ETCS Exemption in France 2026: What Changes for Railway Operators

Key data

Railway operators operating in France have relevant news as of 1 June 2026: certain locomotives are exempt from the obligation to install the ETCS system (European Train Control System), the European standard for train control integrated into the ERTMS system. Implementation Decision (EU) 2026/1193 of the Commission — notified as C(2026)3501 — formalizes this exception under the Directive (EU) 2016/797 on the interoperability of the railway system.

The exemption is not unlimited: it applies under justified technical and operational conditions, and its validity must be verified by each affected company. Ignoring the limits of this exception may compromise the authorization for rolling stock to operate, especially in cross-border operations.

What does this regulation establish?

The Commission Implementing Regulation (EU) 2023/1695 establishes as a general requirement the installation of the ETCS system on board locomotives operating on the European railway network. ETCS is the control component of the ERTMS system (European Rail Traffic Management System), the European standard for railway traffic management, designed to ensure interoperability between national networks.

France requested an exception to this requirement from the European Commission for certain locomotives on its network. Implementation Decision (EU) 2026/1193 approves that request, allowing the affected locomotives to operate without the ETCS system installed on board, provided that the technical and operational conditions that justified the exception are met.

Economic and operational impact

The installation of the ETCS system on a locomotive represents a significant technical investment: it involves on-board hardware, certified software, homologation tests, and recurring maintenance costs. The approved exemption allows affected operators in France to defer or avoid this expenditure for rolling stock covered by the decision.

However, the operational impact has a less favorable side: locomotives without ETCS installed may see their ability to operate on cross-border corridors where the system is mandatory limited. This directly affects the planning of international routes and the marketing of traction services in the European market.

• Potential savings: Costs of ETCS installation and homologation avoided for exempt rolling stock.
• Operational risk: Circulation restrictions on cross-border corridors with mandatory ETCS.
• Conditional validity: The exemption is subject to technical and operational conditions; non-compliance may invalidate it.
• Fleet management: Infrastructure managers must update their rolling stock registers to reflect which locomotives operate under exemption.

Who does it affect?

• Railway operators in France with locomotives that would be subject to the ETCS installation requirement according to Regulation (EU) 2023/1695.
• Railway infrastructure managers in France who must manage the operation of rolling stock with and without ETCS on their network.
• Railway companies with cross-border operations that use exempt French locomotives on international corridors.
• Technical and homologation departments responsible for rolling stock certification and compliance with technical specifications for interoperability (TSI).
• Operations directors and CFOs who manage fleet modernization investment planning.

Practical example

A freight railway operator based in France has a fleet of shunting locomotives used exclusively in classification yards and sections of the national network without ERTMS equipment. Under Regulation (EU) 2023/1695, these locomotives would be required to incorporate the ETCS system on board, which would involve a homologation process and a relevant technical investment per unit.

Thanks to Implementation Decision (EU) 2026/1193, if these locomotives are among the rolling stock covered by the exemption approved for France, the operator can keep them in service without installing ETCS, provided it complies with the technical and operational conditions established in the decision. The first mandatory step for this operator is to verify, with its technical department and before the French national railway safety authority, whether its specific locomotives fall within the scope of the exemption and what exactly those conditions are.

What should companies do now?

1. Identify affected rolling stock: Review the fleet of locomotives operating in France and determine which would be subject to the ETCS requirement according to Regulation (EU) 2023/1695.
2. Verify the scope of the exemption: Consult the full text of Implementation Decision (EU) 2026/1193 to confirm which locomotives are covered and under what technical and operational conditions.
3. Contact the French national railway safety authority: Confirm the procedure for accreditation or registration of exempt locomotives with the competent body.
4. Evaluate the impact on cross-border operations: Analyze whether exempt locomotives operate or could operate on international corridors where ETCS is mandatory, and plan accordingly.
5. Update fleet investment planning: Review rolling stock modernization and homologation plans in light of this exemption, adjusting timelines and budgets.
6. Monitor the validity of the exemption: The exception is conditional on compliance with technical and operational requirements; establish a monitoring process to ensure that conditions are maintained over time.

Official source

Consult complete regulation in official source

Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32026D1193