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Mobility as a Service: code of practice

Jun 17, 2024Jun 17, 2024

Published 30 August 2023

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In response to the increasing availability of data and digital capability in transport, we are seeing new business models emerge that package different modes and services together into one mobile application or online platform to make the planning and payment of trips easier for people and businesses. Such innovation has been termed ‘Mobility as a Service’ (MaaS), which we have defined as ‘the integration of various modes of transport along with information and payment functions into a single mobility service’ Future of mobility: urban strategy, 2019.

MaaS platforms integrate and analyse data from multiple modes of transport, such as rail, bus, taxi and cycle hire, to offer choice in journey planning to consumers. This requires, for example, the ability for MaaS platform providers to access service timetabling data, along with the ability to purchase tickets digitally. Some existing digital products are also developing incrementally to incorporate MaaS elements. For example, Google Maps now enables users to locate nearby e-scooters. There are often commercial arrangements between platform providers and transport operators underpinning access to this information. Established MaaS schemes can be found in several cities worldwide including the Jelbi mobility app in Berlin and the Whim app in Helsinki.

Through better access to quality information to aid journey planning, MaaS has the potential to improve the user’s experience of the transport network, while also enabling more active and sustainable ways to travel. MaaS platforms can make journeys more convenient through streamlining planning and payment and allowing people to tailor journeys to their specific needs, which could encourage the use of sustainable modes of transport and empower more people to travel. By enabling multimodal journeys and integrating ticketing and payment, MaaS can also offer more cost-efficient journeys to users. The benefits of MaaS are expanded on in Government ambition for MaaS.

New and emerging technologies are radically reshaping how people and goods move around. Changes in how we do business and how we travel bring opportunities for us to seize benefits such as cleaner, safer and quieter streets, and creating better places and communities to live in. The Department for Transport (DfT) is responding to these changes by preparing the UK for new technologies, supporting the transition to net zero, stimulating innovation and creating a world-leading future transport system that is safe, secure, and accessible to all.

In 2019, we published the Future of mobility: urban strategy in which we set out a principles-based approach to guide the government’s response to emerging transport technologies and services in our towns and cities. This strategy aims to help urban areas harness the benefits and opportunities of new transport innovation, such as MaaS, and proactively manage any challenges and potential risks. 

Our urban strategy principles provide a framework for how the government will achieve this. We have also invested £92 million in four Future Transport Zones (FTZs), to support local leaders and industry to trial MaaS solutions and develop viable business models, which will lead to the creation of new services and commercial opportunities. In our forthcoming rural strategy, we will outline how MaaS can play a role in tackling rural mobility issues, improving connectivity and accessibility in these communities.

As part of DfT’s transport decarbonisation plan, which sets out the government’s commitments and the actions needed to decarbonise the entire transport system in the UK, we committed to consult on a MaaS code of practice. This consultation ran between 8 February 2022 and 3 May 2022. It sought views and evidence from all those with an interest in MaaS to understand how a code of practice might help to shape and support this emerging industry.

new modes of transport and new mobility services must be safe and secure by design

the benefits of innovation in mobility must be available to all parts of the UK and all segments of society

walking, cycling and active travel must remain the best options for short urban journeys

mass transit must remain fundamental to an efficient transport system

new mobility services must lead the transition to zero emissions

mobility innovation must help to reduce congestion through more efficient use of limited road space, for example, through sharing rides, increasing occupancy, or consolidating freight

the marketplace for mobility must be open to stimulate innovation and give the best deal to consumers

new mobility services must be designed to operate as part of an integrated transport system combining public, private and multiple modes for transport users

data from new mobility services must be shared where appropriate to improve choice and the operation of the transport system

Portsmouth, Southampton, South Hampshire, Isle of Wight, UK

The Solent Transport Breeze app is part of the funding allocated from DfT’s FTZ programme.

Solent Transport set out to create a MaaS solution that would have every transport mode and option in one place, be designed to be easy and attractive to use, and leave complex technical integrations between systems behind the scenes and not burdensome by users.

The initial specification for the platform included the following 5 areas:

integration with public transport operators and services and micromobility services as they become available

multimodal journey planning

integration of car and driving options within the MaaS environment

comparative journey planning by price, sustainability, time and ease

multimodal booking, ticket and payments

collaboration with research partners (University of Portsmouth and University of Southampton) to continuously assess and improve the application

A beta version of the MaaS app was launched in November 2021 to a closed testing group. This included basic functionality and limited mobility services and was used as part of a comprehensive test plan to ensure functionality and user experience are as expected and to identify any issues or improvements that were required to be made.

Developing MaaS is a complex undertaking. There are many technical and commercial challenges to overcome when designing a MaaS solution, alongside overlapping regulatory frameworks that create a challenging environment for MaaS to succeed. In addition, MaaS is still in its infancy worldwide, with testing and trialling taking place alongside small-scale deployments. From these trials, we are starting to understand the digital infrastructure needed for MaaS platforms to be deployed at larger scales, along with broader social behavioural changes to adjust to these new service offerings.

Now is an opportune time to take a voluntary, guidance-based approach through a code of practice to enable these platforms to emerge and mitigate any unintended consequences. A code of practice will enable us to support MaaS as it grows without introducing regulations at a time that could stifle innovation in this emerging industry. A code of practice will also provide an opportunity to gather further evidence in a structured manner to understand if and where regulation might need to be brought forward in the future.

This code of practice provides a resource for organisations involved in MaaS schemes to navigate these challenges, making it easier for MaaS to thrive in the UK. It offers specific technical and regulatory advice, and guidance on the government ambition for MaaS, which will be most useful for MaaS platform providers, transport operators and local authorities. However, members of the public, legal advisors and other third parties involved in designing and deploying MaaS schemes may also find the content helpful.

Government believes that MaaS has the potential to provide substantial benefits and cost savings for the travelling public. Better use of data and digital technologies can help improve the efficiency of the transport system, providing greater freedom and choice for how we travel around. Joining up different modes of transport can also improve the commercial viability of services and help them to reach more people.

Better transport connectivity can have other knock-on benefits for the public, such as greater access to healthcare and jobs, and helping to link up communities, particularly in rural and remote areas. Government would like to see the next generation of MaaS platforms go beyond transport, realising the social and economic benefits of better connecting people to the places they live and their local community by including information about local events and activities.

