Cross-border rail in Europe: how it works
Running a train across a European border requires four separate processes to align — infrastructure access, vehicle authorisation, crew certification and traffic management — each governed by different bodies on different timelines.
A railway undertaking seeking to operate across borders cannot treat the journey as a single transaction. It must secure track access in each country, obtain authorisation for its vehicles in each territory, certify its drivers to local requirements and equip its trains to handle signalling transitions at the border.
Infrastructure access: slots and the One-Stop Shop
Track access for a cross-border service requires separate applications to the infrastructure manager (IM) in each country. Each IM controls capacity allocation on its own network and operates within its own timetabling cycle.
For freight trains operating on the European Transport Corridors, a One-Stop Shop (OSS) mechanism allows railway undertakings to request cross-border path capacity through a single contact point rather than approaching each IM individually.
For passenger services, no equivalent mechanism exists. Access remains largely bilateral, with timetable coordination handled through Rail Net Europe, a cooperation body between infrastructure managers that facilitates cross-border path requests but does not replace the national allocation processes. The result is that coordinating a new cross-border passenger service involves separate negotiations with each infrastructure manager along the route.
Vehicle authorisation: ERA and the national residue
The European Union Agency for Railways (ERA) issues vehicle authorisations that cover all relevant EU member states in a single procedure, replacing the earlier system of separate national approvals. A manufacturer or operator seeking to place a vehicle in cross-border service submits one application to ERA rather than one per country.
In practice, national technical rules (NTR) specific to individual networks — covering matters such as platform heights, loading gauges or specific safety requirements — can still require supplementary documentation even under ERA authorisation. National safety authorities (NSAs) retain a validation role in this process.
The consequence for rolling stock manufacturers is that vehicles intended for cross-border use are typically designed from the outset with multi-system capability, with compliance requirements built into the base specification from the start.
Crew: what the directive did and did not harmonise
The EU locomotive driver directive established a harmonised basic licence structure across member states, creating a common framework for driver qualifications. It did not harmonise language requirements or route knowledge, both of which remain national obligations.
In practice, a driver operating across a border must either hold certification meeting the requirements of both countries, or the railway undertaking must change drivers at the border. Both approaches remain in use.
Driver changes at the border add time and operational cost and place a practical ceiling on service frequency on many cross-border routes. Double certification requires investment in training and assessment but allows continuous operation.
Traffic management: class B systems and the STM solution
Most of Europe’s rail network still operates under national signalling systems, known as class B systems, developed independently before the European Train Control System (ETCS) existed.
A train equipped with ETCS crossing onto a class B network requires either a Specific Transmission Module (STM) — an onboard component that allows ETCS-equipped vehicles to communicate with the national system — or full multi-system onboard equipment capable of operating natively under both regimes.
STMs are the standard solution on most cross-border transitions today. Multi-system onboard equipment offers greater functionality but adds weight, complexity and cost to the vehicle. The more national systems a train must be capable of handling, the heavier and more expensive the onboard package becomes.
ERA’s expanded authorisation role is gradually reducing friction in vehicle authorisation. ERTMS rollout across the core TEN-T network is doing the same for traffic management, on a separate timeline and under separate governance. Infrastructure access and crew certification are harmonising more slowly.
Both are operational and commercial in nature rather than technical, and neither has a regulatory mechanism equivalent to ERA’s single authorisation window or ERTMS’s common signalling standard. The coordination cost in these two areas remains structurally high.