Questions About Delay Repay Claims and Third-Party Services in the UK

[ethp2000]

Hi, I’m currently looking into Delay Repay in the UK and had a few questions I was hoping someone could help with:

1. Is it possible for a third party to submit a Delay Repay claim on my behalf?

2. Can the compensation from a Delay Repay claim be paid into someone else’s bank account and then transferred to me later?

3. Are there any third-party companies or services that manage Delay Repay claims on your behalf?



Really appreciate any help with this — thanks a lot in advance!

 

[saismee]

As for question 2: According to the National Rail Conditions of Travel 29.4, it can only be paid into the account used to purchase the ticket if paid for by card. With cash it states it can be repaid into "your bank account" which implies that someone else cannot receive it.

Your Rights and Obligations as a Passenger | National Rail

When you buy a train ticket to travel on the rail network, you enter into an agreement with the train companies. Find out about your rights and obligations as a passenger, and how to get more information.

www.nationalrail.co.uk

 

[ethp2000]

Hi Saismee, thanks for your response. National Rail Conditions 29.4 specifically applies to “Refunds on Tickets Which You Have Chosen Not to Use or Have Been Part-used,” right? That wouldn’t cover Delay Repay compensation, which applies when you have used your ticket but were delayed in reaching your final destination.





So, do you know if this would still apply, given that Delay Repay is a different process from the one used when requesting a refund directly from the retailer you bought your ticket from?





Also, do you happen to know anything about my first or third question?

 

[ethp2000]

Hi, I had a quick question about Delay Repay Law in the UK. If I use my Delay Repay account to claim compensation for someone else’s ticket — with their permission, entering their correct passenger and journey details, and then send them the money — is that allowed, or could it make me liable for prosecution?

 

[saismee]

Hi Saismee, thanks for your response. National Rail Conditions 29.4 specifically applies to “Refunds on Tickets Which You Have Chosen Not to Use or Have Been Part-used,” right? That wouldn’t cover Delay Repay compensation, which applies when you have used your ticket but were delayed in reaching your final destination.

So, do you know if this would still apply, given that Delay Repay is a different process from the one used when requesting a refund directly from the retailer you bought your ticket from?

Whoops! Cited the wrong section. The refund methods apply similarly as stated in 30.4.

I do not know anything about your first or third questions. I would imagine it is possible for someone else or a company to manage it, but I don't believe it is based on what I have read. Someone more knowledgeable will have to clarify that for you.

 

[minderbinder]

Hi, I had a quick question about Delay Repay Law in the UK. If I use my Delay Repay account to claim compensation for someone else’s ticket — with their permission, entering their correct passenger and journey details, and then send them the money — is that allowed, or could it make me liable for prosecution?

The Thameslink t&cs, for example, state that “claims must be made by the person who experienced the delay except under mitigating circumstances.”

(Claiming for a child or elderly relative is mentioned)

 

[redreni]

The right to be compensated for a delay is, per the NRCoT, enjoyed by "you". We know from page 3 that this means the passenger:

NRCoT, page 3:

The key responsibilities of passengers (‘you’) are: [...]

So I would say if somebody other than the passenger claims delay repay, they are not entitled to it. If they were doing it with the knowledge and consent of the passenger and they passed on any monies received to the passenger, then I doubt anybody would notice or mind.

 

[ethp2000]

Hi minderbinder, thanks for the response! Yeah, that’s true — Govia Thameslink specifically says third-party claims aren’t allowed except in mitigating circumstances, as stated in their passenger charter. CrossCountry, on the other hand, says: “We accept claims made by a third party as long as they are made in the name of the claiming passenger.”



As for Avanti, LNER, GWR, Southern, and most of the other TOCs, they don’t explicitly say that third-party claims are not allowed — they just mention that passengers are responsible for submitting claims. That makes me think they’re referring more to the fact that they don’t automatically reimburse passengers, rather than outright prohibiting third-party submissions.



So, do you think it’s safe to assume that third-party claims might be accepted by those TOCs as long as the correct passenger and journey details are provided? Or is it more of a grey area?

 

[zwk500]

Hi, I’m currently looking into Delay Repay in the UK and had a few questions I was hoping someone could help with:

1. Is it possible for a third party to submit a Delay Repay claim on my behalf?

2. Can the compensation from a Delay Repay claim be paid into someone else’s bank account and then transferred to me later?