MaaS has the potential to help the UK meet its decarbonisation and net zero ambitions. MaaS can drive the UK towards these ambitions by building trust and confidence in innovative new technologies and ways to travel, such as an increased focus on shared transport, like car clubs and lift sharing, and micromobility modes like e-scooters. MaaS can help the travelling public make more sustainable choices by providing information on carbon emissions and enabling walking and cycling routes, in line with ambitions set out in the transport decarbonisation plan.

Government wants the UK to have a transport system that is accessible, inclusive and available to all segments of society. MaaS has the potential to make multimodal journeys easier for all users through the ability to tailor these journeys to individual preferences and needs. Government has set out ambitions for a transport system that is fit for all in the inclusive transport strategy and future of mobility urban strategy.

The intelligent mobility sector more widely is estimated to be a potential source of £4 billion gross value added (GVA) per annum for the UK by 2025[footnote 1]. Government wants to position the UK at the forefront of this emerging industry and for home-grown MaaS platforms to thrive alongside encouraging inward investment into the UK MaaS market. Government will support the MaaS industry and enable MaaS platforms, transport operators and local authorities to develop a commercially viable product.

This code of practice is intended to support the MaaS industry as it emerges in the UK, by doing this government hopes to secure the benefits of MaaS for the UK’s transport system in a way that is aligned with the future of transport principles. It covers a range of issues government believes to be most important to ensuring a fair, accessible and innovation-friendly environment for MaaS to thrive. The code will be monitored and updated to ensure it continues to guide the development of the MaaS industry in the UK, now and in the future.

Through public consultation, we have identified a range of issues within the MaaS ecosystem that this code of practice can support and shape. The following recommendations are informed by the views of the public, local authorities, transport operators and other private organisations.

1. We recommend MaaS platform providers proactively identify and engage with users who have protected characteristics that may be adversely impacted by platform design choices.

2. We recommend MaaS platforms adhere to web content accessibility guidelines and incorporate accessibility features into their interface design, which could include screen reading features, optimised menus and buttons and features that help blind and visually impaired users interact with their device.

3. We recommend MaaS platform providers test accessibility features with a diverse range of users, including those from groups sharing protected characteristics, throughout the design process.

4. We recommend MaaS platforms consider accessibility needs when suggesting routes. For example, identifying wheelchair-accessible routes and stations, calculating step-free journeys by default and considering the needs of users with visual, audible and non-visible disabilities.

5. We recommend MaaS platforms, transport operators, local authorities, or any bodies responsible for processing data, take due consideration when handling special category data. Further protection or safeguarding processes should be considered for such data due to its sensitive nature.

6. We recommend MaaS platform providers use robust product testing processes and data practices to ensure the datasets used in journey planning algorithms are as representative as possible. And that the algorithms are tested regarding bias and effective governance is established.

7. We recommend MaaS schemes should consider the specific needs of users in rural areas where, for example, internet connectivity could be a barrier to accessing online journey planning.

8. We recommend community transport services should be integrated as far as possible into MaaS schemes.

9. We recommend MaaS platforms ensure users have access to different types of offline support if they need assistance with their journey, for example, if they need to request further information or seek compensation.

10. We recommend MaaS platforms provide information so that users can access physical support at stations.

11. We recommend that personal safety should be a key consideration for organisations developing MaaS solutions. The journey options presented in a MaaS platform should consider the needs of users disproportionately affected, such as children, older people and women, by offering safe and appropriate routes. For example, allowing the user to plan their journey to select main roads in their preferred routes and the ability to share their live location.

12. We recommend MaaS platforms provide users with information about the carbon dioxide (CO2) savings that can be made by walking or cycling, so users can make informed choices about sustainable modes of transport. This information should be displayed to the user in an accessible and easy-to-understand format. We recommend organisations use the Department for Energy Security and Net Zero (DESNZ) emission conversion factors to calculate emissions on a per person, per journey basis. Where other methods are used, we encourage organisations to show their workings.

13. We recommend MaaS platforms display the health benefits of active travel to users, for example by calculating the calories burned when walking or cycling.

14. We recommend MaaS platforms display active travel choices for routes offered, where appropriate, and ensure these options are clearly signposted to users. For users with accessibility needs, platforms should allow users to set their preferences for certain transport modes so that only appropriate journey options are displayed.

15. We recommend MaaS platforms offer transparency and give users meaningful control over the way in which results are presented to them and allow them to tailor these options to suit their needs and preferences. For example, allowing users to see all journey options, or allowing them to filter out certain travel modes.

16. We recommend MaaS platforms collate aggregated and anonymised journey information, to understand how customers are using their service and the ways in which improvements can be made, including encouraging users to make more sustainable travel choices.

17. We recommend transport operators and MaaS platform providers make use of the wide range of published national and international standards that are available to support the delivery of mobility services. These formal standards are available through standard bodies such as the British Standards Institute (BSI) or open platforms. Such organisations can also facilitate the sharing of best practice and lessons learned from other organisations and countries that have already implemented MaaS successfully.

18. We recommend transport operators share the following types of data, under the Open Government License to improve service provision, user experience and encourage more sustainable ways to travel:

data to assist journey planning including route, distance and time

payment data including ticket price

reservation data

timetable data

location data to help users track the progress of their journey

data to show vehicle availability and location for ride-hailing services

disruption data to help users reroute their journeys when necessary

occupancy data to track the busyness of their journey

accessibility data to enable disabled users to fully access MaaS services, for example, information about stations and interchanges with step-free access

carbon emissions data to help users choose more sustainable journeys

data of specific relevance to shared rental bike, e-bike and e-scooter schemes, such as live vehicle location and charge data, parking locations and rental cost

19. We recommend MaaS platform providers reciprocate data sharing where possible, for example, sharing anonymised passenger travel data to support transport operators’ planning and operations activities. MaaS platform providers sharing data in this way need to consider whether the data would be truly anonymised, meaning that data protection legislation would not apply. If the data was only pseudonymised then data protection legislation would apply to its processing.

20. We recommend MaaS platform providers and local authorities use the Information Commissioner’s Office (ICO) Data Sharing Code of Practice for further guidance. Specialised guidance is available for AI projects.

21. We recommend agreements are put in place to enable the secure sharing of relevant data between transport operators and platform providers. The ICO’s data sharing code of practice recommends data sharing agreements are put in place to ensure good practice and compliance with data protection legislation.

