Trainline plc (LON:TRN)
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Nov 4, 2026, 11:48 AM GMT
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Earnings Call: H1 2027

Nov 4, 2026

Summary

H1 net ticket sales were broadly flat; revenue fell 1%, while adjusted EBITDA rose 7% and adjusted EPS 10%. International Consumer turned profitable, and FY guidance was reiterated amid fare, competition, disruption and CMA uncertainty.

Operator

Hello, everyone, and thank you for joining the Trainline H1 FY 2027 results presentation. My name is Lucy, and I will be coordinating your call today. During the presentation, you can register a question by pressing star followed by one on your telephone keypad.

If you change your mind, please press star followed by two to remove yourself from the question queue. It is now my pleasure to hand over to Ian Brown, CEO, to begin. Please go ahead when you are ready.

Ian Brown
CEO, Trainline

Good morning, everyone, and thank you for joining us this morning for Trainline's H1 FY 2027 results presentation. I am Ian Brown, CEO of Trainline. I am joined today by Pete Wood, our CFO. This is my first set of results since joining Trainline, and I am delighted to be here today. Before we begin, I just want to say how deeply saddened we all are by last week's tragic rail accident near Toledo in Spain.

Our thoughts and prayers are with everyone affected. Now, let me take you through today's agenda. I will start with my early impressions of the business and then provide an update on GBR. Pete will then cover our financial performance and provide a strategic update, including how AI is improving our product and the way we work. Then after the presentation, Pete and I will be happy to take your questions.

For those of you I haven't yet met, by way of background, I spent the CEO part of my career scaling and transforming consumer and technology businesses. Most recently, I was CEO of Flutter U.K. and Ireland, where I led a collection of brands operating in highly regulated markets. Before that, I was CEO of ANS Group. I spent six years at Booking.com, including as CEO of its Trips business unit and as CEO of Rentalcars.com, so I know International Consumer online travel marketplaces very well.

I also created and built out the insurance business at Booking.com. My track record at these businesses has been underpinned by product and commercial innovation. I therefore have a good understanding of what it takes to deliver innovation-led growth at scale, as well as to lead businesses through periods of change. I joined just under two months ago, so it is still early days.

Nonetheless, I have enjoyed spending time with many colleagues across our London, Edinburgh, and Paris offices so far, talking with customers and progressively working my way around our business.

As you might expect, I have also been busy meeting with industry partners and carriers, as well as meeting key stakeholders in government. I look forward to meeting shareholders on our upcoming roadshow, and I plan to engage broadly with our stakeholders in the coming months.

What I have seen so far in my first two months has reconfirmed why I joined Trainline, and I am genuinely excited about what is ahead. First, our fundamentals are strong and genuinely hard to replicate. We have real scale. We are Europe's most downloaded rail app, serving 27 million customers. Our customers' behavior is habitual. Almost 2 million customers use our app every day to plan, book, and manage their rail travel. We have deep loyalty and trust.

Our app is rated 4.9 stars, and we are the most trusted brand in U.K. rail. We are a leading technology platform built on years of deep rail expertise and investment in technology. The Trainline app, or API, connects our customers to hundreds of rail and coach carriers across Europe, many of them operating aging legacy systems. That is hard to build and hard to copy. Our platform sits on an exceptional scale of data assets.

AI is increasingly ingrained in our products and across our business processes, making us smarter and faster in how we deliver for customers and partners. We have an outstanding team. It is innovative and driven, with a strong track record of delivery and execution. The opportunity ahead is very real across the U.K., International Consumer, and our Trainline Solutions business. We are Trainline well-positioned to continue to scale each of them.

Trainline is exactly the kind of business that energizes me. It has some complex challenges to solve in a period of a period of material change for the sector , but many opportunities ahead. The underlying strengths I just mentioned showed in the first half, with the business delivering a robust performance despite multiple headwinds. In the U.K., we improved our proposition and continue to build trust and loyalty.

We now have over 3 million digital railcard holders in our app, up 26% year-on-year. In Europe, in a year without major aggregation moments, we rebalanced growth and profitability. International Consumer is now profitable for the first time.

Our B2B distribution business also continues to scale, led by strong growth from international customers. With broadly flat net ticket sales alongside strong cost management, we delivered 7% growth in adjusted EBITDA and 10% growth in adjusted EPS.

The announcement of a new GBP 100 million buyback in September also reflects both the strength of the underlying cash generation of our business and confidence in our outlook. As you know, on October 9th , the ORR published its draft Retail Code of Practice for consultation. We see it as an important step forward. For the first time, there will be a regulatory framework governing how GBR interacts with all retail market participants.

The overall future rail framework is, of course, wider than just the code. It also includes the GBR business plan, the public service contract, and GBR's own operating license. The draft confirms fair, transparent, and non-discriminatory access to fares, products, systems, and data for third-party retailers in line with the level playing field that the Rail Minister, Lord Hendy, last week committed to.

This reflects our progress to date with government engagement, for example, Delay Repay, where we secured future equivalents earlier this year. The government's fact sheet, published alongside the draft code on October 9th , also says GBR must act in a way that does not exclude competitors, distort the online retail market, or abuse a dominant position. For the first time, an independent regulator, the ORR, will have a statutory responsibility to enforce compliance.

These are all positive steps. However, we believe the framework needs strengthening. In particular, we are seeking stronger mechanisms and oversight to ensure equivalence of treatment with GBR online retail. In other sectors where state-backed entities operate in the market, such as the BBC or BT, there is a clear precedent for strong safeguards on economic equivalence and economic transparency. We are not yet seeing the same here.

The government has, however, been clear on the continuing role independent retailers will play and on the need for safeguards. The government's fact sheet is clear that GBR should compete alongside other retailers in a fair and open online retail market.

Indeed, as Lord Hendy told the Lords on September 8, when asked about the cross-subsidy, he said, and I quote, "GBR will not be overcompensated to deliver retail functions in a way that distorts the market." Unquote.

Our focus is on seeing these very clearly stated principles translate into the strongest possible market framework. We continue to engage actively in the consultation process, and more broadly, we maintain our assertive stance. With that, I'll hand over to Pete for the Q&A at the end of the presentation.

Pete Wood
CFO, Trainline

Thank you, Pete, and good morning, everyone. Before I share the group results, let me start by unpacking the performance of each of our business units, starting first with U.K. Consumer. Net ticket sales were GBP 2.1 billion, up 0.4%. This reflected both strong underlying rail demand as well as fewer refunds as a result of a change to the industry refund policy in April 2026, which narrowed the window in which refunds could be claimed.

As a reminder, there was no contribution to NTS from inflation in the half, given the regulated fare freeze. We continue to face headwinds from train operating companies self-preferencing their own retail channels, as well as the expansion of Project Oval. There were also additional headwinds from the very hot weather in the summer months, alongside other disruptions to the rail network.

