Barclay Davies, Bus Users UK Director for Wales and a leading expert on the Rights of Passengers in Bus and Coach Regulations, has welcomed publication of the Post Implementation Review of the Rights of Passengers in Bus and Coach Transport (Exemptions and Enforcement) Regulations
Rights on paper are not enough: making bus passenger protection real is what truly matters
We contributed extensively to the Review which confirmed the Regulations remain broadly fit for purpose and should be retained. The Review also rightly affirms a fundamental principle: that bus and coach passengers are entitled to clear rights, protection from discrimination and effective routes to redress when things go wrong. It also recognises the continuing value of the existing enforcement framework, including the role of designated passenger bodies.
However, the Review also reinforces the long-standing truth: that rights that are not well understood, visible or easy to exercise, are rights in name only.
Awareness and accessibility remain critical gaps
One of the most significant findings of the Review is the low level of passenger awareness. Many people simply do not know what their rights are, how to raise concerns, or who to turn to when problems occur. This weakens the impact of the Regulations and leaves passengers without the confidence to challenge poor service or treatment
For Bus Users UK, this is not a peripheral issue. Passenger protection must be practical, accessible and actively promoted. We would like to have seen a commitment following the Review to launch a UK wide promotion of the rights. It should not depend on a passenger already knowing the system or having the time and energy to navigate it after something has gone wrong.
Enforcement must be clear and meaningful
The Review also highlights uncertainty around enforcement and complaints handling. While responsibilities exist in law, the experience for passengers can feel fragmented and unclear. Better signposting, greater consistency and clearer communication would go a long way towards building trust and ensuring passengers feel heard.
There is also scope to strengthen the passenger voice within enforcement processes, so that lived experience informs not only individual case handling but future policy and regulatory decisions.
Disability rights require more than compliance
The Review acknowledges that forthcoming and recent legislation, including requirements for disability awareness and assistance training, will help address some long-standing gaps. This is welcome and necessary.
However, training alone will not deliver equality. Disabled passengers continue to report barriers to travel, inconsistent assistance and a lack of confidence that their rights will be upheld in practice. Any future Review must place greater emphasis on outcomes and lived experience, not simply on whether obligations exist on paper.
Looking ahead: from retention to improvement
The conclusion that the Regulations should be retained provides stability, but stability must not mean complacency. There is a clear opportunity to build on the existing framework by improving passenger awareness, strengthening enforcement in practice and ensuring that passenger experience is central to future development.
There is scope to improve the Regulations to provide greater protection for passengers. The implementation of the Bus Services (No.2) Bill in England and the Buses Bill (Wales) will go some way to achieve this. The rights can be strengthened by accommodating rights seen across other modes such as covering delays on arrival of services rather than simply on departure and the thorny issue of lost luggage.
Bus Users UK believes that effective passenger rights depend on participation as well as protection. Passengers must be informed, listened to and involved if the system is to work as intended.
As the most used form of public transport in the UK, bus services deserve a regulatory framework that is not only legally sound, but genuinely passenger focused. Bus Users UK looks forward to continuing to work with government, operators and enforcement bodies to ensure that passenger rights are not just preserved, but understood, respected and delivered in practice.
Read the Review in full: PIR – Rights of Passengers in Bus and Coach Transport (Exemptions and Enforcement) Regulations