Europe’s most

downloaded

rail travel app

Annual Report & Accounts 2026

Empowering

greener travel

choices,

connecting

people and places

Strategic Report

02

Highlights

04

Chair’s statement

06

At a glance

08

Business model

10

CEO’s statement

12

International case studies

14

Regulatory overview

15

Our technology

21

Strategic priorities

22

Strategy in action

27

Key performance indicators

29

CFO’s financial highlights

32

Principal risks and

uncertainties

38

Viability statement

39

People, community and

planet

46

TCFD, SECR and SASB

disclosures

53

Stakeholder engagement

and Section 172(1) statement

Financial Statements

90

Independent auditors’ report

103 Consolidated income statement

103

Consolidated statement of comprehensive income

104 Consolidated balance sheet

105

Consolidated statement of changes in equity

106

Consolidated statement of cash flows

107

Notes to the Group Financial Statements

142

Alternative performance measures

144 Parent Company balance sheet

145

Parent Company statement of changes in equity

146

Notes to the Parent Company Financial Statements

Governance

58

Chair’s governance statement

59

Governance structure

61

Board of Directors

65

Report of the Nomination Committee

67

Report of the Audit and Risk Committee

72

Directors’ remuneration report

85

Directors’ report

88

Statement of Directors’ responsibilities

Trainline plc Annual Report & Accounts 2026

01

Contents

Strategic priorities

Growing

supply

Offering all the tickets,

fares and value-saving

features in the UK, while

aggregating new carriers

and routes as markets

liberalise across Europe.

Enhancing

the customer

experience

Enhancing the customer

experience through in-app

travel companion features

that help customers get

from A to B, including

AI-powered rail disruption

features.

Building

demand

Encouraging rail travel and

growing brand awareness,

while also leveraging

emerging AI distribution

channels.

Increasing

customer

lifetime value

Deepening customer

relationships, transaction

frequency and

monetisation.

Growing

Trainline Solutions

Supporting our travel

partners, leveraging the

strength of Platform One,

our single global platform.

Find out more on page 21

Find out more on page 29

1. Constant currency (“CCY”) year-on-year growth calculated for International Consumer and Trainline Solutions using prior period average €/£ exchange rate applied to current year reported numbers.

Basic EPS

+48%

Improved to 19.4p, from 13.1p in

FY2025

Operating profit

+43%

Increased to £122 million from

£86 million last year

Financial highlights

Adjusted EBITDA

+11%

Adjusted Basic EPS

+23%

Net ticket sales

+7%

Revenue

+2%

02

12

International case

studies

Trainline’s structural tailwinds across

both its domestic and foreign travel

markets.

39

People, community

and planet

Progress made in the year with our

people through diversity indicators

and Trainline’s cultural values, and

our efforts in the community and

environment.

10

CEO’s statement

Updates from our CEO, Jody Ford,

on our milestones in the year, and

progress made towards Trainline’s

strategic priorities.

29

CFO’s financial

highlights

Updates from our CFO, Peter

Wood, on the Group’s financial

performance in the financial year,

and the outlook for the coming year.

Strategic Report

02

Highlights

04

Chair’s statement

06

At a glance

08

Business model

10

CEO’s statement

12

International case studies

14

Regulatory overview

15

Our technology

21

Strategic priorities

22

Strategy in action

27

Key performance indicators

29

CFO’s financial highlights

32

Principal risks and

uncertainties

38

Viability statement

39

People, community and

planet

46

TCFD, SECR and SASB

disclosures

53

Stakeholder engagement and

Section 172(1) statement

Trainline plc Annual Report & Accounts 2026

Strategic report

03

Positioned for growth

Strong strategic progress and robust operating performance.

Trainline delivered a year of continued strategic progress,

underpinned by resilient growth, strong cash generation

and further enhancement of its product and technology.

This reflects the team’s unwavering focus on the customer

and championing of rail as a greener way to travel. The

business remains well positioned against attractive long-

term structural tailwinds in both the UK and across Europe.

UK rail reform and GBR

The publication of the Great British Railways (GBR)

consultation output in November 2025 provided greater

clarity on the future structure of rail retailing. At a high

level, it reaffirmed the Government’s commitment to

a fair, open and competitive retail market, alongside

recognition of the important role independent retailers

play in driving innovation and improving customer

outcomes.

