TEL TSI compliance for passenger railway undertakings

Under EU 2026/253, a passenger RU grants access to its passenger timetable and conditions of carriage via the national access points, and to its tariffs where a contract requires it. It gives distributors access to availability and reservation data through its attributing system where they have a contractual right. It sends path requests, the passenger train composition and, when necessary, train-ready messages, and it receives the train traffic messages from the infrastructure managers. The lead RU of a service also does the tasks of Art. 13(1).

Passenger and freight RUs share the operational messages for paths, train composition, train ready and train traffic. Passenger RUs also have data with no freight equivalent: passenger timetable, tariffs, conditions of carriage, availability and reservations, and on-board passenger information (Annex pt. 4). The timetable, the conditions of carriage and the tariffs go through the national access points, each under its own Creative Commons licence (CC BY-NC-ND 4.0 or CC BY-ND 4.0) or an equivalent or less restrictive licence. The PassengerTrainCompositionMessage also carries seating maps and the location of on-board facilities (pt. 2.5.1(15)).

They run from 2025 to 2029 (Appendix G). Passenger timetable data: 14 December 2025, already passed. Common reference data, conditions of carriage and security elements for product distribution: 13 December 2026. Passenger travel information during the journey: 12 December 2027. Implementation report to the Agency on train preparation, rail ticketing and rail passenger travel information: 2 March 2028 (Art. 17(2)(b)). Train traffic data and tariff data: 10 December 2028. Path requests and object identifiers: 4 March 2029. Availability and reservations: 10 June 2029. Train composition, train ready and readiness forecast: 9 December 2029. Two milestones of other actors affect you: connection times of the station managers (12 December 2027) and the common reference data for ticketing that the Agency manages (10 December 2028). MMTIS adds its own national access point dates: most fell between 1 December 2019 and 1 December 2025, and dynamic data off the comprehensive TEN-T network is due 1 December 2028.

The common interface is a specification, not a central platform. Except for rail ticketing and rail passenger travel information, every API and web UI that a telematics stakeholder deploys must follow ERA-TD-104 (Annex pt. 1.7(1); Appendix C, index [104]). For those two processes, the specifications of Annex Section 4 apply. You exchange the operational messages, such as path requests, train composition and train running, through these APIs and web UIs, and you use public key infrastructure in accordance with ERA-TD-106 (Annex pt. 1.3(b)). The national access points carry the timetable, the conditions of carriage and the tariffs (Art. 6). Availability and reservations go through a direct connection to your attributing system (Art. 6(4)). The ERA Ontology is the semantic model behind the message specifications (Appendix C, index [1]).

Each infrastructure manager sends you the train traffic messages for its network: train running information, train forecasts, delay causes and service interruptions. When your train causes a service disruption, you send the interruption message, or the forecast and delay cause messages, to the infrastructure manager of that network. All four messages follow the ERA Ontology (Appendix C, index [1]), and the infrastructure manager grants access to the data under CC BY-SA 4.0. Under the TEL TSI, SIRI (EN 15531-2:2022) applies to the travel information that you share with the stakeholders who manage connections to other transport modes, including the MMTIS dynamic data (Annex pt. 4.9(d)).

Sources: Art. 5(1)(b), Annex pt. 2.6.1, pt. 2.6.6 and pt. 4.9 of EU 2026/253.

No. The TEL TSI (Reg. (EU) 2026/253) governs the data exchange: the messages you send and receive for train composition, train readiness, train running, forecasts and interruptions. That is what this tool records. The operational obligations behind those facts come from the OPE TSI (Reg. (EU) 2019/773). For example, OPE point 4.2.3.3.2 requires the railway undertaking to inform the infrastructure manager when a train is ready for access to the network. TEL TSI Annex point 2.5.2 sets out how. The obligation is "deemed to have been fulfilled" without a message in two cases: the train is ready on time according to the working timetable, or Railway Mobile Radio (RMR) or the ETCS L2 "Start of mission" procedure is available as reported in the RINF and mandated by the infrastructure manager of the network of departure through its network statement. When the train is ready late, the railway undertaking must send a TrainReadyMessage. When it is ready early, it may send one. When it is not ready on time, point 2.5.3 also requires a TrainReadyMessage with the status "NotReady". Appendix A.2 of the TEL TSI Annex links train composition (point 2.5.1), train ready (2.5.2), train readiness forecast (2.5.3), train running (2.6.3) and train forecast (2.6.4) to their OPE points. Points 2.6.5 (train delay cause) and 2.6.6 (service disruption) refer to the OPE TSI in their own text. For those messages, OPE creates the duty and the TEL TSI defines the data exchange that implements it. This does not hold for every TEL TSI obligation: the electronic consignment note (point 3.1.1), for example, has no link to the OPE TSI.

The two are also demonstrated in different ways. The OPE TSI is a functional subsystem with no interoperability constituents (OPE point 5.2), and none of its requirements needs a separate assessment by a Notified Body. OPE requirements that refer to structural subsystems and are listed in its interfaces (OPE point 4.3) are assessed under the structural TSIs. Railway undertakings and infrastructure managers demonstrate OPE compliance within their Safety Management System when they apply for a new or amended safety certificate or safety authorisation, and the national safety authority then supervises it (OPE point 6.2.1).

So what you record here shows your readiness to exchange the data the TEL TSI requires. It is not a declaration of compliance: under TEL TSI Article 18, a presumption of compliance comes from a positive result in the web application that ERA provides. It also does not mean that your OPE obligations are met. Those belong in your SMS. Sources: Commission Implementing Regulation (EU) 2019/773 (consolidated version of 31.03.2025), points 4.2.3.3.2, 4.3, 5.2 and 6.2.1; Commission Implementing Regulation (EU) 2026/253, Article 18 and Annex points 2.5.2, 2.5.3 and Appendix A.2.