Organisation-of-public-transport-follow-up-audit-of-county-public-transport.pdf

24th Jun 2026

Organisation of public
transport (follow – up
audit of county public
transport)

Does county public transport form a whole with the remaining transport
network and has the service been developed efficiently and in consideration
of people’s mobility needs?

Report of the National Audit Office to the Riigikogu
Tallinn, 13 October 2025

Organisation of public transport (follow -up audit of county public transport)
1 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025

Summary
The Ministry of Regional Affairs and Agriculture has not managed
the area of public transport in a manner that proceeds from the
actual mobility needs of people. County public transport is not
integrated with the rest of the transport network and there is also
no single ticketing system. The Ministry of Regional Affairs and
Agriculture has not set standards for public transport service
levels, which define the level of connections that must be
guaranteed with existing funding – below which the frequency of
departures and connections must not fall.
According to public transport satisfaction surveys, the main bottleneck
for people in public transport is that the timetables do not meet their
needs. 1 This means that the timetable is too infrequent, the departure
times or the route are not suitable. Although the national goal has been
to increase the number of people using public transport, the data of
Statistics Estonia show that the use of public tra nsport by commuters
has been declining over the past decade.
Considering the needs of the people who already use county bus
services is not enough to get more people to use public transport.
Although more research is being done on the patterns of people’s actual
movements than in the past, few public transport centres have identified
the needs of those who do not use public transport. Analysing mobility
patterns throughout Estonia using, for example, mobile positioning or
traffic counting data, would help plan a more efficient public transport
system and increase the number of public transport users.
Timetables that integrate the different modes of transport into a
coherent whole would allow shorter waiting times and make
transfers more convenient, which would make public transport
more competitive, but the Ministry of Regional Affairs and
Agriculture has not managed to coordinate public transport
nationwide. The current bus route network and timetable planning
tends to be focus on single counties and does not support inter -county
and intermodal mobility. The analysis of the routes selected by the
National Audit Office showed that the average waiting time for transfers
was 26.5 minutes and sometimes reached an hour.
The need for a single nationwide ticketing system has been talked about
for years, but so far it has not been created. The connection of the
timetables of different modes of transport (county, long -distance and
local bus services, planes, ferries, trains) should be centrally
1 Source: The survey “Nationwide satisfaction of residents with the living environment
and the public services of local authorities” commissioned by the Ministry of Regional
Affairs and Agriculture in 2024.
Did you know that…
since 1 July 2023, the
management of public
transport is a responsibility of
the Ministry of Regional
Affairs and Agriculture; before
that, the Ministry of Economic
Affairs and Communications
was responsible for the area.
Public transport centre – a
non -profit association jointly
established and financed by
local authorities (except
Saaremaa Municipality
Government and Hiiumaa
Municipality Government) and
the state, to which the
founders may delegate
relevant tasks with an
administrative contract,
based on the need for a more
efficient organisation of
regional public transport.
In Saaremaa and Hiiumaa,
county public transport is
organised by the local
authorities. In the report,
public transport centres
include Saaremaa and
Hiiumaa Municipality
Governments.
Source: Public Transport Act, § 15
(1) and (2)

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 2
coordinated. At present, the timetables are prepared on different
grounds and within the competences given to the organiser , leading to
fragmentation and inconsistencies between timetables. Changing
modes of travel would be made easier by light traffic paths and car
parks, but usually there are none near bus stops.
Creating a route network that better meets people’s needs is
difficult to achieve, as the current funding arrangements do not
ensure that the route network can be maintained even at the
current level, as funding the obligations assumed with public
transpor t contracts is already a struggle. In 2024, the state
subsidised the transport of passengers by public transport with €148.5
million in total: €72 million was spent on bus services, €40.8 million on
rail transport, €28.7 million on ferry routes and €7 mill ion on air routes.
The public transport subsidy has increased year on year and the forecast
of the Ministry of Regional Affairs and Agriculture shows that the need
for support of all modes of transport continues growing.
For years, less money has been allocated for public transport from the
state budget to the basic budget of the Ministry of Regional Affairs and
Agriculture, i.e. the starting point of budgeting, for covering the fixed
costs and liabilities of the Ministry than is necessary for the
performance of the obligations assumed with contracts, although the
necessary amounts have largely been known at the time the state
budget is planned. In the last four years, an additional €83.7 million has
been allocated from the reserve fund of the Government of the Republic
to cover the deficit in the core public transport budget.
The draft of the 2026 State Budget Act is being discussed in the
Riigikogu at the time of publication of the report. The draft includes
plans to increase the support for public transport in the budget of the
Ministry of Regional Affairs and Agriculture in comparison to previous
years in order to fund the obligations assumed with contracts.
As the current size of the basic budget of the Ministry of Regional
Affairs and Agriculture meant for funding public transport is not
sufficient to allow providing the service at the same level in the
coming years, the Ministry must establish, taking into account the
money available for use, what kind of service the state wants and
can provide at all, and develop solutions for a more efficient
organisation of county bus transport. The Ministry explained that the
large gap between the revenues and costs of p ublic transport can mainly
be reduced by reducing the volume of public services, i.e. by shortening
routes, reducing frequencies, closing routes or raising the fares.
Reserve fund of the
Government of the Republic –
resource of money from which
allocations are made only for
expenditure and investments
that could not have been
foreseen when the state
budget was prepared, and for
financing the specific
activities approved by the
Government of the Republic.
Source: Government of the
Republic Regulation No 123
“Procedure for allocation of funds
from the reserve fund of the
Government of the Republic and
for use of allocated funds”, § 1

Organisation of public transport (follow -up audit of county public transport)
3 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
In order to better plan and justify costs and revenues, it is important for
the Ministry of Regional Affairs and Agriculture to clearly define at the
legislative level what service the state expects for the money allocated
to public transport and in which cases maintaining a route should be
considered unreasonably expensive and to offer people demand -based
transport , for example. The low and unclear funding of public transport
does not allow the Ministry of Regional Affairs and Agriculture and
public transp ort centres to plan the maintenance of the current network
or develop public transport in the longer term.
The organisation of public transport still includes duplication of tasks,
such as accounting, the organisation of procurement, data collection
and the commissioning of studies. The clear definition of
responsibilities is also made more complicated by the institutional
frag mentation of the planning of public transport infrastructure .
The classification of bus services is not clear. The Public Transport
Act does not make it clear which routes – county, long -distance or
municipal – must be managed and financed by the state and which by
the local authority. The concept of an on -demand or demand -responsive
bus service is not mentioned i n law at all. It should be clear to all
parties, in a manner that can be legally interpreted, who must manage
route transport and what it must be like, who must pay for certain routes
and in which cases the s ervice must be provided by county or local bus
services.
The tasks of public transport organise rs overlap and responsibility
is fragmented. There is duplication of tasks in the management of
public transport, including in the provision of supporting services, data
collection and commissioning of studies. The clear definition of
responsibilities is also made more complicated by the institutiona l
fragmentation of the organisation of public transport, particularly in the
planning of public transport infrastructure , which is a task of the areas
of government of the M inistry of Regional Affairs and Agriculture and
the Ministry of Climate at the same time.
Recommendations of the National Audit Office to the
Minister of Regional Affairs and Agriculture:
• develop a procedure for sharing data with public transport centres in
order to study the mobility needs of people who use public transport
as well as those who do not; and set up a nationwide system to
coordinate all modes of transport (including ferries, planes, trains,
county and local bus transport);
• establish standards for the level of service of public transport and to
set uniform principles for the financing of the route network based
on service levels, including the limits in the case of which
maintaining a route is unreasonably expensive;
Demand -responsive transport
(DRT) – the National Audit
Office defines demand –
responsive bus transport as
transport without a regular
route or timetable.
Public transport infrastructure
– a bus or railway station, port,
passenger terminal, quay,
platform, shelter, stop,
information or communication
system and other route
facilities and equipment and
the fixtures and fittings
intended or necessary for their
operation.
Light traffic paths and car
parks are built to improve
accessibility and facilitate
transfers and are not included
in public transport
infrastructure.
Source: Public Transport Act,
§ 11 (1)

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 4
• agree, in cooperation with local authorities, on the unambiguous
content and distribution of county bus, long -distance, local authority
and on -demand services, and on the principles of financing.
Response of the Minister of Regional Affairs and Agriculture: All in
all, the Ministry of Regional Affairs and Agriculture welcomes the
recommendations made by the National Audit Office and considers that
the audit of the organisa tion of public transport supports the resolution
of the problems raised by the public transport reform initiated by the
Ministry in 2024.
The Ministry of Regional Affairs and Agriculture does not consider it
necessary to develop a separate procedure for data sharing, as it has
provided public transport centres with a practical solution in the form of
a web -based software for analysing the ro ute network, which can display
relevant statistics and mobility data in different layers of maps to assess
the impact of route network changes. The report on the use of stops,
based on validation data from county routes, will be ready for use by
public tra nsport centres in the near future. The Ministry will then
continue to analyse other indicators based on the validation data, using
the Power BI tool, which helps study the available data dynamically and
better assess the feasibility of the routes.
The development of service level standards is underway and a single
network of routes is already being developed as part of the mobility
reform. It is planned to change the definitions of routes and services
with an amendment to the Public Transport Act in order to divide
responsibility and funding principles more clearly.

