Bus Accessibility Under UN Regulation 107

Bus accessibility under UN Regulation No. 107 is a class split, not one standard for all buses: Annex 8 is compulsory for Class I vehicles, while for every other class the regulation leaves the choice of approach to Contracting Parties and binds Annex 8 on any accessibility feature actually fitted.

The class split decides everything

Paragraph 2.1.1 divides vehicles with a capacity exceeding 22 passengers in addition to the driver into three classes: Class I, constructed with areas for standing passengers to allow frequent movement; Class II, constructed principally for seated passengers and designed to allow standing passengers in the gangway and/or in an area which does not exceed the space provided for two double seats; Class III, exclusively for seated passengers. At 22 passengers or fewer in addition to the driver, paragraph 2.1.2 gives Class A, designed to carry standing passengers, and Class B, which is not.

Paragraph 5.2 requires Class I vehicles to be accessible for people with reduced mobility, including at least one wheelchair user and one unfolded pram or pushchair, according to Annex 8. Paragraph 5.3 covers the rest: Contracting Parties are free to choose the most appropriate solution for other classes, but features or devices for people with reduced mobility fitted to such a vehicle must comply with the relevant Annex 8 requirements. Paragraph 5.4 lets national authorities reserve certain operations for Annex 8-equipped vehicles. The discretion belongs to the state, not the manufacturer or the operator.

Low-floor is defined in the regulation; low-entry is not

Paragraph 2.1.4 defines a low-floor vehicle as one of Class I, II or A in which at least 35 per cent of the area available for standing passengers — its forward section in an articulated vehicle, its lower deck in a double-decker — forms an area without steps and includes access to at least one service door. A Class III coach falls outside it because 2.1.4 names only Classes I, II and A; having no standing area to measure follows from the class, it is not the test.

The term low-entry appears nowhere in the regulation. The bodywork concept recorded at type approval under paragraph 2.2.1(d) is single/double-deck, articulated, low-floor, with no fourth option. Low-entry describes a step-free front with steps up to a raised rear floor over the driveline; in regulatory terms it either passes the 35 per cent test or it does not.

Step heights and the kneeling function

Annex 8 paragraph 3.1 sets the first step from the ground of at least one service door at not more than 250 mm for Classes I and A and 320 mm for Classes II, III and B; as an alternative for Classes I and A it shall not exceed 270 mm in two door openings, one entrance and one exit. Steps in the access passage at those doors, and throughout the gangway, are limited to 200 mm for Classes I and A and 250 mm for Classes II, III and B.

The same paragraph separates layouts: in low-floor vehicles only a kneeling system, and not a retractable step, may be engaged to reach those figures; in other vehicles either may be. Paragraph 2.31 defines kneeling as a system which lowers and lifts totally or partially the body of a vehicle relative to the normal position of travel, and 3.11.2.4 caps driving at 5 km/h while the vehicle is lower than normal travel height.

MAN gives the City version of the Lion’s Intercity LE, on 275/70 R22.5 tyres, an entry height of 320 mm with a platformless low-floor area; the intercity version, on 295/80 R22.5 tyres, 380 mm. Tyre choice alone moves entry height by 60 mm, almost the whole 70 mm gap between the 250 mm Class I and 320 mm Class II first-step limits. These are manufacturer entry heights, not the R107 first-step height, which paragraph 5.5 measures at mass in running order with any kneeling system at normal ride height.

Ramps and lifts

Paragraph 3.11.4.1.3 carries two modal verbs. The useable surface of a ramp shall be at least 800 mm wide; the slope, extended onto a kerb of 150 mm in height, should not exceed 12 per cent, and extended to the ground should not exceed 36 per cent, with a kneeling system permitted to achieve the test. The load figure is a shall: under 3.11.4.1.5 any ramp shall be capable of operating safely with a load of 300 kg. Under 3.11.3.1.2 a lift platform shall be not less than 800 mm wide and 1 200 mm long and carry at least 300 kg; under 3.11.1.2 lifts and ramps shall be capable of manual operation if power fails.

Wheelchair space and priority seats

Paragraph 3.6.1 requires, for each wheelchair user provided for, a special area at least 750 mm wide, 1 300 mm long and 1 400 mm high, slip-resistant, with a slope not exceeding 5 per cent fore and aft and 3 per cent laterally. The limits are not absolute: they may be exceeded at the rear of the area where differently directed slopes merge, provided such areas total no more than 25 per cent of the wheelchair area, and a rearward-facing wheelchair complying with 3.8.4 may sit on up to 8 per cent longitudinally where the slope inclines upwards front to rear.