Turning next to International, net ticket sales were GBP 579 million, down 4% year-on-year. Performance was affected by a number of external factors, including softer foreign travel, reflecting ongoing geopolitical tensions in the Middle East, weaker consumer sentiment in Spain following the tragic rail accidents earlier this year, and heat and strike-related disruption in the summer, which affected many parts of the European network.

Performance also reflected our more disciplined approach to marketing as we balanced growth and profitability in the half ahead of future aggregation moments. Meanwhile, in Southeast France, net ticket sales grew by double digits, sustaining growth a year on from Trenitalia's expansion into the market.

This demonstrates our position as the aggregator of choice ahead of the next wave of carrier competition across Italy and France. Turning next to Trainline Solutions, our B2B business, net ticket sales grew 3% to GBP 548 million.

Within this, B2B distribution, which helps large travel management companies sell train tickets, led the way up 22%, with international B2B continuing to grow very strongly, up 45%, driven by new client wins across Europe. We are on track for international B2B sales to overtake U.K. sales by the end of the calendar year. As expected, this growth was partially offset by the roll-off of two white label contracts, including ScotRail, which we stopped providing services to in the half, and the drag from CrossCountry,

which ended last November. Bringing this together, group net ticket sales were GBP 3.3 billion, and revenue was GBP 233 million, down 1%. This largely reflected a lower U.K. revenue take rate, which was the result of changes in the industry refund policy. This led to fewer refund transactions and therefore lower refund fee revenue.

Despite lower revenue, gross profit increased 1% to GBP 195 million, driven by an improvement in the settlement rate we pay to payment processors. This was achieved through renegotiated fee rates with our main payment providers. Cost of sales savings also came from lower customer service costs due to WhatsApp and voice AI handling more contacts. Turning to costs, where we delivered strong discipline across the business. Total OpEx and CapEx were down 5% year-on-year.

In addition to lower cost of sales, we drove marketing costs down, reflecting efficiencies in both the U.K. and International, and a more disciplined approach to marketing in International. CapEx was broadly flat, reflecting ongoing investment in our product and tech platforms. We continue to invest in AI and in our products, but we do it in an efficient way. Together, these savings offset an increase in other administrative costs.

That increase was driven by inflation, investment in AI, and ongoing higher legal and public affairs costs. As a result of this cost discipline, and on a slightly lower revenue base, adjusted EBITDA grew 7% to GBP 100 million. This was driven by the improvement in International, which moved from an EBITDA loss of GBP 8 million last year to a profit of GBP 6 million. That is on a post-transaction fee basis, which means covering the cost of the platform serving these transactions.

Furthermore, all of our markets in International were profitable, another milestone for us. Adjusted EPS grew a little faster at 10% to 13.8 pence, supported by continued accretion from our share buyback. Turning to cash, adjusted free cash flow was GBP 45 million, with the year-on-year movement reflecting the timing of working capital as well as tax payments, and leverage at the end of the half was 1.2 x.

Our capital allocation framework remains consistent to invest in the business at appropriate returns, maintain a strong balance sheet, and return surplus cash to shareholders. In September, we announced a new GBP 100 million share repurchase program. Over the last three years, we have returned GBP 356 million to shareholders, the equivalent of 28% of our share capital.

This highlights both the cash-generative nature of our business and the continued confidence in our outlook. Before turning to guidance, an update on the CMA's investigation and our booking fees are presented. We operate across multiple regulatory frameworks, each with its own requirements of how rail fares and fees are presented.

At the same time, rail tickets are complex in themselves, with booking fees varying depending on the choices customers make. We have always engaged actively with the ORR on our fee presentations.

Since the CMA letter in November, and following the announcement of an investigation in August, we have continued to engage proactively with both the CMA and the ORR, and are seeking a swift resolution. To conclude, I am pleased with our financial performance. We delivered what we planned and grew earnings despite multiple headwinds. Looking ahead to the full year, we are reiterating our guidance.

We continue to expect net ticket sales of between GBP 6.2 billion and GBP 6.45 billion, underlying revenue of between GBP 440 million and GBP 455 million, and EBITDA of around 2.9% of net ticket sales, with International Consumer expected to be about break-even for the full year. With that, I will move on to our strategic progress, starting with U.K. Consumer.

Trainline is the U.K.'s number one travel app, and customers rely on it for the best value, the most accurate information, and peace of mind on their rail journey. That position is the result of investing over a number of years to build our technology platform and the best capability in rail. We make U.K. rail simple. Every ticket type, journey combination, and fare is searchable in one place quickly and easily.

We also offer products that help customers save money, including SplitSave, Railcards, and season tickets. In the first half, we invested in our U.K. proposition, and Railcards were a particular highlight.

We have made it even easier for customers to buy or renew a Railcard with relevant prompts, timely reminders, and simpler eligibility checks. We have also grown Railcard adoption through partnerships, including Monzo, which offers a free digital Railcard to its Monzo Perks subscribers.

Railcards give customers real savings, an average saving of GBP 175 per year. The results of these improvements are clear. We now have over 3 million customers with a digital Railcard in our app, up 26% year- over- year. We hold over a third of the Railcard market, and we grew the number of Railcards at over 3x the rate of the rest of the market. We are also growing in key categories.

In 16 to 30 Railcards, shown in light blue in the middle chart, we have 47% of the market. Another example is Network Railcards, shown in dark blue, which offer savings across the Southeast. As we have made it easier to discover, buy, and use Railcards, more people in this part of the network are adopting them and unlocking the benefits. Holding a Railcard also builds loyalty.

Digital Railcard holders transact more than 4x as often as non-holders and spend more than 3x more, a competitive advantage that is hard to replicate. Railcards give customers a reason to join us. Our product gives them a reason to stay. Our travel and disruption features help customers along their journey and are unique to Trainline, powered by our data and our technology.

On the left, the live tracker. Maps are now available to all users, so you can see your position, your stop, and any disruption on your route. In the middle, travel forecast. We predict your arrival time using our own journey data, providing us with a more accurate forecast than the one you would see at the station or in the train. On the right, when a delay happens, the app knows.

Eligible customers are redirected to claim Delay Repay from the app, and more than half now do, nearly double since January. These features build habit. Today, 91% of eligible travelers see our disruption features, double the level since the start of the half, and customers come back month after month.

We will continue to iterate and improve this feature set to give customers even more reasons to stay. In the half, we also added products that give customers more value, flexibility, and convenience.

Trainline Flex is a new ticket type that combines an Advance ticket with insurance, so customers can cancel for any reason. We are also using our scale to build advertising and partnership revenue, with relevant discounts and promotions, such as through PayPal, available to customers in the app. Together, insurance and advertising helped grow U.K. ancillary revenue by 22%.

