Govind Tekale
What the New Retail Code Means for Your Train Ticket Purchase
The Office of Rail and Road has launched a consultation on a draft Retail Code of Practice that will reshape how passengers buy rail tickets online when Great British Railways takes over. The practical effect is this: when GBR begins centralizing ticket sales, regulators are demanding protections to ensure you can still choose from multiple retailers rather than being forced to buy only from GBR’s own website.
Currently, 14 separate websites and apps from different train operators sell tickets, alongside independent retailers. Under GBR, one operator will control both the main retail platform and the underlying systems that competing retailers depend on—a structural conflict of interest. The proposed Retail Code of Practice is designed to prevent GBR from exploiting this position to squeeze out competitors and limit your options.
How GBR’s Dual Role Creates Risk
GBR will operate most passenger rail services and manage the customer offer across those services. It will also sell tickets directly to passengers through digital channels, at stations, and on board trains. Simultaneously, GBR will control the central IT systems, data processing infrastructure, and licensing framework that independent online retailers need to access fares and sell tickets. This means GBR will effectively act as both competitor and market operator.
The Retail Code of Practice requires GBR to provide all competing retailers with fair, transparent, and non-discriminatory access to these essential services and data. Critically, GBR cannot give its own retail operation an undue advantage through preferential access to fares information, system speeds, or other market functions.
Enforcement and Competition Protection
The regulator will monitor GBR’s compliance with the Retail Code through GBR’s operating licence, creating enforceable obligations rather than voluntary guidelines. If GBR violates the terms, ORR can pursue formal enforcement action. Additionally, GBR remains subject to existing competition law and cannot engage in practices that exclude competitors, distort the online retail market, or abuse its dominant position.
The Code also mandates that GBR manage conflicts of interest and protect commercially sensitive information from retailers. Market-wide decisions affecting all retailers must be made transparently rather than unilaterally in GBR’s favor.
Timeline and What Comes Next
The consultation opened on 9 October 2026 and closes on 11 December 2026. The ORR is actively seeking input from independent retailers, train operators, passenger groups, and consumer organizations. These responses will inform a final version of the Retail Code expected to be published in spring 2027, giving GBR and the rail industry time to prepare before the new regulatory framework takes effect.
What Stays the Same
Independent retailers will continue to operate much as they do now. Open access operators and devolved operators will retain the ability to sell tickets online. The change is structural: functions currently managed by the Rail Delivery Group—such as central IT system management, commission arrangements, technical standards, and retailer licensing—will transfer to GBR. The Retail Code ensures these functions operate fairly rather than being leveraged to benefit GBR’s retail arm.
For passengers, the immediate benefit is clarity. Rather than waking up to a single GBR platform with no alternatives, regulators are putting guardrails in place during the transition. Whether you book through a third-party app, an independent retailer, or GBR directly, the framework aims to preserve real competition and passenger choice as the rail system consolidates under one operator.
