The OPE TSI still points to TAF and TAP. Here's what replaced them.
The OPE TSI sets the operational duties, and the TEL TSI specifies the messages that carry them. Here is how the two fit together.
What replaced TAF and TAP in the OPE TSI's references?
The TEL TSI replaced them. Commission Implementing Regulation (EU) 2026/253 entered into force on 2 March 2026 and repealed the TAF and TAP TSIs (Article 25(1)). Under its Article 25(2), references to the repealed Regulations, such as the one in OPE point 4.2.3.4.2.1(c), are construed as references to the TEL TSI. TEL TSI recital 40 restates the OPE duty to report a train ready for network access (OPE point 4.2.3.3.2). Annex point 2.5.2 implements it with the TrainReadyMessage where a message is necessary, next to RMR and the ETCS L2 ‘Start of mission’ procedure.
The hook
Open the consolidated OPE TSI (Commission Implementing Regulation (EU) 2019/773) at point 4.2.3.4.2.1(c) and it directs the infrastructure manager to provide train-position-reporting data:
Those are the two TSIs that the TEL TSI (Commission Implementing Regulation (EU) 2026/253) repealed and replaced (Article 25(1)). The OPE text has not been updated, so a reader who follows it arrives at two repealed regulations. The legal link still works: under TEL TSI Article 25(2), "References to the repealed Regulations shall be construed as references to this Regulation." If you read OPE 4.2.3.4.2.1(c) and look for TAF or TAP, read the TEL TSI.
"…according to Commission Regulation (EU) No 1305/2014 (Telematics Applications for Freight - TAF TSI) and Commission Regulation (EU) No 454/2011 (Telematics Applications for Passengers - TAP TSI) required in relation to train position reporting."
OPE point 4.2.3.4.2.1(c)
The structural relationship
For the flows below, the relationship is simple: OPE creates the operational duty, and the TEL TSI carries the message that implements it. The link is deliberate. TEL TSI recital 40 restates the duty in OPE point 4.2.3.3.2 and says that the ways to communicate train readiness should be limited and harmonised. The TEL TSI Annex tags the related message flows "pursuant to OPE TSI", and Appendix A.2 lists the links in a table. The four flows below are the main ones for train preparation and train reporting. Appendix A.2 has more rows, for example for object identifiers, capacity allocation and the historical record of train traffic data.
Train ready for network accessOPE 4.2.3.3.2TrainReadyMessage
OPE point 4.2.3.3.2 sets the duty ("The railway undertaking shall inform the infrastructure manager when a train is ready for access to the network"). The TEL TSI TrainReadyMessage (Annex pt. 2.5.2) carries it when a message is necessary: when the train is ready late, or when it is not ready (pt. 2.5.3). The duty is fulfilled without a message when the train is ready on time, or where RMR or the ETCS L2 ‘Start of mission’ procedure is available as reported in the RINF and the infrastructure manager of the network of departure mandates it in its network statement (pt. 2.5.2(1), (2)). Appendix A.2 lists pt. 2.5.3 under OPE point 4.2.3.4.2 (train reporting).
Train compositionOPE 4.2.2.5.2 · 4.2.2.7TrainCompositionMessagePassengerTrainCompositionMessage
Appendix A.2 links it to OPE points 4.2.2.5.2 (train composition) and 4.2.2.7 (ensuring that the train is in running order). The TEL TSI TrainCompositionMessage for freight services and the PassengerTrainCompositionMessage for passenger services carry it (Annex pt. 2.5.1).
Train running, forecast and delayOPE 4.2.3.4.2.1TrainRunningInformationMessageTrainRunningForecastMessageTrainDelayCauseMessage
The duty is the infrastructure manager's, in OPE point 4.2.3.4.2.1 (train position reporting, the point that names TAF and TAP). Appendix A.2 maps TEL TSI Annex pt. 2.6.3 and 2.6.4 to OPE point 4.2.3.4.2. The infrastructure manager, or the operator of a rail freight service facility, sends the TrainRunningInformationMessage, the TrainRunningForecastMessage and the TrainDelayCauseMessage (pt. 2.6.3 to 2.6.5). Point 2.6.5 is not in the A.2 table, but its own text refers to the OPE TSI, and OPE point 4.2.3.4.2.1(c)(7) requires an initial explanation of any single delay over 10 minutes.