That diversifies our revenue and gives us new ways to earn more from our large customer base. Trainline remains the most trusted brand in U.K. rail. In a recent survey, 51% of U.K. respondents said that we were the brand they would most likely consider for a ticket, well ahead of the competition. Our campaigns in the half widened our reach, particularly among families and new audiences.

We launched a podcast series for families traveling with young children on trains, alongside a number of social media campaigns and a sponsorship opportunity of Arthur Fery's team at Wimbledon. Moving on to International. While there are no major aggregation moments this year, International remains an aggregation story, and Trainline is ready for when each market further opens. Our business has three parts, each at a different stage of aggregation maturity.

First, Spain and Southeast France, which are 21% of International net ticket sales. Here, the aggregation story is proven. Southeast France continues to grow at double digits, and Spain shows how we can invest to scale a market and then turn it profitable.

Second, the rest of France and Italy, around two-thirds of International net ticket sales. With no near-term competition, we are balancing spend carefully here while being ready to invest more ahead of aggregation moments. Third, Germany and the rest of Europe, the remaining 15%.

These are longer-term growth opportunities. For now, most of our customers there are traveling cross-border or away from home. We are building more profitable base in Europe by applying the U.K. playbook. French Railcards are growing strongly through upsell and prompts.

Railcard sales rose over 70% year- on- year in the half, and that is building a base of loyal French customers who are more likely to travel with Trainline. Ancillary revenue also grew strongly, led by insurance and hotels. It contributed to a more than 30 basis points increase in the International take rate and makes our revenue in the region more diversified. Carrier competition remains the catalyst for the next phase of growth in Europe.

In Spain, the market has gone from one high-speed carrier brand to four competing across the five largest routes. In Italy, Trenitalia and Italo already compete on the high-speed network. SNCF is now expected to launch from mid-2028, a year later than we had originally anticipated. In France, Velvet is on track for a summer 2028 launch, having obtained its railway operating license in September.

Alongside other entrants, we expect four competing carrier brands from mid-2028. On the Channel Tunnel, there has been recent progress, with Trenitalia ordering trains and Virgin Trains recently receiving its license to operate. Together, these markets represent GBP 12 billion TAM by 2030, providing us with significant headroom for growth. Foreign travel is a further overlapping opportunity. We estimate the inbound market from the E.U. and the rest of world at around GBP 5 billion.

It is a high margin, and our proposition is built for this customer. So International is a large market with clear catalysts. Until further aggregation moments arrive, we will keep deepening customer loyalty, driving engagement, and managing profitability. Now to Trainline Solutions, a business with over GBP 1 billion annualized net ticket sales. Our focus is growing business travel through B2B Distribution and branded B2B.

European rail is fragmented, leaving travel management companies with a challenge of connecting to more APIs, including aging legacy systems. Our global API aggregates this supply into a single connection. Demand is building on both sides. Corporates want more rail, and carriers want more B2B because business customers spend more per transaction and drive more first-class demand, which helps carriers manage yield.

Sustainability targets, more capacity, and more competition are also making rail a genuine alternative to air, both cross-border and domestic. B2B distribution is a large and sticky segment. Our average customer has been with us for seven years, and switching costs are high, which gives us recurring revenue. It remains a success story for Trainline. In H1, we won 18 new customers, four of them large travel management companies.

Finally, turning to AI, an area that remains a big opportunity for Trainline and where we continue to make good progress against our three pillars. First, AI-powered products, solutions tailored to each customer need. Over 1 million customers used Travel Assistant and voice AI in the H1 , up 20%. They are ROI positive per conversation. We build efficiently, keep the cost to serve low, and customers resolve simple issues like refunds themselves.

Second, new AI distribution channels. We are working alongside leading AI companies so customers can reach us wherever they start. We lead in Google AI rail citations in every market except France, and we are live in the ChatGPT app. While AI referrals remain under 1% of sales today, we are building now and are ready if and as that grows. Third, using AI to move faster.

Lead and cycle times are down 10%, and defects are down 18% across the tech team. Where we use AI more heavily, the gains are much bigger, and we expect more to come. Our agent platform is live in our data business, completing workflows, and we are rolling it out across the organization. Taking a closer look next at the impact of AI in distribution.

Today, over 90% of customers come direct to our app, mostly for everyday repeat purchases where speed matters. However, customers have more options on how to plan their journeys than ever before. They might start in Google, ask ChatGPT or Claude, or use an agent such as Meta Muse. We have strong SEO and are well-connected into these tools through our ChatGPT app and our MCP infrastructure.

Whether the buyer is a person or an agent, we can surface the journey options and complete the purchase. A journey doesn't end when the ticket is sold. 60% of customers fear travel disruption, so after purchase, they need live updates and help when things go wrong. They may need to change a ticket, get a refund, or claim Delay Repay. That is where our proprietary data and tools sit, and it is data we own.

Rail is different from most things people plan with AI. It is live, the stakes are high when things go wrong, and customers need to trust what they are told. Our app is built for rail and nothing else. We make it visual. You check the map, you check the platform, and act on it all in one place and fast. These are the features that bring customers back.

As we face an ever-changing market, whether it is through AI or GBR, our structural advantages matter more. There are four, and they reinforce each other. It starts with the foundation. We hold a retail license and direct integrations with every carrier, plus the contracts, accreditations, and bonding facilities. That position gives us data. Every search, booking, journey, and after-sales interaction sits in one place on a leading technology platform built over many years, with AI increasingly integrated.

Better data builds better, more innovative products, because we can see what travelers actually need and build for it. Better product builds habits and loyalty, so customers will choose us. We are the number one travel app in the U.K. and the number one rail aggregator in Europe. Active customers in the U.K. transact frequently with us, and it takes just 23 seconds for search to purchase for familiar routes.

That, in turn, gives us trust and scale. AI strengthens each of these advantages, so the position grows with every journey. In summary, this was a resilient first half. Net ticket sales were robust, margins improved, and we have continued to return cash to shareholders. In the U.K., we have a stronger proposition with a better travel experience, clearer value for money, and more flexibility for customers.

In Europe, in a year without major aggregation moments, we rebalanced growth and profitability, with International Consumer now profitable, and we are building strong foundations for growth.

In AI, we are executing faster and building a deeper competitive moat. Our balance sheet is strong, so we can keep returning cash while we navigate change and shifting markets, and we are confident in the outlook. Ian and I are now happy to take your questions, so I will hand back to the operator.

Operator

Thank you. If you would like to ask a question, you may do so by pressing star followed by one on your telephone keypad now. If you change your mind, please press star followed by two to remove yourself from the question queue. When preparing to ask your question, please ensure your device is unmuted locally. The first question today coming from Alastair Reid of Investec. Your line is now open. Please go ahead.

