The OPE TSI still points to TAF and TAP. Here's what replaced them.

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Those are the two TSIs the TEL TSI (Commission Implementing Regulation (EU) 2026/253) repealed and replaced. An infrastructure manager who follows the OPE TSI's own cross-reference today lands on instruments that no longer describe the current telematics regime. This is not a criticism of the regulator or of ERA - cross-references between technical specifications go stale between legislative cycles, and this one plainly has. It is, however, a fact worth stating plainly, because nobody else currently does: if you're reading OPE 4.2.3.4.2.1(c) and looking for TAF or TAP, what you actually want is the TEL TSI.

The structural relationship

The reason the cross-reference matters at all is that OPE creates the operational duty; the TEL TSI carries the message that implements it. The two regulations are not competitors - they are two halves of the same operational fact, one setting the duty, the other specifying how it is communicated. TEL TSI recital 40 quotes OPE point 4.2.3.3.2 verbatim, and the TEL TSI's Annex tags the relevant message flows "pursuant to OPE TSI." The mapping, duty by duty:

• Train ready for network access - the duty arises in OPE point 4.2.3.3.2 ("The railway undertaking shall inform the infrastructure manager when a train is ready for access to the network"); the TEL TSI's TrainReadyMessage (Annex pt. 2.5.2) and readiness forecast (pt. 2.5.3) carry it.
• Train composition - the duty arises in OPE point 4.2.2.5.2 (route compatibility and train composition); the TEL TSI's TrainCompositionMessage (Annex pt. 2.5.1) carries it.
• Train running, forecast and delay - the duty arises in OPE points 4.2.3.4 (traffic management) and 4.2.3.4.2.1 (train position reporting - the very point that cites TAF/TAP); the TEL TSI's TrainRunningInformationMessage, TrainRunningForecastMessage and delay-cause data (Annex pt. 2.6.3–2.6.5) carry it.
• Service disruption - the duty arises in OPE point 4.2.3.4; the TEL TSI's TrainRunningInterruptionMessage (Annex pt. 2.6.6) carries it.

In each case, the underlying obligation to act - to inform, to report, to manage the disruption - is an OPE TSI matter. The TEL TSI does not create these duties; it standardises how they are communicated electronically.

The asymmetry

The relationship is not symmetric, and the asymmetry is itself informative. The TEL TSI formally interfaces with the OPE TSI - Appendix A.2 of the TEL TSI is a dedicated interface table naming the OPE TSI explicitly. The OPE TSI does not return the favour. Its own interface chapter, point 4.3, lists the subsystems it interoperates with: infrastructure (INF), control-command and signalling (CCS), rolling stock - locomotives and passenger (LOC&PAS) and freight wagons (WAG) - energy (ENE), safety in railway tunnels (SRT), noise (NOI), and persons with reduced mobility (PRM). Telematics does not appear on that list at all.

Put the two facts together and the picture is consistent: OPE was drafted, and last substantively cross-referenced on this point, before the TEL TSI existed in its current form. The TEL TSI, being the newer instrument, was built to reference OPE; OPE's interface chapter was not updated to reference back.

Why this matters operationally

The two TSIs are not just conceptually distinct - they are assessed through completely different routes, and conflating them creates real risk. The OPE TSI is a functional subsystem: point 5.2 states plainly that "in respect to the operation and traffic management subsystem, there is no interoperability constituent." Point 6.2.1 goes further: railway undertakings and infrastructure managers "shall demonstrate compliance with the requirements of this Regulation within their safety management system when applying for any new or amended safety certificate or safety authorisation," and "none of the requirements contained within this Regulation require separate assessment by a Notified Body."

The TEL TSI, by contrast, is a data-exchange regime assessed on its own terms - message formats, data quality, timeliness, the Common Interface. Getting your TEL TSI messages right does not discharge your OPE TSI duty, and 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 two regulations also don't share a timeline, and it's worth being precise about which date belongs to which. 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 - and 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's own core data-sharing obligations run on a separate, later schedule, culminating in full Common Interface deployment for the working timetable that enters into force in December 2029. An organisation tracking its TEL TSI deadlines should not read 15 December 2026 as one of them - and should not assume that meeting it satisfies any TEL TSI requirement.

What this tool does - and does not do

This tool assesses readiness for the TEL TSI's data-exchange obligations: whether your organisation is prepared to send and receive the messages the TEL TSI specifies, correctly formed and on time. It does not assess OPE TSI compliance, which - as set out above - has no Notified Body route and is instead demonstrated within your safety management system. A strong result here means your organisation is ready to exchange the data the TEL TSI requires. It is not, and cannot be, a statement about your OPE TSI obligations, which belong to a different regulation, a different assessment route, and in the case of the 15 December 2026 date, a different clock entirely.