Organisation of public transport (follow -up audit of county public transport)
5 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
Contents
Trends in public transport development 6
The management of public transport does not guarantee a service that meets people’s
expectations 11
The mobility needs of people who have not yet used buses for their journeys have generally
not been studied or taken into account in the management of county bus transport 12
It is difficult to coordinate the timetables of different modes of public transport because
there is no central coordination 16
The lack of the necessary infrastructure (e.g. car parks) and of a single ticketing system
makes the journeys with transfers inconvenient 21
The Ministry of Regional Affairs and Agriculture has not set standards for public transport
services or common rules for their management 26
In order to develop public transport, the Ministry of Regional Affairs and Agriculture must
define the services that the state is prepared to ensure 27
The Ministry of Regional Affairs and Agriculture has not developed public transport
sustainably 30
Responsibility in the management of public transport is fragmented and there is overlap in
the performance of tasks 36
There is an overlap of tasks in public transport management and no clear legal basis for
the allocation of some of these tasks 36
Supervision of public transport centres is obstructed by a lack of clarity on the content of
tasks in contracts and funding applications 45
Recommendations made by National Audit Office and responses of the auditees 49
Characterisation of audit 56
Earlier audits of National Audit Office in the area of public transport 60
Annex A. Main observations of the 2021 audit on county public transport and their
implementation 61
Annex B. Summary of the survey National Audit Office 63
Annex C. Place of residence and place of work of employed persons by region 66

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 6
Trends in public transport development
1. The goal set in the Transport and Mobility Development Plan 2021 –
2035 is to increase the share of commuters who use public transport,
cycle and walk to 55% by 2035.
2. The audit “County Public Transport” published in 2021 showed that
the share of commuters using public transport among all commuters
had not increase d. The situation has not improved.
3. Despite the introduction of free transport on public county bus
services from 2019 –2024, there has not been a significant increase in
the use of sustainable transport among commuters. Although the share
of commuting by public transport, walking and cycling increased slightly
in 2024 compared to the previous year, the increase was due to a
decrease in the share of remote working, not a decrease in car use, and
thus the trend of car ownership and use will continue (see Figure 1).
Figure 1. Share of sustainable mobility and car users (%) of all
commuters, 2015 –2024

Source: Employed people by gender and manners of commuting. Statistics Estonia TT230, 2024
4. According to Statistics Estonia, the share of public transport users
has been on a downward trend over the last decade. Due to the COVID –
19 crisis, the use of public transport was severely restricted in the period
2020 –2021 and the number of users fell fur ther. To date, the number of
people using public transport has not reached the pre -crisis levels.
5. In 2018, free bus travel was established for all residents in most
counties. As of January 2024 2, a fare for working -age people was
2 In Põlva and Võru County, working -age people had to start paying for tickets a couple
of months later than in other countries, i.e. from April 2024, due to the change of carrier.
42,5 40,2 38,9 38,5 38,7 36,9 34 34,3 34,9 35,1
21,9 20,9 20 20,7 20,6 18,4 15,9 16,9 17,8 18,3
53 54,9 55,9 56,5 56,1 57,1 57,4 58,1 59 59,1
0
10
20
30
40
50
60
70
2015 2016 2017 2018 2019 2020 2021 2022 2023 2024
Sustainable modes of transport (public transport/on foot/by
bicycle/by moped)
including public transport (bus, ship, plane, train)
Car
Goals of the
development plan and
their achievement
Did you know that…
The traffic count data of the
Transport Administration for
2024 show that overall traffic
volumes have increased by
8.4% compared to 2020.
Source: Teede Tehnokeskus AS,
traffic count results in 2024.

Organisation of public transport (follow -up audit of county public transport)
7 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
established on county bus services. Pupils, people over 63 years of age,
people with partial or no capacity for work and disabled people can still
travel free of charge across Estonia.
6. Transfer of responsibility for organizing public transport . A significant
management change occurred in the public transport policy and
oranisation in 2023. At the implementation level, the task of organi sing
national public transport (excluding infrastructure) was transferred from
the Transport Administration and the task of organi sing passenger
transport by rail was transferred from the Ministry of Economic Affairs
and Communications to the Ministry of Regional Affairs and Agriculture.
7. At the policy -making level, the development of national public
transport policy moved from the Ministry of Economic Affairs and
Communications to the area of government of the Ministry of Regional
Affairs and Agriculture. Investments in public transport in frastructure
and international public transport policy became the responsibility of
the area of government of the Ministry of Climate.
8. An analyst, support staff and supervision specialists engaged in the
organisation of public transport still work at the Transport
Administration after the change made in 2023. All policy -making
competences concerning public transport, including national and
international public transport, which were in the Ministry of Economic
Affairs a nd Communications, are in the Ministry of Climate since 2023
and were not transferred with the tasks to the Ministry of Regional
Affairs and Agriculture.
9. According to the Ministry of Climate, the Ministry of Economic Affairs
and Communications did not have any officials working full -time on
tasks related to public transport. Tasks in the area of public transport
were divided between different officials who also had to perform tasks
related to other areas.
10. According to the Ministry of Climate, the officials who moved from
the Transport Administration to the Ministry of Regional Affairs and
Agriculture had sufficient policy -making competence (except in the area
of railways), as they were also involved in poli cy discussions.
11. Tasks related to the organisation of procurement of regular services
under public service contracts in public transport and the management
of contracts are currently the responsibility of both the implementation
and policy -making levels.
12. Whilst the contracting partners for the public service contracts for
route transport (excluding railway) since 2021 were carriers on one side
and implementation level authorities, such as the Transport
Administration and public transport centres, on the other side, it was
decided to bring the organisation of procurement and the management

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 8
of contracts in the areas of maritime and air traffic back to the
ministerial level, i.e. to the Ministry of Regional Affairs and Agriculture
from 2023. In bus transport, the public transport centres remained the
contracting partners. .
13. The costs of route transport provided under public service contracts
are mainly covered by subsidies allocated for public route transport from
the state budget or the budget of the local authority and by ticket
revenue.
14. In 2024, the state subsidised the carriage of passengers by bus with
€72 million, by rail with €40.8 million, by ferry with €28.7 million and by
air with €7 million. Almost two thirds of all state -subsidised public
transport journeys are made by county buses (see Figure 2).
Figure 2. Number of passengers by type of public transport financed
from the state budget in 2024 (million)

Source: Reports on the use of the 2024 subsidy by public transport carriers
15. The data provided by the Ministry of Regional Affairs and Agriculture
show that the subsidies for public transport have been steadily
increasing and the forecast shows a continued increase in the need for
subsidies across all modes of transport (see Figure 3).
Figure 3. Public transport subsidies by mode of transport

* A forecast is given from 2025 onwards.
21,9
7,9
2,7 0,06
County bus Train Ferry Ferry
The costs of
managing public
transport have risen
more than projected

Organisation of public transport (follow -up audit of county public transport)
9 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
Source: Ministry of Regional Affairs and Agriculture
16. Support for county bus transport has increased the most compared
to 2019. The forecast presented to the National Audit Office in the audit
published in 2021 showed that the expected financial need for
organis ing county bus transport in 2024 is €64.6 million. However , the
subsidies given in 2024 already reached €72 million. The Ministry of
Regional Affairs and Agriculture forecasts a further increase in the cost
of county bus transport, with €87.1 million expected to be spent by
2029.
17. The main reason for the increase in the cost of county bus transport
is the sharp rise in the price indices in the current transport contracts,
i.e. the consumer price index, the fuel index and the average wage index,
as well as the need to replace commerc ial routes following the
introduction of free county bus transport.
18. The increase in rail, air and maritime transport costs is mainly
affected by the increase in the charges for the use of infrastructure, i.e.
railway, airport, port. In rail transport, costs will increase due to the
introduction of 16 new electric trains ordered by the rail company AS
Eesti Liinirongid (Elron) and the Tartu -Riga train service, which is
scheduled to open by the end of 2025.
19. For years, less money has been earmarked in the state budget for
public transport than is needed to meet the commitments entered into
in the contracts, even though the amounts are to a large extent
predictable on the basis of the public service contracts c oncluded with
the carriers and known at the time the state budget is planned.
20. Money has been allocated from the reserve fund of the Government
of the Republic from 2022 –2025 to cover the shortfall in the public
transport subsidy (see Figure 4). However, the reserve fund should be for
unforeseen costs, not for covering costs related to the performance of
known obligations.
Figure 4. Funds allocated from the reserve fund of the Government of
the Republic to cover the total public transport shortfall, 2022 –2025 (€
million)
The shortfall in public
transport funding has
long been covered
from the reserve fund
of the Government of
the Republic

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 10
Source:
Ministry of Regional Affairs and Agriculture
21. At the Cabinet meeting on 07.02.2025, the principles of funding
public transport from the state budget developed by the Ministry of
Regional Affairs and Agriculture (hereinafter referred to as the funding
model) were approved.
22. The funding model, which is expected to be implemented from
2026, foresees that the cost of public transport will be planned from the
state budget to the extent corresponding to the volume of the
commitments undertaken under public service transport contra cts.
According to the model, the reserve fund of the Government of the
Republic would in the future cover only those costs that are difficult to
foresee in the budgeting process, such as increases in infrastructure
charges, taxes and price indices.
23. The National Audit Office published an audit on the management of
county public transport in 2021, and the National Audit Office also
examined the resolution of the problems identified in this audit (see
Annex A for details).
24. The National Audit Office investigated whether , in the organisation
of county bus services , the mobility needs of people have been
identified, a user -friendly ticketing system has been created and the
timetables have been coordinated with the timetables of rail, water and
air routes, and local and long -distance bus services.
25. In addition, the National Audit Office analysed the clarity of the roles
and responsibilities of public transport organisers , the situation of
transfers, including the duration of transfers, the possibilities of parking
cars and bicycles at bus stops, the connections to light traffic routes and
whether the financing of public transport makes it possible to develop a
public tran sport service that meets the needs of people.

9,3
18,3 18,3
37,7
0
10
20
30
40
2022 2023 2024 2025
The National Audit
Office audited the
financing and
organisation of public
transport and the
compliance of county
bus transport with the
mobility needs of
people

Organisation of public transport (follow -up audit of county public transport)
11 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
The organisation of public transport does
not guarantee a service that meets
people’s expectations
26. The public transport satisfaction surveys commissioned by the
Transport Board and referred to in the audit published in 2021 showed
that people were the least satisfied with the routes and transfer options
on county bus services and the arrangements for pa rking cars and
bicycles at bus stops.
27. According to the study “Nationwide satisfaction of residents with the
living environment and the public services of local authorities”
commissioned by the Ministry of Regional Affairs and Agriculture in
2024, the biggest bottlenecks in public transport at present are the non –
compliance of timetables with people’s needs and the inconvenience of
travelling by public transport (see Figure 5).
28. The reasons for dissatisfaction with public transport timetables cited
by 55% of the respondents are that the timetables are too infrequent,
the vehicles run at the wrong times or do not cover a suitable route.