Alastair Reid
Analyst, Investec

Yeah, morning. Thanks very much. A couple from me. Firstly, could you expand more on the opportunity you formed the tender to build the GBR app? Is there any scope for the commercial terms of that to impact the government's decisions around the funding mechanisms for GBR, for example?

Secondly, on the topic of pricing more broadly, could you perhaps expand a little on the strategy for Trainline Flex, whether you are looking to differentiate pricing more versus train operators, and could you have booking fees more explicitly linked to whether you have a SplitSave ticket? I guess the last thing linked to that, do you think the GBR ticketing operations would have the incentive to do SplitSave as well, given the lower revenues it would generate for its parent? Thanks very much.

Pete Wood
CFO, Trainline

Thanks, Alastair. Let me work through those. First, you asked about the tender opportunity. This we expected earlier in this year. I think it is a complex set of attributes that the government is trying to pull together here, and that is why there has been some delay. There is a chance this will emerge pre-Christmas, although it may also appear early in the new year as well.

In terms of whether the options that Trainline could offer something and how that might fit into the funding, no, I do not really see that as an opportunity here. I think the government has got an idea about what it is seeking to acquire. It is refining those proposals at the moment, we understand, and as I say, we are expecting that to appear imminently. The mechanism for funding GBR more generally is somewhat separate to that.

Of course, there is some look across, and they need to ensure that it fits the right envelope. But I do not think there is a role for Trainline to play here. There is quite a clear set of rules around procurements, and I am not sure that there is any option that you are pointing to here. Next you asked about the Trainline Flex and pricing more broadly. I think we have made really good progress with ancillary products.

To start with, it was a question of layering in insurance and hotels, often post-sales, if you like, as options for the customers to buy. Over time, we have found better ways to surface this, targeting the right customer at the right time, and have managed to scale this. Now we are into the second era, which I think is really interesting.

Obviously, if you blend these products together, you can create unique inventory, tickets with different terms and conditions, or a package for rail and hotels are things that we are now exploring. As ever, and as we have always done, we will test and learn our way into this and see where there is opportunity and where we can exploit things that work for customers.

That is really what we will figure out as we work through that. But we are pleased with the progress we have made so far on that. You asked about SplitSave as well. I do not think that there is a chance that GBR. Well, there is a chance that they will offer SplitSave. I am not sure that is really the approach they want to take.

I think really this is one of those things that exists because there is yield management in the platform, and they are trying to make sure that they get the loading on trains, the popular ones that are perhaps early in the morning versus the ones later in the day.

That is really what creates this whole system. Yeah, our working assumption is that they won't offer SplitSave. They may find ways to remove certain splits, but I think overall, with yield management still a requirement in the system, I do not think there will be major changes here.

Essentially, what they are doing here is keeping the subsidy under control by charging people who are traveling first thing on a Monday morning between Manchester and London who are able and willing to pay more, and that is able then to subsidize tickets on empty trains or for families traveling at the weekend or such. I think there is not really the appetite to increase that subsidy.

In fact, the government has stated that they want to reduce the subsidy over time. I do not think you end up removing some of these things by normalizing prices up either. That certainly counts as the direction of the travel for the government, who really sees train tickets as already quite expensive, and it would not be a popular decision either. Yeah, I do not think they will offer it.

I am sure they will continue to innovate and reform fares, but I think it will be there for Trainline and others to use in the longer run.

Alastair Reid
Analyst, Investec

Thanks so much.

Pete Wood
CFO, Trainline

Thanks.

Operator

Thank you. The next question comes from Gareth Davies of Deutsche Numis. Your line is now open. Please go ahead.

Gareth Davies
Analyst, Deutsche Numis

Yeah, morning both. Just a couple from me. Firstly, very useful update on the French liberalization. When Velvet enters and the other players come in calendar year 2028, do we have any feel yet for kind of regional targets or kind of how extensive their ambitions are in that early phase? Or should we really think of this as a Trainline opportunity in 2029, 2030? The second one was really following up just quickly on the SplitSave question.

You have been trialing SplitSave fees on the app. Just wondered if there is any sort of feedback in terms of are you seeing that impacting customer purchasing, or what are the learnings from putting that SplitSave fee in rather than charging a booking fee? Then finally, just on the travel management business, clearly four large international wins is great in the H1 , 18 new customers.

Are you kind of there in terms of the opportunity for the big international customers, or can you see further opportunity looking forward? What is the scale of opportunity across that international Trainline Solutions business? Are there white label opportunities starting to emerge as well? Thank you.

Pete Wood
CFO, Trainline

Great. Thanks, Gareth. Yeah, let us go first to the liberalization. Yes, I think 2028 looks like it could be an exciting year and kind of a restart, both initially with SNCF and then Velvet in France. The routes, I think there are five key routes that SNCF is looking to run.

It is relatively extensive, and I think the important and exciting thing for us is that the rail-traveling public who have got used to some degree of juggling two apps will have a third to deal with as well on some of these routes.

That does represent an interesting opportunity for us. I think that, again, Velvet is launching in a part of France out to the west of Paris, which is not served by any other carriers at the moment. Obviously, down to Lyon and down to Marseille, you have already got some aggregation.

This is going to be the first time that those customers traveling out that way are faced with more than just the incumbent carrier. Both of these offer similar but slightly different options for us. As we get clearer on the launch plans, we will begin to refine our planning. But typically what we do, the tickets go on sale ahead of the launch of the services, and there is a moment at that point for us to invest in brand and to capture early sales.

Then really, you get more momentum as the service launches and as it starts gaining. When people start seeing a different branded train at the station, then part of the marketing, if you like, or even awareness of the fact there is a new service, is somewhat visual, if you like. That is where we will further lean in and seek opportunity to build.

I think what we have seen in Southeast France with Marseille is, obviously there is a good first year for us to get after in acquiring new customers and building sales. But actually, it persists over time and builds momentum. To your point around 2029 and 2030, yes, I think we expect that to kind of continue into those years from a good start.

We really want to build momentum over time, if you like. You asked about SplitSave fees. Yeah, I think we are very mindful of how the world is evolving, and ahead of GBR being stood up, we have still got a window to explore. I think we have got a long history of offering a differentiated service and features that customers love.

If you went back, I do not know, what, five years or so, you had live train and platform information in the app, and of course, you got the saving by booking in advance. People were willing to pay a fee for that. We are now layering in quite a lot of new features with travel disruption and Delay Repay notifications and things like this. I think those features are things that customers are going to continue to love based on the feedback we see now.

We may evolve the fee mechanism over time with that. The SplitSave test is one of those, and there could be other things over time as we look to evolve that model more broadly. But the learnings are good. I think customers understand the proposition. They understand why the value being tied close in really makes sense.