22. We recommend that MaaS platform providers, transport operators and local authorities work proactively to ensure the data they share is fully compliant with any data standards employed to ensure the user can access high-quality information about their journey. They should expect to be able to demonstrate how the information that they share is accurate and be responsive when users or other data consumers raise data quality concerns.

23. We recommend MaaS platform providers, transport operators and local authorities work collaboratively to offer a consistent ticketing experience that provides convenience and value for money for passengers.

24. We recommend MaaS platform providers have due consideration for emerging and future technologies that may affect the service they offer, in order that any future integrations can be easily adopted.

25. We recommend organisations deploying MaaS schemes should develop realistic plans to scale multimodal ticketing schemes, using iterative design processes to incorporate different modes of transport over time and learn from the experiences of other projects.

26. We recommend that conversations between MaaS platform providers, transport operators and local authorities begin as early as possible in the setting up of any MaaS scheme.

27. We recommend ticketing schemes offer transparent pricing structures to ensure all users can access the “best value fares” for their journey.

28. We recommend ticketing schemes can be tailored to individual requirements including those of different disabled passengers, take into account users with different protected characteristics in the design process, and those who may need concessionary fares.

29. We recommend MaaS platform providers offer transparent and consistent information for multimodal journeys and set out points of contact for users upfront so they understand how they can provide feedback on their journey, claim for compensation for delays or cancellations or request a ticket refund, should they need to.

30. We recommend MaaS platforms make clear where a particular journey, mode, or operator is being promoted or prioritised owing to a prior commercial arrangement. This might be through a visual cue to users, for example, a “sponsored” or “promoted” tag.

31. We recommend that all organisations involved in a MaaS scheme ensure user’s personal data is processed in a manner that complies with data protection legislation.

32. We recommend that where data processing is likely to result in high risk to individuals, data controllers conduct a data protection impact assessment prior to the processing to assess such risks and identify potential mitigations.

33. We recommend local authorities, MaaS platform providers and transport operators ensure that any commercial agreements that are entered into promote fairness on pricing, avoid exclusivity of services and encourage data sharing to guard against any negative competition outcomes.

34. We recommend all possible public transport options and services available in the area to be shown in the MaaS app to avoid fragmentation of services across apps.

The Equality Act 2010 ensures that passengers with protected characteristics are not discriminated against when using public transport. The act includes the public sector equality duty, setting out requirements against a range of issues for public authorities. These are both covered in more detail in the legislation section below.

Our ambition, set out in the 2018 inclusive transport strategy, is that disabled people will have the same access to transport as any other user, meaning they can travel confidently, easily and without extra cost. By 2030, we envisage equal access for disabled people using the transport system, with assistance if physical infrastructure remains a barrier.

MaaS can tailor journeys to individual needs, taking away the barriers experienced by disabled passengers. MaaS can help by simplifying journey planning and making travel more integrated, safer and comfortable. By enabling multimodal journeys and integrating ticketing and payment, MaaS can offer more cost-efficient journeys to users and help more people to access jobs and services.

However, multimodal journeys planned and paid for through a MaaS platform could present challenges for users if, for example, they do not provide appropriate assistance for passengers transferring between modes. Disabled users may not feel comfortable booking a journey through a MaaS platform if they do not have confidence in its ability to meet their specific needs. It is imperative that multimodal journeys do not introduce new barriers for disabled passengers and that the needs of all users are considered when designing new systems and considering potential impacts of any change.

MaaS platform providers and transport operators must comply with the Equality Act 2010 which ensures passengers with protected characteristics are not discriminated against when using public transport. The 9 protected characteristics under section 4 of the act are defined as:

age

disability

sex

gender reassignment

pregnancy and maternity

race

religion or belief

sexual orientation

marriage and civil partnership (only need to be considered in relation to the first aim of eliminating discrimination and only in relation to employment)

Further information on each protected characteristic can be found on the Equality and human rights website.

The act includes the public sector equality duty (PSED), which is laid out under section 149. The PSED requires public authorities to have due regard to the need to:

eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by or under the act

advance equality of opportunity between persons who share a relevant protected characteristic (see below) and persons who do not share it, which means having due regard to the need to:

remove or minimise disadvantages suffered by persons who share a relevant protected characteristic

take steps to meet the needs of persons who share a protected characteristic that are different from the needs of persons who do not share it, and this includes particular steps to take account of disabled persons’ disabilities

encourage persons who share a relevant protected characteristic to participate in public life or in any other activity in which participation by such persons is disproportionately low

foster good relations between persons who share a relevant characteristic and persons who do not share it, which means having due regard, in particular, to the need to tackle prejudice and promote understanding between people from diverse groups

MaaS platforms should ensure that the services they provide are inclusive and accessible to all customers. This means that MaaS platforms should be designed with all users in mind, including those who could be adversely impacted by a failure to consider them from the outset such as users with visual impairments, wheelchair users and those who cannot access a mobile device or computer.

We recommend MaaS platform providers proactively identify and engage with users who have protected characteristics that may be adversely impacted by platform design choices.

We recommend MaaS platforms adhere to web content accessibility guidelines and incorporate accessibility features into their interface design, which could include screen reading features, optimised menus and buttons and features that help blind and visually impaired users interact with their device.

We recommend MaaS platform providers test accessibility features with a diverse range of users, including those from groups sharing protected characteristics, throughout the design process.

The Netherlands

Glimble is a MaaS app created by transport operator Arriva Netherlands and journey planning technology provider Moovit.

Glimble is committed to providing accessible and inclusive mobility solutions to all, giving special attention to disabled people, empowering them to confidently travel around their cities using public transit and maximising their potential for employment, education and social life. This commitment means that accessibility capabilities are included in the app. These features have been developed with and tested by users with disabilities.

Every screen across the app has been optimised for VoiceOver and TalkBack screen-reading technologies. With this enhanced accessibility integration, users use gestures to navigate through screen elements. Once the user is focused on an element, including buttons and labels, the VoiceOver or TalkBack feature reads aloud the text that appears on it. Specifically, with the live directions feature, the user gets step-by-step GPS-style guidance for their journey and receives alerts when the bus is arriving, or get-off alerts to get ready before they’ve reached their destination or stop.

The proprietary multimodal trip planner calculates trips that are wheelchair and stroller accessible and this information is displayed inside the app. Glimble is also running a pilot in the northern part of the Netherlands that makes planning, booking and payment for accessibility taxis available.