The proposed framework includes GBR assuming

industry governance responsibilities, a formal code of

practice, with independent oversight from the Office of

Rail and Road (ORR), and clear mechanisms for industry

consultation and challenge.

Maintaining an assertive stance with Government

The Board views the GBR consultation output as a

constructive step towards establishing appropriate

level playing field safeguards for rail retailing. However,

Trainline maintains its assertive stance with the

Government to ensure that they meet their commitments

to a fair, open and competitive retail market, particularly

around the development of its new code of practice.

In addition, Trainline is making progress in rectifying

examples where TOCs self-preference their own retail

channels. An important example is the denial of access to

Delay Repay for third-party retailers – a consistent priority

for our customers and a key focus of our engagement

with Government.

In March 2026, the Government announced that, once

GBR is established, customers will be able to access Delay

Repay compensation through the retailer from which they

purchased their ticket, including independent retailers.

Disciplined capital allocation

The Group continues to generate strong cash flows,

supported by its scalable, asset-light model, and we have

a clear and consistent capital allocation framework. In line

with this framework, we have continued to execute our

share buyback programme. As at 30 April 2026, we have

repurchased £94 million of shares under the current £150

million programme.

This brings total capital returned to shareholders to £294

million since September 2023, equivalent to around 23%

of issued share capital

1

.

The Board considers this a disciplined use of capital,

reflecting both strong cash generation and confidence in

the long-term value of the business.

The business remains

well positioned with

attractive long-term

structural tailwinds in

both the UK and across

Europe.”

Brian

McBride

Chair

1. Calculated by reference to the original number of shares in issue at the

start of Trainline’s first share buyback programme in September

2023

(481 million shares).

Leadership transition

I would like to thank Jody Ford for his outstanding leadership

of Trainline. Over his tenure, the Group has undergone a

period of exceptional growth, establishing itself as Europe’s

leading rail app, now serving 27 million customers

1

. The

business has doubled net ticket sales across both UK and

International Consumer segments, more than doubled

profits, and strengthened its position in key European

markets including France, Spain and Italy.

Jody has also built a high-quality leadership team and

a strong platform for continued growth. On behalf of

the Board, I

would like to thank him for his significant

contribution during this important phase in the Company’s

development. We have initiated a succession process and

will appoint a CEO with the experience and capabilities

to lead Trainline through its next phase. This will include

navigating the establishment of Great British Railways as

the strategic authority for UK rail, alongside the continued

liberalisation of European rail markets, where we see

significant long-term opportunity.

Looking ahead

The rail industry is entering a period of significant transition.

While some uncertainty remains, the direction of travel is

becoming clearer. The Board remains focused on ensuring

Trainline continues to deliver value for customers and

partners, engages constructively with Government and

regulators and invests to strengthen its competitive position.

I would like to thank our colleagues for their continued

commitment, and our shareholders for their ongoing support.

Brian McBride

Chair

5 May 2026

Empowering:

Making it easy for customers to

access a range of value-saving

products across carriers and

journey options – championing

a much greener way to travel

Enhancing:

Leveraging scale, data and

technology to offer a superior

customer experience

Connecting:

Offering carrier partners

distribution and online retail

services at a lower cost to serve

We are Europe’s most downloaded rail travel app. Through our customer-centric,

scalable platform, we are committed to driving responsible and sustainable

business growth, by:

1. Number of customers across the UK and Europe who

have transacted at least once over the last 12 months.

Trainline plc

10

Currencies and multiple

payment methods

including Apple Pay,

Google Pay, PayPal,

SOFORT and iDEAL

We enable millions of travellers to unlock value when

booking rail travel through our highly rated mobile App

and website, as well as through our partner channels.

We work with over 270 rail and coach companies across more than 40 countries throughout

the UK and Europe.

By bringing all of the major carriers and new entrants onto one platform, we provide customers

with a large array of train and coach options. Our smart technology and data-driven features

help our customers to stay one step ahead.

For our carrier and B2B

partners, Trainline Solutions offers access to a huge supply of rail carrier

inventory across the UK and continental Europe through our proprietary platform. With tested

and proven technology, we enable them to offer best-in-class customer experience at low cost.

