The obligations of transport service providers need to be clarified, specified and given a clear timeframe.
We support the principles in this section. We do, however, request a specification to clarify the obligation to make tickets and comparable products available, as this is not clear, especially visavi the very clear commitments for MaaS operators in section 4.1.
We also ask that the timeframe for digital services/means of transport/tickets relevant to the MaaS solution is specified clearly, as experience tells us ambiguity can easily lead to challenges and conflicting views. We would recommend a maximum of 6-12 months to implement this, with a deadline in the second quarter of 2022.
We also strongly recommend that the determination of the relevance of products is made in cooperation with a neutral third party, to avoid conflicts. Finally we want to highlight that the statement on the value proposition according to the free-market-principle, although very positive, is conflicting with the requirements for public transport resales, i.e. with the obligations on pricing and bundling.
