ITS UK responds to ORR draft Retail Code of Practice

Intelligent Transport Systems UK (ITS UK), the national industry association for transport technology, has responded to the Office of Rail and Road’s (ORR) draft Retail Code of Practice, published for consultation today (9 October). The code will set out how Great British Railways (GBR) must treat other ticket retailers once it takes on its retail role.

ITS UK welcomes the draft’s commitment to fair, transparent and non-discriminatory access to fares, retail systems and data. However, it has questions about why the code sits separately from GBR’s licence obligations on “seamless passenger travel”, and what this means for the Government’s ambition, set out in its Better Connected strategy, to create integrated, multi-modal journeys. ITS UK is also seeking clarity on how GBR Online Retail will engage with pay-as-you-go schemes, which are excluded from the code’s scope.

Max Sugarman, Chief Executive of ITS UK, said: “We welcome the ORR’s commitment to fair and open access to rail products, systems and data. We will respond to the consultation in full in due course, but from an initial reading, we are keen to understand how GBR Retail will work with the wider transport network to deliver integrated journeys, of which pay-as-you-go is a key part.

“If passengers are to continue benefiting from a thriving independent rail retail market, it is also vital that GBR competes on equivalent commercial terms with other retailers, with appropriate guardrails to ensure it cannot distort the market. We will be looking for that commitment to be reflected clearly in the final Code of Practice.”

Notes to editors

  • The ORR published its draft Retail Code of Practice for consultation on 9 October 2026. The code will be binding on Great British Railways through its licence under the Railways Bill.
  • According to the Rail Minister, Lord Hendy, independent retailers currently sell around 70% of rail tickets bought online. Investment from private sector retailers, has therefore supported much of the innovation in rail retail.
  • Intelligent Transport Systems UK (ITS UK) is the national industry association for transport technology, representing a sector worth £3.2 billion, supporting 45,000 jobs and providing £500 million in tax revenue each year. We provide a national platform to support the roll out of technology for a cleaner, safer and more effective transport network, both at home and abroad.