Whilst the terms of reference for the review state that wider ticketing reform is out of scope, it is impossible to consider the rail industry’s approach to revenue protection without considering it alongside the need for a more integrated rail fares system. Labour’s Plan for Rail1 acknowledges there is a ‘confusing array of fares’ and commits to introducing ‘more integrated timetables, ticketing and fares’ under Great British Railways (GBR) and ‘an ambition to introduce a best-price guarantee’.
1 https://labour.org.uk/wp-content/uploads/2024/04/GETTING-BRITAIN-MOVING-Labours-Plan-to-Fix-Britains-Railways.pdf
The complexities inherent in the ticketing system understandably can cause passenger confusion and increase the likelihood of passengers inadvertently purchasing an incorrect ticket. The complex ticketing system therefore also makes the job of revenue protection more difficult and also makes it easier for intentional fare evaders to ‘play the system’.
In our survey, many members also felt that the conditions associated with different fares and railcards were not always well communicated to passengers and that this could also be improved.
Inconsistent approaches amongst train operators
Again, as a result of privatisation and fragmentation, there are numerous rail operators, each with their own revenue protection policy, and it is apparent that there is significant variance amongst the approaches taken by different operators.
As our survey showed, some staff felt under pressure from their employer to report ticketing irregularities for prosecution, some felt their company did not take a sufficiently rigorous approach to revenue protection, and others felt their company’s approach was proportionate. Some members reported that they were not supported by their operator if they delayed rail services to deal with fare evasion issues. There were examples cited in our survey of two operators running trains from the same station but having significantly different approaches to enforcement.
Again, this lack of consistency increases confusion for passengers and adds additional pressures on revenue protection staff who must enforce the rules as instructed by their employer. This therefore puts staff at greater risk of coming into conflict when undertaking revenue protection.
The majority of our members reported they are able use their discretion when dealing with ticketing irregularities, although a not insignificant minority reported that they were not able to use discretion. There was a clear theme from the survey that staff felt the ability to analyse circumstances on a case-by-case basis and use their discretion to take the most appropriate response is important.
There was a distinct view expressed by members in that there should be a rigorous approach to intentional and/or repeated fare evasion, and many also expressed concern that they felt that deliberate fare evasion was becoming more widespread. The majority of our members felt that the severity of the response to ticketing irregularities should vary depending on the seriousness of the case, for instance, genuine mistakes compared to deliberate fare evasion. Again, this reinforces why ensuring that staff are empowered to use their discretion is important.
Staff undertaking revenue protection are skilled and trained professionals and it is absolutely right that they should be trusted by their employer to take what they believe is the appropriate and proportionate response to cases of ticketing irregularities. Furthermore, we expect employers to support their staff who take enforcement action in response to fare evasion, and it is not acceptable for staff to be penalised by their employer for doing so.
Whilst noting that the criminal justice system in Scotland is devolved, RMT believes that there should be a consistent and standardised approach to revenue protection across the network, which balances the need to protect fare revenue with the ability for staff to use
their discretion and educate passengers in cases of genuine mistakes. This approach would be supported by standardised training and procedures for staff to follow. Similarly, consistent signage and communications for passengers across the railway is also important to avoid mixed messaging. This approach to revenue protection will, of course, be much easier to achieve under a publicly owned and integrated railway and we believe the Government must ensure that this is one of the goals of GBR.
Problems caused by Trainline and third-party retailers
RMT has longstanding concerns about the practices of market dominant third-party retailer Trainline, and these are set out in detail in our briefing ‘On the gravy Trainline – how the ticket retailer rips of passengers and taxpayers’.2
Our report exposes an array of problems encountered by rail workers when assisting customers who have used the Trainline including: invalid tickets, more expensive tickets and incorrect timetabling and platform information. Trainline exploits the complexities in the ticketing system and defaults its sales to ‘splitsave’ meaning many journeys are split into a number of separate tickets, often with a mix of flexible and non-flexible advance fares. Yet the restrictions associated with these fares are not explained to passengers by Trainline, meaning many passengers travel on trains they think their ticket is valid on, when it is not. Our members, not the Trainline, receive the brunt of passengers’ frustrations when they find out Trainline has mis-sold them a ticket.
