Consultation outcome

Mobility as a Service: code of practice consultation – government response

Updated 30 August 2023

Executive summary

Introduction

The Department for Transport (DfT) Future of Transport Programme aims to secure the UK’s position as a world-leading innovator, creating a greener and more inclusive future transport system for us all. We want to create a safe, secure and accessible transport system that is fit for the future and helps people to move around. 

Mobility as a Service (MaaS) platforms can make journeys more convenient for users through streamlining planning and payment, which could encourage users to choose more sustainable modes of transport and empower more people to travel.

This consultation on a Mobility as a Service code of practice ran between 8 February 2022 and 3 May 2022. It sought views and evidence from all those with an interest in MaaS to understand whether a code of practice would be helpful and, if so, what the content of that code should be.

Government response

This consultation was designed to gather evidence to understand how a MaaS code of practice might help to support this emerging industry. The consultation asked questions on a broad range of topics related to MaaS including data, multimodal ticketing, accessibility and inclusion, algorithmic bias and competition. The responses highlighted some current challenges that exist in deploying MaaS schemes and how a code of practice could address these issues. This document summarises the consultation responses and provides a government response to each section.

Summary of responses

Code of practice

Responses called for a code of practice to clarify the government’s ambition for MaaS and address the issues of data sharing, data standardisation and data privacy by providing relevant guidance to MaaS platform providers, local authorities and transport operators. Respondents also suggested that any code of practice should ensure the needs of users who may struggle to access MaaS – such as those without access to a smartphone, bank account or with disabilities – are considered throughout. The majority of respondents felt that any code of practice should not be as overly prescriptive as to stifle innovation in this emerging industry.

Data

Responses focused on the types of data MaaS platforms might require and the way that such data should be collected and stored. Standardisation of data formats and encouraging data sharing were frequently mentioned by respondents. Responses highlighted the potential need for common, interoperable standards to make data integration easier. Finally, respondents felt a code should address issues around data privacy for transport users and commercial organisations when sharing data.

Multimodal ticketing

The majority of respondents identified barriers to creating multimodal ticketing schemes including commercial concerns in regard to revenue sharing, potential loss of passenger numbers and the complexities of creating multimodal ticket pricing structures. Respondents suggested that a code of practice could play a role in helping to resolve some of these issues by encouraging interoperability between modes and providing guidance on how providers can work together, including addressing consumer protection and liability issues.

Accessibility and inclusion

The majority of respondents suggested that a code of practice could help provide guidance on accessibility and inclusivity by highlighting existing standards and relevant legislation, offering best practice case studies on accessibility and inclusion in MaaS and endorsing the inclusion of protected groups in the design process. Some respondents also suggested that, as MaaS has the potential to improve access to transport for those with protected characteristics, any code of practice could consider ways to monitor how MaaS services are affecting these groups and government should play a role in seizing these opportunities.

Consumer protection

The majority of respondents felt that a code of practice should define roles and accountability for each organisation involved in a MaaS scheme and who is liable to deal with any compensation claims from users. Some respondents acknowledged that given its voluntary nature, a code of practice could be limited in what it can achieve beyond clarifying existing regulation. Respondents suggested a code of practice could set expectations that MaaS platforms put systems in place to deal with this risk by presenting clear information on how to claim compensation to users upfront.

Algorithmic bias

Respondents felt any code of practice should strike a balance between bias and user preference, endorsing inclusive data sets to guard against biases, placing a focus on transparency and ensuring MaaS providers audit their data sets to help identify potential biases. Respondents also noted that to encourage users towards sustainable travel options, a code of practice could endorse journey options that are nuanced and realistic, allowing individuals to define their preferences. The majority of respondents also noted that a code of practice could provide a method for calculating carbon emissions as it can be difficult to arrive at a consistent measure.

Competition

Respondents were clear that there were potential competition risks in the emergence of the MaaS market in the UK, owing to the possibility of first mover advantage and exclusivity of rights of platforms that are first to launch. They noted that a voluntary code of practice would have limited scope to challenge market conditions. However, it was important that any code offer recommendations that are not too prescriptive and take into account the evolving nature of the MaaS market in the UK. Relevant legislation should be referenced and made clear how organisations can comply.

Other questions on MaaS

The majority of respondents felt it was important that the objectives of any code are clearly articulated upfront. Other suggestions included the need to consider community outreach and stakeholder engagement to raise the profile of MaaS and to address the issue of creating a unified calculation for carbon emissions.

