1. Executive summary
Safety Management Systems (SMS) are central to how the rail industry controls risk, assures safety and drives continuous improvement. ORR expects dutyholders to maintain an SMS that complies with the Railways and Other Guided Transport Systems (Safety) Regulations 2006 (ROGS) and demonstrate continuous improvement using the Risk Management Maturity Model (RM3).
Industry performance in 2024–25 shows that progress has been made in leadership and incident learning, but weaknesses persist in fatigue risk management, risk assessment, change control and asset integrity.
These challenges come at a time of significant organisational and sector reform. The transition toward Great British Railways (GBR) and wider operational pressures increase the importance of maintaining effective SMS that can manage both day-to-day and emerging risks.
Raising SMS maturity remains essential to sustaining high safety performance. Dutyholders should expect continued emphasis on applying RM3, improving assurance and learning, and demonstrating measurable progress toward Predictable and, ultimately, Excellence.
To support consistent improvement, ORR’s regulatory focus will centre on three strategic themes to guide dutyholders towards building resilience and accountability across their operations:
