The Competition and Markets Authority (CMA) has played a pivotal role in addressing issues through its reviews, including the Public Transport Ticketing Schemes Block Exemption (PTTSBE).
Public transport is an essential component of daily life in the United Kingdom, facilitating millions of journeys each day and contributing to economic productivity, social mobility, and environmental sustainability. However, the collaborative nature of ticketing arrangements among operators could sometimes intersect with competition laws, potentially raising concerns about anticompetitive practices. Such frameworks could allow operators to collaborate on multi-operator ticketing without breaching antitrust regulations, provided certain conditions are met.
In this article, we delve deeper into the background, the meticulous review process, and the far-reaching implications of the CMA’s findings.
Drawing on the latest developments as of early 2026, this piece aims to provide comprehensive insights in respect of the Public Transport Ticketing Schemes matter with the CMA.
The PTTSBE has reportedly been instrumental in enabling integrated ticketing solutions that could benefit passengers by simplifying journeys across different operators and modes of transport, such as buses, trams, metros, and ferries. Without such exemptions, operators might hesitate to collaborate due to fears of violating the Competition Act 1998 (CA98), which prohibits agreements that restrict competition.
The CMA’s review reaffirms the value of these schemes in a post-pandemic world where digital ticketing and mobility-as-a-service (MaaS) platforms are gaining traction. Introduced in 2001 under the Competition Act 1998, the PTTSBE provides an automatic exemption for agreements that establish Public Transport Ticketing Schemes, allowing operators to collaborate without falling foul of the Chapter I prohibition on anticompetitive agreements.
This exemption is crucial because it recognises that certain collaborations can deliver overriding benefits to consumers, such as reduced transaction costs, improved accessibility, and encouragement of public transport use over private vehicles, thereby aiding in reducing traffic congestion and carbon emissions.
Over the years, the PTTSBE has undergone several amendments to adapt to changing industry dynamics. Key updates reportedly include the 2005, 2011, 2014, and 2016 Orders, which refined its scope and conditions. Prior to the recent review, the Office of Fair Trading (predecessor to the CMA) conducted assessments in 2003-2005 and 2010, leading to extensions.
In 2015, the CMA recommended a ten-year renewal until February 28, 2026, highlighting the ongoing need for legal certainty in ticketing collaborations. At its core, the PTTSBE covers five main categories of ticketing agreements: Through Tickets (TTs) for complementary services on specific journeys; Multi-operator Individual Tickets (MITs) for competing services on a chosen journey; Multi-operator Travel Cards (MTCs) for multiple journeys across non-substantially similar routes; Short-distance Add-ons to extend local tickets; and Long-distance Add-ons linking local schemes to longer routes. These schemes must be written agreements open to qualifying operators on objective, transparent, and non-discriminatory terms. They cannot restrict operators from offering their own single-operator tickets or limit service frequencies unless essential for connections.
For example, in urban areas like London or Manchester, MTCs such as daily or monthly travelcards could allow passengers to hop between buses and trams operated by different companies, fostering a network effect that boosts ridership. Similarly, TTs can enable seamless transfers on non-competing routes, such as from a local bus to a ferry.
The CMA’s review concluded that Public Transport Ticketing Schemes remain vital for delivering consumer benefits, including seamless integration, reduced fares through bundling, and legal certainty for operators engaging in pro-competitive collaborations. Key findings highlighted that the PTTSBE effectively meets the criteria under section 9(1) of CA98, with benefits outweighing any restrictions on competition. Notably, the decision to remove the fixed expiration date via the 2025 Amendment Order ensures long-term stability, preventing the risks associated with lapse, such as increased costs for operators and diminished ticketing options for passengers.
The exemptions can ensure these Public Transport Ticketing Schemes prioritise consumer benefits, like convenience and cost savings, while preventing abuses like undue price-fixing or market exclusion. Without the PTTSBE, operators might face lengthy individual assessments under section 9(1) of CA98, which could stifle innovation in areas like contactless payments or app-based ticketing.
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