Respondents suggested that to monitor the effectiveness of a code of practice, clear objectives and terms of reference should be set, alongside periodic reviews to consider if regulation may be needed in the future. Some respondents highlighted the need to engage stakeholder groups and conduct surveys to assess the uptake of a code, to track how many times a code is downloaded, collate learnings and best practice.

Respondents suggested that in the future, DfT could consider further investment in MaaS and the infrastructure needed to support it.

Introduction

Background

In 2019, we published the future of mobility: urban strategy, setting out our approach to maximising the benefits and managing the risks of new technology in urban areas. One of the principles of this strategy is that new mobility services must be designed to operate as part of an integrated transport system combining public, private and multiple modes for transport users. We recognise the potential of new technologies and business models such as Mobility as a Service to make the planning and execution of multimodal journeys easier.

What is mobility as a service (MaaS)

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 application or platform to make the planning and payment of trips easier for consumers. 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.

Why a MaaS code of practice?

This consultation was the third in a series of public consultations on MaaS, following the publication of the future of mobility urban strategy in March 2019 and the future of transport regulatory review: call for evidence on micromobility  vehicles, flexible bus services and MaaS, which concluded in July 2020. A summary of responses was published in November 2020. This consultation aims to build on our 2019 and 2020 work. 

As part of the transport decarbonisation plan (2021), 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.

Taking a voluntary approach through 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 where regulation might need to be brought forward in the future.

Consultation

DfT ran a consultation on a Mobility as a Service code of practice between 8 February 2022 and 3 May 2022. It sought views and evidence from all those with an interest in MaaS to understand whether a code of practice would be helpful and, if so, what the content of that code should be. The consultation invited respondents to submit their views on 24 questions.  

This document summarises the points raised in response to the consultation and provides the government response. The responses will inform the development of the content of any code of practice. The identification of particular suggestions within this document does not mean that DfT will necessarily take them forward. Similarly, the absence of a suggestion from this report does not mean it will not be considered. 

Structure of this document

Respondents had the opportunity to answer 24 questions spread across the thematic sections as follows:

• Section 1: Code of practice
• Section 2: Data
• Section 3: Multimodal ticketing
• Section 4: Accessibility and inclusion
• Section 5: Consumer protection
• Section 6: Algorithmic bias
• Section 7: Competition
• Section 8: Other questions on MaaS

Overview of respondents

Sixty-six responses to the consultation were received via email and online survey.

Responses were submitted by a mixture of individuals and organisations including local councils, transport operators, MaaS platform providers, academics, membership and trade associations, charities, businesses, pressure groups and think tanks.

Code of practice

Our consultation asked respondents for their views on the ways in which we could ensure a code of practice would be relevant for various MaaS stakeholders and to help us understand what content it would not be appropriate to include in a code of practice.

Questions

1. How can we ensure a code of practice is relevant for:

• commercial MaaS platform providers (for example, Citymapper, Moovit, Whim)
• local authorities (local council authorities within the UK)
• sub-national transport bodies (for example, Transport for London, Midlands Connect, Transport for the North)
• transport operators (for example, National Express, LNER, Stagecoach)
• transport users (those using transporting systems)

2. What issues do you feel would not be appropriate to include in a code of practice for MaaS?

Commercial MaaS platform providers

The most common theme identified by respondents was the need for a code of practice to clarify DfT’s definition of a MaaS platform and make clear the obligations of MaaS platform providers, such as expected levels and quality of service and certainty of access to transport services for users. Respondents also highlighted the need for a code of practice to provide clarity on the roles and responsibilities of MaaS platform providers on the issues of data sharing, data standardisation and data privacy. Finally, respondents called for further clarity on the government’s longer-term ambition for MaaS.

Local authorities and sub-national transport bodies

The majority of respondents identified data as a key topic where a code of practice could add value for local authorities by helping to make appropriate data more easily available and identifying which types of data local authorities need to share with MaaS platform providers. Respondents were also clear that a code of practice should provide sufficiently flexible guidance to allow for future developments in the MaaS industry and that a code should encourage innovation, support interoperability between transport modes and ensure all transport modes are represented.

Respondents called for a code of practice to provide practical guidance and procurement advice to local authorities in setting up MaaS schemes by providing templates for legal documents, support when choosing a MaaS platform to partner with and guidance for managing these contractual relationships.

