TSI revision 2023/1694 and the residual-value curve: practitioner's read
The 2023 TSI revision tightens CCS and energy provisions and extends ETCS Baseline 4 mandates. For rolling-stock financiers the critical questions are transitional regimes, retrofit cost pass-through and the implications for resale after the primary award.
What 2023/1694 changed
Implementing Regulation (EU) 2023/1694 of 10 August 2023 amended a large bundle of TSIs simultaneously — including TSI CCS, TSI LOC&PAS, TSI WAG, TSI NOI, TSI ENE and TSI INF — and consolidated a number of changes that had built up since the Fourth-Railway-Package interoperability recast. On the command, control & signalling (CCS) side the revision establishes ETCS Baseline 4 as the default reference and defines a coherent migration path from Baseline 3 Maintenance Releases. On the energy side (TSI ENE) the revision tightens the provisions on regenerative braking and on coexistence of multiple power systems.
What matters for the residual-value curve
Three financing questions follow from the text of 2023/1694.
Transitional regimes. A vehicle authorised before the amendments remains authorised under its original scope; the TSIs' transitional rules determine when a future upgrade or scope extension triggers compliance with the new requirements. Lessors and PTA pools should map the transitional clock against the intended redeployment dates for each vehicle family.
Retrofit cost pass-through. Where an ETCS Baseline 4 migration, a TSI ENE upgrade, or a TSI CCS change-of-frequency is required during the service life of the vehicle, the Verkehrsvertrag and the Fahrzeugnutzungsvertrag determine who pays. Older Verkehrsverträge often lack a clear pass-through mechanism for regulatory capex; more recent contracts distinguish «mandatory regulatory change» from «optional operator-driven change» and allocate the former to the PTA.
Resale and cross-border re-deployment. The value of a German-authorised EMU in a secondary market (other PTAs, other Member States) depends on how quickly an ERA one-stop-shop authorisation for the target use can be obtained. 2023/1694 harmonises parts of that authorisation basis, but national notified rules persist in defined areas; the resale friction is therefore a function of the specific Member-State combination.
Two practitioner takeaways
On new procurements, the Leistungsverzeichnis should specify the ETCS Baseline target and the retrofit obligations as a function of the TSI transitional clock, not as a function of the contract start date. On existing fleets, the ECM maintenance-management plan should be cross-checked against the 2023/1694 transitional provisions to confirm that no obligation has been overlooked.
Where this sits
See the TSI section of the Regulation page and the Fourth Railway Package section for the institutional basis under Directive (EU) 2016/797.
Last reviewed: 18 April 2026. These notes are not legal advice. See the Disclaimer.