Reasons for
dissatisfaction with
public transport

Did you know that…
the conclusions of the
Estonian Mobility Study 2021
of the Transport
Administration are the same
as the ones of the
satisfaction survey carried out
by the Ministry of Regional
Affairs and Agriculture in
2024. The top three reasons
for choosing a car over p ublic
transport were:
• travelling by public
transport is too time –
consuming (64%);
• public transport does not
go where people need to
go (54%);
• the timetables of the
services do not match the
movements of people
(41%).
Source: Estonian Mobility Study
2021 of the Transport
Administration

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 12
Figure 5. People’s reasons for dissatisfaction with public transport in
2024 (%)*

* A random sample of 9713 people took part in the study. The study was carried out as
an online and telephone survey. 20% of respondents said that nothing bothers or
hinders them. The study does not specify the mode of public transport (train, plane, boat,
long -distance bus, country or local bus) for which respondents have given their opinions.
Source: National Audit Office based on the study “Nationwide satisfaction of residents with the
living environment and the public services of local authorities” commissioned by the Ministry of
Regional Affairs and Agriculture
The mobility needs of people who have not yet used
buses for their journeys have generally not been studied
or taken into account in the management of county bus
transport
29. In order to prepare a timetable that meets the mobility needs of
residents, those needs must be first identified. The Ministry of Regional
Affairs and Agriculture is obliged to carry out both national and county –
level studies of mobility needs and the Ministry of Regional Affairs and
Agriculture has delegated the latter to the public transport centres by
means of a administrative contract.
30. The National Audit Office investigated whether the Ministry of
Regional Affairs and Agriculture and the public transport centres have
analysed the mobility patterns of residents when developing the
5,93
7,95
8,29
11,49
13,32
28,85
31,74
54,96
0 20 40 60
Public transport is too expensive
The journey to the stop is unpleasant
(e.g. noisy, unsafe, lack of sidewalks, etc.)
I am limited by a mobility impairment (or
other health-related restriction)
The stop is too far away
Being on public transport is unpleasant
(overcrowded, hot, dirty, etc.)
Travelling by public transport takes too
much time
Using public transport is more
inconvenient and difficult than using a
car, bicycle, or walking
Schedules do not meet needs
Criterion
Study of mobility needs – the
analysis carried out to clarify
the actual mobility patterns of
people and to plan mobility
expediently and sustainably
has been considered the
study of mobility needs in the
audit

Organisation of public transport (follow -up audit of county public transport)
13 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
timetables of county bus services, what data are used for this purpose
and whether the results of the analyses have been used to adjust the
routes and times.
31. Compared to the audit published in 2021, people’s needs to move
around by county bus transport have been studied more. The audit
showed that, in general, all public transport centres analyse mobility
needs as part of their day -to-day work. Six public trans port centres have
used external help to identify mobility needs, including commissioning
mobility studies, using data from third -party work or gaining new
knowledge from the graduation theses of students. 3 Four public
transport centres have carried out surveys themselves.
32. According to the Tartu County Public Transport Centre, the Ministry
of Regional Affairs and Agriculture has announced that there is currently
no money to open new routes or to increase service frequency of
existing routes , and therefore the Tartu County Public Transport Centre
has no motivation to outsource studies.
33. The responses to the survey of the National Audit Office (see Annex
B) show that studies of mobility needs have been used as a basis for
making changes to the route network, and that in the period 2020 –
2024, the public transport centres of Järva, Pärnu, Jõgeva, Kagu and
Viljandi have made changes to their route networks and timetables
based on such studies ..
34. However, it became evident that if the results of a study recommend
the opening of a new route that needs additional funding, it is up to the
Ministry of Regional Affairs and Agriculture to decide whether or not the
public transport centre can implement the change. The North -Estonian
Public Transport Centre stated that it has not received money even to
open routes that are likely to have high demand , such as the new
developments in the surroundings of Tallinn.
35. Public transport centres use passenger validation data, passenger
and carrier feedback to plan routes, i.e. mainly to change routes and
travel times. A weakness in analysing this data is that the public
transport centres only have the right to view the dat a of their own
administrative area and have no information on how many people from
the region of the public transport centre travel to another county. In
addition, these data do not reflect the mobility patterns of people who
do not use public transport.
3 For example, the topics of bachelor’s and master’s theses have included the feasibility
of implementing demand -based public transport in regions, analysis of the route
network, planning a new route network, the impact of planned service level standards on
the public route network.

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 14
36. Mobile positioning, commuting and other data describing the
mobility patterns of residents, which would also take into account the
needs of those who do not travel by bus, are mostly not used (with the
exception of the Viljandi Public Transport Centre and the Southeastern
Public Transport Centre), although the Ministry of Regional Affairs and
Agriculture has access to the data. According to the North -Estonian
Public Transport Centre, there is currently no money or human resources
to analyse these data. The Ministry of Regional Affairs and Agriculture
itself has not analysed the data because, according to the Ministry, it
does not have the necessary analytical expertise and outside help has
not been used for analyses.
37. According to rail company Elron, adapting existing studies to plan
their timetables is standard practice. Elron finds that there should be a
single database of studies. For example, when the Transport
Administration orders mobility studies but they cannot be found in a
single database, Elron may not be aware of the existence of a study and
may order a similar one i tself.
38. In 2021, the Transport Administration carried out a nationwide
population survey . Based on the data of the survey, the Ministry of
Regional Affairs and Agriculture has not made any proposals to the
public transport centres for changes to the county route network, as the
surveys did predominantly not provide any new information.
39. The results of the survey were used to prepare the concept of the
public transport reform. For example, a cooperation project on public
transport routes in Saaremaa and Lääne -Harju is being planned and its
main objective is to develop the principles for de signing the route
network. Based on the survey data, the Transport Administration has
started to develop a nationwide mobility model for 2025 in cooperation
with the Ministry of Regional Affairs and Agriculture.
40. Mobility needs have been studied both by the Ministry of Regional
Affairs and Agriculture (previously the Transport Administration) at the
national level and by the public transport centres at the county level,
also after the 2021 audit. For the public tra nsport centres, analysing
people’s mobility needs is part of their day -to-day work. However, the
clarification of the mobility needs of people who do not use public
transport but who would need it has not progressed in all public
transport centres. The public transport centers have cited as the reason
the fact that no additional funding is provided for increasing service
frequency in the route network .
41. Nevertheless, according to the National Audit Office, possibilities for
more efficient use of money should be sought in the budgets of the
public transport centres and thus make changes in the timetables. For
Did you know that…
On 1 April 2025, bus number
27 started operating in
Viljandi County, connecting
Matapera Village, where no
public bus transport had been
provided before, and the Päri
summer cottage region with
Viljandi City. The line was set
up on the basis of mobile
phon e mobility data.
Source: Viljandi Public Transport
Centre
Did you know that…
the next nationwide mobility
study is planned in the 2025
budget of the Transport
Administration in cooperation
with the City of Tallinn
Source: Transport Administration
Opinion of the
National Audit Office

Organisation of public transport (follow -up audit of county public transport)
15 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
example, demand -based transport could be used to optimise the current
network at places where passenger numbers are small.
42. The Ministry of Regional Affairs and Agriculture can provide the
public transport centres with access to the county -based data from
nationwide surveys, so that the public transport centres would not have
to commission surveys from their own budgets to obta in the same data.
This would allow the public transport centres to study people’s mobility
patters more sustainably.
43. In the opinion of the National Audit Office, an analysis that only
includes data on the current users of public transport is not sufficient to
develop timetables that meet the actual mobility needs of the
population, as this analysis does not show the mobi lity patterns of
people who do not use public transport but could start to do so. At
present, approximately 60% of working people commute by car – the
mobility needs of these people are not reflected in the data on the use
of stops or directly in the data on the location of services.
44. Recommendation of the National Audit Office to the Minister
of Regional Development and Agriculture: develop a procedure for
sharing data with public transport centres in order to study the mobility
needs of people who use public transport as well as those who do not.
Response of the Minister of Regional Affairs and Agriculture: We
produce regular annual reviews, which we share with the public transport
centres. The report on the use of stops, based on validation data from
county routes, will be ready for use by public transport centres in the
near future. We will then continue to analyse other indicators based on
the validation data, using the Power BI tool, which helps study the
available data dynamically and better assess the feasibility of the routes.
In addition, the Ministry of Regional Affairs and Agriculture has provided
the public transport centres with a n online route network analysis
software, which can display different data, such as the location of
people’s places of residence, schools and kindergartens, as map layers.
We also plan to add validation data, i.e. the usage of stops, as a data
layer. As new data are generated, we add new data layers to the analysis
software. In addition, there is the possibility to use mobile positioning
data.
The Ministry of Regional Affairs and Agriculture does not consider it
necessary to develop additional procedures, as all information exchange
runs smoothly on a day -to-day basis and, as new IT solutions become
available, these tools will immediately be mad e available to the public
transport centres.

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 16
It is difficult to coordinate the timetables of different
modes of public transport because there is no central
coordination
45. Synchronised timetables and an integrated nationwide network
require coordinated planning between the route organiser s of different
modes of transport. The organisation of the public transport network
and timetables must allow passengers to make connections with
reasonable waiting times.
46. There are people in all counties whose place of work is not in the
county of residence.
47. The National Audit Office examined whether, given the current
distribution of tasks, it would be possible to develop county bus services
in such a way that people could move between different counties and
transfer between different modes of transport using local bus and coach
services, as well as train, boat and air services.
48. The Ministry of Regional Affairs and Agriculture coordinates the
development of public transport in counties and nationwide, designs the
route network of public transport services in the counties linked to the
network of municipality and urban routes, and long -distance services,
and issues route licences to commercial operators and approves
timetables for bus services on county, national long -distance and
international services.
49. In addition, the Ministry of Regional Affairs and Agriculture is the
competent authority for the carriage of passengers on the county bus
services operated under public service contracts and by the long –
distance bus services. Among other things, the competent authority
organises a public procurement to find a carrier.
50. Under administrative contracts concluded with the Ministry, public
transport centres have been entrusted with overseeing and coordinating,
in cooperation with the Ministry of Regional Affairs and Agriculture, the
development of public transport in the county; approving the timetables
of the county’s bus services operated by commercial operators, taking
into accoun t the timetables of long -distance bus routes, municipality
and urban routes, ferries, planes and trains, and the proposals of the
local authoritie s concerned; and designing the route network of public
bus services in the county linked to the national and local networks.
Criterion
Did you know that…
in 2021, 14.3% of all people
in employment travel from
their county of residence to
work in another county, and
there are such people in all
counties (see Annex C).
Source: Statistics Estonia
Public transport
centres are not
expected to or ganise
bus services across
county borders

