Northern has completed a 23-point improvement plan to strengthen disability awareness training for passenger-facing staff following an Office of Rail and Road investigation that uncovered significant weaknesses in the operator’s training governance and monitoring.
ORR has now closed its intervention after Northern delivered all of the actions required by the regulator, including clearer accountability for training, improved monitoring systems, work to address gaps in historic training records and changes to induction and refresher training.
The regulatory intervention followed the discovery in August 2025 that around 800 Northern passenger-facing employees – approximately a third of its permanent passenger-facing workforce – did not have the required disability awareness training recorded.
ORR will now return Northern to regular monitoring, with the operator required to provide quarterly information on its disability awareness training.
Training gaps exposed wider governance problems
The issue went significantly beyond several hundred employees needing additional training.
Northern’s Accessible Travel Policy (ATP) requires new passenger-facing employees to receive disability awareness training as part of their induction and all staff to receive refresher training at least every two years.
However, ORR’s March investigation found that induction training for new station staff had only been provided since late 2023, while evidence indicated that most station staff did not have access to disability awareness refresher training until 2025.
The problem emerged through new regulatory reporting requirements introduced in 2025 rather than Northern’s own monitoring arrangements.
More significantly, when ORR attempted to establish the full scale and duration of the problem, Northern acknowledged that it did not hold sufficiently complete historic records to determine which station employees required training or whether it had been completed.
An internal audit subsequently identified three fundamental weaknesses: undefined responsibilities for delivering and monitoring training, fragmented data without a single source of truth and the absence of a formal standard operating procedure for managing disability awareness training.
ORR concluded that these represented systemic weaknesses in Northern’s governance, monitoring and controls.
Long-running concerns over passenger assistance
The investigation also needs to be viewed against Northern’s wider accessibility performance.
ORR had already been working with the operator over passenger assistance after Northern was the poorest performer for assistance reliability in the regulator’s survey between 2020 and 2024. A separate improvement plan was agreed in 2024, with staff training identified as central to delivering reliable assistance.
Data included in ORR’s investigation illustrates the challenge. In 2024-25, 19% of Northern passengers surveyed said they received none of the assistance they had booked, compared with 11% across other operators. In 2021-22, Northern’s figure had been 24%, against 11% elsewhere.
ORR did, however, distinguish between the training failures and passenger satisfaction more broadly. Northern reported relatively strong satisfaction among disabled passengers with assistance and staff knowledge, while accessibility-related complaint volumes remained low.
The regulator nevertheless concluded that inadequate training creates a clear risk of negative experiences because employees may not properly understand the challenges faced by disabled passengers or their own responsibilities in providing assistance.
23 actions now completed
Northern initially moved quickly to tackle the immediate training backlog, delivering face-to-face training through Passenger Assist Champions and team leaders during October 2025.
But ORR’s concern was whether the underlying systems had changed sufficiently to prevent the same problem developing again.
Northern subsequently produced a 23-action programme focused on four areas: reviewing governance and reporting controls, defining training requirements by role, addressing historic gaps and improving induction, onboarding and refresher training. ORR described the programme as “comprehensive and well-targeted” at the systemic weaknesses identified.
The operator has now completed the programme, strengthening responsibility and accountability, improving its ability to identify which employees require training and addressing deficiencies in existing records.
Stephanie Tobyn, ORR’s Director of Strategy, Policy and Reform, said: “Disabled passengers should be able to trust that staff have the knowledge and confidence to provide the support they need.
“Our investigation found serious weaknesses in Northern’s management and monitoring of disability awareness training. Northern has responded positively, completing all the actions we required and putting clearer accountability and stronger checks in place. We welcome these improvements and will continue to work with Northern to ensure they are sustained.”
Wider lesson for operators
Northern’s case highlights the difference between delivering training and being able to demonstrate that training requirements are being systematically managed across a large operational workforce.
Accessible Travel Policies are regulatory commitments rather than voluntary customer service aspirations. ORR’s investigation was formally opened to determine whether Northern had contravened Condition 5 of its passenger and station licences, under which operators are required to establish and comply with their ATP.
For other operators, the case therefore provides a warning about the importance of robust training records, clearly assigned responsibilities and systems capable of identifying non-compliance before it reaches significant scale.
For Northern, completing the 23 actions closes the immediate regulatory intervention, but not the scrutiny. Quarterly monitoring will now provide the test of whether the changes have become embedded in business-as-usual operations – and, ultimately, whether stronger training governance translates into more reliable assistance for disabled passengers.