MaaS platforms should not offer passengers inappropriate journeys, such as non-accessible journeys to disabled users. For example, if a taxi or private hire vehicle forms part of the MaaS journey for a disabled passenger, it should be of a type that provides the accessibility required by the specific passenger, so there is no risk that passenger will be left stranded. MaaS platforms should also enable neurodiverse passengers to tailor the journey options presented to them to their needs.

Where passengers, including disabled passengers, need assistance to use a particular mode or to transfer between modes within a MaaS journey (such as the passenger assistance service for disabled people wishing to take a train) or require information on provision within modes (such as wheelchair space availability), this should be factored into the MaaS offer where practicable.

We recommend MaaS platforms consider accessibility needs when suggesting routes. For example, identifying wheelchair-accessible routes and stations, calculating step-free journeys by default and considering the needs of users with visual, audible and non-visible disabilities. The types of data needed to support this are outlined in Data considerations to facilitate MaaS.

Understanding user preferences will likely require the processing of special category data, such as health data. MaaS platforms, transport operators and local authorities need to be aware when they are processing special category data.

We recommend MaaS platforms, transport operators, local authorities or any body responsible for processing data takes due consideration when handling special category data. Further protection or safeguarding processes should be considered for such data due to its sensitive nature.

MaaS platforms may use algorithms to determine which journey options are displayed to the user. There is a risk that the data used to train the algorithm may reflect wider historic or social inequalities. When this is the case, the insights from the tool may produce an outcome that is deemed unfair, prioritising the needs of certain groups over others.

In the case of MaaS platforms, these algorithms could use data mostly or wholly derived from journeys undertaken by a small population size or make biased inferences. This may not be representative of all transport users, such as disabled passengers. This could potentially put some users at risk by not considering accessibility requirements. Appropriate governance structures will be needed to address any concerns and to provide assurance.

We recommend MaaS platform providers use robust product testing processes and data practices to ensure the datasets used in journey planning algorithms are as representative as possible. And also that the algorithms are tested regarding bias and effective governance is established.

Transport operators should continue to ensure their services are accessible to all users, including those who are not able to use or access a computer or mobile device. There is a risk that the benefits of MaaS do not reach certain groups, such as:

those living in rural communities

those who are not able to use or access a computer or mobile device

users who do not have their own bank accounts or online banking/payment

users who rely on community transport services

We recommend MaaS schemes should consider the specific needs of users in rural areas where, for example, internet connectivity could be a barrier to accessing online journey planning.

We recommend community transport services should be integrated as far as possible into MaaS schemes.

We recommend MaaS platforms ensure users have access to different types of offline support if they need assistance with their journey. For example, if they need to request further information or seek compensation.

Functions such as the ability for disabled passengers to report issues and rate their experiences of transport routes could be beneficial. While not responsible for providing physical support to disabled travellers, MaaS platforms are well-placed to provide accurate information about the support available during a journey.

We recommend MaaS platforms provide information so that users can access physical support at stations.

The Highlands and Islands, Scotland UK

Go-Hi was launched in summer 2021 in the Highlands and Islands of Scotland and allows users to plan, book and pay for an end-to-end, multimodal journey in a single transaction using their smartphone or desktop devices.

The Go-Hi MaaS app is designed to make it easier for residents, tourists and business users to switch between different modes of sustainable transport to increase the use of public transport, car club and car hire and encourage active travel. The scheme also includes access to planes, ferries and demand-responsive transport to offer a solution to some of Scotland’s most rural areas and islands and allows tourists to book hotels as part of their trip to support sustainable tourism in the Highlands.

Alongside a focus on providing services to the whole community, the Go Hi project also generates data for operators and the HITRANS transport authority to better understand the needs of users and make decisions to ensure the long-term viability of the transport services.

The personal safety of all transport users is important. Some transport users might experience heightened levels of insecurity when travelling and some may feel more at risk when using certain transport modes or undertaking certain journeys. Users may make journey decisions based on the perceived safety of a route. MaaS platforms can help facilitate safer journeys for all users by offering more detailed information about a route to help inform better decision-making.

We recommend that personal safety should be a key consideration for organisations developing MaaS solutions. The journey options presented in a MaaS platform should consider the needs of users disproportionately affected, such as children, older people and women, by offering safe and appropriate routes. For example, allowing the user to plan their journey to select main roads in their preferred routes and the ability to share their live location.

The Citymapper app offers users and enterprise customers the option of walking routes that prioritise main roads, which is usually a good proxy for being well-lit and avoiding parks. This helps users both when navigating a city after dark and when they’re in an unfamiliar area and want to keep the turns simple. Citymapper also offers a ‘share trip’ functionality that enables users to share their live location and estimated time of arrival (ETA) with friends, combined with turn-by-turn navigation. The aim of these features is to help everyone navigate their city confidently at all times of the day.

As outlined in our future of mobility: urban strategy principles, government wants new innovations in mobility services to lead the transition to zero emissions and to help reduce congestion through more efficient use of limited road space. In July 2021, government published the transport decarbonisation plan, the first such plan in the world, which sets the transport sector on the path to net zero by 2050, in line with the Paris Agreement. In this plan, government sets out an ambition for public transport, cycling and walking to be the natural first choice for our daily activities. MaaS platforms can play an important role in encouraging users to take active journeys and choose more sustainable modes of transport.

MaaS could help to enable sustainable travel by making it easier for the user to access public transport and shared mobility by streamlining journey planning and payment, providing real-time updates, high-quality maps and information on the CO2 savings and health benefits for each form of transport. This could help the user decide when walking or cycling is the best option to reach their destination.

Citymapper journey planning includes the CO2 savings for each transport option compared to taking the same trip by car, both per trip and overall, across all the trips a user has taken. Citymapper has found that giving users quantifiable ways to understand the environmental benefits of their transport choices and gamifying this with features, such as a cumulating scorecard, can provide important behavioural nudges to support users in adopting greener travel habits.

We recommend MaaS platforms provide users with information about the CO2 savings that can be made by walking or cycling, so users can make informed choices about sustainable modes of transport. This information should be displayed to the user in an accessible and easy-to-understand format. We recommend organisations use the DESNZ emission conversion factors to calculate emissions on a per person, per journey basis. Where other methods are used, we encourage organisations to show their workings.