Organisation of public transport (follow -up audit of county public transport)
17 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
51. However, in practice, most of the public transport centres (except
Saaremaa, Hiiumaa) operate services that start in one county and end in
another. There are 392 bus routes organised by public transport centres
that cross county borders (including 39 between more than two counties
and 353 between two counties), representing 20% of all routes (1,918).
52. The Ministry of Regional Affairs and Agriculture itself does not
organise public procurement for long -distance bus services. It is
therefore not clear at this stage on what basis the public transport
centres organise and the Ministry of Regional Affairs and Agriculture
finances the carriage of passengers on long -distance bus routes.
53. All the public transport centres are trying to take other modes of
transport into account when planning their county bus routes and have
tried to make them compatible.
54. In the survey of the National Audit Office, the most cited obstacle to
the smooth interconnection of county bus traffic with other modes of
transport was the fact that trains and ferries do not adhere to the agreed
timetables. In the case of trains, the pu blic transport centres have cited
railway repairs as the reason for this, and in the case of ferries, weather
conditions (ice, strong winds, etc.), which either prevent ferry s from
adhering to timetables or lead to cancellations.
55. The responses of the Ministry of Regional Affairs and Agriculture to
the National Audit Office’s inquiry about the basis on which timetables
are prepared revealed that the timetables of trains, commercial bus
services and ferries do not take into account the actual mobility needs
of the people in the county, and are based on the organiser’s own
network of routes. For example, according to Elron, train timetables also
depend on the capacity of the railway infrastructure, which makes
changing the timetable on the railways less flexible compared to buses.
56. In addition, changing the traffic schedule and increasing capacity on
the railways is a more long -term process. For example, it will take a
minimum of five years to procure new trains, and these trains cannot be
fully operational until the electrification of the Tallinn -Tartu and Tallinn –
Narva lines is completed.
57. Long -distance bus services are mainly operated on commercial
basis , i.e. according to the carrier’s own wishes about the centres
between which it wants to provide services, which stops it adds in the
timetable, on which days of the week to operate the service, etc. The
carrier considers its business interests when managing commercial
services. The carrier submits an application for a licence to provide
long -distance bus services to the Ministry of Regional Affairs and
Agriculture, which proceeds from the pr inciples of discretion for issuing
long -distance licences and approving timetables. However, there are no
Did you know that…
the North -Estonian Public
Transport Centre is the
largest public transport hub,
whose region covers Harju,
Rapla, Lääne and Lääne -Viru
counties.
The Southeastern Public
Transport Centre operates
bus services in Põlva and
Võru counties. The public
transport centres of Pärnu,
Jõgeva, Järva, Valga, Ida -Viru,
Viljandi and Tartu counties,
and Saare Municipality
Government and Hiiu
Municipality Governmen t
have regions based on a
single county.
Source: Statutes of public
transport centres, public law
contracts There is no systematic
approach and no
unified co -ordination
for aligning the
timetables of county
bus and other
services

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 18
criteria in the principles of discretion to motivate commercial carriers to
align their services with county bus transport.
58. The ferry timetables are prepared by carriers who, according to the
terms and conditions of their contracts concluded with the Ministry of
Regional Affairs and Agriculture, coordinate these plans with the
relevant local authorities and submit them to the Ministry of Regional
Affairs and Agriculture for approval. If local authorities do not grant their
approval, the timetable applied in the same period of the previous year
is used. Situations where the opinion of local authorities cannot be
taken into accoun t are rather common.
59. The public transport centres are usually informed of changes to
train, ferry, air, local and long -distance bus timetables. However, public
transport centre have pointed out that, for example, in the case of trains,
the notice period is often too short to c hange the timetables of bus
services in the region. According to the contract concluded with the
carrier, the public transport centres need information at least 30 days in
advance to make changes to the timetable. According to the
Southeastern Public Trans port Centre, they sometimes receive
information three days in advance in practice.
60. Elron has a contract with AS Eesti Raudtee for the use of railway
infrastructure, which sets out, among other things, the process and
deadlines for approving the timetable. According to this agreement, AS
Eesti Raudtee must notify Elron of the repair work schedules and other
planned changes to the traffic schedule 60 day s before the changes
enter into force and submit a draft of the amended traffic schedule 30
days before it enters into force.
61. According to Elron, they do not always receive notifications and draft
traffic schedules from the infrastructure operator in time, and even if the
information arrives on time, there are cases where it is later changed
(location of a closed section or the d ates of works are changed).
62. According to Elron, the advance notice period agreed in the current
operating contract does not provide sufficient time for informing
passengers, let alone the public transport centres, and does not make it
possible to sell tickets sufficiently long in adv ance.
63. The National Audit Office analysed selected routes with transfers
(see the description of the sample in the audit description) to find out
how long the average waiting time for transfers can be when moving
from one county to another using different modes o f public transport.
The analysis of the selected routes showed that the average waiting
time for transfers was 26.5 minutes and sometimes reached an hour.

Organisation of public transport (follow -up audit of county public transport)
19 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
64. The Ministry of Regional Affairs and Agriculture has carried out a
nationwide analysis of the possibilities for connecting different modes
of transport into a coherent and functioning system. The underlying
principle of such a network structure is the cohe rence of timetables and
the assumption of fixed interval schedul ing , which means departures at
certain intervals.
65. In this case, the main mobility needs would be covered by a
frequent national rail service, supported by a county bus service, which
takes passengers to the trains, as well as fixed interval carriage service
between regional centres. Trains, buses, on -demand bus services and
also ferries must operate as a whole, with fast and convenient transfers
between routes.
66. The Ministry of Regional Affairs and Agriculture believes that the
transition to a fixed interval schedule needs centralised management to
allow the development of a nationwide system of linked timetables that
people can easily understand when using any mode of transport.
67. In its legislative intent for the development of the draft act
amending the Public Transport Act, the Ministry of Regional Affairs and
Agriculture has pointed out that at present, routes only form a set of
individual routes – there is no comprehensive syst em as the alignment
of timetables is mostly random. Current timetable coordination is
voluntary for the compilers of timetables and is based on their own
route networks, rather than taking into account the nationwide route
network.
68. Various analyses have shown that, from the state’s perspective, the
national route network should be designed by a single authority, as this
would better meet people’s need to move outside counties.
69. For example, in the 2016 analysis of state functions concluded that a
single authority would not face territorial obstacles when designing the
route network; a study on alternative administrative models for the
management of public transport published in 2024 points out that the
passenger -centred solution is based on a single authority, where all
modes of transport are managed in all regions in such a way that
different modes of transport do not compete with each other.
70. Despite the results of the analyses, the Ministry of Regional Affairs
and Agriculture made a proposal to the public transport centres to
merge into regional public transport centres in 2025, so that local
authorities retain their voting rights in the publi c transport centres. The
study of administrative models does not support this solution, as the
parties have no common vision of possible regions.
71. The public transport centres oppose regional mergers because the
point of merging the public transport centres is not clear to them, and
According to studies,
the nationwide route
network should be
designed by a single
authority

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 20
there has been no guidance from the Ministry on how and on what
principles the merger should take place.
72. The Ministry of Regional Affairs and Agriculture has currently put the
merger of the public transport centres on hold, although the
administrative changes should be completed by early 2026 according to
the schedule of the concept of the public transport re form. The merger
was put on hold because the Ministry of Regional Affairs and Agriculture
had not yet developed a clear position or determined the merger
process.
73. The Ministry of Regional Affairs and Agriculture has so far failed to
lead the development of nationwide public transport. The current
timetables are prepared on a different basis for each mode of transport
and within the operational limits of the service organiser . This is why
coordinating the timetables of the services is difficult and time –
consuming, and the parties also lack the motivation for this.
74. Although timetables depend on, among other things, a number of
unforeseeable circumstances (e.g. rail infrastructure failures, storms at
sea), the large number of organisers of different modes of transport
means, in the opinion of the National Audit Office, that it is essential
that the Ministry of Regional Affairs and Agriculture establishes a
functioning coordination system to connect all these timetables.
75. The current county -based route network and timetables do not
support the movement of people by different means of transport and
between different counties. Given Estonia’s small size, at least the route
network in mainland Estonia, which would cover differ ent modes of
transport, could be designed by a single authority. The fact that public
transport should be planned across counties is also confirmed by
practice – most of the long -distance bus services of the public transport
centres already cover different counties, even though they are not
obliged by the administrative contracts to provide such a service.
76. Recommendations of the National Audit Office to the Minister
of Regional Affairs and Agriculture:
• ensure the functioning of a single nationwide public transport
service covering different modes of transport (including ferry, train,
county and local bus services), which also includes the creation of a
central timetable coordination system;
• if the use of the current public transport model continues, amend
the administrative contracts with the public transport centres so that
they have the right to organise transport beyond their own county’s
borders.
Response of the Minister of Regional Affairs and Agriculture: We
also see the need for nationwide coordination of all modes of transport.
Did you know that…
the Minister of Regional
Affairs and Agriculture has
stated on 17.09.2025 that the
plan is to consolidate the
current public transport
centres under one or two
control centres.
Source: Terras: basic funding for
public transport will increase by
€54 million next year. ERR ,
17.09.2025
Opinion of the
National Audit Office

Organisation of public transport (follow -up audit of county public transport)
21 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
The plan is to resolve the hierarchy of routes and the nationwide
timetable coordination system by amending the Public Transport Act.
The administrative contracts with the public transport centres will also
be reviewed, while the current contracts do not prohibit the opening of
cross -border routes by the public transport centres.
Comment of the National Audit Office: The National Audit Office
points out that the public transport centres are competent to manage
those public functions that are entrusted to them by the administrative
contracts. At present, the Ministry has not delegated the management of
long -distance bus services to the public transport centre in the
administrative contracts, although the Ministry has this option.
The lack of the necessary infrastructure (e.g. car parks)
and of a single ticketing system makes the journeys with
transfers inconvenient
77. In order to ensure convenient and accessible transfers from one way
of travelling (e.g. walking, public transport, car, bicycle) or means of
transport (e.g. bus, train, boat) to another, it is necessary to develop
stops that are well -connected and also mee t the special needs of
people, and to at least create a single ticketing system, which allows
passengers to use different modes of transport on their journey with one
ticket.
78. One of the objectives of the Transport and Mobility Development
Plan 2021 –2035, similar to the previous period (2014 –2020), is to
create a single nationwide ticketing system for all modes of transport,
where the same ticket products can be used for both pu blic and
commercial services regardless of the mode of transport (e.g. cross –
usable tickets on buses, trains, ferries).
79. One of the important activities in the public transport programme in
the period 2025 –2028 is, in addition to the development of a single
nationwide ticketing system, the development of a fare system
(including monthly passes, zone tickets, etc.) to encourage passengers
to transfer.
80. The audit showed that, to date, there is still no environment where it
is possible to buy a single ticket for all modes of transport on a
nationwide route with transfers. Each public transport service provider
operates independently and there is generally no cooperation on
ticketing (except for the combination of long -distance bus services and
ferry services operated on a commercial basis).
Special need – according to the
accessibility concept based on
the life cycle, the accessibility
needs that may emerge during a
person’s entire life cycle, e.g.
parents of small children, the
elderly, temporarily injured
people, etc., could be added to
the view of dis abled people.
Source: final report of the
Accessibility Task Force, Government
Office
Criterion
No single nationwide
ticketing system has
been created

