AERRL and ALLRAIL support the European Commission’s initiative to revise Regulation (EU) 2016/796 on the European Union Agency for Railways (ERA). This revision represents a key opportunity to further strengthen the Single European Railway Area, accelerate market opening, and enhance the competitiveness, sustainability and innovation capacity of the European rail sector.

As representatives of rolling stock keepers, lessors, and independent passenger rail companies, we believe the Agency’s mandate must evolve to reflect market developments, technological transformation and the Union’s environmental and competitiveness objectives.

First, ERA should be explicitly mandated to support asset life optimisation and circular economy principles. Extending the lifetime of rolling stock through maintenance, upgrades, access to spare parts, software access and obsolescence management is essential to reduce costs, improve fleet availability and strengthen the business case for rail investment. A longer asset life directly enhances European competitiveness by lowering barriers to entry and improving return on investment for new market players.

Second, the revision should address the growing risk of premature obsolescence and spare parts unavailability. ERA should systematically assess how Technical Specifications for Interoperability (TSIs) impact asset lifetime, spare parts accessibility and upgradeability. Ensuring interchangeability and standardisation of key spare parts will improve resilience, sustainability and operational continuity across the sector.

Third, the Agency’s governance and technical work must reflect the evolution of the market. Rolling stock keepers have emerged as key actors in the European railway system, assuming significant responsibilities and making substantial long-term investments in rolling stock assets. Despite this central role, they are not explicitly represented among the stakeholders on the ERA Management Board. The revised Regulation should therefore ensure that they are formally included among the stakeholder representatives.

The roles and responsibilities of stakeholders should be clearly defined in technical recommendations and TSIs. Clarifying these roles is essential for safety, legal certainty and efficient cooperation.

Fourth, ERA should be required to assess the economic impacts of new technologies and ensure a fair balance between stakeholders. Innovation must not unintentionally distort competition or disproportionately favour certain actors. A stronger impact assessment methodology would help guarantee that technological progress supports equitable market growth and accelerates modal shift.

Lastly, the revision should clarify ERA’s role in assessing compliance of railway registers and relevant third-party databases with the Agency’s data standards, including semantic interoperability. As digitalisation accelerates across the sector, the proliferation of regulatory and market-driven databases risks creating fragmentation and inconsistent data models. Providing ERA with an explicit mandate to assess compliance with common Union data standards will help prevent semantic inconsistencies and support reliable cross-border operations within the Single European Railway Area.

Ultimately, the Agency’s core objective should be to contribute to increasing rail’s market share while ensuring safety, interoperability, sustainability and open competition. A more inclusive Agency with a mandate aligned with asset life optimisation, circular economy principles and competitive neutrality will support a dynamic, innovative and investment-friendly European railway market.