We recommend MaaS platforms display the health benefits of active travel to users, for example, by calculating the calories burned when walking or cycling.

How journey options are presented to users in a MaaS platform is also likely to have an impact on their choice of transport. If active travel or sustainable modes are prominent, users may be more likely to choose such options. Providing more detailed information on journey options could better support users to make choices that are more sustainable. MaaS platforms should consider the user interface design of their applications and how the presentation of mode choice, fares and routes may influence how users travel.

We recommend MaaS platforms display active travel choices for routes offered, where appropriate and ensure these options are clearly signposted to users. For users with accessibility needs, platforms should allow users to set their preferences for certain transport modes so only appropriate journey options are displayed.

MaaS platform providers should also be transparent about the way their journey planning algorithms are built and maintained and allow users to have meaningful control over the way in which the algorithm displays results to them, allowing them to make choices including favouring walking and cycling routes, cheaper modes of travel or accessible routes.

We recommend MaaS platforms offer transparency and give users meaningful control over the way in which results are presented to them and allow them to tailor these options to suit their needs and preferences. For example, allowing users to see all journey options or filter out certain travel modes.

Building the case for new technologies, business models and policies to be adapted will require robust evidence. Gathering and sharing this evidence with relevant parties, such as local authorities, may help decision-makers and planners to assess the need for change and amend services.

We recommend MaaS platforms collate aggregated and anonymised journey information to understand how customers are using their service and the ways in which improvements can be made, including encouraging users to make more sustainable travel choices.

MaaS is a digital, data-driven business model that relies on the ability to access accurate information relating to service timetables, routes, fares and ticketing. For MaaS to work, data-sharing arrangements need to be in place between transport operators and MaaS platform providers, and data should be shared in a timely way and of satisfactory quality to provide the most accurate travel information to the user and enable payment for travel services.

Without sufficient data sharing and data standardisation arrangements in place between MaaS platform providers, transport operators or any bodies responsible for processing data, transport users will be put at a disadvantage due to poorer service provision, less tailored journey planning information and a disjointed user experience where all modes are not represented in the app.

Helsinki, Finland

Whim is a mobility app developed by the Finland-based company MaaS Global Ltd. It combines multiple different modes of transport and allows the user to plan, book and pay for their trips in one place. The focus of the app is on users’ mobility needs and the goal of Whim is to make all their trips easier to start on a whim. It also allows for a simpler travel experience in more locations: wherever Whim is live, the traveller can use the same application they use at home.

The design process for the app began from a holistic perspective to respond to the growing demands of urban areas to be a compelling alternative to a private car. Sustainability is a major driving force behind the creation of the app, as road traffic is responsible for a large part of CO2 emissions. To design the product, MaaS Global held interviews, co-creation sessions and service design workshops with the Finnish capital region citizens. Based on feedback, they began to design a model that would respond to their goals at a time when mobility needs were becoming more multimodal and brought on by spur-of-the-moment decisions. Whim is currently available in Finland (Helsinki, Turku), Austria (Vienna), Belgium (Antwerp), Japan (Tokyo) and Switzerland (nationwide).

We have already undertaken a number of initiatives to open, share  and digitise relevant data across modes, which can help to facilitate MaaS. This includes the Bus Services Act 2017, which includes open data provisions and ticketing powers that make it easier for passengers to use buses, move between different modes of transport and access timetables, fares, locations and punctuality data. Other data forms, such as accessibility and occupancy, have been provided voluntarily by some operators, making it easier for people to use active, shared and public travel options.

There are also several government strategies that support data standardisation and data sharing. These include but are not limited to the:

joint rail data action plan

rail sector deal

local data action plan

In addition, the national data strategy, published in September 2020, sets out our vision to harness the power of responsible data use to boost productivity, create new businesses and jobs, improve public services, support a fairer society and drive scientific discovery, positioning the UK as the forerunner of the next wave of innovation.

The national data strategy mission 1 policy framework, which was published in November 2021, sets the ambition to unlock the value of data in the economy by improving data availability, access and use, for example, by setting data standards and improving foundations such as data quality.

For transport data more specifically, our forthcoming transport data strategy sets out the vision for how DfT will work with a wide range of partners from transport operators to data innovators to improve the discoverability, accessibility and quality of transport data. The document focuses on improving data standards by creating and maintaining a transport data catalogue and creating a transport data standards expert panel to identify barriers to data interoperability and develop innovative solutions through the promotion, development and implementation of data standards.

Regarding the use of artificial intelligence (AI), the National AI Strategy (2019) sets out the UK vision to be a world-leader and the core pillars that underpin this ambition. Pillar 2 (ensuring AI benefits all sectors and regions) and Pillar 3 (governing AI effectively) will be of relevance to MaaS platform providers, as well as the next steps, such as establishing the AI standards hub.

Finally, organisations that are responsible for processing personal data in the UK must comply with data protection legislation. This is covered below in more detail and in the Consumer protection section.

By improving data quality and data collection processes, better data standardisation can ensure MaaS platforms offer the most suitable journeys to users, taking into account their personal needs. Improved data standardisation could make it easier for new players to enter the MaaS market, creating more transparency, increased flexibility and lower operating costs. Ultimately this could help to accelerate the delivery of MaaS schemes in the UK and lead to better solutions for transport users.

An example of this is NaPTAN, which acts as a single source of information for public transport nodes or more typically stations. This means that public transport journey planners have an open, reliable repository of stop information that is interoperable across multiple other datasets (such as timetables, fares) and modes of transport.

We recommend transport operators and MaaS platform providers make use of the wide range of published national and international standards that are available to support the delivery of mobility services. These formal standards are available through standard bodies such as the British Standards Institute (BSI) or open platforms. Such organisations can also facilitate the sharing of best practice and lessons learned from other organisations and countries that have already implemented MaaS successfully.

MaaS platform providers need to be able to access journey and payment data to increase the functionality of their apps by providing users with tailored information about their journey, such as service availability, timetable data, payment methods, reservation details and disruption data. Data sharing between transport operators and MaaS platform providers will allow MaaS to fully integrate with public transport, payment processers and local authorities.