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 22
81. In order to integrate different ticketing platforms, the Transport
Administration has initiated the MaaS X -road project in cooperation
with the Ministry of Climate and the Ministry of Regional Affairs and
Agriculture, which is an important prerequisite in the context of the
public transport reform for a single cross -carrier ticketing system to
work. According to the Minist ry of Regional Affairs and Agriculture, the
state primarily wants to create a base or mediation platform, but at the
moment it is not kno wn whether there is a commercial party on the
market interested to manage the user interface for the ticketing
software.
82. The prototype of the MaaS X -road should be ready by January 2026
and the plan is to implement the full version from October 2026. The full
version does not mean that the system should immediately cover all
market participants. According to the concept of t he public transport
reform, it would be practical to start with the integration of train and
county bus ticketing via MaaS X -road, to which other service providers
would gradually be added.
83. In addition to the integration of ticketing systems, the concept of
the public transport reform prepared by the Ministry of Regional Affairs
and Agriculture in 2024 aims to create a nationwide system of uniform
fares, zones and discounts on county bus, loc al bus and train services by
October 2026 at the latest, in order to facilitate the use of different
types of public transport.
84. Although a single system of fares, zones and discounts has been
discussed for more than a decade, fares and discounts continue to vary
from region to region. The Ministry of Regional Affairs and Agriculture
wants to harmonise the discounts, but agreeing on the same discounts
requires an agreement between the Ministry of Regional Affairs and
Agriculture, the public transport centres and local authorities, which is
difficult due to the multitude of the parties involved. The possibility of
uniform tariffs and discounts depends on the degree of cooperation
between local authorities and on policy choices (e.g. travel concessions
often apply to local residents).
85. A goal of the public transport reform is to view the passenger
journey as a whole that does not start or end at a public transport stop.
It is also important to ensure that connections and the start and end of
the journey are smooth and easy. In order to m ake transfers more
convenient, it is possible to develop cycle and pedestrian paths leading
to the stops, ensure that a car park is close to the stop.
MaaS X -Road – a secure data
exchange layer connecting all
public transport providers (bus,
train, etc.). The objective of the
development of the MaaS X –
road is to create the prototype
of a software that mediates
travel requests and connects
mobility services, and to t est it
as a mediation channel to
connect different transport
service providers and to create
single tickets, travel rights or
discount products for the
participants in the system.
Source: website of the Government
Office
Only a small number
of stops are
connected to light
traffic paths or
parking facilities

Organisation of public transport (follow -up audit of county public transport)
23 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
86. The National Audit Office investigated whether the Transport
Administration as the planner of transport and mobility infrastructure
objects, and the Ministry of Regional Affairs and Agriculture as the
coordinator of public transport development, have an ov erview of the
condition of the equipment of bus stops, footpaths, cycle paths and car
parks in the county. The National Audit Office looked at the stops of
county bus routes that had departures to see whether and how many
had footpaths, cycle paths and car parks nearby to allow for better
access.
87. Neither the Transport Administration itself nor the Ministry of
Regional Affairs and Agriculture has a complete overview of the access
infrastructure of the stops on county bus routes, or information on their
use. The Transport Administration knows which stops have car parks
nearby. Information on the frequency of boarding at bus stops on county
routes, i.e. the frequency of use of the stops, is also k nown. However, it is
not known, for example, what the occupancy rate of car parks is and how
well equipped they are with bicycle racks.
88. According to the Transport Administration, neither it nor the Ministry
of Regional Affairs and Agriculture has an exhaustive database of
pedestrian and cycling paths and the data provided to the road register
of local authorities is incomplete.
89. Based on the analysis of the data on car parks in the map layer of
points of interest of the Land Board and the data on light traffic paths in
the road register (see the description of the analysis in the audit
characterisation), the National Audit Office found that, for example,
23.6% of light traffic paths and 5% of car parks are within a radius of
50 metres 4 of the surveyed stops (see also Figure 6). Of all the stops
surveyed, 37.3% have a light traffic path and 25.8% have a car park
within a radius of one kilometre.
90. According to the Transport Administration, not every stop on a
county bus route necessarily has to have a car park or light traffic path
nearby. The idea is to solve access on most roads on an as -needed
basis by moving along the roadside and not by a separ ate footpath.
91. From 2021, the budget of the public road maintenance plan also
includes funding for the measure “Construction of infrastructure
promoting more sustainable mobility”, which is used to finance the
construction of pedestrian and cycling paths and the creation of
conditions to encourage changing the ways of travelling or mode of
transport, including the construction of mobility centres and park -and –
4 In Estonia, there is no agreement on how far an onward connection should be from a
car park. However, the Transport Administration has published on its website an
Estonian translation of the Finnish guide “Design of pedestrian and cycle paths”,
according to which the majority of bicycle spaces should be built no more than 50
metres from the onward connection .
Did you know that…
the possibility of combining
cycling and rail transport is a
viable alternative to car travel
and could therefore increase
the number of rail
passengers. In the
Netherlands, 40% of
passengers arrive at the train
station by bicycle and 10% of
passengers con tinue their
journey by bicycle when
leaving the train. 14% of bus
passengers also use a bicycle
to get to the bus stop.
Source: the manual “Increasing
the Proportion of Cycling in City
Transport in Small and Medium –
sized Cities of Central and
Eastern Europe by 2020
Figure 6. Possibility to
use park -and -ride car
parks

Source: Estonian Mobility Study
2021 of the Transport
Administration
25%
29%
46%
Yes
Hard to say
No

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 24
ride car parks. The Ministry of Climate also supports the construction of
public transport hubs and cycle paths through the European Regional
Development Fund.
92. Sites have been financed for €4.3 million from 2022 –2024. During
this time, twelve light traffic paths, one park -and -ride car park and four
bus stops have been built. There are plans to build four sites in 2025.
93. In order to fund the most important and high -impact sites, the
objective principles of prioritising them must be established. The
Transport Administration has the model “Potential travel by foot and
bicycle”, which is used to select the sections of cycle paths and
footpaths with the highest potential for use, taking into account public
transport stops. The list of selected objects may also include sites that
comply with the criteria presented in the guide “Light Traffic
Infrastructure Planning” of the Transport Administration. 5
94. In accordance with the procedure for selecting state road
infrastructure sites that promote sustainable modes of transport
established by the Transport Administration , proposals for the list of
other sites related to public transport are made by the Ministry of
Regional Affairs and Agriculture. The priority for the Ministry of Regional
Affairs and Agriculture are sites that act as a mobility hub, i.e. a place
where passengers can transfer from one mode of transport to another
(bus -train, county -local bus, etc.). Mobility hubs will be prioritised
according to their regional impact and the number of passengers
affected.
95. According to the Public Transport Act, one of the starting points for
planning and managing public transport is to ensure that the supply of
public transport meets the demand, which arises, among other things,
from the mobility needs of people with disabil ities, the elderly and
schoolchildren.
96. The National Audit Office investigated whether the people with
special mobility needs have been taken into account in the organisation
of the county bus service.
5 In county centres and around towns with at least 10,000 inhabitants, on the light traffic
paths leading towards the town centre if there is a town with at least 1,000 residents on
the outbound route, which is located up to 10 km from the town border.
A more systematic
approach to people
with special needs is
needed

Organisation of public transport (follow -up audit of county public transport)
25 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
97. The public transport centres that set conditions for buses in their
procurement have highlighted, from the viewpoint of special needs, the
problems related to the winter maintenance of bus stops, the lack of
light traffic paths leading to bus stops, the la ck of a waiting area and
lighting (see also paragraphs 166 –170 on bus stops) in their replies to
the survey. From the list of problems presented by the Estonian
Chamber of Disabled People, the unwillingness of bus drivers to help,
the unsuitability of the bus fleet for disabled people, such as narrow
aisles and problems with fastening wheelchairs, were also highlighted.
98. Buses with low floors allow better access to public transport for
disabled people, as well as the elderly, children and people with prams
and pushchairs. According to the final report of the Accessibility Task
Force of the Government Office of 2021, the pe rcentage of low floor
buses on the county bus services operated by the public transport
centre was only 29%. According to the Ministry of Regional Affairs and
Agriculture, the share of low floor buses on county bus routes has
increased to 60% in 2024, and the target for the end of 2027 is 79%.
99. However, the Southeastern Public Transport Centre pointed out that,
following the acquisition of low floor buses, it has become apparent that
in some cases buses cannot pull up to the edge of the waiting platform
to open the door, because the waiting platf orm is higher than the lower
edge of the bus door (see recommendation in paragraph 185).
100. The concept paper on the public transport reform of the Ministry of
Regional Affairs and Agriculture indicates that the Ministry does not
know how many bus stops are wheelchair -accessible and how many
need to be rebuilt. According to the Ministry of Regional Affairs and
Agriculture, the Ministry has an overview of the bus stops reviewed in
the analysis “Accessibility of transport and the artificial environment” of
2020, i.e. 2.4% (401 bus stops out of the 16,642 bus stops in the
sample) of all bus stops.
101. There are no metrics against which to assess the state of
accessibility, and ensuring accessibility is currently not monitored at
stops. According to the Ministry of Regional Affairs and Agriculture, what
makes the adaptation of stops difficult is the fact that the Public
Transport Act does not clearly define who is responsible for bringing
stops into conformity with requirements (see also paragraphs 166 –170).
102. The have been plans to implement a nationwide single ticketing
system and a system of uniform fares, zones and discounts since at
least 2014. New deadlines have been set time and again, but there is
still no single ticketing system and no uniform pricing p rinciples. At the
same time, it is still inconvenient for the passenger to navigate between
different modes of public transport, as connecting routes where several
Did you know that…
the Ministry of Climate will
allocate €2.5 million to 34
municipalities to address the
accessibility and safety
bottlenecks in public transport
infrastructure sites identified in
the analysis of the accessibility
of transport and the artificial
environment in 2020 by 2028 at
the latest.
Source: Minister of Infrastructure
Directive of 07.08.2025 “Support to
local authorities for improvement of
accessibility of public transport”
Opinion of the
National Audit Office