We are Europe’s leading

independent rail platform

>270

rail and coach companies

>40

countries travelled

in and across by

Trainline customers

93%

of our UK transactions

are through our App

4.9/5

star app rating¹

1. iOS rating as at 30 April 2026.

Trainline plc Annual Report & Accounts 2026

At a glance

06

UK Consumer:

#1 Travel App in the UK

We are the #1 travel app in the UK

1

, with 18 million

total active customers

2

. Trainline continues to

invest in its customer proposition, strengthening

the loyalty and engagement of our customer base

and, in turn, deepening our competitive moat.

Trainline is well placed to scale, particularly in

Spain, France and Italy as carrier competition

becomes more widespread over the next few

years. The three markets today represent an

addressable market of around €17 billion,

expected to grow to €23 billion by 2030

3

.

Within Trainline Solutions, B2B distribution was

the fastest-growing sub-segment and represents

our primary growth opportunity. Within a €6 billion

European business travel market

3

, our Global

API enables multi-carrier rail distribution, driving

strong growth across partners and markets.

International Consumer:

#1 Rail Aggregator in Europe

Trainline Solutions:

#1 B2B Rail

Platform Across UK and Europe

Our three business units are leaders in their

respective markets and each has significant

headroom to scale.

Read more on page 23

Read more on page 10

Read more on page 26

3. OC&C 2024 analysis and internal estimates.

1. Trainline is the number one app in the UK versus

major travel peers as per daily average active user

data in

H2

FY2026, as sourced from Sensor Tower.

2. Number of customers across the United Kingdom who

have transacted at least once over the last 12 months.

Trainline plc Annual Report & Accounts 2026

07

At a glance

07

Leveraging our

advantages to further

strengthen our

competitive position.

We understand the travel needs and

patterns of our customers in over

40 countries through our B2C and

B2B channels with around 130

million visits to our platform

each month.

Scaling

Europe’s

#1 rail

platform

Platform One is our agile and

proprietary technology. It is the engine

behind our App and website, and it

also powers the booking and retailing

solutions for our B2B partners (rail

carriers and travel platforms).

Using our product and technology

expertise, plus the unique data insights

generated across our large customer

base, we are leveraging AI to further

enhance our customer proposition.

Expertise

Expertise and scale

to invest

Technology

Scalable tech platform

optimised for

rail travel

Customers

We earn a commission and fees on B2C ticket sales. We also generate

revenue from advertising and ancillary services such as hotel booking,

travel insurance and multi-currency payment options.

B2B partners pay a commission and/or transaction fee on ticket sales,

as well as other related technology service fees.

We seek to expand the services we provide, meeting more of our

customers’ needs and increasing our monetisation.

Most of our customers transact through our

mobile App, benefitting from products and

features like Travel Forecast, AI Travel Assistant

and digital railcards, which in turn build loyalty

and engagement.

Brand

Strong brand

affinity and

trust

Supply

All tickets, fares 

and value-saving

features

Trainline plc

Annual Report & Accounts 2026

08

4.9/5

star-rated app on iOS

A highly-rated user

experience for our

customers and

partners

For our B2B partners

We give travel sellers

access to our rail content

via our Global API.

• Access to our rail content

and local features

through one connection

• Allowing travel sellers to

integrate rail into their

offering, helping them

grow their business

For carrier partners

We provide end-to-end

online retailing solutions

for rail carriers.

• Fast and secure tech

platform for retailing and

ticketing at a lower cost

to serve

• Deep rail tech expertise:

customised, high-

converting and high-

quality solutions

• Broad range of products

and features to integrate

into their retail channels

Our people

Clear purpose at Trainline: make greener travel choices, connecting people and places.

Shareholders

Helping shareholders understand our business and strategy, while simultaneously

addressing their objectives and concerns.

Government and regulators

Encouraging modal shift while advising on fair, open and competitive rail markets.

Environment

Building motivation and pride to switch from driving and flying to rail, with route

emission information and brand campaigns to drive awareness for sustainability of rail.

Our wider stakeholders…

For travellers

Highly-rated customer experience for travellers globally.

• 4.9/5 star-rated app on iOS

•

Search and book train tickets for journeys in over 40 countries

• All ticket types, journey combinations and fares across major carriers

in one place

• Seamless, friction-free booking experience

• Multiple currencies and payment options

• Digital tickets, smart personalisation, real-time travel information and

many more features

Innovating at pace

FY2026: A year of strong delivery from Europe’s #1 rail app.