3. Are there any third-party companies or services that manage Delay Repay claims on your behalf?



Really appreciate any help with this — thanks a lot in advance!

I'm not sure quite what your motivation would be to get a company to handle this. Delay Repay claims are free to submit and your receive the compensation as set out by the delay bands and ticket types. Further, Delay Repay claims must be submitted within 28 days so the volume of claims that could be submitted at any one time seems limited to make it worth paying some level of fee for somebody else to handle it.

Out of curiosity I checked Greater Anglia and Thameslink's websites (the two main operators serving Cambridge), and Thameslink explicitly say the claim must be made by the traveller unless there are exceptional circumstances:

Please note that each individual traveller must submit their own delay repay claim (unless it is for a child or under mitigating circumstances - please review our Frequently Asked Questions (FAQs) on this page for more information. If you submit multiple claims for the same journey these will be declined and will add a delay to you receiving any compensation due.

GA did not appear to mention third party claims at all.

 

[Adam Williams]

I'm not sure quite what your motivation would be to get a company to handle this

I think wanting your retailer to do it for you, instead of having to waste copious amounts of time re-typing in journey details and uploading E-Tickets, would be quite reasonable.

I would stress that there are probably more technical constraints here than non-technical ones, such as CAPTCHAs and other "bot detection" measures.

 

[ethp2000]

Whoops! Cited the wrong section. The refund methods apply similarly as stated in 30.4.

I do not know anything about your first or third questions. I would imagine it is possible for someone else or a company to manage it, but I don't believe it is based on what I have read. Someone more knowledgeable will have to clarify that for you.

Thanks for your response, saismee — really appreciate you taking the time to clarify that! That makes sense about the refund conditions.

== Doublepost prevention - post automatically merged: 10 Apr 2025 ==

The right to be compensated for a delay is, per the NRCoT, enjoyed by "you". We know from page 3 that this means the passenger:

NRCoT, page 3:

So I would say if somebody other than the passenger claims delay repay, they are not entitled to it. If they were doing it with the knowledge and consent of the passenger and they passed on any monies received to the passenger, then I doubt anybody would notice or mind.

Yeah, that’s a good point — I agree. I just feel like, since the passenger is technically the one entitled to the compensation, a third party can take that responsibility to make sure the claim is made properly on their behalf. And of course, I’d only ever do this with the full consent and knowledge of the passenger in question. I just wasn’t sure if the TOC would flag it as potential fraud, even if everything is done transparently.

== Doublepost prevention - post automatically merged: 10 Apr 2025 ==

Hi zwk500, thanks for the response!

I guess the motivation behind this is that the Delay Repay process can be quite tedious. It requires a good understanding of the system — especially when it comes to things like split tickets — and the process isn’t centralised, meaning you often have to contact multiple TOCs directly. For smaller, cheaper journeys, it’s often not worth the time and effort to make a claim, which is probably why around 50% of eligible passengers don’t submit Delay Repay claims.

Also, yeah, it’s true — Govia Thameslink explicitly says third-party claims aren’t allowed except in mitigating circumstances, according to their passenger charter. CrossCountry, on the other hand, says: “We accept claims made by a third party as long as they are made in the name of the claiming passenger.”

As for Avanti, LNER, GWR, Southern, and most of the other TOCs, they don’t specifically say third-party claims are prohibited — they just note that passengers are responsible for submitting claims. That seems to suggest they’re referring more to the fact that claims aren’t automatic, rather than outright banning third-party submissions.

So do you think it’s fair to assume that third-party claims might be accepted by those TOCs, as long as the correct passenger and journey details are provided? Or is it still a bit of a grey area?

== Doublepost prevention - post automatically merged: 10 Apr 2025 ==

I think wanting your retailer to do it for you, instead of having to waste copious amounts of time re-typing in journey details and uploading E-Tickets, would be quite reasonable.

I would stress that there are probably more technical constraints here than non-technical ones, such as CAPTCHAs and other "bot detection" measures.

Hi Adam, thanks for the response!



Yeah, that’s true — technical constraints like CAPTCHAs and bot detection are definitely a challenge. But I do think they could be worked around with the right approach, especially if done carefully and within the rules. I’m just wondering whether making third-party claims is actually within the TOCs’ guidelines — that’s the bit I’m still unsure about.