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 26
counties need to be crossed by several means of transport cannot
usually be covered by a single ticket.
103. The creation of a single ticketing system would also make sense
because the operators of the various modes of transport have had to
invest in the development of ticketing software in parallel with the
Ministry. The Ministry of Regional Affairs and Agricult ure, in cooperation
with the Transport Administration, has initiated the creation of a data
interchange layer, which is a positive step towards a single ticketing
system, but until there is clarity on who is responsible for the creation of
the user environ ment for ticketing, there is no certainty that it will be
possible to buy tickets from a single central place in 2026.
104. In the opinion of the National Audit Office, achieving the objective
described in the public transport programme – the creation of a
nationwide system of uniform fares, zones and discounts – in its current
form is not realistic. In order to create a single fare system across local
authority and county borders, a solution is also needed to include the
municipality and urban routes of local authorities.
105. In the opinion of the National Audit Office, the attractiveness and
usability of county bus transport can be improved if the service is
developed in such a way as to ensure better access to the bus stop and
smooth and safe movement to the bus stop and boar ding the bus,
including for people with special needs. At present, few bus stops on
county routes are connected to car parks and light traffic paths, which
means that there are often no possibilities to park a car or bicycle, or to
safely cycle or walk to the bus stop.
106. The Ministry of Regional Affairs and Agriculture does not have
exhaustive information on the accessibility of public transport
infrastructure and services for people with special needs. On the
positive side, a targeted financing measure for the development of
infrastructure has been established to encourage the use of public
transport, which has clearly defined principles for prioritising sites that
facilitate the use of public transport infrastructure. In addition, the
increasing use of low floor buses des erves recognition.
The Ministry of Regional Affairs and
Agriculture has not set standards for
public transport services or common
rules for their organisation
107. In order to increase the number of people using public transport, it
is important to develop public transport (including increase the
frequency of traffic schedules, invest in stops and other infrastructure)
so that it meets people’s actual mobility needs.

Organisation of public transport (follow -up audit of county public transport)
27 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
108. State support has increased significantly for all modes of transport,
so it is important that taxpayers’ money spent on public transport is
used as economically and efficiently as possible.
In order to develop public transport, the Ministry of
Regional Affairs and Agriculture must define the services
that the state is prepared to ensure
109. In order to develop and invest in the route network, it is important
to have clear and long -term principles for planning and financing the
public transport network. However, this requires agree ment on what is
the frequency and level of demand for the regular route transport that
the state must guarantee, i.e. which routes must be provided and
financed by the state and which ones by the local authorities.
110. Service level standards are the basis for creating a route network
that meets the needs of the population and is economically viable, as
they can be used to assess where the bus service is essential and where
it can be optimised or reorganised – for example, by decreasing
frequency in the route network or providing a n on -demand service.
111. The state must manage, including optimise, the route network
across Estonia on the basis of uniform principles so that regular route
transport is provided precisely where and when they are needed most,
without wasting resources on redundant or underused routes.
112. In its response to the audit published in 2021, the Transport
Administration confirmed that it is planning to develop service level
standards for regional public transport, which will determine the
population density of regions that warrants ensuring the m obility of
residents with regular bus route transport and the regions where more
economically efficient solutions should be sought.
113. The National Audit Office clarified whether the Ministry of Regional
Affairs and Agriculture has developed service level standards and
whether the principles of financing routes are understandable and
uniformly applied.
114. Th e audit showed that although the Minister of Regional Affairs and
Agriculture has the authority to establish service level standards, the
Ministry of Regional Affairs and Agriculture has not set the minimal
base level below which the frequency of departures and connections
must not fall.
115. In addition, it emerged that according to the administrative
contracts, the public transport centres themselves must, where
necessary, set and enforce the public transport service standards on the
public county bus routes. As the administrative contracts with the public
transport centres are worded in such a way that the public transport
Criterion
There are no service
levels for public
transport provision

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 28
centre performs its tasks within the borders of the county, this would
entail different service standards, including route network design
practices (e.g. use of on -demand services). In practice, none of the
public transport centres have set standards for s ervice levels in their
regions.
116. Although the public transport centres have proposed service levels
and submitted them to the Ministry of Regional Affairs and Agriculture
in April 2024, there is still no agreement on where, how many people
and how often the bus should reach as a minimum. The proposal of the
public transport centre includes, among other things, a basic level that
should meet the most basic mobility needs of residents who do not own
cars, i.e. their journeys to centres.
117. The Ministry has sent its inputs for improving the service level
standards proposal to the public transport centres, but the standards
have not yet been approved. The Ministry has taken the view that the
standards drawn up by the public transport centres may be indicative.
118. The National Audit Office found in its audit published in 2021 as
well as in the present audit that the definitions of county bus route,
long -distance route and local and urban route formulated in the Public
Transport Act give a wide scope for interpretation and the concept of an
on -demand bus service is not included in the Act at all. Therefore, it is
still not clear which routes must be managed and financed by the state
and which by the local authority.
119. Until now, the public transport centres and local authorities have
interpreted the borders of the organisation of bus routes differently,
because the border where the responsibility of one party in the
organisation of a bus route starts and the responsibility of the other
party ends remains unclear. This has led to an unequal situation where
the routes of some local authorities are urban and municipality routes
managed and financed by the local authorities themselves , while the bus
routes of other local aut horities with similar characteristics are county
bus routes managed and financed by the state.
120. The Southeastern Public Transport Centre highlighted in the survey
that there are bus routes funded from the state budget that cover one
local authority as well as routes where 90% of the stops are in one
county and 10% in another.
Did you know that…
according to the proposal of the
public transport centres, the
following should be guaranteed
at the base level:
• journeys to the centre every
day (1 –2 round trips);
• connections to major long –
distance/county traffic
terminals in the county centre
for work or other important
purposes at key times .
Source: Service level proposal of the
public transport centre, 2025
The division of
responsibility for the
management of county
and local public
transport remains
unclear

Organisation of public transport (follow -up audit of county public transport)
29 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
121. According to the concept of the public transport reform prepared by
the Ministry of Regional Affairs and Agriculture, on -demand bus services
should provide an elementary connection at the base level and be a
local service that takes people to stops on the main routes. However, the
Ministry of Regional Affairs and Agriculture has still not analysed the
additional cost to local authoriti es if they had to use local budgets to
finance the on -demand stops or entire on -demand services of county
bus routes, which were hitherto managed by the public transport centres
from the state budget (see also paragraphs 137 –139).
122. This year, the Ministry of Regional Affairs and Agriculture has
initiated the legislative intent for the development of an act amending
the Public Transport Act to bring the definitions of routes into line with
the actual situation. It has been suggested t hat routes could be divided
into long -distance, regional and local bus routes.
123. However, the implementation of the definitions given in the
legislative intent requires a change in the administrative model of public
transport management and a more precise definition of the financing
rules, as the change may increase the burden on the b udgets of the
local authorities.
124. The National Audit Office finds that although the concept of the
public transport reform sets the goal of guaranteeing access to services,
education and jobs for people, the Ministry of Regional Affairs and
Agriculture has not yet set standards for the lev el of service or a
baseline for when people’s travel needs must be met by regular county
bus route transport .
125. Unless legally enforceable standards are agreed, it will not be
possible to decide uniformly on which routes will be financed and on
what conditions. It should be clear to all parties, in a manner that can be
legally interpreted, who must manage regular bus route transport and
what they must be like, who must pay for certain routes and in which
cases the service must be provided by county or local bus services.
126. In the opinion of the National Audit Office, the service level
standards, which are optional for the organisers and financiers, do not
create certainty for the users of public transport in terms of the
availability of the service and for the organisers in terms of the volume
of the service. Therefore, it is necessary to establish at least a minimum
basic level of service that has legal force.
127. It is important that the service standard of public transport is
maintained, even where the budget for service provision is limited, as
this will help avoid unjustified regional disparities and ensure that
people in different regions are offered the servic e at least at the
minimum level.
Did you know that…
there are a number of
problems from the user’s
point of view in managing
demand -responsive transport :
• an on -demand stop must
be ordered in advance;
• it is difficult to understand
in the peatus.ee
environment whether or not
a bus service is on –
demand;
• it is difficult to predict the
time and duration of a trip.
The Ministry of Regional
Affairs and Agriculture, in
cooperation with Pärnu
County, Tartu County and the
Southeastern public transport
centres and Saaremaa
Municipality, is planning to
complete a software
development in 2026 that will
make ordering on-demand
transport more automated
and easier to use.
Source: Response of the public
transport centres to the survey
carried out in 2025, Ministry of
Regional Affairs and Agriculture
Opinion of the
National Audit Office