This has been a strong year for Trainline, delivering record

net ticket sales and revenue alongside double-digit growth

in profitability, making good progress in strengthening our

competitive position, and leveraging AI to innovate at pace.

Robust financial performance

Group net ticket sales increased 7% year-on-year

1

to

£6.3 billion. Revenue grew 2%

1

to £453

million, reflecting

the impact of the previously announced UK commission

rate change. We delivered double-digit adjusted EBITDA

growth, underpinned by operating leverage, our cost

optimisation exercise last year, and ongoing cost discipline.

We maintained a disciplined approach to capital

allocation, supporting both strategic investment and

significant returns to shareholders through our enhanced

share buyback programme.

Strengthening our competitive position

UK Consumer

In UK Consumer, we focused on building loyalty and

deepening engagement across our customer base. We

launched AI-powered features under the banner ‘The

Way to Train’ to help customers navigate disruption on

the rail network. We grew our digital railcard user base

16% year-on-year to 2.7 million

2

, which is notable given

railcard users are typically amongst our most frequent

and loyal customers. Such initiatives are strengthening

customer loyalty and helping to mitigate industry

headwinds, including Transport for London’s (TFL)

expansion of contactless travel (Project Oval) and TOCs

self-preferencing their own retail channels.

Self-preferencing occurs where operators offer features

that we are prevented from offering, or market in ways

that we are not allowed to do. These examples highlight

areas where competition is not yet fair and open. Through

our sustained engagement we have made progress to

remove examples where we are discriminated against. The

Government has confirmed our access to all temporary

fares and granted our ability to advertise in stations and on

trains. Furthermore, in March 2026 they announced that,

once GBR is established, passengers will be able to claim

Delay Repay compensation from wherever they purchased

their ticket – including through Trainline. This was a

meaningful step forward, however it will take some time for

this change to come into effect. Similarly, we are still unable

to offer customers access to train operator loyalty schemes.

We continue to engage Government stakeholders and the

wider industry to remove these restrictions.

We are also increasing the opportunity to monetise our

18 million customer base in the UK through our range

of ancillary products and services. We have made these

services more prominent and visually engaging within the

App, helping drive strong double-digit growth in hotels

and insurance sales in the UK.

International Consumer

In International Consumer, we are actively focusing

marketing investment on European high-speed routes

with emerging carrier competition. We saw encouraging

progress on newly competitive routes, particularly in

South-East France where we grew 26% this year following

Trenitalia’s expansion of services.

We are strengthening our

competitive position and

leveraging AI to innovate

at pace.”

Jody

Ford

Chief Executive

Officer

1. Constant currency (“CCY”) year-on-year growth calculated for International Consumer and Trainline Solutions using prior period average €/£ exchange rate

applied to current year reported numbers.

2. Trainline’s digital railcard user base in the United Kingdom as at 3 January 2026.

Our progress in France builds on our learnings in Spain.

Spain has been an ideal market to hone our aggregation

playbook and over the past few years we have scaled our

net ticket sales, giving us a considerable lead versus other

market aggregators. While we continue to see runway

for further growth in Spain, this year we evolved our

approach to strike more of a balance between growth and

profitability, including normalising our brand marketing

investment.

With the next wave of liberalisation in Europe set to

commence from late 2027 in Italy and from 2028 in

France, we are well positioned to scale our presence and

capture a growing share of this significant opportunity.

Foreign travel sales reaccelerated in the second half of

the year as we lapped the negative impact of changes to

Google’s search results page while also benefiting from

increasing generative AI

sales traffic.

Overall, our approach is driving improved profitability and

in FY2027 we expect the International Consumer business

to breakeven

1

.

Trainline Solutions

Trainline Solutions delivered another strong year,

driven by growth in business travel. B2B Distribution

net ticket sales were up 36

%, reflecting strengthening

business travel sales from a growing number of travel

management company clients (including Amex GBT,

Navan, Perk and Havas). This was particularly evident in

Europe, where International B2B sales through Trainline’s

Global API were up 58%.

Leveraging AI to innovate at pace

Our AI strategy focuses on three core areas: AI-enabled

products and features, extending distribution through

emerging AI channels, and AI-enabled acceleration.

