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Nederlandse Spoorwegen

NS

NS is actief in de wereld van het openbaar vervoer.

Lobbying Activity

Meeting with Lara Wolters (Member of the European Parliament)

21 Oct 2025 · High-speed rail

Meeting with Lara Wolters (Member of the European Parliament)

15 Jul 2025 · European railway sector

Meeting with Anne Bergenfelt (Cabinet of Commissioner Apostolos Tzitzikostas)

15 Jul 2025 · Single European Railway Area

Meeting with Tom Berendsen (Member of the European Parliament)

25 Mar 2025 · Developments in railway policy

Meeting with Jeannette Baljeu (Member of the European Parliament)

21 Mar 2025 · Working visit NS Rotterdam

Response to Technical specification for interoperability relating to the telematics subsystem of the rail system

13 Mar 2025

The Commission has published a draft for the TSI Telematics Implementing Regulation. Nederlandse Spoorwegen has read the documents with great interest. We will try to respond succinctly. ERA published the TAF/TAP recommendations in January 2022 after 4 years of work by the ERA TAF and TAP working parties according to the TSI revision mandate (decision 2017/1474) and traceability of the modifications in the ERA CCM Revision tool. As first output an intermediate revision was included by amendment in TAF TSI in 2021. DG MOVE did not support the recommendations. Instead to grant an updated mandate to ERA, DG MOVE took over a large redrafting of the TAF/TAP TSI from mid-2023 with a completely new approach and without mandate. Since 2 years and after 7 versions of the Telematics TSI, the sector does not see any significant improvements with the new unjustified measures in particular: Change of nature of the TSI which is now more about making rail data public instead of exchanging or make available the information between the stakeholders; Very general wording and lack in details that lead to various interpretations and misunderstanding on how to implement; New structure of Act and Annex interconnected together, different of the usual and clear TSI structure, leading to difficulty to understand the requirements; From one version to the next, large modifications without concertation or new requirements not mature or even abolishment of requirements already implemented in TAF/TAP systems; Additional constraints put on the rail sector compared to all other modes (as freight on road); These issues concern all processes: RU/IM exchanges, freight services, retail and passenger services. That is due to the redrafting process of the TSI since mid-2023 where article 5 of the Interoperability Directive (drafting, adoption and review of TSIs) is no longer respected: ERAs role in drafting the content of the TSI has been taken over by DG MOVE; Modification of the scope without mandate; New or modified requirements without traceability via CRs and without justification of added value; No comprehensive discussion and study by the ERA working party with the experts of the sector and MSs; instead the EC Expert Group is used to discuss technical content that is not the aim (almost 10 EC EGs since mid-2023, that was never the case for other TSIs); No full impact assessment or cost-benefit analysis yet necessary considering the numerous modifications (the advisory note on impact was launched only very late in November 2024 that doesnt permit a correct assessment before vote planned in June 2025); No draft of a realistic and sustainable implementation plan without clear financing estimation and resources; Very late delivery of the Technical Documents yet necessary to assess the specifications to implement and unclear approval process of the TDs for the vote planned in June 2025; Implementation deadlines planned to be defined in the RISC of June 2025 without involvement of the sector in charge to implement. Implementing this TSI EN07, for the requirements beyond the ERA TAF/TAP recommendations of 2022, is for the moment impossible based on the current wording which is very general and interpretable in different manners, without common understanding of what has to be deployed, without justification of benefit, without realistic and sustainable implementation plan and without clear financing estimation and resources. The redrafting in a more understandable and realistic manner, including shifting the non-mature requirements as open points, is necessary to allow a cost-efficient and business-efficient implementation. It is not too late to establish a common writing team between EC, ERA, MSs and sector to achieve this redrafting with the criteria of openness, consensus and transparency. The attachments describe in more details some main issues and proposals (list not exhaustive). We hope you will take this feedback in account
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Meeting with Apostolos Tzitzikostas (Commissioner) and

17 Feb 2025 · Exchange of views with CER CEOs on the margins of the 18th European Railway award event.

Meeting with Lara Wolters (Member of the European Parliament)

5 Feb 2025 · Introductory meeting

Meeting with Lara Wolters (Member of the European Parliament)

21 Nov 2024 · Rail policy

Meeting with Wopke Hoekstra (Commissioner)

1 Jul 2024 · Introductory meeting with the CEO of NS

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

3 Jul 2023 · International connectivity and ticketing

Meeting with Tom Berendsen (Member of the European Parliament)

7 Mar 2023 · PSO guidelines - meeting with APA

Meeting with Tom Berendsen (Member of the European Parliament)

28 Feb 2023 · PSO guidelines - meeting with APA

Meeting with Frans Timmermans (Executive Vice-President)

29 Nov 2022 · boost of international passenger transport

Meeting with Barbara Thaler (Member of the European Parliament, Rapporteur) and Alstom and Société nationale SNCF