For sub-national transport bodies, the themes identified by respondents echoed the responses above, including practical guidance, interoperability and data sharing. Respondents also highlighted the need for a code to include best practice examples of successful MaaS schemes and integrations with sub-national transport bodies.

Transport operators

Respondents felt that to ensure a code of practice is relevant for transport operators, it should clearly articulate the government’s vision for MaaS, the benefits of MaaS and encourage transport operators to get involved in MaaS schemes. To do this, any code could outline the expectations for transport operators in relation to data sharing and clarify how to take part in a MaaS scheme.

Transport users

The majority of respondents identified the need for a code of practice to build public awareness of MaaS and its benefits for transport users, highlighting the potential environmental benefits and cost savings to travellers. Respondents also felt any code should ensure inclusivity is a key focus by putting transport users at the heart of decision-making and supporting those who may find accessing MaaS platforms more difficult, for example, those without access to a smartphone. Finally, respondents noted it was important that users understand how their personal, financial and travel data would be handled and that users should be protected from any potential negative competition outcomes in the MaaS market.

Issues it would not be appropriate to include in a code of practice

The majority of respondents felt that a code of practice should not be as overly prescriptive as to stifle innovation in this emerging industry. A code of practice should not include restrictive guidelines on technologies and should avoid taking a prescriptive stance on MaaS business models, such as setting barriers for entry too high and avoiding any statements that could impact open competition.

Government response

We agree that a code of practice could play an important role in clarifying the government’s vision for MaaS and articulating the benefits of MaaS to raise public awareness.

In the consultation, respondents highlighted data sharing, data standardisation and data privacy as key concerns. In the code of practice, we will include a section on data issues to facilitate MaaS, which will provide relevant guidance and recommendations to MaaS platform providers, local authorities and transport operators.

We will also include a section on accessibility and inclusion in the code of practice that will offer recommendations to ensure the needs of users who may struggle to access MaaS – such as those without access to a smartphone, bank account or people with disabilities – are placed at the heart of the design of any MaaS scheme.

We agree that it would not be appropriate for the code of practice to provide recommendations or endorsements for specific technologies or business models for MaaS. However, the code will offer best practice case studies and point to useful resources where possible.

Data

Our consultation highlighted data sharing and modal data standardisation as 2 areas in which barriers currently exist to realising the full potential of MaaS. We asked respondents for their views on the ways in which a code of practice could play a role in supporting data issues to facilitate MaaS. 

Questions

3. What, if any, should be the role of a code of practice in addressing:

• data issues overall to facilitate MaaS
• data sharing arrangements to facilitate MaaS
• data quality to facilitate MaaS

4. What are the benefits of data standardisation?

5. What, if any, challenges to accessing standardised data:

• exist now
• will exist in the future

6. How should data sharing arrangements between transport operators and MaaS platform providers be managed? For example, contractual or voluntary arrangements

7. What are the main challenges to sharing data?

8. What do you think will be the impact of your challenges?

9. Are there other data issues beyond data sharing and data standardisation that a code of practice could address?

The role of a code of practice in addressing data issues

Several common themes emerged in response to this question. Respondents felt that a code of practice could play a role in addressing data issues in relation to MaaS by offering guidance on what types of data are required to set up a MaaS scheme and how that data should be collected and stored. The promotion of the standardisation of data formats and encouraging data sharing was also highlighted, alongside the potential need for a focus on common, interoperable standards to make data integration easier. Finally, respondents felt a code should address issues around data privacy for transport users and commercial organisations when sharing data.

Modal data standardisation and data quality

Ninety per cent of responses to this question agreed that there are benefits to data standardisation for MaaS. Respondents identified these benefits could include easier integration and interoperability between transport operators and MaaS platform providers, increased flexibility with the option to use different vendors when setting up MaaS schemes and the ability to collect comparable data across transport modes and geographies. Data standardisation could make it easier for new entrants to enter the MaaS market, creating more transparency and lower operation costs. Ultimately this could lead to better solutions for transport users by helping to accelerate the delivery of MaaS schemes in the UK.

Respondents highlighted a number of challenges that currently exist to accessing standardised data. These include a lack of common data standards and consistency in standards across transport modes, a lack of digital maturity in organisations where data is often kept in silos, and legacy issues can cause problems. Respondents also expressed concern about the lack of incentives or regulatory pressure to standardise data and that to do so would incur additional cost and resource.

In the future, the majority of respondents were concerned about the ability to gain access to relevant data where transport operators or platform providers may act as gatekeepers. They also identified the need for any standards that are introduced to be sufficiently flexible. Some respondents expressed concerns about the potential complexity of applying new standards alongside existing data.

Respondents felt that any code of practice could play a role in clarifying a minimum standard for data quality, taking into account accuracy, reliability, granularity and format. Some respondents suggested a code should offer support for modes that may be further behind in gathering and standardising data, such as community transport and car clubs.

Data sharing

Eighty-five per cent of responses agreed there are currently challenges to data sharing. The challenges identified include a lack of understanding of the benefits of data sharing and the need to build trust between the parties involved in data sharing agreements, alongside commercial concerns about market cannibalisation and the fear of increased operating costs. Respondents also highlighted issues with the quality of the data being shared, such as a lack of standardisation, availability and interoperability between modes. Data privacy and intellectual property issues for both users and organisations were also a concern. The majority of respondents felt the impact of these challenges would be to limit the uptake of MaaS, making it more difficult to meet the associated environmental policy goals and leading to a poorer quality of service for the user.

Sixty-seven per cent of responses felt that any data sharing agreements between transport operators and MaaS platform providers should be managed contractually. A small number of respondents suggested voluntary agreements or a hybrid of contractual and voluntary agreements would be most appropriate. Respondents identified that contractual agreements would allow for more consistency for users and ensure data privacy is protected. These agreements could also help to protect commercial interests, clarify expectations and ensure controls are enforceable. Some respondents suggested that voluntary agreements were more appropriate to avoid stifling innovation. A small number of respondents noted that some datasets could be shared voluntarily, but critical data should be shared contractually.

The majority of respondents felt that a code of practice could play a role in encouraging data sharing by outlining how organisations can protect themselves and the personal information of users when sharing data. A code could design or support the development of a single MaaS standard and identify which data types can be opened, and which should remain closed, articulating the responsibilities of MaaS platform providers, transport operators and local authorities.

Other data issues

Seventy-three per cent of responses felt there were other data issues that any code of practice should address. These included offering guidelines on how consumer data is stored, processed and shared; guidance on mechanisms for dispute resolution if data sharing protocols break down or fail; and drawing attention to the importance of data integrity and reliability.

Government response

We agree that there are a number of challenges that currently exist for organisations looking to deploy MaaS schemes when it comes to data standardisation and data sharing.

The code of practice will seek to address this by highlighting relevant legislation and government strategies to help organisations navigate these complexities and understand the government ambition for data issues relating to MaaS. The code will also provide clear recommendations to MaaS platform providers, transport operators and local authorities to guide their approach to data standardisation and data sharing in line with government goals.

Data privacy for both users and commercial organisations emerged as a key issue for consideration from this consultation and we will provide recommendations on this topic throughout the code of practice.

Multimodal ticketing

Our consultation sought to understand how a code of practice could help MaaS platform providers, local authorities and transport operators overcome the challenges of offering multimodal tickets. 

Questions

10. What do you believe are the barriers to creating multimodal ticketing schemes?

11. What do you think will be the impact of your challenges?

12. What role, if any, can the code of practice play in supporting multimodal ticketing?

Barriers to multimodal ticketing

Seventy-seven per cent of responses agreed there are barriers to creating multimodal ticketing schemes. The majority of respondents identified that these barriers could include commercial concerns in regard to revenue sharing, potential loss of passenger numbers and the complexities of creating multimodal ticket pricing structures. Additionally, a lack of interoperability, including a lack of ticketing standards and incompatible technologies to underpin digital tickets could also be a barrier.

Respondents highlighted that each mode has different requirements and it could be difficult to get participation from all operators. Concerns around digital exclusion were also raised, including reliance on access to a smartphone and ensuring the inclusion of concessionary fares. Finally, a lack of clarification on liability issues for users was also raised as a potential barrier, for example, who is responsible for settling any compensation claims from users should one leg of their multimodal journey fail.

Respondents identified that the impact of these challenges could include delays to the implementation of MaaS schemes, impacting its growth in the UK. It could also make it more difficult to develop a sustainable business model for MaaS. Ultimately, this would lead to a fragmented user experience and fewer people using MaaS schemes. Some respondents noted that disabled users or those without access to a smartphone may be excluded from purchasing tickets through a MaaS scheme.