The problems caused by Trainline were also reflected in the findings of our revenue protection member survey. In this, Trainline was by far the most commonly cited point of sale for ticketing irregularities. Many of our members also highlighted concerns that Trainline and online ticketing had made fraudulent travel much easier, for instance, with some passengers only buying short journey tickets when already on trains if they encounter staff. Many members thought it is problematic that Trainline and other online ticketing platforms allow purchasers to add a railcard discount without verifying that they have a valid railcard. Whereas when tickets are purchased at ticket offices, staff will verify a valid railcard before applying the discount.
In addition, Trainline also charges a booking fee on most transactions, as well as charging commission on most sales. This is yet another example of passenger revenue being diverted away from the public purse. RMT believes that third-party retailers, and in particular Trainline is the cause of a lot of the problems encountered with ticketing irregularities and fare evasion, and the continuation of such retailers is ultimately not compatible with GBR. We note that the Government has recently confirmed it will unify its online retail ticket offering under GBR3. RMT believes that passengers would be best served by GBR developing a publicly owned and integrated ticketing system which maximises GBR’s capacity to directly provide the best value fares, as well as protecting and enhancing the vital role of rail staff.
Importance of staffing
The presence of staff at stations and on-trains is essential for ensuring that passengers are able to purchase the most appropriate ticket for their journey, and for deterring and identifying cases of fare evasion.
2 https://www.rmt.org.uk/news/trainline-accused-of-ripping-off-customers-anddeliberately/#:~:text=RMT%20General%20Secretary%20Mick%20Lynch,profits%20at%20the%20public's%20expense.%E2%80%9D 3 https://www.gov.uk/government/publications/great-british-railways-online-rail-ticket-retailing/great-british-railways-online-rail-ticketretailing
Yet, decades of privatisation have led to a significant de-staffing of the rail network, with continued attacks on ticket offices and station staffing, attempts to extend Driver Only Operation (DOO) and reductions in dedicated revenue support teams.
The result of this is that many passengers do not have the opportunity to buy the most appropriate ticket for their journey from a staffed ticket office and there are far fewer staff on the network to respond to fare evasion. This has created an environment whereby people who do intentionally fare evade do not feel it is likely they will be caught. This is reflected in Transport Focus’ recent research4 it published in response to ORR’s review:
“Forfareevaderstheamountofthepenaltyfareisalessimportantdeterrentthanthe chanceofbeingcaught.Thelowlikelihoodofbeingcaughtisoftenarationaleforfare evaders.Farepayingpassengersarealsooftenawareofthelowprobabilityofevaders beingcaughtandfindtheperceivedlackofeffortfromtherailwaystocollectfares dismaying…Asaresult,thelackofstaffatstationsandontrainsisanimportantissuefor manypassengers.”
Only around 11% of train stations are fully staffed, and a further 45% are only partially staffed. There is a concerning trend in that new rail stations, regardless of projected footfall, are consistently being built without ticket offices, despite the overwhelming response to the 2023 ticket office closure consultation showing how vital these services are for passengers. This means that many passengers do not have access to a staffed ticket office to purchase their ticket.
This creates significant barriers for many passengers and particularly affects certain groups including disabled and older people. Forcing people to use TVMs or online ticketing when they are digitally excluded or do not find these technologies accessible or userfriendly, therefore, also increases the likelihood that passengers may inadvertently end up with the wrong ticket. This was reflected in the Transport Focus research which “spoketo manypeoplewhomanyexperienceadditionaldifficulties,includingthosewhoaredigitally excludedandpassengerswithspecificneeds”and found that “manyinthesegroups prefertobuyticketsfromastaffedticketofficeratherthanonline”.
Unlike online ticketing platforms, ticket office staff will clearly explain the conditions associated with a fare to passengers. If they do sell split tickets at passengers’ requests, they will ensure that they are aware of the restrictions associated with this, they will advise passengers buying advance tickets which service they must travel on, check the validity of the railcard and ensure that the ticket sale abides by any restrictions relating to railcard, such as minimum fares.
In our member survey, there was a consistent theme that rail workers felt their employer did not employ enough dedicated revenue protection inspection staff, with many operators implementing short-sighted cuts to their revenue teams in past decades. This means that there are simply not enough revenue protection staff working on the railway to ensure a consistent presence. Significantly increasing revenue protection staffing would increase passengers’ likelihood of encountering revenue checks on the network and tackle the widespread perception that train operators do not take revenue protection seriously. The cost of increasing revenue protection staff would undoubtedly be met by the increase in
4 https://www.transportfocus.org.uk/publication/fare-evasion-and-revenue-protection-what-do-passengers-think/
revenue they would be able to recoup and from the wider shift in attitudes to fare evasion.