 

[redreni]

For me (and I'm not necessarily a good bellwether for what demand might or might not be out there), I would only be willing to farm out delay repay to a third party if they were actually going to get me the compensation to which I was entitled even if the TOC initially refuses the claim for one spurious reason or another.

While it is probably true that a great many rejections occur because the passenger did something wrong when they submitted their claim, I would not assume that introducing a third party into the mix would solve that problem, as the third party would be reliant on information provided by the passenger.

If the third party is only going to do the straightforward claims, then I struggle to see what value it is adding. That type of claim is already easy.

 

[saismee]

While it is probably true that a great many rejections occur because the passenger did something wrong when they submitted their claim, I would not assume that introducing a third party into the mix would solve that problem, as the third party would be reliant on information provided by the passenger.

Unless the retailer managed it, like what @Adam Williams mentioned. Though I doubt any retailer would bother with the hurdles unless they got a cut of the repayment. The DfT (or RDG? I'm not sure here) would never approve that.

On a side note: I hate posting from mobile! Text editing is awful.

 

[redreni]

Unless thr retailer managed it, like what @Adam Williams mentioned. Though I doubt any retailer would bother with the hurdles unless they got a cut of the repayment. The DfT (or RDG? I'm not sure here) would never approve that.

On a side note: I hate posting from mobile! Text editing is awful.

If I buy a flexible ticket from a retailer against a particular itinerary and that journey is delayed, the retailer doesn't know if I attempted to travel according to that itinerary or if I changed my plans between booking and travelling (taking advantage of the flexibility of the ticket I had bought). So they don't know whether or to what extent I might be entitled to delay repay unless I tell them.

Even if my booking is advances tied to a specific train and that train arrives late, the retailer doesn't know if I travelled unless I tell them. Unless the retailer and the TOC are one and the same, in which case they may know from scan data that the passenger travelled, but there are already auto delay repay schemes for that scenario.

 

[Watershed]

I don't see anything in the NRCoT which excludes Delay Repay claims from being brought by agents acting on behalf of the passenger. Individual Passenger's Charters might contain such restrictions; arguably, these could be enforceable to the extent they apply to compensation that is less than the NRCoT minimum (50% of a single/25% of a return for a 60+ minute delay).

 

[Mike395]

About a decade ago, and before most TOCs realised that donating Delay Repay to charity was a good thing to offer, I toyed with the idea of having a charity Delay Repay portal doing exactly this - essentially claiming the DR on the traveller's behalf and sending it on, with Gift Aid, to the nominated charities on a regular basis.

The attitude then when I asked the TOCs was 'no, you'd be breaching all sorts of terms, don't even think about it' - I don't think that mindset would have changed in any substantial way and personally wouldn't want to try it now.

 

[30907]

Am I wrong in assuming that the OP, located in hi-tech "Cambridge, Englamd,UK" is exploring a business opportunity? Not that they are wrong to do so, I'm just curious

 

[Hadders]

A few years ago there were several websites were about offering to submit delay repay claims on passengers behalf. They all seem to have disappeared.

 

[Gonzoiku]

Am I wrong in assuming that the OP, located in hi-tech "Cambridge, Englamd,UK" is exploring a business opportunity? Not that they are wrong to do so, I'm just curious

You might well be, but you would not be alone in your assumption!

GZ

 

[Mike395]

A few years ago there were several websites were about offering to submit delay repay claims on passengers behalf. They all seem to have disappeared.

I'm not surprised if the reaction to a commercial venture was equal or worse than to the nonprofit I was trying to start!

 

[Tram203]

A few years ago there were several websites were about offering to submit delay repay claims on passengers behalf. They all seem to have disappeared.

I'd have thought these would be potentially letting themselves in for more hassle than any gains they may make would be worth.

Theoretical example;

"We are Delay Repay Direct. Free yourself of the hassle of claiming compensation for delayed train journeys. Simply send us your tickets and journey details along with your bank details, and let us do the rest".

"If you are due compensation of £25 or under, we will take £5. £25.01-£50, we will take £10. £50.01 or above, we will take £15".

Sounds simple on the face of it, but the mind boggles at the amount of to-ing and fro-ing that would be needed with the passenger if TOC-A rejected a claim for reason A, TOC-B rejected a claim for reason B, etc etc.

Not to mention of course any legal considerations that Delay Repay Direct (other company names are available) may have to adhere to.