The role of a code of practice in addressing multimodal ticketing issues

Respondents felt a code of practice could play a role in addressing these issues by setting a minimum standard for MaaS providers and transport operators by:

• standardising contracts and clarifying which modes should be covered
• encouraging interoperability and providing guidance on how providers can work together
• clarifying government objectives for multimodal ticketing and offer best practice guidance

Government response

We understand that creating multimodal ticketing schemes can be a complex undertaking and this consultation has highlighted a number of important barriers.

The code of practice will seek to address these issues by including a section on multimodal ticketing, which will clarify government objectives for multimodal ticketing and MaaS by pointing towards current legislation and government strategies.

The code will also provide recommendations on the issue of consumer protection and liability for multimodal journeys. We believe it would not be appropriate for the code to set a technical standard for ticketing.

Accessibility and inclusion

MaaS has the potential to make travel more accessible and inclusive by offering journeys for everyone tailored to individual needs. Through our consultation, we sought views on the ways in which a code of practice could help provide guidelines on accessible and inclusive travel.

Questions

13. How can MaaS platforms ensure their systems are accessible and inclusive to all users, and the journeys they provide are accessible and inclusive to all users?

14. How, if at all, do you think a code of practice can help to ensure that MaaS is inclusive for those who may struggle with access, such as those without a smartphone or access to a bank account?

15. Are there other ways our code of practice can help to provide guidelines on accessibility and inclusivity?

Accessible and inclusive systems

Respondents suggested a number of ways in which MaaS platform providers could ensure their systems are accessible and inclusive to all users. The majority of respondents suggested MaaS platforms could engage protected groups when designing the interface of their applications to consider visible and non-visible disabilities and to comply with web content accessibility guidelines. Respondents also felt it was important that MaaS platforms work with diverse voices to avoid any bias in the design process and test their products with protected groups.

Respondents also noted that users should have access to non-digital payment options, such as paper tickets, and non-digital communication methods, such as call centres and physical kiosks.

The majority of respondents felt that it was important for MaaS platforms to provide the ability for users to tailor their journey based on individual needs and that MaaS applications should incorporate real-time accessibility data to help to facilitate this and ensure assistance is available throughout the journey.

Respondents also highlighted the importance of considering low-income users and ensuring that concessionary travel is still available and that non-app users are not financially penalised.

Accessible and inclusive journeys

The majority of respondents felt that for MaaS platforms to offer accessible and inclusive journeys, they could give users access to dynamic, real-time data that incorporates all available modes to allow users to plan their journeys based on their individual needs. MaaS platforms could also offer tailored route options in line with the user’s needs and offer physical assistance and interchanges. Some respondents also noted that offering free or more cost-effective route options, such as walking, could help to make MaaS more inclusive.

Digital exclusion

The majority of respondents noted that the code of practice could help to ensure MaaS is inclusive to those who may struggle with access to a smartphone or bank account by encouraging MaaS platforms to engage with these users and gather feedback from groups that may be digitally excluded. Respondents gave examples of non-digital solutions including:

• physical assistance at information points
• the ability to pay in cash or via pre-payment cards and mobility credits
• customer support offered outside the app

A small number of responses noted that MaaS solutions are digital by nature and that may result in some users being excluded. They noted the code of practice could play a role in guarding against this by suggesting alternative approaches.

The role of a code of practice

The majority of respondents suggested that a code of practice could help provide guidance on accessibility and inclusivity by highlighting existing standards and relevant legislation, providing best practice case studies on accessibility and inclusion in MaaS and endorsing the inclusion of protected groups in the design process. Some respondents also suggested the code of practice could consider ways to monitor how MaaS services are affecting those with protected characteristics.

Government response

We agree that MaaS platforms and the journeys they offer should be accessible and inclusive to all users. The code of practice will clarify the minimum legal requirement that MaaS platform providers should adhere to. It will also encourage all organisations involved to deploy MaaS schemes to go beyond this to put disabled passengers’ needs at the heart of the design process, making MaaS accessible and inclusive by design in a way that safeguards all users. The code of practice will also offer best practice examples.

Consumer protection

Through our consultation, we wanted to understand if a code of practice could help to clarify the roles and responsibilities within existing legislation and offer good practice solutions for tackling the interface between modes when it comes to consumer protection.