Furthermore, many members expressed concern that there were insufficient station staff employed by operators to staff gatelines, and therefore gatelines were routinely left open, further enabling fare evasion. RMT believes that rail operators, and the future GBR, must employ sufficient station staff to ensure that where gatelines are present, they are operational.
Anti-social behaviour and violence
Our survey showed overwhelmingly that rail workers experience anti-social and abusive behaviour when undertaking revenue protection duties and it is clear that there is a link between fare evasion and anti-social and abusive behaviour. There was also a view expressed by many members that both fare evasion and anti-social and violent behaviour are becoming more prevalent on the railway.
It was clear from our survey that our members feel that more needs to be done by employers to protect rail workers from abusive and violent behaviour at work. This includes ensuring that enforcement action is taken against perpetrators, ensuring that there are sufficient staff employed at stations and on-trains, an end to lone working, and having processes in place to support staff who are abused or assaulted at work. There should be consistent and strong messaging across the railway that there is a zerotolerance approach to abuse and violence against rail workers.
The recently announced cuts to British Transport Police5 are also of concern given that many of our members already report that BTP presence on the railway is patchy and insufficient.
Introducing a standardised approach to revenue protection across the railway should also help to reduce conflict situations by giving passengers a clearer understanding of how the railway responds to ticketing irregularities.
What can be done about fare evasion?
RMT believes that it is evident that the current approach to revenue protection across the railway is inconsistent and, in many instances, not as comprehensive as it should be, largely as a result of decades of understaffing and a lack of dedicated revenue protection roles. We are concerned that many of our members report that both fare evasion and associated abusive and violent behaviour is increasing.
We believe that the creation of a publicly owned and integrated railway via GBR provides the best opportunity to address the causes of this inconsistency and also create an environment where fare evasion is less prevalent, staff are safer, and passengers feel the ticketing system is fair and easier to understand.
Specifically, RMT believes that the following measures would improve the railway’s approach to revenue protection:
Fares reform and GBR:
Whilst future rail reform is not within the scope of this review, it is clear that a simplification and integration of the ticketing system should significantly reduce the
5 https://www.theguardian.com/uk-news/2025/jan/18/dozens-of-uk-transport-police-stations-may-close-despite-rise-in-assaults
likelihood of unintended ticketing irregularities; make cases of genuine fare evasion more obvious and support staff undertaking revenue protection duties. Many of the anomalies that have arisen as a result of privatisation and fragmentation such as the proliferation of split-ticketing, or operator specific tickets would be addressed through the creation of an integrated fares system as part of a publicly owned GBR.
RMT believes that the existence of third-party ticket retailers, in particular Trainline, which are well documented to routinely mis-sell tickets to passengers and also drain money out of the publicly funded railway in the form of commission and booking fees, are ultimately incompatible with GBR. RMT believes that the Government could explore ceasing granting third-party retail licences to retailers such as Trainline that routinely mis-sell tickets to passengers.
Consistent approach to revenue protection under GBR
The creation of GBR as a single employer should enable the creation of a standardised approach to revenue protection across the railway. It is vital that this standardised approach includes maintaining discretion for staff when dealing with cases of ticketing irregularities with a focus on identifying and taking the strongest action in response to repeat offenders (who are the cause of the biggest loss of revenue). We believe that GBR should also investigate the creation of central database for railcards and fare evasion incidents.
Staffing
It was clear from our survey, and from Transport Focus’ research that the presence of staff is vital for many passengers, both in terms of ticket purchasing and also maintaining a presence on the railway and demonstrating that the railway is being proactive in dealing with intentional fare evasion.
The creation of a standardised approach to revenue protection under GBR should also involve a significant expansion in staffing including expanding dedicated revenue protection teams, and at stations, including on gatelines. Increasing the staff available to recoup revenue supports the Government’s goal of delivering value for money.
The measures detailed above could help tackle the prevalence of anti-social and abusive behaviour, but it is clear from our survey that more action needs to be taken by employers to support staff at work. We expect employers now, and GBR in the future, to take and communicate to passengers, a zero-tolerance approach to abuse and violence towards rail workers and for action to be taken against perpetrators. Whilst outside the scope of this review, RMT believes that the Government should also legislate to create a specific offence of abusing or assaulting a public transport worker (mirroring existing legislation for emergency services).