Link to the doc: Free the Norms

Free the Norms: Make all norms directly referenced in EU regulations publicly accessible

This is a letter drafted and signed (add yourself here) by standardisation experts involved in CEN TC278 WG3 and beyond. Most of us are independent experts who are actively contributing to Transmodel (EN 12896 series), NeTEx (CEN/TS 16614 series), SIRI (CEN EN/TS 15531 series), OpRa (CEN/TS OpRa, under final drafting), OJP (CEN/TS 17118) and DATEX-II (CEN EN/TS 16157 series). 

All of the above mentioned European Norms/Technical Specifications/Formats, hereafter referred to as “standards”, are directly mentioned in the European legislative framework under the umbrella ITS Directive ((EU) 2023/2661). They all go hand in hand with the mandate for all Member States to have a National Access Point (NAP) with public transport and road data openly accessible.

Today, accessing the official versions of these standards typically costs hundreds of euro per document. This creates a very high paywall that must be equally overcome by industry experts, public transport company developers, industry data adopters, innovators, start-ups, private individuals and critically, even the very people that create and improve these very EU standards.

This paywall model may have been a valid solution when those standards were used by a small circle of specialists, but it is no longer valid when these standards are referenced in EU legislation and expected to underpin large‑scale, public‑facing digital mobility services across Europe and are funded through the voluntary volunteer effort of the experts.

We are asking for a simple, concrete change: all standards that are referenced in EU regulatory framework for public deployment, including but not limited to Transmodel, NeTEx, SIRI, OJP, OpRa and DATEX-II, must be freely and publicly accessible in digital form.

This would align with EU principles of legal certainty and access to law, and with the Court of Justice’s case‑law (including the so‑called “Malamud” ruling, C-588/21 P) which stresses that binding norms must be accessible to the people they bind.

1. Why paywalled information is blocking EU mobility goals

2. Concrete harms currently seen on the ground

2.2. Barriers for newcomers and talent

2.3. Friction for entrepreneurs and investors

2.4. Weaker community processes and quality feedback

2.5. AI, tooling and education are blocked

2.6. Misinterpretation and competing implementations

3. What we ask for

1. Why paywalled information is blocking EU mobility goals

Transmodel, NeTEx, SIRI, OJP, OpRa and DATEX-II are at the heart of EU ambitions for interoperable, multimodal, real‑time mobility data. Yet:

• Legal certainty and access to law. When a standard is referenced in EU or national law and becomes de facto mandatory, people must be able to read it freely. Paywalled, mandatory standards are in tension with EU principles of transparency, legal certainty and democratic legitimacy.

• Experts and NAP members must pay to read the standards they implement. As a member of a National Access Point (NAP), we have to pay to access the standards that define our work. This slows down the implementation of core features within NAPs themselves.

• Efficient use of public money. Many implementers who rely on the standards are working on publicly funded projects. Some Member States explicitly forbid funding closed resources with public money. Paying individually for personal  access to standards referenced in law is an inefficient use of already strained budgets, and an archaic distribution model not suitable for the modern IT development landscape.

• Critical appraisal of the norms is weakened. The available pool of expert knowledge is kept smaller than needed, in part because of the need to pay to access the standards. Academic institutions, which often provide valuable critical appraisal in other spheres of knowledge, are not going to get to know and understand what is hidden behind a paywall.

• Adoption is weaker than competing industry specifications. For example, North American specifications used for navigation tools are freely accessible, making them easier to adopt. Publishing on NeTEx/SIRI requires constant references to paywalled material, which makes it riskier for experts, companies and newcomers to invest in this ecosystem.

• Updating an implementation is held back. Existing implementations in Europe should be following the efforts by the standards and not get left behind. If for each iteration a full new standard must be bought, the upfront investment to merely consult if changes should be made, costs thousands of euros. 

• Public authorities are pushed towards alternative formats. We have seen entities develop competing internal formats at Member States level simply because the official standards are hard to access and harder to defend politically.

• Innovation, competition and SMEs (small & medium enterprises). The paywall favours large incumbents who can easily absorb the cost and keeps SMEs, open‑source projects and individual innovators at the periphery.

• EU strategic autonomy. If EU‑backed standards remain hard to access, the market will continue to converge on open, non‑EU specifications, or purchase off the shelf products from commercial vendors. This undermines the EU’s ability to shape the future of mobility data.

This is not a theoretical problem. It is already undermining the EU’s own strategic standards. It can also raise issues of priorities or worldviews if our technology relies only on North American industry-led specifications instead of European-governed ones.

2. Concrete harms currently seen on the ground

The paywall on Transmodel, NeTEx, SIRI, OJP, OpRa and DATEX-II documentation creates very practical, harmful frictions.

• It is cumbersome for proponents to even access the standards they are trying to promote.

• There is a strong sense of injustice in having to pay for a document that effectively governs mandatory implementation.

• The credibility of the standard suffers: it is difficult to argue that a standard is realistic and pragmatic when we cannot publicly point to its content. This is in direct contrast to current alternative specifications.

2.2. Barriers for newcomers and talent

• It is a deal-breaker for young professionals to have to pay hundreds of euros to even begin understanding the European standards.

• Even as motivated NAP members, it can take years to learn how to deploy standardised exchanges (e.g. make compliant SIRI requests), partly because the core documents are not publicly available.

• This negative first impression slows down renewal of users, contributors and expertise and inadvertently promotes alternative specifications.

2.3. Friction for entrepreneurs and investors

• Stakeholders have to pay just to read the standards they are betting their investments on.

• This creates doubts for investors, who see free and widely diffused alternatives and wonder whether choosing Transmodel/NeTEx/SIRI/OJP/OpRa/DATEX-II is a sound decision.

• The paywall shifts the cost and risk to the very people trying to defend and promote the standards.