AI-enabled products and features

We increasingly use AI to enhance our App user

experience, leveraging first-party data from our

18 million

UK customer base alongside a breadth of industry supply

data. Our new AI-powered features help customers

navigate disruption on the rail network. Travel Forecast

provides customers with personalised notifications if

their journey is likely to be disrupted. It features a map-

view interface, powered by our Signalbox technology, so

customers can see the location of their train in real-

time. AI Travel Assistant is our in-app conversational

support feature, which offers a live native chat function

to customers on the go, with real-time rail travel advice

and agentic tools like refund processing without human

intervention.

Extending distribution through emerging AI channels

Emerging AI channels represent a new way for Trainline to

engage with customers and drive incremental demand for

our products and services. We are the number one cited

rail app in Google Gemini across all our core markets, and

the number one in ChatGPT in all core markets except

France. However, sales traffic from generative engine

optimisation (GEO) remains low, representing less than

1% of International new customers.

We recently launched an integrated app within the

ChatGPT ecosystem. Through ChatGPT, users can now

seamlessly search for routes and compare options – all

within a conversational interface – before completing

their booking within Trainline.

AI-enabled acceleration

AI-enabled acceleration is becoming a core capability,

enabling faster execution, greater agility and more

scalable innovation across the Group. For example, in

Customer Service, we will trial Voice AI, while in software

development, our teams are using AI to support and

accelerate product development and are now shifting

their focus towards scaling AI agent capabilities.

Significant opportunity for growth

At Trainline, our purpose is centred around empowering

greener travel choices. Looking ahead, we see a clear

pathway for growth. Structural tailwinds, including

increasing rail liberalisation in Europe and growing

demand for more sustainable travel, remain firmly

in place. We are mindful of regulatory and legislative

developments in the UK – where we are engaging

with Government and regulators to deliver on their

commitments for a fair and open retail market. However,

we remain confident in our ability to execute against our

strategy and deliver long-term value for customers and

shareholders.

As

this will be my final Annual Report as

CEO, I would like

to thank the Board for the opportunity to lead Trainline

over the past six years.

I am proud of what the team has achieved and deeply

grateful to colleagues across the Group whose energy,

resilience and commitment have made this possible.

Together, we have built a stronger, more internationally

diversified business, with a clear platform for continued

growth.

As Trainline enters its next multi-year chapter, I believe

this is the right time to transition to new leadership.

I will work closely with the Board and the team to ensure

a smooth and orderly handover, and I look forward to

seeing the business continue to thrive in the years ahead.

Jody Ford

Chief Executive Officer

5 May 2026

1. International adjusted EBITDA including the internal transaction fee paid

to Trainline Solutions to access Platform One.

Trainline plc

Annual Report & Accounts 2026

Our core markets in Europe are Spain, France and Italy – markets that have

liberalised or are set to liberalise in the next couple of years. In aggregate, these

markets generate industry passenger revenues of around €17 billion per annum

1

.

Those revenues are expected to grow to €23 billion by 2030

1

, €12 billion of which

will come from routes with carrier competition.

Spain

•

Since 2021, Spain has increased from one high-speed carrier – the national incumbent

Renfe – to four different carrier brands competing across its five largest

high-speed routes (representing €1.5 billion in annual passenger revenues

1

)

•

Increased carrier competition is benefiting customers, who now enjoy significantly

more choice coupled with lower ticket prices

Italy

•

Trenitalia and NTV Italo already compete on the high-speed network, generating

€2.0 billion of annual passenger revenues

1

•

SNCF are set to launch operations in Italy from late 2027 – connecting Turin-Naples

and Turin-Venice with 13 daily round trips – becoming the third nationwide competitor

France

•

In FY2026, Trenitalia significantly expanded services across South-East France’s

c.€1 billion high-speed rail network

1

, increasing Paris–Lyon frequencies from five

to 14 daily return services and introducing four daily return services on Paris–Marseille

•

Several new entrant carrier brands are due to launch, with the first arriving in 2028:

–

Velvet launching on Bordeaux, Rennes, Nantes and Angers to Paris from 2028

–

Le Train to launch services to Bordeaux, Rennes, Tours and Nantes

–

Illisto planning to launch on Lille, Strasbourg and Lyon to Paris

•

Carrier competition on the Channel Tunnel expected to arrive from 2029 on the

lucrative €1.7 billion route

1

. Trenitalia and Virgin Trains have both announced plans to

launch competitor services to Eurostar

1. OC&C 2024

analysis and internal estimates.