Positive signals from that, and yeah, we will continue to iterate overall. Then finally, yes, it is really great to see momentum, particularly into Europe with the travel management companies.

We are talking to customers who perhaps a few years ago felt that they did not need Trainline, but eventually came back round because the work and the effort going to actually integrating these things directly on what are often legacy systems and require nurturing and maintenance.

They are not kind of, "Hey, we connect once and that is done for five years." These things are evolving organisms, if you like. So yeah, great to get momentum there. I think you then talked about white label and whether there was more opportunity. I think it is in the back of our minds, but it is not something that is kind of most obvious and we are actively pursuing right now.

It is more that B2B cohort rather than trying to serve new operators with white label businesses. But look, the world is continuing to change. I think as AI washes through and as we embrace that might mean that it is a more attractive proposition in years to come. I am not shutting it down, just giving some kind of realism in the near term.

Gareth Davies
Analyst, Deutsche Numis

Thank you very much.

Operator

Thank you. The next question is from Andrew Ross of Barclays. Your line is now open. Please go ahead.

Andrew Ross
Analyst, Barclays

Great morning, all. Thanks for taking my questions. I have three, if that is okay. First one is for you, Ian. Welcome, and thanks for the opening remarks as to what attracted you to Trainline. Appreciating that you have only been in the business for a relatively short period of time, but wondering if I could ask if you have any early thoughts on if anything needs to change from a strategic perspective, e.g., levels of investment,

The product, the geographic exposure, et cetera. Any additional comments would be very helpful. That is the first one. The second one is to ask about the U.K. ticket price into next year. Obviously, there was not a regulated increase this year. How are you guys thinking about the likelihood of there being one next year, or indeed any other year in this Labour government?

The third question is for you, Pete, on the accounting of the CMA study. There is a small exceptional that you have booked. If you could explain what that is. You are still referring to underlying revenue, so I guess there is still some uncertainty as to how that may or may not change. It would be helpful just to get all the context as to how you are thinking of accounting for the potential risks about the study over time. Thanks.

Ian Brown
CEO, Trainline

First one, Pete. Good morning, Andrew. Thanks for the questions. I mean, look, as you said, it's early days. Not that I'm striking them off on the wall or anything, but I think this is day three and week six in the CEO seat. As you'd expect, I'm working my way around the business, a broad set of stakeholders, listening to customers, and absorbing a lot of stuff and asking a lot of questions. It's too early, honestly, to say what we'll be having changed in strategy.

What I will say is, I've been struck by how strong the foundations of the business are. I touched on them earlier, fantastic product, great brand. The other thing I'd call out is just the strength of the team and the culture here, which I've been very impressed by and I'm proud to be part of.

Look, my focus right now is really three areas. One is external engagement, as you'd expect, particularly with the government around GBR. The second is ensuring we continue to execute on the plan well across U.K., International Consumer, B2B, and of course technology.

The third is, as you'd expect, as I'm working my way around the business and our stakeholders and listening to a lot of people, it's early stages, but starting to think with, in senior team and the board, what is that next growth arc for the business, which will answer your question. So forgive me, I can't give you a direct answer today, but as that takes shape, we'll update you in due course.

Pete Wood
CFO, Trainline

Thanks, Ian. Let me take the second question around ticket prices in the U.K. Look, I think the budget didn't provide any clarity, if you like, or didn't announce that there would be a fare freeze or not. I still think that it's a possibility. The last time it was announced, till further towards Christmas. But if you take a step back and look at the mood music more broadly,

I think the government under Burnham are seeking in many ways to try to relieve pressure from the public and their finances in many ways. We know that Burnham is close to transport. He's shared a few hypotheses and thoughts around, is there a Railcard that could fit between the young persons and the senior?

I think generally this idea that rail is expensive and they want to make it more affordable, against the backdrop of a challenge in the treasury, is one that they continue to explore. I think net, that there will be pressure on fares into next year. That's kind of our planning assumption, if you like. Whether that's through a headline fare freeze or whether that is through other reforms or mechanisms, I think that that's most likely to persist for the next year.

Then you asked about the CMA accounting and the exceptional charge that we pushed through. So yeah, probably worth just clarifying. Obviously, this is an ongoing investigation, and it's about how we present fees, not whether we can charge them or not, just to be very clear. This charge is really a kind of accounting interpretation.

The application of those standards to the situation we are in required us to make some judgments, and this was ultimately what the accounting standards led us to, if you like. It covers the total cost, if you like, the legal aspects, potential fines, and things like that. If you then go deeper into reading through note 10, there are still a wide range of outcomes.

Please, I don't want you to think that this is the answer or where the number will land. It could be zero, it could be a different number, and we will have to find out in due course exactly how that plays out. Likewise, to your point around underlying revenue, again, this is really to point at, based on how the business is performing today, we have reconfirmed guidance.

If there are some implications from the CMA that impact revenue, then those will come on top, but I wanted to provide some visibility about how the underlying business is performing in the meantime.

Andrew Ross
Analyst, Barclays

Thank you.

Operator

Thank you. The next question is from Ed Young of Morgan Stanley. Your line is now open. Please go ahead.

Ed Young
Analyst, Morgan Stanley

Good morning. Two for me, please. First of all, there has been quite a few mentions during the presentation around balancing investment and efficiency, and I know you did not want to get drawn on the strategy writ large, but I do wonder if you could, between you, maybe provide some color on how you address that challenge.

You have obviously managed to drive EBITDA growth despite flattish top line, so it is clearly something you have done this year. Are there more levers to pull next year, and how do you sort of look at that when you have got the prospect of some more opportunities in the business over the next couple of years? Second of all, on the CMA, you have said the next update you expect is January. You have said you want to resolve this as quick as possible.

Is it possible that is the answer, or is that just an initial update and we should be expecting a much longer process to get some certainty on the CMA? Thank you.

Pete Wood
CFO, Trainline

Yeah. Thanks, Ed. Good question. Just on the first one, I think as we look into next year, and obviously it is very early days for Ian, who is learning the business very fast, but we have got a process ongoing internally, both on bringing Ian up to speed and in the loop, and also to define what next year and beyond looks like. I think about it in two halves, if you like.

There are some pressures that we have in the business from rail-specific pressures, if you like, that I think will persist. We just spoke about the fares in the U.K., and the pressure I think will persist into next year there. Of course, we have the tragic accident in Spain, which will undoubtedly result in some longer-term headwinds there.

We have got a delay in Italy with SNCF launching now in 2028 rather than 2027, which we had expected. More broadly with geopolitics and fuel prices, I am not sure that inbound is set to recover either. So, if I look over the next 12 or so months, I think there is a bit of pressure at the top overall. On the other hand, we look further out, and there is really interesting opportunities for us to chase after.

