Independent report

Independent regulatory review of the Office of Rail and Road (ORR) executive summary

Published 3 September 2026

This independent review sets out an achievable pathway for the Office of Rail and Road (ORR) to evolve from a respected regulator into an organisation with a rebalanced remit that also serves as an independent strategic advisor to the Secretary of State (SofS) on the overall rail system. In doing so, ORR can contribute to the ambitions of rail reform and a more integrated, resilient and efficient transport system. Realising this opportunity will require alignment on vision, sustained commitment and collaboration across government, industry and ORR itself.

Collectively, the review’s recommendations provide the early steps on that pathway. These provide a basis for a refocused ORR to generate significant value and support economic growth by addressing recognised gaps and bolstering whole-of-system perspectives. They also take ORR into new territories and call for new mindsets, always easier said than done.

Opportunity

ORR’s independence is central to its credibility and trustworthiness. It allows ORR to produce objective, evidence-based advice; gather insights that might not otherwise be shared; act as a ‘fair’ intermediary and provide assurance with no perceptions of bias.

This is an asset that can be deployed in many ways while recognising and respecting Great British Railways’ (GBR) future role as the railways’ ‘directing mind’. Applied judiciously in support of the SofS, and backed by investment in skills, capability and culture, ORR’s independent expertise can underpin the advice and assurance that helps to unlock system wide change and deliver the ambitions of both rail and road reform.

The ORR’s independent expertise already delivers significant value. The report highlights opportunities to extend this, in areas such as long term stewardship of roads and by greater integration of lessons, insights and expertise across its rail, roads and safety functions (potentially also supporting the Department for Transport (DfT’s) ‘Better Connected’ strategy). Additionally, with the ambitions of many organisations deeply reliant on rail and/ or road infrastructures, including national governments and mayoral authorities, ORR’s impartiality could make it well placed to advise the SofS as they navigate the multiple interfaces and strategic trade-offs involved.

Regulatory performance

ORR is generally respected as a regulator, valued for its independence and recognised for its economics and safety capabilities (underpinned by a depth of rail and road sector experience). Examples cited by stakeholders include ORR’s:

• Rail Safety Directorate playing its part in contributing to Great Britain being consistently amongst the safest railways in Europe

• Roads Team supporting anticipated efficiency savings of £0.5 billion to £1.2 billon in the recent Roads Investment Strategy (RIS3)

• rail economists boosting investor confidence by fostering stable, predictable investment conditions

Stakeholders identified opportunities to build on these strengths through greater strategic awareness, stronger whole-of-system thinking and improved integration of its multidisciplinary expertise. These need investment in capability. Enhancing visibility of the overall operational and economic impacts of its decisions was seen as a key element of rebalancing operational detail and strategic, system level contexts. When applied to safety contexts, stakeholders drew out parallels to a recent review of Nuclear Regulation.

ORR expects to take on a significant new role as the regulator for any future roads project built under a regulated asset base (RAB) financing model, with the first application being the Lower Thames Crossing (LTC). Whilst ORR will be building on existing regulatory experience, new capability and skills will still be needed to support this.

Maintaining effectiveness will require continuing investment in robust frameworks and partnerships that enable ORR to anticipate and adapt to emerging technologies and evolving cyber threats. Future demands may be markedly different from those its current practices were designed to address. This risk could be compounded by the pace and scale of change widening knowledge imbalances between ORR and the industries it regulates.

ORR and rail reform

The key elements of ORR’s future role are understood at headline level. However, the range of stakeholder expectations about the associated scale of change highlight the need for even greater clarity on how the vision translates into practice.

Without practical clarity and alignment on the long term ‘end state’, the full opportunity of rail reform may be missed. An understandable focus by ORR and DfT teams on Day 1 readiness and operational continuity, coupled with deeply embedded analytical methods and approaches, could default to incremental change rather than the fundamentally reformed ways of working and cultural shift that some stakeholders are envisaging. Maintaining a clear link between immediate implementation decisions and longer-term ambition will also be essential to ORR’s organisational redesign, and the skills, capability and culture audit that will underpin that design.

DfT’s proposed policy for GBR licence and accountability frameworks and ORR briefing on its future role, show how the necessary clarity is steadily developing. These reinforce that GBR will take integrated decisions as the single ‘directing mind’ for the railways, with ORR providing independent expert advice and assurance for the SofS. on strategic matters such as GBR performance, funding and overall rail system outcomes. ORR will also enforce the new GBR licence.

The vision for ORR’s reformed role would be strengthened by clear examples of what success will look like in practice, as well as expected new opportunities. Providing a practical sense of the intended end state would help align stakeholder expectations on themes such as the pace of change, future approaches to assurance, and what a ‘whole of-system’ focus means.

Background context

This review forms part of the Department for Business and Trade’s (DBT’s) programme of regulator reviews, designed to assess performance and strategic alignment with government priorities, including economic growth. It examines how ORR is preparing for rail reform while continuing to deliver its established responsibilities across rail safety, non-mainline rail and roads.

The review is grounded in extensive evidence, including more than 80 confidential interviews with stakeholders from across government, industry and transport authorities, supported by analysis from DBT and an independent expert panel. It reflects perspectives from passenger, freight, infrastructure and supply chain organisations across public and private sectors.

The findings provide a snapshot of ORR between December 2025 and June 2026, a period of significant change as the Railways Bill progressed through Parliament and the supporting policy and implementation details continued to be developed.