Carrier competition set to expand across

France and Italy from next year

Trainline plc

Foreign travel opportunity

An attractive market driving

International Consumer profitability

Alongside the aggregation opportunity in Europe,

foreign travel represents a large and attractive growth

opportunity. Foreign travel comprises customers

travelling in Europe from the

US, UK and the rest of the

world, alongside intra-EU cross-border travel.

The foreign travel market in Europe today is worth €

4

billion

1

and offers significant headroom for growth.

Foreign travel benefits from favourable economics, with

a less price-elastic customer base and a greater skew

towards long-distance travel. Foreign travel sales are

relatively higher-margin, generating double-digit revenue

take-rates, supported by higher attach rates for ancillary

products and carriers willing to pay higher commission

rates for inbound travellers.

International Consumer is well placed to win

Trainline is well positioned to capture the headroom

opportunity in foreign travel. We combine broad

inventory coverage (including recently adding rail supply

from Ireland and Poland), with a consistent, high-quality

user experience across multiple European markets. We

offer a broad range of features tailored to international

customers, including multi-language support, multi-

currency pricing and flexible payment options. Together

with our post-sales capabilities, this enables customers to

plan, book and manage their journeys seamlessly.

Trainline citing prominently within

generative AI search results

We see signals that emerging AI channels are playing an

increasing role in foreign travel, given its ability to inspire

travel plans while compressing journey research time. In

terms of generative engine optimisation (GEO) rankings,

Trainline is the early market leader for ticket retailing,

with GEO

channels contributing c

.3% of our new foreign

travel customers.

1. OC&C 2024

analysis and internal estimates.

Trainline plc

Annual Report & Accounts 2026

13

Regulatory and political environment

UK:

GBR Online Retail and future market design

Major focus points for investors are the

UK

Government’s intention to launch GBR

Online Retail – its

consolidated app and website – and the design of the future retail market.

In November

2025, the UK

Government published the output from its industry consultation on the

Railways Bill. This represented a further step towards the establishment of Great British Railways (GBR

) as

an arm’s-length body responsible for rail services and infrastructure.

The document included key points around rail retailing, providing more clarity around the Government’s

commitment to a fair, open and competitive future market design, most notably:

•

Separation of governance of third-party rail retailing from GBR’s own commercial retailing arm

•

A commitment to develop for the first time a ‘code of practice’, codifying how GBR should interact with

third-party retailers

•

A strengthened role for the Office of Rail and Road (ORR), who will provide independent oversight and

binding enforcement of the code

The Railways Bill is currently progressing through Parliament and the

ORR

has begun developing GBR’s

code of practice in consultation with third-party retailers like Trainline. In our engagement with this

process, we are maintaining an assertive stance with the Government for it to deliver on its commitment

to an open, fair and competitive future retail market.

In late 2025, the UK

Government announced a preliminary market engagement exercise to deliver GBR

Online Retail. Trainline has engaged with this exercise thus far, however the full procurement process

is still yet to begin. The Government intends to award a procurement contract from January 2027

, and

thereafter hold two phases of work under the GBR Online Retail project:

•

Phase 1: build phase for GBR Online Retail (app and website)

•

Phase 2: TOC integration – over up to 12 months post-launch to integrate capabilities, across all

Department for Transport (DfT) publicly owned operators

Rectifying TOC self-preferencing

We are also actively challenging where operators self-preference their retail channels currently. Key

examples include

TOCs

deploying features like automated Delay Repay or branded loyalty schemes,

where third-party retailers like Trainline are effectively locked out. In March

2026, the UK

Government

announced that, for the first time, once GBR is established passengers will be able to claim Delay Repay

compensation from wherever they purchased their ticket. This will include independent retailers such as

Trainline. While this change may take a couple of years to come into effect, it represents a positive signal

from the UK

Government of their commitment to a fair and level rail retailing market.

Protecting and growing UK rail industry revenues

We are taking steps to prevent fraud and protect industry revenues.