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 30
128. It is also important for the state to set clear rules on the
management and financing of on -demand services, so that it is known
at what point a route or a part of a route becomes on -demand and
whether demand -responsive transport should be financed by the state
or by local authorities.
129. Recommendations of the National Audit Office to the Minister
of Regional Affairs and Agriculture:
• set standards for public transport service levels and implement them
uniformly across Estonia;
• develop the principles for managing and financing demand –
responsive transport to make county public transport more cost –
eff icient ;
• agree, in cooperation with local authorities, on the unambiguous
content and distribution of county bus, long -distance, local authority
and on -demand services, and on the principles of financing.
Response of the Minister of Regional Affairs and Agriculture : the
goal of the Ministry of Regional Affairs and Agriculture is that the
service level standards ensure support for the implementation of the
public transport reform. The development of service level standards is
underway and the planned deadline is next y ear. A pilot project for
demand -responsive transport is underway in Saaremaa, and an analysis
of the results of this project can be used as a basis for drawing up more
general principles for the organisation of demand -responsive transport .
However, the organisation of demand -responsive transport may not
always be a more cost -eff icient solution, because it serves a small
number of passengers at a time. It is planned to change the definitions
of routes and services with an amendment to the Public Transport Act in
order to divide responsibility and funding principles more clearly.
The Ministry of Regional Affairs and Agriculture has not
developed public transport cost -eff iciently
130. As it will not be possible to provide the service at the same level in
the coming years with the current budget, the Ministry of Regional
Affairs and Agriculture must develop solutions for the management of
public transport more economically, given the mon ey available.
131. One option to maintain the county route network sustainably is to
identify and close or shorten unreasonably expensive routes.
132. The National Audit Office clarified whether the Ministry of Regional
Affairs and Agriculture has developed criteria for the optimisation of the
route network and whether the public transport centres have optimised
the use of the route network according to the criteria. In addition, the
National Audit Office looked at whether the public transport centres
Criterion

Organisation of public transport (follow -up audit of county public transport)
31 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
have considered the use of alternative travel options for the purpose of
optimisation and whether the Ministry of Regional Affairs and
Agriculture has guided the public transport centres to do so.
133. The Ministry of Regional Affairs and Agriculture has so far not
established common principles for optimisation, including for example
the cost limit per passenger that, when exceeded, indicates the need to
reorganise routes, refuse to open them or stop sub sidising them from
the state budget.
134. Since the transfer of public transport tasks to the Ministry of
Regional Affairs and Agriculture, the Ministry has not had the capacity to
analyse the economic feasibility of the route network. The public
transport centres have been analysing the performan ce of routes based
on ticket validation data since April 2024.
135. Almost a year and a half after the transfer of public transport
management tasks to the Ministry of Regional Affairs and Agriculture,
an analyst started working at the Ministry, whose tasks include analysing
the cost and usage of routes. The Ministry is pl anning to start analysing
the usage of the route network for public transport centres during 2025,
but at the time of preparation of the audit report, such analyses have not
yet been carried out.
136. Responses to the survey of public transport centres showed that the
principles of optimisation differ from region to region. For example, on
the routes of the Southeastern Public Transport Centre, the cost per
passenger per trip on any one route should not exceed ten euros.
Instead, the North -Estonian Public Transport Centre monitors bus
occupancy, for example reacting if there are fewer than five people per
bus trip on a route.
137. All public transport centres have made county bus routes or parts of
them demand -responsive for the purposes of optimisation . For example,
the Pärnu County Public Transport Centre has reorganised regular bus
route transport so that the end or beginning of less busy routes are
served on demand.
138. According to a survey by the National Audit Office, demand –
responsive transport is used the most in Hiiumaa and the least
compared to others in the region of the North -Estonian Public Transport
Centre (see Table 1).
Table 1. Share of on -demand services among county services operated
on the basis of public service contracts
Public transport
centre
Number of
county
routes
Number of on –
demand routes
Share of on –
demand
routes (%).
The Ministry of
Regional Affairs and
Agriculture has not
analysed the route
network indicators or
set cost limits for the
optimisation of the
route network
Public transport
centres are offering
increasingly more on –
demand stops

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 32
Hiiumaa Municipality
Government
69 63 91
Järva County Public
Transport Centre
34 21 62
Pärnu County Public
Transport Centre
98 40 41
Ida -Viru County Public
Transport Centre
53 20 38
Viljandi County Public
Transport Centre
100 32 32
Tartu County Public
Transport Centre
329 101 31
Järva County Public
Transport Centre
176 53 30
Southeastern Public
Transport Centre
350 94 27
Saaremaa Municipality
Government
123 21 17
Valga County Public
Transport Centre
152 24 16
Northern Estonia Public
Transport Centre
235 Lääne 8; Lääne -Viru 1;
Harju 2; Rapla 1 5
* The National Audit Office has also included routes where only some of the stops are
served on demand among on -demand routes .
Source: Response of the public transport centres to the survey carried out in 2025
139. According to public transport centres, demand -responsive transport
may be more expensive if the cost per route kilometre per passenger is
taken into account, but savings can still be made on the account of
unnecessary route kilometres. For example, the Tartu County Public
Transport Centre has estimated that approximately €22,000 could be
saved per month, which could be used to provide more services on other
routes.
140. The Ministry of Regional Affairs and Agriculture explained that the
large gap between the revenues and costs of public transport can mainly
be reduced by reducing the volume of route transport – shortening
routes, reducing frequencies, closing routes – or raising the fares. The
county bus service contracts include the possibility to reduce the
volume of the contract by up to 20%, but so far the Ministry of Regional
Affairs and Agriculture has n ot instructed the public transport centres to
reduce the volume of routes.
141. According to the Ministry of Regional Affairs and Agriculture and
considering the trend to stop providing some services (including
Reducing the volume of
bus services and
increasing the fares
could reduce the
number of public
transport users

Organisation of public transport (follow -up audit of county public transport)
33 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
schools, shops) in smaller settlements, the need for public transport
continues to grow.
142. Public transport centres are cautious about making cuts to the
route network, because stability is important for people using public
transport. Routes are interconnected, so a cut on one route affects the
other. Making big changes to the established route network will reduce
the trust of people and they choose cars or lose the opportunity to travel
to destinations that are important to them.
143. On the other hand, there are plans to increase the capacity of rail
traffic and make the timetables more frequent by adding new trains in
2026. According to Elron, the introduction of new trains depends on the
completion of infrastructure investments (e.g. electrification), but also
on the state’s ability to finance the additional capacity of Elron’s routes.
Priority is given to increase capacity on the high -demand Tallinn -Tartu
and Tallinn -Narva routes, where train occupancy is high. The plan to
increase t he frequency of the train timetable is also in line with goal of
the Ministry of Regional Affairs and Agriculture to offer more fixed
intervals services.
144. According to the financing plan developed by the Ministry of
Regional Affairs and Agriculture, the revenue from tickets should cover
25% of all public transport costs on average in 2025 and the share
should increase to 28% by 2030. According to the concept of public
transport reform, the state hopes to increase ticket revenue by
increasing the attractiveness and accessibility of the service, and
through faster and more frequent train and bus services.
145. At the same time, the Ministry of Regional Affairs and Agriculture
estimates that the ticket revenue on county bus routes is likely to fall in
2025 compared to 2024 due to a decrease in the number of
passengers. 30% of all passengers currently pay for a ti cket. People
older than 63, pupils, people with partial or full incapacity for work and
disabled people currently travel free of charge.
146. While in 2024 the train fare covered about 35% of the operating
and capital costs of the train, it only accounted for approximately 9% of
the costs of county bus routes.
147. In order to cover 25% of the costs of county bus routes by the fare,
the ticket price would have to be increased by approximately three
times, assuming that the number of passengers and the concession
rates remain the same. The revenue base could also be i ncreased by
reducing concessions for students, residents aged over 63, and people
with partial or no capacity for work and disabled people.
Did you know that…
in cooperation with Elron, a
westbound clock -face train
service is tested since April
2025, which means that
departures take place at fixed
intervals.
Source: website of AS Eesti
Liinirongid

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 34
148. The fare policy has affected the number of passengers on county
bus routes, which increased following the decision of the Government of
the Republic to allow residents to travel free of charge on county bus
routes from the second half of 2018. In 2024, a f are for working -age
people was established again, leading to a slight decrease in the
number of passengers thereafter. However, there has been a steady
increase in the number of kilometres travelled. The Public Transport
Programme 2025 –2028 still forecasts a further increase in the number
of passengers on county bus routes (see Figure 7).
Figure 7. Number of passengers and route kilometrage on county bus
routes 2018 –2024 and expected growth in passenger numbers

Source: Reports on subsidies for public regular services for road transport and the Public Transport
Programme 2025 –2028
149. The concept of the public transport reform foresees increasing the
share of commercially operated bus services as one of the options to
reduce the need to subsidise public transport. In the case of increased
commercial initiative, the role of the state would remain first and
foremost to determine the need for the service to be covered by
monitoring it.
150. According to the public transport centres, commercial operators
are currently not interested in resuming the operation of routes between
hubs without public co -financing, as it is not financially viable. The
Union of Estonian Automobile Enterprises, which brings together the
enterprises operating major bus services, has confirmed that
commercial bus services will not return to the levels seen before the
introduction of free public transport in the foreseeable future at current
fare levels.
151. According to the National Audit Office, public transport should be
financed according to uniform principles and the state should not pay
for unnecessary or too expensive routes. This means that the Ministry of
38,9 42,3
48,5 48,9
19,5 22,5 23,1 21,9 24,1 25,6
0,0
10,0
20,0
30,0
40,0
50,0
60,0
2018 2019 2023 2024 2025 2028
Route kilometrage (million km)
Number of passengers, forecast indicated by dotted lines (million)
Did you know that…
there are no plans to raise
fares for county bus services
or ferries in 2025. The price
of train tickets was increased
both in early 2024 and in
2025. The price of airline
tickets increased from 1
February 2025. For example,
a regular ticket to Kuressaare
costs €36 instead of the
former €30. A change in train
fares entered into force in
March: The fares on longer
trips on long -distance routes
decreased by 16%, while on
some routes, the price
increased by up to 23%.
Source: Ministry of Regional
Affairs and Agriculture
Opinion of the
National Audit Office