27 Jun 2022 · TEN-T

Response to Multimodal Digital Mobility Services

2 Nov 2021

NS realises that, while national journeys are quite easily arranged, today booking a train ticket for an international journey can leave much to be desired. Therefore, the railway undertakings of the Community of European Railway and Infrastructure Companies (CER) committed to improve international ticketing for rail in their Ticketing Roadmap. Passengers should have a seamless user experience when searching, selecting and buying their railway services. Booking a train ticket should be as easy as booking a flight. European railways have a plan to achieve many elements of the vision already by 2025 at the latest, which we believe is both an ambitious and realistic plan. We appreciate any support that the Commission can provide in helping us to reach it. In order to achieve seamless ticketing, sector-based solutions should be supported and considered as the starting point when improving multimodal ticketing. Rail is already working with other stakeholders, like ticket vendors, to ensure transparency and better service to our clients. It is also worth pointing out that no organization willing to join in these efforts was ever refused. Mobility providers should be allowed to freely negotiate their pricing policy and we do not agree that tickets could be re-sold at different prices without prior agreement. Under the same objective, through-tickets are mentioned as something lacking in rail services today. In EU legal obligations through-tickets already exist today and are already widely offered, while the sector solution Open Sales and Distribution Model (OSDM) is further facilitating through ticketing between different railway undertakings and ticket vendors. On top of OSDM, CER members have committed themselves to go beyond the current legislation, e.g. with the Agreement on Journey continuation (AJC). Furthermore, some European passenger operators have implemented the Hop On The Next Available Train (HOTNAT), which is open to all operators. Any kind of future legislation on this topic should take those agreements into consideration and not invent something new and not fit for purpose. We expect the Commission proposal to provide a legal framework to maximize efficiency and transparency of these solutions, without extra administrative burden. It should be more clearly stated that extra administrative obligations will not be put in the regulation as it would hamper the attainment of frictionless multimodal ticketing. Interoperability should be the first course of action in order to achieve cost effective solutions; only in extreme cases should standardization be an option, when ensuring EU-wide multimodal ticketing. We need to avoid the creation of only one or two online MMDMS platforms, which would automatically become gatekeepers, resulting in a platform economy with the risk of (paid) algorithms deciding which is the preferred mobility solution. The European Union should take the many challenges in regulating digital mobility services into account before proposing new regulation. While digitalization has eased the life of European citizens, it brought with it yet unsolved questions of transparency, both on the side of data collection and analysis, as well on the side of using that data to influence the consumer. We fully support the Commission objective to enhance the efficiency and sustainability of the transport system. It is a step into the right direction and informing passengers of the impact of their mobility choices is something the rail sector has been advocating for years. It is important to mention that only raising awareness has limited effects. To have a systemic and holistic approach to sustainable mobility, we need to achieve a full equal level playing field for all modes. Please note that safety, convenience, ease, speed and cost are all important elements for the passengers when choosing their mobility solution and there is no silver bullet when it comes to achieving modal shift.
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Response to Revision of ERA Fees & Charges

30 Sept 2021

Through this consultation contribution, the Dutch Railways (Nederlandse Spoorwegen; NS) would like to voice its disappointment in the recitals of the Commission Implementing Regulation (EU) 2018/764, as it will impact competitiveness of the rail transport sector as a whole. The Commission is of the opinion that fees and charges regime payable to the EU Agency for Railways (ERA) for these services have repeatedly shown a significant imbalance between costs and income, and therefore needs to be balanced. However, the proposed changes to the fees & charges payable to the ERA pose a significant financial burden on the sector. Not only does this decrease the competitiveness of the rail transport sector as a whole, but it also counteracts the objectives as set out in the European Green Deal and the EU Strategy for Sustainable and Smart Mobility (EUSSSM), which aim to stimulate the rail transport sector as one of the most sustainable modes of transport. The proposed increase of the hourly rates by almost 80%, from (€135 to €230), including the mandatory software (OSS) fee of €400 per application, pose an unnecessary burden to the rail transport sector. Combined with the introduction of charging for revoking an SSC or VA, these measures directly contradict the ambitions of the 4th Railway Package, which aims to improve interoperability while reducing administrative burdens. Over the last years, the ERA already has had its fair share of challenges. Should the Commission choose to follow through with this significant increase of the fees imposed on railway undertakings, NS expects that this shall be balanced with a corresponding increase of the quality of the tasks to be performed by the ERA, e.g., through a significant reduction of the delay for the proper processing of the different applications. However, at this stage we do not have reason to believe that, despite the intentions it expressed, the ERA will be able to commit to the higher standards that go hand in hand with the proposed increase in costs. NS would like to reiterate that it supports the Community of European Railway and Infrastructure Companies (CER) position in that it believes in the central role of ERA, supports its important work, and acknowledges that the costs of the European Union Agency for Railways must be covered. However, making the European railway sector pay for all costs, including several wrong decisions being taken by the European institutions in the past years, seems wrong.
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Meeting with Frans Timmermans (Executive Vice-President)

3 Dec 2020 · E-introduction/Rail in the European Green Deal

Meeting with Samira Rafaela (Member of the European Parliament)

10 Jan 2020 · Working visit