AI, we are already finding unlocks some real potential, particularly in travel experience at the moment, and that is, I think, an exciting area for us to differentiate. We are obviously starting in the U.K., but over time, that would be something that could be interesting in Europe as well. Obviously, there is more liberalization on the horizon, and high-speed rail tailwinds continue to persist.

We just spoke about Trainline Solutions and the great momentum we have got there, and look, that is before we even get beyond Europe, if we really want to keep dreaming, if you like. Then finally, ancillary revenues. Again, we have spoken about this, and I think there is opportunity there as well.

Then it comes to, well, how do you balance and judge the near-term factors that we need to consider with the longer-term opportunity? In essence, that is exactly what we are doing alongside Ian. I do not know, Ian, if you have a few things you want to add to that thinking.

Ian Brown
CEO, Trainline

Yeah. Well, yeah, just very briefly. I mean, firstly, I echo everything Pete has just said, but maybe from my perspective as I look at the business, and you would expect there would be quite a bit of homework on the business as I went through the process and before saying yes. I would just say this. So, we have got a bunch of things to navigate in terms of uncertainty and external factors, and Pete has narrated that really well.

Just from my perspective, as I sit here, I will say one thing, which is, I am even more excited about the business today than I was on day one. I would say the medium-term opportunities for the business are much greater than I anticipated as I did my homework from the outside.

I think we both sit here genuinely bullish about the medium to long term, but recognizing we have got quite a few things we need to navigate in the short term.

Pete Wood
CFO, Trainline

Thanks, Ian. Then to address your question on the CMA, when the announcement of the investigation started, the timeline was that by January, this investigation would be concluded, and that is really what underpinned this timeline. I think as we have got into this, we have recognized that there is a certain rhythm to how these investigations unfold.

We are working hard and fast to hit the deadlines and make sure that we do everything our side. There is a certain rhythm, and as far as I am concerned, the CMA will still hit the January deadline. Maybe we will hit before, but as I say, it is a live situation, and we will have to see how it unfolds.

Ed Young
Analyst, Morgan Stanley

Thank you.

Pete Wood
CFO, Trainline

Thank you.

Operator

The next question comes from Peter McNally of Stifel. Your line is now open. Please go ahead.

Peter McNally
Analyst, Stifel

Good morning. Thanks for taking the questions. You mentioned just moments ago that any CMA ruling would come on top of any current guidance. But I guess my question is, when you actually start displaying the booking fee, do you have any expectation on how that might impact bookings? Does your reconfirmed guidance reflect any sort of changes to the presentation of the booking fee, given that it's supposed to be coming imminently?

Then second question is, you mentioned the phased rollout of single-leg pricing in the statement with an impact on lower average transaction value. Just wondering how big of an impact that is. Just a quick third one. Spain and France are 21% of International Consumer. Can we carve out Spain specifically of that, please?

Pete Wood
CFO, Trainline

Thanks, Peter. Starting with the CMA and the display of fees, I would say that the funnel that people go through to purchase is clearly, it is a critical part of our real estate, and we have spent years refining and optimizing that. Changes to that can have some impact, but we have a skilled team that kind of work through those changes and maximize the conversion rate, if you like, over time.

That all said, people do know that Trainline has a booking fee. We have a very high repeat rate. A lot of people are returning customers who love the service we provide. To some extent, changing the visibility or the presentation in some way, I am not expecting to have particularly big effects.

We will need to work through any changes that we do make, and there will be probably opportunities to refine it over time, because with all these things, you never get them perfect the first time out, and we are always running A/B tests on our experience. I am not expecting a significant impact, but there might be something, and we will have to work through it. Then you asked around single-leg pricing.

I think the government has explored various different things, and they have slightly different dynamics. On the East Coast Main Line, they explored this idea of there being a sort of semi-flex ticket that could move. You could catch the train before or after, or at least there was a window, and that kind of created different complexities in a way.

Sometimes, in seeking simplification, they actually introduce more complexity, and that is, I think, one challenge that they face in trying to not create too many losers with the changes they make. Governments typically do not like the kind of winner-loser trade-off. They like just creating winners overall. The single-leg pricing is another interesting one.

What we have really seen here is that transaction counts have gone up a bit, and average transaction value has gone down a bit, and overall, it kind of washes out. It is relatively neutrally for us. People are, as ever, very efficient in trying to find the best form of ticket that is available to them, and net-net, it is kind of priced in a relatively similar way overall, even if the presentation is a bit clearer and ostensibly a bit fairer, if you like.

That sometimes drives certain other mechanisms, like the transaction fee that we have in our accounting. Actually, you are seeing more revenue apportioned out to Trainline Solutions than before because we have got a higher transaction count. So, there are sort of second-order effects that we need to keep an eye on, but overall, for customers, it is, I do not think, a material shift, and it is not driving much change at the NTS level for us.

Then finally, you asked about Spain and Southeast France. Yes, 21% for those two combined. We do not split Spain out overall, and we are not about to do that now. I think that it is the smallest of the three markets, and of course, we hope to create a path of profitability growth in this market over time. We are really going to have to see what unfolds in the coming weeks and months.

Obviously, we have only got a few days of data at the moment on the impact here. We will share more once we have a better understanding. I think if you make assumptions around some reasonable proportion of that being Spain, you will not be too far off. But it is not the majority nor the minority in a sort of 80/20 way. It is probably more balanced than that, I would say, if you want to do some calculations.

Peter McNally
Analyst, Stifel

Okay, thank you.

Operator

Thank you. The next question comes from Sean Kealy of Panmure Liberum. Your line is now open. Please go ahead.

Sean Kealy
Analyst, Panmure Liberum

Good morning, Ian. Morning, Pete. Two from me if I can. First of all, you have taken quite a lot of spend out of marketing in International Consumer, which makes sense in the context of delays to carrier competition in Europe. When do you think you are going to get to sort of the minimum level of marketing that you are willing to put in without potentially compromising the brand in markets and then having to spend a bit more later on?

Do you think that sort of where we are now is you would not want to go below that, or do you think there could be some more you could take out for next year, given further delays? I am just interested on the trade-off on that point.

Second of all, on inbound foreign travel, I think it is fair to expect that it has been pretty weak or slightly weaker at least, given hot summer, civil unrest in France, and so on. What are you seeing at the moment, and could there be some upside to International Consumer numbers next year if the Iran war ends and so on, and various other bits wash out? Thank you.

Pete Wood
CFO, Trainline

Thanks, Sean. I think the marketing, the shift we have taken is definitely the bigger of the moves that we might make. At this point, we are now into more marginal trimming, which could be up or down as we look ahead. Really, there might be ways to seek further efficiencies on the one hand. On the other, the backdrop continues to evolve. You have Google and the search results page continues to change.

