The ambition was clear. A single European railway area where trains cross borders seamlessly, signalling systems interoperate without modification, and infrastructure managers work from a common rulebook. Twenty-five years of regulation, directives, and technical specifications later — how close are we?

Closer than we were. But far less close than we should be given the time and resources invested. And in some respects, the regulatory process itself has become part of the problem.

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The Fragmentation That Remains

ATP systems are the most visible symptom. ETCS was designed to replace the patchwork of national Automatic Train Protection systems with a single interoperable standard. Yet today, trains operating across Europe still routinely carry multiple onboard systems: KVB in France, PZB/LZB in Germany, ASFA in Spain, SCMT in Italy, ATB in the Netherlands, SHP in Poland — and that is not a complete list.

Each system has its own logic, its own interface requirements, its own certification process. A locomotive operating cross-border needs to be equipped and certified for every system it encounters. The cost and complexity of this is enormous — and it was precisely what ETCS was supposed to eliminate. The problem is not that ETCS does not work. It does, where it is deployed. The problem is the pace and consistency of deployment, which varies dramatically between member states and even between lines within the same country.

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A Proliferation of Assessors

One of the less-discussed consequences of the EU railway regulatory framework is the ecosystem of assessment bodies it has created — each with a defined role, each generating its own workload, and collectively creating a web of overlapping responsibilities that projects must navigate.

A typical ETCS or safety-critical railway project today may involve:

• NoBo (Notified Body) — assesses conformity of subsystems against TSI requirements
• DeBo (Designated Body) — assesses conformity against national rules not covered by TSIs
• AsBo (Assessment Body) — assesses the safety management system, typically for operators
• ISA (Independent Safety Assessor) — provides independent assessment of the safety case under EN 50126/50129

In principle these roles are distinct. In practice, the boundaries blur. Projects frequently find that NoBo and ISA assessments cover overlapping ground, that DeBo requirements add nationally-specific layers on top of what the NoBo has already assessed, and that coordinating the timelines and outputs of four separate bodies is itself a significant project management challenge.

The cost of all this assessment is real and it falls on the project. More importantly, the time it consumes — in preparation, coordination, response to findings, and re-assessment cycles — is one of the primary drivers of the authorisation timelines that make European railway projects so expensive and slow to deliver.

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The Bureaucracy That Grew Around the Solution

The TSI update cycle creates its own pressures. Projects that span multiple years face the genuine risk of beginning under one regulatory baseline and being required to comply with a revised one before completion. TSI CCS 2023 is the latest example — a necessary consolidation, but one that resets the compliance clock for organisations mid-project.

National deviations compound the problem further. They exist for legitimate reasons, but their volume and persistence has made them less an exception and more a structural feature of the system. An ETCS supplier cannot simply comply with the TSI — they must track and comply with the national deviation registers of every market they enter. For smaller suppliers this is effectively a market entry barrier, consolidating the industry around a handful of large players with the resources to manage it.

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What Has Actually Worked

Fairness requires acknowledging what ERA has genuinely achieved. The common ETCS specification created a baseline that did not exist before. The European Vehicle Authorisation process has reduced the need for full national re-authorisation in some cases. Cross-border corridors like Rhine-Alpine have demonstrated that ETCS interoperability can work at scale when deployment is properly coordinated and funded.

These are real achievements. The question is whether the framework built around them is proportionate to the outcomes it delivers.

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The Bottom Line

The single European railway area is worth building. The technical foundation is solid. What is needed now is a leaner process around it — fewer overlapping assessment bodies, more consistent enforcement of existing harmonisation, a more stable regulatory baseline, and a serious plan to phase out the national ATP systems that ETCS was designed to replace.

Twenty-five years in, the industry deserves a framework that measures success by trains crossing borders, not by documents produced.

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