Service disruptionOPE 4.2.3.4.2.1(b)TrainRunningInterruptionMessage
OPE point 4.2.3.4.2.1(b) requires information on service disruption. The TEL TSI TrainRunningInterruptionMessage carries it when the length of the delay is not known. When the length is known, the forecast and delay cause messages carry it (Annex pt. 2.6.6(2)). The railway undertaking sends these messages when the disruption comes from the operation of its train (pt. 2.6.6(3)). Its own OPE duty for this is in point 4.2.3.3.2: inform the infrastructure manager of any anomaly affecting the train or its operation.
The TEL TSI names the OPE TSI. The OPE TSI does not name telematics.
The relationship is not symmetric. The TEL TSI formally interfaces with the OPE TSI: its Appendix A.2 is a dedicated interface table that names the OPE TSI. The OPE interface chapter, point 4.3, lists the TSIs it interfaces with: infrastructure, control-command and signalling, rolling stock, energy, safety in railway tunnels, noise and persons with reduced mobility. Telematics does not appear on that list. The only OPE link to telematics is the TAF and TAP reference in point 4.2.3.4.2.1(c).
OPE point 4.3 · interfaces with
- Infrastructure
- Control-command and signalling
- Rolling stock
- Energy
- Safety in railway tunnels
- Noise
- Persons with reduced mobility
- Telematics · not listed
Related obligations, verified through unrelated processes
The two TSIs are also demonstrated through different routes.
For the OPE TSI, point 5.2 states that "in respect to the operation and traffic management subsystem, there is no interoperability constituent." Point 6.2.1 requires railway undertakings and infrastructure managers to "demonstrate compliance with the requirements of this Regulation within their safety management system," and states that "none of the requirements contained within this Regulation require separate assessment by a Notified Body."
For the TEL TSI, the Agency's web application checks individual messages, and a positive result gives a presumption of compliance (TEL TSI Article 18).
Getting your TEL TSI messages right does not discharge your OPE TSI duty. Satisfying your OPE TSI duty through your safety management system does not, by itself, mean your TEL TSI messages are correctly formed or timely. They are related obligations, verified through unrelated processes.
The dates run on different clocks
The 15 December 2026 date is an OPE TSI obligation, and the December 2029 date is a TEL TSI one. OPE point 4.2.1.2.3 (as amended by Commission Implementing Regulation (EU) 2023/1693) requires that train running information be provided digitally to train drivers by 15 December 2026. This is an OPE TSI obligation: a railway-undertaking-to-driver duty concerning working-plan information, with planned times updated up to departure. It is not a TEL TSI requirement, not an infrastructure-manager-to-railway-undertaking data exchange, and not a telematics obligation in the sense the TEL TSI regulates.
The TEL TSI has its own milestones in Appendix G, from 14 December 2025 to 9 December 2029. The main deadline is the working timetable for 2030, which applies from 9 December 2029 (Article 16(2)). Operators of rail freight service facilities have 12 more months (Article 16(3)). One TEL TSI milestone, 13 December 2026, falls two days before the OPE date. An organisation that tracks its TEL TSI deadlines should not read 15 December 2026 as one of them. Meeting it satisfies no TEL TSI requirement.
What this tool does, and does not do
The Companion is a readiness tool for the TEL TSI's data-exchange obligations. The register tracks whether your organisation is prepared to send and receive the specified messages, correctly formed and on time. The Companion does not assess OPE TSI compliance. OPE compliance has no Notified Body route and is demonstrated within a safety management system instead. A strong register here means your organisation is ready to exchange the data the TEL TSI requires. Such a result is not a statement about OPE TSI obligations. Those belong to a different regulation, a different assessment route, and, for the 15 December 2026 date, a different clock entirely.
Sources: Commission Implementing Regulation (EU) 2019/773 (consolidated text 02019R0773-20250331, as amended by Commission Implementing Regulation (EU) 2023/1693), points 4.2.1.2.3, 4.2.2.5.2, 4.2.2.7, 4.2.3.3.2, 4.2.3.4.2, 4.2.3.4.2.1, 4.3, 5.2, 6.2.1; Commission Implementing Regulation (EU) 2026/253, recital 40, Articles 16, 18 and 25, Annex pt. 2.5.1 to 2.5.3, pt. 2.6.3 to 2.6.6, Appendix A.2 and Appendix G.
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