We recommend transport operators share the following types of data, under the Open Government Licence, to improve service provision, user experience and encourage more sustainable ways to travel.

data to assist journey planning including route, distance and time

payment data including ticket price

reservation data

timetable data

location data to help users track the progress of their journey

data to show vehicle availability and location for ride-hailing services

disruption data to help users reroute their journeys when necessary

occupancy data to track the busyness of their journey

accessibility data to enable disabled users to fully access MaaS services, for example, information about stations and interchanges with step-free access

carbon emissions data to help users choose more sustainable journeys

data of specific relevance to shared rental bike, e-bike, and e-scooter schemes, such as live vehicle location and charge data, parking locations and rental cost

We recommend MaaS platform providers reciprocate data sharing where possible, for example, sharing anonymised passenger travel data to support transport operator planning and operations activities. MaaS platform providers sharing data in this way need to consider whether the data would be truly anonymised, meaning that data protection legislation would not apply. If the data was only pseudonymised then data protection legislation would apply to its processing.

We recommend MaaS platform providers and local authorities use the Information Commissioner’s Office (ICO) Data Sharing Code of Practice and Data Sharing Information Hub for further guidance. Specialised guidance is available for AI projects.

Concerns over data privacy should not be a barrier to sharing data. Resources, such as those available through the ICO, can help navigate any challenges around data privacy. MaaS platforms and transport operators will have access to and be required to process large amounts of personal, financial and journey data. Such data should be handled appropriately in compliance with data protection legislation (see Consumer protection) and to ensure users have trust and confidence in using MaaS services.

We recommend agreements are put in place to enable the secure sharing of relevant data between transport operators and platform providers. The ICO’s data sharing code of practice recommends data sharing agreements are put in place to ensure good practice and compliance with data protection legislation.

It is important that bodies are clear about which types of data would constitute personal data, as the processing of which would be subject to data protection legislation and must comply with the data protection principles.

MaaS presents us with the opportunity to access better quality data, which can allow users to make informed choices when planning their journeys through a MaaS platform. For example, enabling them to consider which mode of transport is most suitable for their journey by taking into account time, route, price, accessibility requirements and the impact on the environment through the inclusion of carbon data. Data quality is crucial to avoid the risk of offering inaccurate journey information to the user, which could undermine the credibility of MaaS.

There is often an expectation that data standardisation will help improve data quality. However, those providing data against a certain standard should expect to have their level of compliance against that standard checked in to ensure that users are receiving accurate information. These checks might well be independent and automatic at the point of data sharing, a practice that is standard for systems that rely on large amounts of data exchange in real-time, including DfT’s own bus open data service. Through these systems, information made available by transport operators will often end up in the hands of transport users before any human could independently check that information, thus making such checks a necessity.

MaaS platform providers, transport operators and local authorities should, therefore, expect to need to be responsive to data quality concerns about information they share, and build-in quality control mechanisms pre-publication to reduce the frequency with which data quality issues arise.

We recommend that MaaS platform providers, transport operators and local authorities work proactively to ensure the data they share is fully compliant with any data standards employed to ensure the user can access high-quality information about their journey. They should expect to be able to demonstrate how the information they share is accurate and be responsive when users or other data consumers raise data quality concerns.

Alongside the ability to plan a journey using multiple modes of transport, MaaS can offer customers the option to purchase a ticket for their journey through the MaaS platform, using either pay-as-you-go or subscription models. This approach can save the user time, allow them to compare different options more easily and increase convenience and value for money. This can also bring benefits to transport operators by encouraging greater use of public transport for end-to-end trips and potentially reducing journey times through quicker boarding.

We have published strategies that outline the government’s ambition to increase the offer of integrated, multimodal ticketing across the transport network. Government continues to prioritise the continued rollout of digital ticketing on rail, alongside delivering commitments to Pay-As-You-Go travel.

Though the focus currently is on a rail-first approach, in the longer term this could assist MaaS platforms in offering multimodal tickets and support local-led schemes. In the levelling up white paper and the national bus strategy, as well as the bus strategy’s subsequent guidance documents, the government outlined its longer-term expectation that operators and local transport authorities would work together (through the enhanced partnership model for buses) to offer more integrated ticketing.

Our future transport zones (FTZ) programme has funded several local authorities to develop MaaS pilot projects throughout the UK. Through this programme, we have the opportunity to gain a clearer understanding of the processes needed to create multimodal ticketing schemes and will continue to gather feedback and evidence as it develops.

The Citymapper native booking functionality allows users to pay for and access transport services, for example, ride-hail and micromobility, directly within the app. This is integrated with the navigation functionality to create a frictionless end-to-end travel experience. Citymapper also offers public transport ticketing using EMV contactless technology, enabling users to access transit with a tap of their phone. Both of these systems are powered by Citymapper’s MaaS accounts platform that combines public transport with micromobility, ride-hail and the likes in flexible bundles, subscriptions and personalised offers for consumers. With all mobility payments in one place, this accounts-based platform enables the creation of multimodal products that reflect how users travel in real-life.

Whim utilises both monthly subscriptions and pay-as-you-go tickets as well as bundles designed specifically for Whim users. With Whim, the user can combine, for example, a 30-day public transport subscription and a 30- or 60-minute e-scooter ride. Whim was designed to allow urban users to travel more conveniently without a car, but also to make the decision not to buy a car easier. In the Whim user study 2020, 24% of users say Whim has helped them either get rid of or avoid buying a new car.

There are several existing legislative frameworks that can help to facilitate multimodal ticketing schemes. The Transport Act 2000 is a wide-ranging piece of legislation covering many modes of transport, the operation of services, ticketing and franchising. It also covers aspects of competition and the duties of operators. For rail services, the requirements of the Railways Act 1993 are delivered through the ticketing and settlement agreement (TSA) and the national rail conditions of travel (NRCOT). While not legislation, they act as industry-wide agreements that underpin how fares and ticketing operate on the railways to ensure they continue to operate as an integrated national network. They also act as agreements between the rail company and passenger when a passenger purchases a ticket, to ensure people enjoy the benefits of a national network despite the existence of the various different train operators.

For bus services, there are a range of relevant regulations and legislation. The Competition Act 1998 (Public Transport Ticketing Schemes Block Exemption) Order 2001 specifies that certain forms of agreements between transport operators are exempt from the prohibition on anticompetitive agreements in the Competition Act 1998. The agreements allow operators to integrate their ticketing systems, meaning that consumers can buy a single ticket for use on the services of multiple operators.

The Public Service Vehicles Open Data (England) Regulations 2020 requires bus operators to provide open, accurate and up-to-date information on timetables, fares and real-time vehicle location.