You have more people spending a bit more time with other tools such as ChatGPT and a bit of fragmentation in that space. I think we are solving against an evolving backdrop, and we will have to continue to test and learn, which frankly is how we have always operated. You are kind of putting campaigns live in areas that are new. You are trying to hone them, and you are trying to balance the overall equation.

You have kind of got this seed capital to test and learn, and then you put the bulk wherever you are getting the best return overall. Yeah, I think we are more or less at the right level. It could go up or down a little bit at this point, but I am not expecting a more significant shift like the one we have taken so far to unfold. Yes, thank you for your question on inbound.

I am in two minds on this one. I think that, yes, if there is a swift resolution to things in the Middle East, then that is undoubtedly going to be supportive next year in terms of travelers. That said, I think there is quite a lot of stress already in the system with regards to fuel prices and futures and things like that. So, I do not think this suddenly unwinds.

It is very difficult to read the kind of broader civil unrest backdrop. I think particularly Americans do not like the idea of there being unrest in Europe, and that can put them off planning their travel.

We saw that previously when France had some heat in it, and that may also spill into that planning horizon over Christmas, New Year, that that may also impact some of the travel plans that they are making as well. So yeah, it is a mixed bag, I would say, but at the moment, I am probably a bit more cautious looking into next year based on my read of where we are.

Sean Kealy
Analyst, Panmure Liberum

Brilliant. Thank you.

Operator

Thank you. The next question comes from Chris Lux of Bank of America. Your line is now open. Please go ahead.

Chris Lux
Analyst, Bank of America

Good morning. Just two from me if I can. You just mentioned the balance sheet is strong enough to keep a little bit in cash while you navigate the change. Could you maybe talk us through how you are thinking about the pace of the new GBP 100 million buyback program? Execution so far seems fairly measured, with the CMA expected to conclude by January.

Should we expect the pace to pick up if there is more clarity? Then just a second one that was helpful on the CMA timetable. Maybe, Ian, just turning to the GBR, you mentioned BBC and BT as examples of strong safeguards. Which mechanisms would matter most to you in the final Retail Code of Practice?

For example, separate accounts for GBR's retail arm or maybe protected access to the full retail, full range of fares, including splits, and when do you kind of expect the code to be finalized?

Pete Wood
CFO, Trainline

The line was really bad for us. I do not know if others on the call heard it. I think I got the first question, which I can answer. I am not sure I got the second one, but let me start with the first, and we will go back around. I think the question was around the pace and the execution of the GBP 100 million buyback that we have put out.

Look, I think there are a couple of factors that determine pace. Obviously, the availability of cash is one, and there is no issue on that over the last few months. One other is when we go into closed periods, we take a more prudent stance. So, if you look back over the last month, we have had a slower rate running here, and that is because we cannot touch the order once we have submitted it through a closed period.

You should expect that to be readjusted, I guess, in the coming days or so. Working capital fluctuations is another factor in all of this. We announced it back in September. Nothing has materially changed, and I am expecting to complete this program over the course of the months through to next September. Did anyone in the room catch,

Ian Brown
CEO, Trainline

Shall I take the GBR one? I think it was around access, or the bits I heard, access to full range of fares, and where in particular we needed, or what we are calling for the framework to be strengthened. If that is right, Chris, I will quick crack at that.

Chris Lux
Analyst, Bank of America

Yeah, that is correct.

Ian Brown
CEO, Trainline

Okay. Well, you think you're loud and clear now. Did we get anything else on that, Chris, or are we going that way?

Chris Lux
Analyst, Bank of America

No, that's great. That's perfect.

Ian Brown
CEO, Trainline

Okay, perfect. Look, on access to products and fares, the Minister, Lord Hendy, has been very clear in his words on this one. "The draft code requires GBR to ensure access to products providing services and data on fair, transparent, and non-discriminatory terms," quote. This is an area we see most of the government's words and commitments and assurances reflected in the draft code, albeit there's,

We might have a few nitpicks around the odd word, like products that form a core part of the online customer offer. That's an example of where we'll be engaging constructively through the consultation process that runs to December 11th. Your second question, where we're calling for it to be strengthened. I'm going to go back and make two points first.

The first is, GBR formation is an enormously complex thing that it's going to take the government time to get right. It's really important for all of us as citizens and taxpayers and passengers that the government do get this right, and we're playing an active and constructive part in that.

The code's the first part, the draft code. We're going to see the passenger service contract, GBR's own business plan, GBR's own license, all come into view over the coming months. It's only when we see all of that together that GBR is fully formed. But nonetheless, the code is an important part of it. Where are we calling for strengthening? There are two very specific areas. One is around economics and transparency, right?

I go back to the government's stated intent and what Lord Hendy said. He said specifically, quote, "GBR will not be overcompensated to deliver retail functions in a way that distorts the market," unquote. The government's own fact sheets refer to the GB Rail Retail Market as among the most competitive in Europe. They are very clear on that. Basically, we see a meaningful gap between the government's words and what is currently in the draft code.

What we specifically want to see here are the mechanisms that ensure equivalence of treatment between GBR online retail and independent online retail. I am going to reference the BBC and BT as other examples where you have large state-backed entities that participate in well-functioning, competitive, contested markets.

They have very clear precedents established over many years for transparency and safeguards for the parts of those entities that compete in contested markets. We very much want to see the gap close between the government's repeated and ongoing assurances on the record here versus what we currently see given effect to in the draft code. The second piece, very briefly, is around oversight and the powers of the regulator, the ORR.

We want the ORR to have clear upfront visibility of how GBR's online retail activity is funded, and we want the regulator to be able to hear ex ante, so a merits-based appeal. In other words, before a harm occurs, we want the regulator to have the powers to hear those appeals and to be able to bind GBR to outcomes.

In other words, regulators to be able to act swiftly and with confidence where there is an imminent possibility of something that, again, goes against the minister's words and risks distorting the market. I will just close by saying, look, it is a big, complex thing in multiple parts. We have seen really positive steps forwards with the publication of the draft code.

We are engaging constructively, proactively. We maintain our assertive stance. Maybe the final point I would just observe is, the government makes clear throughout, and it is made clear in the code, that competition law continues to apply, and that is a backstop here.

Chris Lux
Analyst, Bank of America

Great. Thank you very much.

Operator

Thank you. The next question comes from Giles Thorne of Jefferies. Your line is now open. Please go ahead.

Giles Thorne
Analyst, Jefferies

Thank you. First question was on competition in Europe and how you see competitive dynamics changing, or not at all, as a result of the merger of Omio and Rail Europe. The second question is a bit more philosophical, but I wanted to test or hear how fragile you think the medium and longer-term outlook is in Spain.

