Timescales

We do not intend to bring all of the new requirements in as a single exercise, which would effectively require every bus operator and transport authority to be ready to provide the information from a single date in 2026. Instead, we intend to phase the new requirements in over an agreed period. We are also aware that having the assurance of a specific date helps organisations in planning for a transition, but only where that date is firm and clear.

We therefore consulted on the proposed sequence of requirements, in order to formalise and communicate the dates by which each element will be required. The resulting legislation will also consider this, and it will be subject to the Parliamentary procedure. The timetable we proposed initially was as follows:

  • April 2026, the BOD Regulations come into force, marking the start of mandatory open data duties
  • October 2026, or six months after coming into force, Local Authority requirement to keep NaPTAN up to date commences
  • April 2027, or twelve months after coming into force, Bus operator requirement to submit timetable data in the required standard
  • October 2027, or approximately eighteen months after coming into force. Bus operator requirement to submit simple fares information
  • April 2028, or twenty-four months after coming into force. Bus operator requirement to submit complex fares information and real time data in required standard

We asked:

Do you agree with the proposed timescales requiring the submission of the prescribed data?

Of the responses, 43% agreed with our proposal to phase in the requirements over time, in particular, individuals, groups representing passengers and the ‘technology sector’ including data experts and ticket providers.

Of those who disagreed with this approach, the majority of respondents were individuals who believe that the proposed timescale is too long overall, and that bus operators should be largely ready to provide this information already. One respondent answered:

"…Real-time needs to come sooner" with "exemption for smaller or rural operators" and that "larger city-based operators ie. First/Stagecoach/Lothian/McGill's should be as soon as possible..." – An individual response

Other respondents echoed this sentiment, expressing that they would rather real-time data introduced sooner, with an exemption criterion, with one specific response stating that they believed that even half of the proposed timescale was too long.

It is important that we do not look at provision of this information as simply a burden, but rather from a passenger-focused perspective which will increase bus patronage and promotes modal shift. For example, where a bus service is operating under a Section 22 permit, it is normally for the purpose of increasing the service provision for an area which may have low commercial coverage. In those cases, having the information about when the service runs openly available would support the case for opening up the service to the public, as more passengers would then be aware of it.

There is strong support for the proposed timescales, and we expect that bodies that do not already supply information will now begin to work towards those dates, as they will be laid formally in Parliament. We also strongly encourage earlier voluntary provision of the information in advance, in order to overcome any technical issues, which would put the body into legal non-compliance. This is not to impose an administrative burden, but rather satisfy a clear desire communicated by passengers for that information.

We received a comprehensive response from the Community Transport Association (CTA) bringing together the views of Scotland’s community transport organisations. This response supports the inclusion of Section 22 permit holders in scope and raising awareness of these types of service more generally, but points out that the financial situation for most community transport providers precludes heavy investment in new technology and that in particular the provision of real time information will be a difficult duty to meet if imposed in the same way as for traditional commercial services that are already equipped with ticket machines.

Given the disproportionate impact on these largely local, often not for profit organisations, it would seem reasonable to allow a far longer period for the provision of real time information. As noted in S4, where the service is registered with the Traffic Commissioner by a local authority, the local authority is able to also provide any associated fare and timetable information and remain complaint with this duty.

The revised timetable, which also takes into account delays that may occur due to the upcoming 2026 election, is therefore as follows:

  • Post summer recess 2026. The BOD Regulations come into force, marking the start of mandatory open data duties,
  • Approximately six months after coming into force, Local Authority requirement to keep NaPTAN up to date commences, Bus operator requirement to submit timetable data in the required standard
  • Twelve months after coming into force, or six months after the requirement to submit timetable data. Bus operator requirement to submit simple fares information
  • Around eighteen months after coming into force. Bus operator requirement to submit complex fares information and real time data in required standard
  • Around twenty-four months after coming into force, likely around 2031 - real time information from community transport/not for profit transport

“As a small Community Transport organisation run entirely by unpaid volunteers, we would wish to avoid any onerous demands on us and certainly would not want to incur any additional expenditure.”

Stephen Sparrow, Acting Chairman, Cairn Valley Community Transport

We will bring the requirements forward over the proposed period, which allows for a reasonable adjustment period for bodies which will be required to meet this new information duty, but who are currently not equipped to do so. Additionally, we will introduce a longer period for community or not for profit transport operators to meet the real time information duties, allowing for additional dialogue with that sector.