This regulation aims to help operators publish their data and has developed data standards to ensure a consistent, rule-based approach to support the bus industry to exchange this information.

Creating multimodal ticketing schemes can be a difficult undertaking. There are multiple considerations to navigate including commercial agreements, technical and legislative complexities.

For multimodal ticketing to work effectively with MaaS, passengers need to be able to receive their tickets in a convenient format. MaaS providers also need to be able to integrate with operator retailing systems and back offices, including the potential multi-operator broker concept now in development. Following the publication of bus back better, the national bus strategy, the broker will be designed to support local public transport journeys across multiple bus operators and potentially include light rail and local ferry services.

While digital ticketing is increasingly available on many modes, for example, with the rollout of barcode e-tickets on the majority of rail operators, different modes and operators can adopt different standards for both ticketing and retailing systems, meaning that MaaS providers could need to integrate with a multitude of technical standards for outputs from different ticket issuing facilities. Within the bus sector, data outputs vary according to the ticket machine used, as there is not a common standard for operators to use.

The proposed broker is designed to interpret data feeds from various sources and calculate a fares cap common to all operators in a defined area. In some cases, standard interfaces do not exist, or onerous accreditation standards apply, requiring significant development work for new players in the ticketing and retailing market like MaaS providers.

We recommend MaaS platform providers, transport operators and local authorities work collaboratively to offer a consistent ticketing experience that provides convenience and value for money for passengers.

We recommend MaaS platform providers have due consideration for emerging and future technologies that may affect the service they offer in order that any future integrations can be easily adopted.

In addition to these technical issues, there are also commercial challenges. Transport operators, MaaS platform providers and local authorities need to agree pricing structures and how ticket revenue will be shared, and many local transport infrastructures have multiple competing commercial priorities that can make this a difficult process.

Likewise, local transport authorities (LTAs) should consider how they can encourage operators to invest in smart ticketing systems and MaaS, recognising the benefits to the operator. In areas receiving bus service improvement plan (BSIP) funding, LTAs should highlight the benefits of government-funded investments to productivity and revenue, and the need for operators to work in partnership with them. There may also be scope to negotiate how further BSIP measures such as improved highways and traffic management could improve bus operations.

We recommend organisations deploying MaaS schemes should develop realistic plans to scale multimodal ticketing schemes, using iterative design processes to incorporate different modes of transport over time and learn from the experiences of other projects.

This approach can help build user confidence when purchasing tickets through a MaaS platform.

We recommend that conversations between MaaS platform providers, transport operators and local authorities begin as early as possible in the setting up of any MaaS scheme.

Transport for West Midlands

Over the past 10 years, Swift in the West Midlands has grown to be the largest smart ticketing scheme outside of London. With 190,000 active smartcard holders and 45 million journeys over the past 12 months, Swift strives to make all kinds of transport accessible to its citizens, adapt to new transport trends and make the region more sustainable. Swift cards can be used as a ticket for train, bus or tram, and pay as you go for bus, tram and car parking; you can load season tickets and credit onto your Swift card.

Swift provides the technical infrastructure and the know-how to the user-facing MaaS application. Swift’s multimodal and multi-operator capping solution forms the future-proof payment method for all existing and upcoming MaaS integrations. Both 3- and 7-day capping has arrived as a feature across bus and tram to support more flexible working. Swift’s reporting suite is well-equipped as a foundation to build on for long-term behaviour change through nudging transport users towards more sustainable transport modes.

Multimodal ticketing schemes must also build trust regarding the prices and products transport users will be using. They must also provide similar levels of customer support if things go wrong and provide access to refunds. As highlighted in Accessibility and inclusion, digital exclusion issues must be considered when developing ticketing systems that rely on the user having access to a smartphone. Transport operators and, where appropriate, local authorities will need to consider how best to support those who do not have or do not wish to access smartphones, contactless payment cards and digital banking, ensuring alternatives are available and those passengers are not unnecessarily disadvantaged.

These challenges could impact the growth of MaaS in the UK and the ability to develop sustainable business models, leading to a fragmented user experience where offers are not able to join up effectively.

Pricing structures should be as transparent as possible to allow users to access the most affordable journey offers. Users should have confidence that they are getting the best deal, whether that is flexibility, cost or convenience (for example, total journey time).

We recommend ticketing schemes offer transparent pricing structures to ensure all users can access the “best value fares” for their journey.

We recommend ticketing schemes can be tailored to individual requirements including those of different disabled passengers, take into account users with different protected characteristics in the design process and those who may need concessionary fares.

It is vital that, where possible, consumers receive the same level of service and protection from a multimodal journey as a single-mode journey if purchased through a MaaS platform.

If a leg of a multimodal journey fails, for example, a missing bus service to a train station results in the consumer missing their train, it may be unclear to them who is responsible for service failures within their journey, who they need to contact to request compensation or an alternative means of travel such as a re-booked ticket or another solution to get them to their destination.

As highlighted in the data considerations section of this code, consumers must also have confidence that their personal, financial and journey data is being handled appropriately. Transparent and robust data protection processes can ensure a more seamless experience for the user and build confidence and trust in using MaaS platforms.

The Consumer Rights Act 2015 sets out the basic rules that govern how consumers buy goods and services. Bus and other public transport passengers have been covered by the act since it came into force, with rail included from 2017. The act gives passengers the same legal protection they receive when paying for any other service or goods and the right to redress when a service is not provided with reasonable care and skill or as agreed.

However, some modes of transport have their own passenger rights regulation. For buses and coaches, these are set out in Regulation (EU) No. 181/2011, as retained in UK law, and The Rights of Passengers in Bus and Coach Transport (Exemptions and Enforcement) Regulations 2013.

These regulations give passengers rights to information and support accessibility for all passengers. Passengers have rights regarding the provision of information before and during their bus or coach journey. It should be noted the services provisions of the Consumer Rights Act 2015 do not apply to bus and coach transport if governed by Regulation 181/2011.

For rail passengers, the Rail Passengers’ Rights and Obligations (Amendment) (EU Exit) Regulations 2018 came into force in the UK in 2019. However, in practice, this brought only small additional benefits for passengers, such as the right for passengers who are delayed by over an hour to be offered free meals and refreshment, if available. Rail passenger rights in the UK derive principally from rail contracting and licensing regimes and exceed the minimum standards in the Rail Passengers’ Rights Obligations Regulation.