The reference wheelchair in Annex 4 Figure 21 is 1 200 mm long, 700 mm wide and 1 090 mm high, and 3.6.4 requires a wheelchair user to move freely and easily from outside the vehicle into the special area with it: space to manoeuvre without assistance, and no steps, gaps or stanchions in the way. In Class I at least one wheelchair access door must be a service door bearing a lift or ramp, and wheelchair access doors must be at least 900 mm wide, reducible by 100 mm at handhold level.

Priority seat counts sit in Annex 3 paragraph 7.7.8.5.3: four in Class I, two in Class II, one in Class A, and two and one where Class III and Class B vehicles are subject to Annex 8. Annex 8 paragraph 3.2.6.1 puts the foot space at a priority seating position in Classes I and A level with the adjacent gangway, but 3.2.6.2 limits that, for Class I vehicles not exceeding 2.35 m in width, to two of the required positions; the rest need only a vertical distance to the gangway of not more than 250 mm.

Why Class III coaches sit outside the mandate

A Class III coach carries seated passengers only and is not reached by the paragraph 5.2 mandate. What remains is 5.3, binding on any accessibility equipment actually fitted, and 5.4.

In Great Britain the duty is older than the dates usually quoted. Under the Public Service Vehicles Accessibility Regulations 2000, a single-deck bus over 7.5 tonnes in use on or after 31 December 2000 required a certificate relating to Schedules 1 and 2 (reg 3(2)); a double-deck bus the same from the same date, with no weight threshold (reg 3(5)); a coach a Schedule 3 certificate from 31 December 2000 (reg 3(6)) and a Schedule 1 certificate from 1 January 2005 (reg 3(7)). Single-deck buses of 7.5 tonnes or less fall under reg 3(3) and 3(4), backstop 1 January 2015. The familiar 1 January 2016, 2017 and 2020 are not start dates but end-dates for the pre-existing fleet. And reg 3(9)(b) confines the regime: in use means used to provide a local service or a scheduled service, so PSVAR reaches a coach on scheduled work and not on private hire or tour work.

Regulation (EU) No 181/2011 is EU law; in Great Britain it survives as assimilated direct legislation amended on exit, S.I. 2019/141 having inserted “in the United Kingdom or” into the Article 2(1) scope test. Article 2(1) applies the regime to regular services with a scheduled distance of 250 km or more. Article 9 prohibits refusing a reservation, ticket or boarding on grounds of disability or reduced mobility — but Article 10 permits refusal to meet applicable safety requirements set by international, Union or national law, or where the design of the vehicle or the infrastructure, bus stops and terminals included, makes boarding, alighting or carriage physically impossible in a safe and operationally feasible manner. Article 10(2) then requires the carrier to inform the person of any acceptable alternative service, and 10(3) gives a refused ticket-holder the choice of reimbursement or re-routing. Article 13(1) requires free assistance at designated terminals, conditional under 14(1)(a) on notification at least 36 hours beforehand.

Choosing the floor type by route

Annex 11 counts each wheelchair space as 250 kg, and Annex 3 paragraphs 7.2.2.2.9 and 7.2.2.2.10 take it out of the standing area once occupied or dedicated: a 750 by 1 300 mm space is 0.975 m², or 7.8 places at the 0.125 m² conventional standing space of Classes I and A.

For dense urban stopping work with kerbed stops, the answer is a Class I low-floor vehicle with a ramp at a wheelchair service door, built to the 250 mm first-step and 200 mm gangway-step limits. For suburban and regional work with mixed kerb heights, the low-entry layout trades a step-free rear for seats and luggage volume, and the 35 per cent test decides whether a retractable step may be engaged to reach the step-height figures or whether only kneeling will do. For long-distance and charter work Class III carries no R107 mandate, but any boarding device fitted must meet Annex 8 in full, and PSVAR attaches once the vehicle takes scheduled work.

One date belongs in any current specification: under paragraph 10.36, from 1 September 2027 Contracting Parties are not obliged to accept type approvals to any preceding series of amendments first issued after that date, while 10.37 requires them to accept 10-series approvals first issued before 1 September 2027 until 1 September 2030.

The Department for Transport recorded 30,558 buses used by local bus operators in England as at March 2025, 99 per cent of them issued with an accessibility certificate. For urban buses the construction question is largely settled; what remains open is ramp reliability, kerb height at the stop, and whether the coach fleet can lawfully take scheduled work.