Over the past year, we have blocked over £

40

million of fraudulent ticket

purchases, while our real-time machine learning has contributed towards

us preventing over £

20

million of fraudulent refunds. We are sharing our

data with

TOCs

through bespoke agreements, supporting their revenue

recovery and revenue protection resource deployment, and are trialling a

railcard validation service in partnership with Greater Anglia to prevent

fraudulent railcard use.

We continue to innovate to grow

UK

rail.

We are pleased with the

performance of our digital pay-as-you-go (DPAYG) trial on the East Midlands

Railway network, which is expected to end in the summer. Of the three trials

awarded by the DfT, the East Midlands trial is arguably the most complex as

it encompasses three different cities – Derby, Nottingham and Leicester.

Europe:

The European Commission is expected to publish a formal proposal as

part of its upcoming Mobility Package, aimed at making cross-border rail

travel simpler, more transparent and more passenger-friendly by improving

access to tickets. While details of the proposal are not yet available, it is

expected to address the role of distribution, including reducing operator

control over retail channels. This may include measures to ensure

incumbent operators provide access to timetables, fares and real-time data

on a fair, reasonable and non-discriminatory (FRAND

) basis, remunerate

intermediaries appropriately, and potentially make third-party inventory

available through their own digital channels. Following publication, the

proposal will be subject to negotiation in the European Parliament and

Council, with implementation likely to be phased over several years.

In a similar vein, in April

2026 the French Senate adopted an amendment

to existing transport legislation that would introduce obligations on

SNCF

Connect to distribute competitor tickets, alongside broader requirements

to provide access to rail content on FRAND terms. The legislative process

remains at an early stage, with material uncertainty around both timing and

final scope.

Trainline plc

Annual Report & Accounts 2026

14

Regulatory overview

Our technology is optimised for rail travel

At Trainline, we pride ourselves on our proprietary, modern, scalable tech platform.

Deep inventory connections

• Rail and coach

• Pre and post-sales

• Real-time data

•

Add-on travel services: insurance, hotels etc.

Personalised data-driven products

•

>12 TB data processed per day

•

Scalable agentic AI system underpins our

AI Travel Assistant

>12

TBs of data processed daily

>400

searches per second

Reliable, scalable, secure

•

>700 microservices, increasing speed of

development, flexibility and scalability

• c.500 engineers, data and tech specialists

•

>300 releases per week

Customer-centric ecommerce

•

Simple new App homescreen: hides

industry complexity

•

10+ payment options, including Google Pay

and Apple Pay

>300

releases a week

>700

microservices

Trainline plc

Annual Report & Accounts 2026

15

Our technology

Our teams comprise developers, designers,

infrastructure and data scientists, working

together to create a world-class experience

for our customers and carrier partners.

Distribution and

white label retail

services

Ecommerce

Ticketing and

settlement

Payments and

fraud prevention

Journey planner

and real-time

info

Customer

accounts

Platform One

Our single global tech platform provides a range of tools and services for

our

B2C

and

B2B

customers.

Security, payments, fulfilment,

fraud safeguards

•

PCI-DSS Level 1 (Merchant & Service Provider)

since 2013

•

Partnership with NCSC and NCA

•

Internal standards aligned with NIST framework

•

Business Continuity Planning (ISO 22301) certified

since 2022 and Information Security Management

(ISO 27001) certified since 2023

•

3DS version 2 implemented

•

Payment Services Directive II Secure Customer

Authentication fully live

•

Industry-leading fraud to sales ratio and industry-

leading payment acceptance rates

c.500

engineers, data and tech specialists

~3m

origin-destination pairs per month

Supply data (UK and EU)

Trainline plc

Annual Report & Accounts 2026

16

Trainline’s AI strategy

At Trainline, we benefit from clear advantages when

it comes to deploying our AI strategy. These include

unparalleled first-party data from our scaled user base,

an agile and scalable single global tech platform, and a

tech team of over 500 people. In addition, we operate in

an online rail retailing market that is inherently complex,

providing barriers to disintermediation.

Our AI strategy focuses

on three core areas:

AI-powered products and

features:

leveraging AI and

proprietary data to enhance the

customer experience.

Extending distribution through

emerging AI channels:

meeting

customers where they are to drive

incremental demand.

AI-enabled acceleration:

enabling

faster execution, greater agility and

more scalable innovation across

the Group.

Trainline plc

Annual Report & Accounts 2026

Our technology

continued

17