Question

16. What role, if any, can the code of practice play in addressing consumer protection needs for multimodal journeys?

Addressing consumer protection needs for multimodal journeys

Eighty-six per cent of responses felt that a code of practice could play a role in addressing consumer protection needs for multimodal journeys. The majority of respondents felt that any code of practice should define roles and accountability for each organisation involved in a MaaS scheme, and who is liable to deal with any compensation claims from users. Some respondents acknowledged that given its voluntary nature, a code of practice would be limited in what it can achieve beyond clarifying existing regulation.

Respondents suggested a code of practice could set an expectation that MaaS platforms put systems in place to deal with this risk by presenting clear information on how to claim compensation to users upfront or offer travel insurance. However, respondents felt transport operators were still ultimately responsible for the provision of services. They felt the use of best practice examples could help to demonstrate how this can work in practice.

The majority of respondents suggested that a code of practice should also consider how consumers’ data is used and shared and highlight the need for users’ personal, financial and travel data to be fully protected. Respondents also felt a code of practice should offer ways to guard against multimodal journey failures by highlighting the need for MaaS platforms to offer alternative routes using real-time updates.

A small number of respondents suggested new powers may be needed in the future to protect consumers, which could be similar to the ATOL scheme for air travel.

Government response

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

The code of practice will seek to clarify existing relevant legislation and set clear expectations for consumer protection in the event of a multimodal journey failure. We will 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 or claim compensation should they need to.

Algorithmic bias

MaaS platforms use algorithms to determine which journey options are displayed to the user, and in which order they are presented. These algorithms, and the data that underpins them, could play an important role in encouraging users to take active journeys and choose more sustainable modes of transport. However, there is a risk that the data used to train these algorithms may reflect wider social inequalities.

In this consultation, we wanted to understand if a code of practice could urge MaaS providers to avoid algorithmic bias and unfair discrimination and encourage sustainable travel.

Questions

17. How, if at all, can MaaS platforms encourage sustainable travel options and active travel options, such as walking and cycling?

18. What, if any, role do you think the code of practice should play in addressing algorithmic bias?

Encouraging sustainable travel options

Respondents felt that there were many ways in which MaaS platforms could help to encourage sustainable travel. The majority of respondents suggested nudging, gamification and incentives could play an important role in encouraging users to change their behaviour and switch to more sustainable options. Respondents noted that it was important to provide clear information on journey options and incentivise good choices. A small number of respondents noted that employers could incentivise their employees to use a MaaS scheme through mobility or carbon credits.

Respondents also noted that to encourage users towards sustainable travel options, it is important to build trust in the MaaS app among users. Journey options should be nuanced and realistic, allowing individuals to define their preferences. Options could be presented when suitable for the user’s journey, not only when they generate the least carbon emissions. Respondents noted that any skewing of journey planning results could erode consumer trust.

The majority of respondents highlighted that journey options presented should incorporate active travel, such as walking and cycling, which could include data on step counts and calories burned. A small number of respondents noted that MaaS platform providers, local authorities and transport operators could agree contractually to promote sustainable travel and favour low-emission transport providers in their MaaS schemes.

Respondents also noted that all MaaS platforms could include carbon emissions data and provide users with the ability to sort their journey options by modes with the lowest carbon emissions.

Encouraging active travel

The majority of respondents felt that similar strategies could be used to encourage active travel, such as gamification, offering incentives and providing active travel options only when practical to the user. Respondents also noted that the personal safety of users must be taken into consideration when offering suitable walking routes, such as women travelling alone at night.

Respondents noted that good quality data and network information on walking and cycling routes, such as level of difficulty, could help users make more informed decisions. Some respondents suggested MaaS platforms could prioritise active travel journey options, while others felt journey options could be presented in a neutral way, allowing users to make their own decisions with as much information as possible.

The role of a code of practice in addressing algorithmic bias

Respondents had a range of suggestions for any code of practice, such as striking a balance between bias and user preference, endorsing inclusive data sets to guard against biases, placing a focus on transparency and ensuring MaaS providers audit their data sets to help identify potential biases.

Some respondents noted that bias may erode consumer trust, and any bias should be in favour of user preferences, not specific operators. The majority of respondents also noted that a code of practice should provide a method for calculating carbon emissions as it can be difficult to arrive at a consistent measure. Some respondents felt best practice case studies would be beneficial.