MaaS platform providers should have a clear understanding of the roles and responsibilities of transport operators offering services through their platform, including who is liable for handling enquiries, paying compensation for delays or cancellations, or issuing refunds if part of a multimodal journey fails or service levels drop below an agreed standard.

We recommend MaaS platform providers offer transparent and consistent information for multimodal journeys and set out points of contact for users upfront so they understand how they can provide feedback on their journey, claim for compensation for delays or cancellations, or request a ticket refund should they need to.

This information should be fully accessible and offer offline points of contact for users who may not have access to a smartphone. The MaaS platform should also update the users journey with real-time information to offer an appropriate alternative route to their destination.

Users should have confidence that the journey options presented to them are not skewed due to underlying commercial agreements between the MaaS platform and transport operator.

We recommend MaaS platforms make clear where a particular journey, mode or operator is being promoted or prioritised owing to a prior commercial arrangement. This might be through a visual cue to users, for example, a “sponsored” or “promoted” tag.

We want to ensure transport operators, local authorities and MaaS platform providers maintain the high standards set for processing users’ personal data when delivering services through a MaaS platform.

It is essential that personal data privacy considerations and user privacy needs are incorporated into the design of any MaaS scheme from the outset and that data protection is baked in during the design phase and throughout the life cycle of the data processing.

We recommend that all organisations involved in a MaaS scheme ensure users personal data is processed in a manner that complies with data protection legislation.

We recommend that where data processing is likely to result in high risk to individuals, data controllers conduct a data protection impact assessment prior to the processing to assess such risks and identify potential mitigations.

Prior to any data processing, it is important that the entities involved, including transport operators, platform providers and other bodies clearly establish their relationships from the outset, to ensure clarity of roles and responsibilities as required in Articles 24 to 29 of the UK GDPR.

Given MaaS platforms are likely to be accessed by children, the processing of children’s data should be in compliance with the age-appropriate design code. Platform providers may wish to pay particular focus on meeting standards 10 (geolocation) and 12 (profiling) when designing their MaaS platforms. While not a legal requirement, it is good practice to consult with children or other users who have protected characteristics prior to any data processing.

MaaS is an emerging industry, with many platforms and applications still in their infancy worldwide. Government wants to encourage new entrants in the MaaS ecosystem and help shape and develop a healthy, competitive market that delivers and rewards commercially viable business models. Government is conscious of the risks of low or non-existent competition in platform-based industries and how this lack of effective competition in the MaaS market could undermine the UK’s ability to seize the potential benefits and improve transport for the user.

Given that the MaaS market is still emerging, it is not clear how or whether such issues might arise. Competition issues might arise, or already be present, within transport, technology and data industries, which MaaS will heavily rely upon. The emergence of MaaS platforms could strengthen these positions and make it challenging for new entrants in such industries to emerge. Low levels of competition could result in poor outcomes for users, as journey choices are limited to a smaller number (or even single) operators.

The dominance of some large online technology companies shows that competition risks are a very real prospect for digital platform organisations.

The Competition and Markets Authority (CMA) investigates entire markets where competition or consumer problems arise and aims to foster a pro-competition environment in UK markets. It has the ability to enforce penalties on any firm acting in a non-competitive way. If anti-competitive behaviour in the MaaS market does occur, the CMA is equipped to deal with this.

As the MaaS market grows in the UK, there may be a need for DfT to monitor the market to ensure it is operating in a fair way. Government will ensure that risks are identified and, where necessary, legislation or regulation is brought in to address any competition issues that may arise.

As outlined in our future of mobility: urban strategy principles, government believes that the marketplace for mobility must be open to stimulate innovation and give the best deal to consumers.

A low competition environment could be exacerbated by MaaS platforms entering into exclusive commercial agreements with underlying service providers, such as bus or rail operators. This could prevent other MaaS platforms from using these services, leading to heavily fragmented service provision and subsequent impact on the users willingness to use these platforms.

On the other hand, it may be inefficient and sub-optimal for multiple MaaS providers to try to compete given the number of relationships and commercial agreements needed to enable multimodal platforms.

Local authorities can take a leading role in ensuring that emerging platforms in the MaaS ecosystem place user experience at the heart of their plans. This could be achieved through close working with operators and platform providers. The recommendations and information provided in this code of practice offer a helpful (though unexhaustive) approach to developing a MaaS platform that is user-centric and helps to achieve the wider benefits of MaaS.

We recommend local authorities, MaaS platform providers and transport operators ensure that any commercial agreements that are entered into promote fairness on pricing, avoid exclusivity of services and encourage data sharing to guard against any negative competition outcomes.

We recommend all possible public transport options and services available in the area to be shown in the MaaS app, to avoid fragmentation of services across apps.

Government acknowledges that MaaS is an emerging industry, and this code of practice is intended to respond to the evolving nature of the market. It may be that competition issues arise in the MaaS market once it begins to mature. We will periodically review this code of practice to ensure that we are offering the most useful advice.

MaaS is part of a wider digital economy that is still emerging, with many challenges that are still unknown. We will ensure that our position on MaaS keeps up to date with relevant developments that may affect the wider sector, such as new regulation.

The content and recommendations in this code of practice will be regularly reviewed and updated to ensure it continues to reflect the needs of the MaaS industry as it grows in the UK.

Here are some ways government will be supporting MaaS in the coming years:

our transport data strategy will set out the vision for how the department will improve the discoverability, accessibility and quality of transport data

our future of transport rural strategy will consider how MaaS can provide greater freedom and choice for the travelling public living in rural and remote areas

our future transport zones programme will continue to test and trial MaaS schemes with the aim to develop longer-term viable business models for MaaS

our vision, as set out in the national bus strategy for England and the plan for rail white paper, is for there to be closer integration between all forms of public transport. Our ambition is for greater integrated ticketing opportunities to allow more choice in travelling either through local bus, rail or metro.

as outlined in our transport decarbonisation plan, we will continue to champion future of transport technologies to support the development of MaaS solutions. These solutions can contribute to a reduction in car dependency and drive a shift toward a better-connected multimodal transport system

Government will continue to look for opportunities to support MaaS and its development in the UK by working collaboratively with industry, commissioning research and considering where further funding may be needed.

The case for government involvement to incentivise data sharing in the UK intelligent mobility sector↩

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