Dominant Rail Ticket Platforms Steer To Vertically Integrated Operators – It Is Time For Unbundling

▶ Recently, the EU Commission found Apple guilty of steering customers, bemoaning that “Apple’s App Store should be able to inform customers, free of charge, of alternative offers outside the App Store, steer them to those offers and allow them to make purchases.”

▶ Otherwise, “consumers cannot fully benefit from alternative and cheaper offers…”

▶ Sounds familiar? The EU state-owned rail incumbents’ dominant in-house ticketing platforms (such as SNCF Connect, PKP Intercity and DB Navigator) steer passengers as well – to their own trains.

▶ The only solution is unbundling the dominant rail tickets vendors from the dominant rail operators.

These platforms have Significant Market Power (‘SMP’) in the downstream B2C rail ticket sales market. For instance, the German Monopolies Commission found a few years ago that around 90% of online long-distance rail ticketing website visits went to DB’s website bahn.de* – with no evidence that this has changed since then.

In most cases, these platforms steer passengers to their vertically integrated rail operators that share the same brand – whilst refusing to sell independent operators. This then starves the latter of the exposure needed in order to achieve commercial viability.

But interestingly, on most cross-border routes, these platforms with SMP do sell the tickets of other state-owned rail operators – meaning that there is, in effect, an EU-wide collusion.

ALLRAIL Secretary General Nick Brooks warns: “Passengers need anti-steering regulation. This requires unbundling the vertically integrated sales platforms with SMP into new sales brands that will then sell all willing rail operators.

He adds: “Since independent rail ticket vendors are also in effect new brands, giving all types of ticket vendors equal access to the same rail operator data would finally lead to a level playing field in the B2C rail ticket sales market.”

* Monopolkommission (2021). Bahn 2021: Wettbewerb in den Takt! 8. Sektorgutachten gemäß § 78 ERegG (Eisenbahnregulierungsgesetz), para. 329 and Figure 6.2 (page 119). Link here.