2.4. Weaker community processes and quality feedback

• Having truly open processes for corrections, questions or suggestions based on a paid document that most stakeholders are financially barred from accessing causes influence inequality and loss of transparency.

• It is impossible to publicly share links to the documentation when discussing the use of standards on open platforms, such as social media, newsletters, forums or public events (e.g., during conferences).

• The closed nature of the standards severely limits active and constructive contributions to the standards to a small circle of economically privileged organisations.

2.5. AI, tooling and education are blocked

• Today, it is not possible for anyone to legally feed the full documentation of the standards into AI tools to help discover, explore, summarise or query them, or to verify implementations against them.

• For the same reason we cannot legally build cost-effective, publicly available open-source  training tools that rely on AI to help people learn the standards.

• This contradicts the innovation‑friendly, AI‑ready environment the EU is trying to foster.

2.6. Misinterpretation and competing implementations

• Public servants have been known to misinterpret references to DATEX II in EU legal texts because they are unable to directly access the standard. It would have been more efficient and reliable to directly cite the DATEX II standard, rather than engaging in roundabout discussions about legal wording, data models, and the practical meaning of the requirements.. 

• Without access to the standard itself, it is harder to secure endorsement from decision-makers within national administrations.

• Parts of the documentation (e.g., XML examples used in NeTEx documentation) are available for free download, but the standards they examplify are hidden behind a substantial paywall. This can lead to confusion, misinterpretation, and misunderstandings, especially when what is available for free is contradicted by what is hidden behind the paywall.

• NAP members have witnessed real-world cases of alternative national formats being proposed, where they could not effectively argue against those because the official standard was not easily accessible to the people on either side of the argument.

The compounding effect of the aforementioned cases increases the risk of fragmented, competing implementations, precisely where the EU is trying to build a coherent, interoperable digital single market for mobility data.

3. What we propose

We propose that the EU introduces appropriate legislative amendments or changes to:

1. Guarantee free digital access to all Norms/Technical Specifications/Formats that are referenced in EU law for public‑facing deployment, including but not limited to Transmodel, NeTEx, SIRI, OJP, OpRa and DATEX-II.

2. Allow experts working on the standards to organise or provide official public links to each versioned normative document, so that public authorities, experts, educators and developers can reference and share the official text.

3. Allow reasonable reuse of the text for education, open‑source implementation, documentation and AI‑assisted tools, while preserving attribution and integrity of the standard.

4. Work with CEN and EU/EEA member states to adapt the funding model so that maintaining high‑quality standards does not depend on the currently restrictive funding model. Such a model could aim for a trusted third party that certifies an implementation, after self-certification by available technical artifacts.

This is an achievable reform, with a powerful impact. Freeing access to Transmodel, NeTEx, SIRI, OJP, OpRa and DATEX-II is a high‑leverage step to make EU mobility policy more effective, more legitimate and more future‑proof and would allow a faster roll-out of the EU legal framework that accelerates deployment of high‑quality multimodal travel information and real‑time services across Europe (including accessibility data).

It would make it easier for NAPs, operators, vendors and start‑ups to align on a common, well‑understood standard, and would enable education, training, open‑source tooling and AI‑based support for these standards.

Perhaps most important of all, it would then conform to the EUs own regulations and objectives.

Signed by (roughly in alphabetical order):

• Brede Dammen, Entur, Head of national trip planner and open data, Norwegian NAP - MMTIS

• Christophe Duquesne, Public Transport expert (initiator of NeTEx and SIRI)

• Einar Bjørkevoll, Entur, Head of standardisation, Norwegian NAP - MMTIS

• Thibaut Barrère, French NAP tech, co-chair of the NeTEx sub-group

• Frédéric Menou, French NAP tech

• Brewenn Métayer, French NAP business developer and member of French standardisation group.

• Tim Rivett, RTIG-Inform UK. chair of Public Transport Vehicle Data sub-group

• Tu-Tho Thai, Lead of the French standardisation group for Passenger information (Public Transport), co-chair of the NETEx sub-group

• Wilfried Düx, Head of Scheduling Systems Development at MENTZ GmbH

• Norbert Betko, Team Lead Algorithms for public Transport at MENTZ GmbH

• Malte Herlitze, Head of Passenger Information Development at MENTZ GmbH

• Roland Hesse, System developer at MENTZ GmbH

• Leonard Ehrenfried, Developer of OpenTripPlanner

• Roelof Hellemans, Secretaris General MaaS Alliance / Mobility Alliance

• Birgit Heydenreich, System developer at MENTZ GmbH

• Matthias Erven, Head of Passenger Information Development at MENTZ GmbH

• Menno Manheim, Data Engineer Travel Information at Transdev Nederland

• Anke Beckert, Teamlead of DELFI operation at Rhein-Main-Verkehrsverbund Servicegesellschaft [rms GmbH]

• Nicholas Knowles  UK Standards expert and  CEN WG3 member (Coauthor on SIRI, NeTEx, Transmodel)

• Alban Peignier, enRoute CPO, Public Transport expert

• Lene Bergsler, Realtime expert, Rejsekort & Rejseplan A/S, Denmark

• Nicholas, Data Manager, Rejsekort & Rejseplan A/S, Denmark

• Hans Gelok, Infoplaza Mobility

• Marc Diepenmaat, Information Manager Arriva NL

• Pascal Rhod, Transamo, member of French standardisation group, France.

• Felix Gündling, MOTIS Developer

• Bard de Vries, Lead architect Dutch National Access Point for Mobility Data (NTM), Chair european DATEX II Change Management Board, The Netherlands

• Emmanuelle Magnifici, RATP DEV, responsible for Passenger Information Data

• Jérémy BOIG, RATP CAP Île-de-France, Project Manager for Passenger Information Data