Government response

How journey options are presented to users in a MaaS platform is likely to have an impact on their choice of transport. If carbon-intensive modes are prioritised, 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.

We agree that algorithms that determine these journey options must be fair and transparent. We understand the need to strike a balance between encouraging sustainable travel and the erosion of user trust if the journey options displayed are skewed in favour of certain modes.

Through the code of practice, we will recommend MaaS platform providers 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. We will also recommend MaaS platforms provide users with information about the carbon dioxide (CO2) savings that can be made by walking or cycling, so they can make informed choices about sustainable modes of transport. The code will also provide resources for calculating carbon emissions.

Competition

MaaS is an emerging industry with many platforms and applications still in their infancy worldwide. We are 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.

 In our consultation, we wanted to understand the role a code of practice could play in addressing competition issues that may arise in the MaaS market.

Question

19. What, if any, role do you think the code of practice can play in addressing competition issues that may arise in the MaaS market?

The majority of respondents felt that transport operators and MaaS platform providers should place users’ needs first, ahead of any competitive goals. Local authorities could assist in overseeing the deployment of MaaS schemes in their local area to avoid the dominance of certain operators and ensure the schemes align with their strategic goals.

Respondents noted that a voluntary code of practice would have limited scope to challenge market conditions. However, it was important that any code offers recommendations that are not too prescriptive and take into account the evolving nature of the MaaS market in the UK. Any relevant legislation should be referenced and made clear how organisations can comply.

Respondents also suggested a number of competition issues that could arise, such as fragmentation of services, for example, some services being available only through one MaaS platform, which could require users to use multiple MaaS platforms to complete their journey. Respondents expressed a real concern about first mover advantage in the MaaS market, noting that the longer a platform operates the harder it is for others to compete due to the value and importance of user and journey data.

Some respondents suggested that a new authority to monitor competition risks may need to be established to ensure monopolies do not form. Respondents also noted that keeping data accessible and open, where possible, was key to keeping a level playing field in the MaaS market and avoiding first-mover advantage. Respondents suggested that any code of practice should remain operator agnostic.

A small number of respondents suggested a code of practice could offer procurement and business model advice and seek to link transport operator cooperation with MaaS schemes to access public funding.

Government response

We agree that low levels of competition in the UK MaaS market could result in poor outcomes for users, as journey choices are limited to a smaller number (or even single) operators. We acknowledge that MaaS is an emerging industry and the code of practice is intended to respond to the evolving nature of the market.

Through the code of practice, we will recommend that local authorities, MaaS platform providers and transport operators ensure that any commercial agreements entered into promote fairness in pricing, avoid exclusivity of services and encourage data sharing to guard against any negative competition outcomes. We will also recommend that all possible public transport options and services available in the area be shown in the MaaS app to avoid fragmentation of services across apps.

Other questions on MaaS

Questions

20. What good practice are you aware of in relation to the 6 areas identified above that you would like to see reflected in the code of practice

21. What, if any, other topics do you feel should be addressed through the code of practice?

22. What do you think we should be doing to monitor the effectiveness of the code of practice?

23. Are there any other ways you think we should support MaaS in the future?

24. Any other comments?

Other topics that should be addressed through a code of practice

The majority of respondents felt it was important that the objectives of the code are clearly articulated upfront. Other suggestions included the need to consider community outreach and stakeholder engagement to raise the profile of MaaS and to address the issue of creating a unified calculation of carbon emissions.

Monitoring a code of practice

Respondents suggested that to monitor the effectiveness of any code of practice, clear objectives and terms of reference should be set, alongside periodic reviews to consider if regulation needs to be brought in in the future. Some respondents highlighted the need to engage stakeholder groups and conduct surveys to assess the uptake of a code, to track how many times the code is downloaded and collate learnings and best practice. A small number of respondents suggested industry events and conferences could be used to disseminate information.

Other ways DfT could support MaaS in the future

Respondents suggested that in the future, DfT could consider further investment in MaaS and the infrastructure needed to support it. A small number of respondents suggested the development of a national strategy for MaaS and a stronger evidence base would be beneficial.

Government response

We agree that the objectives of the code of practice should be clearly articulated and we will do this through the inclusion of a section focused on the government ambition for MaaS in the code of practice.

We will also set out our monitoring and evaluation plan to ensure we can examine the uptake of the code of practice and understand where updates may need to be made in the future.