 

[Haywain]

"We are Delay Repay Direct. Free yourself of the hassle of claiming compensation for delayed train journeys. Simply send us your tickets and journey details along with your bank details, and let us do the rest".

So, to claim DR I'd fill in a web form, hit submit and wait for the claim to be approved. I don't get why I would do that through a third party when I can do it directly. And if the full compensation is being passed back what is in it for the third party, apart from the hassle of dealing with dodgy claims or inaccurate information?

 

[redreni]

So, to claim DR I'd fill in a web form, hit submit and wait for the claim to be approved. I don't get why I would do that through a third party when I can do it directly. And if the full compensation is being passed back what is in it for the third party, apart from the hassle of dealing with dodgy claims or inaccurate information?

Happy to be corrected, but it sounds like the idea is that the third party has access to the retailer's info on the ticket and itinerary sold, assumes the passenger travelled on that itinerary, makes a series of further assumptions such as that they wouldn't have made any tight connections below the MCT, then submits the claim without troubling the passenger.

Personally I wouldn't be happy with that if I were a TOC. Most people don't claim if they didn't travel. Most people don't claim if their first train was delayed but they made a tight connection and arrived at their destination on time. If they do, maybe the TOC will detect that and maybe it won't, but the fact most people don't lie is one of the protections against paying out for delays that did not occur.

Some people don't travel on the itinerary they selected when they bought their tickets.

I don't see how you can claim on somebody's behalf without checking with them that they were actually delayed?

 

[ethp2000]

Hi all, thanks for all the responses — they’ve been really helpful!


Yes, you're right in assuming that I’m in the process of developing a business that facilitates Delay Repay claims. Due to competitive reasons, I can’t publicly disclose the full details of how the functionality works, but I can say that the concept significantly reduces the amount of user input required to submit a claim — it’s dramatically more streamlined than the current web forms.


My main concern — now that I’ve made substantial progress — is whether this is legally permitted under the TOCs’ passenger charters. From my research so far, only Govia Thameslink explicitly prohibits third-party claims (except in mitigating circumstances), while CrossCountry states that third-party claims are allowed as long as they’re made in the name of the claiming passenger. As far as I can tell, the other TOCs don’t specifically mention third-party claims at all.


So that’s really the crux of my question: does anyone know whether third-party claims are generally permitted across most TOCs? I’m not concerned about whether people would use the service or whether the process is technically feasible — I just want to ensure full legal compliance.


Thanks for any insights!

 

[Haywain]

If you are looking to do this as a business you would be well advised to take professional legal advice on the legality of what you are planning on doing. The TOCs will have no hesitation in treating you as a business rather than an individual if they feel that you are doing anything illegal.

 

[ethp2000]

If you are looking to do this as a business you would be well advised to take professional legal advice on the legality of what you are planning on doing. The TOCs will have no hesitation in treating you as a business rather than an individual if they feel that you are doing anything illegal.

Thanks for the advice — I appreciate it. Do you happen to know if there are any lawyers or legal professionals active on this forum that I could contact for some initial guidance?

 

[Haywain]

Thanks for the advice — I appreciate it. Do you happen to know if there are any lawyers or legal professionals active on this forum that I could contact for some initial guidance?

There are some legal professionals who post here but you need to be aware that the law is a wide field and a you need appropriate advice in, I suspect, commercial law.

 

[talldave]

A few years ago there were several websites were about offering to submit delay repay claims on passengers behalf. They all seem to have disappeared.

My first line of enquiry would be to find out why they all vanished. If it was a viable business they'd still be operating.

 

[Watershed]

My first line of enquiry would be to find out why they all vanished. If it was a viable business they'd still be operating.

Quite. I wouldn't be surprised if they were effectively forced out of business through "cease and desist" notices, or even just changes to the forms which made it impracticable to submit them en-masse, such as Captchas.

It did seem like a viable business model in principle - indeed, going back nearly 10 years I remember having a subscription to one such service, so that I could more easily submit Delay Repay claims for the frequently missed connections on my commute.

 

[ethp2000]

Yes, the cease and desist aspect is definitely one of the things I’m most concerned about — and it’s exactly what I’m trying to get to the heart of before progressing further. From a technical perspective, those things aren't really an issue for me, but if there’s a legal precedent for TOCs pushing similar services out through formal action, that’s something I’d need to seriously consider.