We have obviously had the events of the crash, but even prior to that, the travel times between Madrid and Barcelona have been extended. ADIF, or A.D.I.F., however you call it, had been reluctant to give any price cuts to reflect those longer train times. We have seen the low-cost carrier, OUIGO, relaunch service between the two cities. The most recent data points are a fairly negative direction of travel for passenger rail services in Spain. Your thoughts there would be useful, thanks, Martin.

Pete Wood
CFO, Trainline

Thank you. First of all, the merger or the acquisition of Rail Europe by Omio. Look, I think Omio is an entity, they go beyond rail, and so we are somewhat different to them. They offer flights as well, for example. Their focus really is on the foreign inbound market. It is an attractive market in so much that the margins are higher. It is also not nearly as big. Majority of rail journeys are taken by people domestically in their home market. I think that it is a natural fit.

I am sure there is a lot of work to be done integrating the two together. But I think we also have a strong proposition in this space. We will continue to compete well here as well. I do not think it materially changes the backdrop from our perspective. Then, yeah, your question on Spain.

I think the government, over the last couple of decades, have put a huge amount of investment into the high-speed network. I think it is fairly clear that there are some questions that need asking, and certain aspects of that network need to be reconsidered and perhaps adjusted and changed. There needs to be the work done to restore consumer confidence, and this will take some time, of course.

We have not had any indication that there is an issue from the fact that it is a private operator that has been involved in this. I think the way the network is run, the same safety standards, the same protocols are applied to all who are operating on the network. So, it is an issue whoever's train is running on it overall. So yeah, I do not think there is a huge amount more to say at this point.

It is obviously very early days from this most recent incident. We will have to see what unfolds. I still see a future for rail and the high-speed network in Spain, given the backdrop, notwithstanding some changes that might need to be made.

Giles Thorne
Analyst, Jefferies

Is it realistic to think that there could be negative NTS growth in Spain over the next three to five years?

Pete Wood
CFO, Trainline

Well, we are in significant negative growth right now on the back of the incidents, and actually through the year, we have been negative on the back of the accidents further earlier in the year. I think, yeah, it will remain to be seen how that kind of laps through, and then once you have got a year out from the most recent incident, what kind of confidence there is and how that builds thereafter. Yes, I think for the near term, some negative growth, but in the longer run, I do not think that it is negative forever.

Giles Thorne
Analyst, Jefferies

Thank you very much.

Operator

Thank you. The next question is from Lara Simpson of JP Morgan. Your line is now open. Please go ahead.

Lara Simpson
Analyst, JPMorgan

Thank you. Morning, all. I think most of my questions have actually been covered. Maybe just coming back to U.K. Consumer and the outlook there. Can you remind us where we are on Project Oval? I know we've spoken in the past around GBP 150 million net ticket sales at risk. It feels like that phasing has probably taken a little bit longer, but how much of that have we now cycled, and what should be incremental over the next two years?

I guess with U.K. Consumer, it sounds like we're a bit more downbeat on pricing, still risk around Project Oval. Do you think we can return to a period of growth in FY 2028, or could there be some downside risk to expectations there on the U.K. Consumer top line? Just on International, it feels like you're quite comfortable with the level of marketing there.

You've obviously swung to profitability in the first half, and our guidance is profitable in H2. Do you think you can hold profitability now on a midterm view, even if we look to 2029, 2030, where carrier competition is expected to intensify and build with profit now? Is there a risk that you could go back to negative territory as you go after that long-term growth opportunity? Sorry, just a last question from me on CMA.

It feels like that GBP 3.7 million provision looks quite low relative to the scale of your booking fee revenue potentially at stake. I just wanted to check that assumption does factor in, I suppose, a probability-weighted view on both redress and fines, because they're two running themes there. If you can just confirm that, and maybe also remind us what your booking fee revenue exposure is.

I know it's not something you carve out, but just to try and gauge what a downside scenario could be, if you can give us any context on the exposure there would be helpful. Thank you.

Pete Wood
CFO, Trainline

Thanks, Lara. So, start first with Project Oval. Look, I think the backdrop here is back in February 2025, we had the first 50 or so stations. December 2025, we had another 30 or so, and then another 20 in March, I think, this year. So, particularly those last two drops, we are still cycling through some of the impact.

Now, I think that has We have got a good handle on it, and typically what happens is on day one, there is not a huge impact, and then it builds over a period of time as people begin to notice the ability to tap in, and then it starts to level out again. As we have seen, the further out from London that you go, the less dramatic the impact is, but it is still there, if you like.

The final 130 stations, I think, are slated to go early next year. TBC exactly if they stay on track time-wise, but they are further out. I think the remaining part of that GBP 150 million is still the best estimate that I can provide to you. But you are right, it has taken longer than we had originally anticipated as this has slipped out to the right overall. So yeah, still a bit of a headwind there.

Then more broadly, to your question around the outlook into next year, obviously not providing formal guidance for next year at this point. I think the rate we are running at the moment, net the good work that we are doing on Railcards and other things, for example, less the impact of some of these factors, the self-preferencing overall, and then we talked extensively about the kind of price backdrop.

I can see it kind of continuing to run at this kind of level into next year. But that is not guidance. That is just joining the dots on what I am seeing at the moment, and we will provide more color as we get into next year with guidance. Then thanks, yeah, for the question on international marketing. I think we have been clear for a long time that when aggregation comes, that is the moment to invest more.

I think we have developed and refined the playbook over time, and really, it depends what exactly gets launched and when, as to exactly how much we invest. If these things all come at the same moment and we think there is good long-term opportunity, then we will not set a floor at the zero line. We will invest with a view to creating longer-term value and building our position out from those moments.

That said, it does not mean that we will drop below, right? There is a way in which these things are spaced appropriately. We have got underlying momentum, and therefore it is not necessary either. But it is hard to say exactly right now without seeing more clarity on the plan. Then finally, yes, just to confirm, the provision considers the potential fine, a potential redress, and some legal costs as well. So, it does cover all those bases.

You are not wrong. We do not split out the booking fee. If you look at the overall U.K. take rate, you can remove the commission, blend through at roughly the 4.5% that the headline is, and you are left with the residual part. A material part of that is booking fees. We have not split it out, but just to give you some altitude, it is a material part of that residual take rate, if you like.

Yeah, as I said already, this is an accounting judgment on the situation as it is today, and there still are a variety of outcomes that could unfold. It could be zero, or it could be a different number. So, don't please think of this as being the answer.

Lara Simpson
Analyst, JPMorgan

Perfect. Thank you so much.

Pete Wood
CFO, Trainline

Great. I think that's all we have time for today. Thank you all to operator, and I thank you all for your questions and for joining us. Just to recap, this was a robust first half. We are executing well and remain confident in the outlook, and I look forward to speaking with you all again soon. Thank you.