Organisation of public transport (follow -up audit of county public transport)
35 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
Regional Affairs and Agriculture must establish rules on when
maintaining a route should be considered unreasonably expensive or
when routes should be reorganised.
152. In the opinion of the National Audit Office, it is positive that public
transport centres are analysing the economic feasibility of the routes in
their region and have increasingly made bus routes or parts of bus
routes in the region demand -responsive in o rder to save money. At the
same time, the optimisation criteria (e.g. minimum number of
passengers, passenger cost per route kilometre) set by the public
transport centres are not uniform and should be set by the Ministry.
153. Reducing the number of routes or increasing the fares may actually
mean a reduction in the number of public transport users, contrary to
the objectives. Nevertheless, and given that there is no money in the
Ministry’s basic budget to cover the current comm itments and that the
shortfall in public transport funding, i.e. the gap between the costs and
revenues of public transport, is increasing, the Ministry of Regional
Affairs and Agriculture should still analyse whether the state can provide
county bus servi ces at the current level and with the current
concessions.
154. Although a concept for the public transport reform has been
prepared in order to achieve cost -efficiency and increase the
attractiveness of public transport, the National Audit Office is not
confident that the actions described in the concept would help ke ep
costs under control unless fares are increased, concessions are cut or a
solution is found to replace public routes with commercial routes .
155. Recommendations of the National Audit Office to the Minister
of Regional Affairs and Agriculture:
• identify options for reducing the funding shortfall and assess the
impact of possible actions to be taken for this purpose on the use of
public transport, including analyse impacts if county bus routes and
concessions were reduced and demand -responsive transport was
developed;
• develop funding rules to clarify the economic considerations on
which public money will not be used to subsidise the continued
operation of routes.
Response of the Minister of Regional Affairs and Agriculture: we
will analyse ways to generate additional revenue and optimise costs in
public transport. The activities of the public transport reform are also
aimed at the development of a cost -eff icient funding model. The co –
creation activities of the public transport reform are currently underway
in seven counties in order to analyse changes to the route network. In
order to reduce the costs of bus traffic, it is advisable to optimise the

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 36
route network and to discontinue departures with low occupancy rates,
or to replace these routes with on -demand services where possible.
Responsibility in the management of
public transport is fragmented and there
is overlap in the performance of tasks
156. The management of public transport is regulated by the Public
Transport Act, pursuant to which the Ministry of Regional Affairs and
Agriculture, the Ministry of Climate, the Government of the Republic and
local authorities are the authorities that plan and organise public
transport.
157. When public transport is organised by several authorities, there is a
risk that different actors perform similar tasks, which wastes both money
and human resources; there is no incentive to seamlessly combine
modes of transport because of different interests and priorities; and the
monitori ng of the performance of tasks is more complex because
responsibility is dispersed.
There is an overlap of tasks in public transport
organisation and no clear legal basis for the allocation of
some of these tasks
158. Economically viable and comprehensive public transport requires
determining the division of tasks, responsibilities and competencies on
legal grounds and in a form that can be interpreted by all actors in the
same manner whilst avoiding duplication.
159. The National Audit Office clarified which tasks are performed by
the ministries, the public transport centres and the Transport
Administration, on what basis, and whether and which activities are
duplicated.
160. The task of the Ministry of Regional Affairs and Agriculture is to
develop and implement county and nationwide public transport policies
(excluding infrastructure) for all modes of transport, including train, bus,
boat and air. The task of the Ministry of Climate is to develop and
implement international public transport policy and to plan and
implement mobility services, including public transport infrastructure
investment and procurement. The task of local authorities is to organise
public transport in th e administrative territory of their town, city or
municipality.
161. The Ministry of Regional Affairs and Agriculture has delegated its
tasks in the field of county bus services to public transport centres,
which are established in cooperation with local authorities and mostly
Did you know that…
the tasks of the Government
of the Republic in the
organisation of public
transport are:
• the establishment of the
procedures for granting
travel fare concessions to
passengers and for paying
them compensation from
the national budget, unless
this is delegated to the
minister;
• the establishment of a
national public transport
register.
Source: Public Transport Act, §
33, § 36 (5), § 73
Did you know that…
domestic public transport is
an important part of the
mobility service. The Ministry
of Regional Affairs and
Agriculture explained that in
the redistribution of
responsibilities between
institutions, public transport
component was separated
from sustainable mobility and
transferred to the Ministry of
Regional Affairs and
Agriculture, whilst cycling and
walking remained in the area
of government of the Ministry
of Climate.
Source: Ministry of Regional
Affairs and Agriculture
Criterion

Organisation of public transport (follow -up audit of county public transport)
37 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
operate within the county boundaries. 6 In addition to county bus
services, the Tartu County Public Transport Centre is also authorised to
carry out tasks in the area of small vessel passenger transport .
162. The analysis conducted by the National Audit Office indicated that
there are currently overlaps in the performance of several tasks (see
Table 2). For example, while the delegation of tasks to the public
transport centres still leaves the responsibility to the Ministry, it turns
out that there are tasks that the Ministry of Regional Affairs and
Agriculture has delegated to the public transport centres, but which it
also performs at least partly in parallel with the public transport centres.
Table 2. Overview of the practices of the managing parties in carrying
out their tasks
Activity Ministry of
Regional Affairs
and Agriculture
Public transport
centre
Transport
Administration
Studies of
mobility
needs
organises
nationwide mobility
needs and public
transport surveys,
which also cover the
counties
organises surveys of
the mobility needs of
the population within
the county

plans mobility to meet
mobility needs,
including organises
mobility studies, of
which public transport
is an important part
Organisati
on of
supervisio
n (see also
paragraphs
186 –198)
organises
supervision of
compliance with the
requirements of
administrative
contracts in bus
traffic
organises supervision
of compliance with
public service
contract in
cooperation with the
Ministry of Regional
Affairs and
Agriculture

Requireme
nts for
compiling
timetables
prepares the
sample form of the
mandatory
procedure for
preparation of
timetables for
public transport
centres
establishes the
requirements for the
preparation of
timetables for public
county bus services
and the procedure for
submitting, reviewing,
amending and
approving those
timetables

Organisati
on of
procureme
nts
organises
procurement to find
carriers for the
operation of
recreational craft,
organises
procurement to find
carriers for county
bus services

6 Pursuant to § 15 (2) of the Public Transport Act, local authorities and the state
authorise a regional public transport centre to perform under a administrative contract
relevant functions for the management of county public transport and upon carriage of
passengers by ferry , small vessels , ferry and air.
An overlap seems to
be primarily in the
execution of the tasks
entrusted by the
Ministry of Regional
Affairs and Agriculture
to the public transport
centres under
administrative
contracts

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 38
ferry and air
services
Source: National Audit Office
163. In addition, all public transport centres procure support services
separately, such as IT and accounting services.
164. In addition to the overlapping tasks, the National Audit Office
found that there are tasks that the Ministry of Regional Affairs and
Agriculture cannot delegate to the public transport centres by means of
administrative contracts.
165. Under the administrative contracts with public transport centres,
compliance with the requirements of the long -distance and country bus
route transport licences granted by the Ministry of Regional Affairs and
Agriculture are monitored in cooperation with the Ministry. However,
such a task has not been assigned to the Ministry by the Public
Transport Act. According to the Public Transport Act, this is a ta sk of the
Transport Administration, which cannot delegate it to the public
transport centres. 7
166. According to the Public Transport Act, it is a task of the Transport
Administration to organise the planning and management of
infrastructure sites for county bus routes and long -distance bus routes
and to take measures to create favourable traffic conditions for public
transport vehicles. The same task is assigned by the Act to local
authorities within the borders of their administrative territories. In
addition, local authorities are respons ible for building the infrastructure.
167. Although the Ministry of Regional Affairs and Agriculture has not
been assigned such tasks by the Public Transport Act, the
administrative contracts concluded by the Ministry of Regional Affairs
and Agriculture assign the planning, construction, maintenance and
operation of the infrastructure of county bus routes to the public
transport centres. The Ministry of Regional Affairs and Agricultur e has
also paid a small grant to the public transport centres for the
management of public transport infrastructure.
168. In practice, the public transport centres themselves generally do
not organise the planning, construction and maintenance of public
transport infrastructure (except for the Pärnu County Public Transport
Centre , which has built the Pärnu bus station and seven countywide
‘mini -bus stations’ ). According to the public transport centres,
7 Public Transport Act, § 17 1 (1).
The administrative
contracts currently
include tasks that
cannot be delegated
to public transport
centres

Organisation of public transport (follow -up audit of county public transport)
39 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
complaints or suggestions from people about infrastructure are passed
on to the road owner or road maintenance partner.
169. Whilst the Ministry of Regional Affairs and Agriculture is
responsible for planning and implementing public transport policy, the
Ministry of Climate is responsible for planning and procuring the public
transport infrastructure 8. This is why the Ministry of Regional Affairs and
Agriculture has no mechanism to directly steer decisions on
infrastructure. Thus, the public transport service for which the Ministry of
Regional Affairs and Agriculture is responsible depends on the task of
the Ministry of Climate to make the necessary public transport
investments.
170. For example, the Ministry of Regional Affairs and Agriculture cannot
independently assign tasks to the Transport Administration for planning
the infrastructure sites of county routes and long -distance routes, as it
is not its area of government. The decisi on -making process is therefore
slower and depends on the level of cooperation between the ministries.
171. For example, the Ministry of Regional Affairs and Agriculture plans
and organises the procurement for regular ferry services. The
construction of the state’s ferries operating between the big islands and
the mainland is at the same time planned and managed by the Ministry
of Climate, which does not itself manage domestic public transport
services.
172. The Ministry of Regional Affairs and Agriculture finds that the best
solution to boosting competition is that the ferries are owned by the
state and an operator is found for them. I.e. if the transport service
contract already concluded expires in 2033, th e Ministry of Regional
Affairs and Agriculture considers that it would be necessary for the state
to have five new ferry s available by that time.
173. However, the Ministry of Climate has said that it has no plans to
procure four new ferries, only one ferry is being procured and it will sail
between the big islands. However, it is not within the competence of the
Ministry of Climate to decide how many fe rries the state needs to own in
order to provide public transport services. The Ministry of Regional
Affairs and Agriculture, however, claims that it is up to the Ministry of
Climate to decide whether or not the purchase of new ferry s is planned.
Final fin ancing decisions for the purchase of ferries will be made by the
Government of the Republic.
8 According to § 6 of the Statute of the Ministry of Climate, the Ministry is responsible
for planning and implementing mobility and mobility services (including public
transport).

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 40
174. According to the Public Transport Act, the manager of an object of
public transport infrastructure ensures that it is maintained and that the
necessary information is available to passengers. In the case of
infrastructure built on a public road, the role of the manager of the site
is performed by the Transport Administration, and the local authority is
the manager in the administrative territory of the local authority.
175. The administrative territory of a local authority is also crossed by
public roads, which is why the current wording of the Act makes the
management of infrastructure along public roads the responsibility of
both the local authority and the state. For examp le, in the case of bus
stops, it is unclear who is responsible for the accessibility of the
infrastructure, including maintenance and adaptation to special needs.
176. According to the Ministry of Climate, the Transport Administration
is responsible for the reconstruction and maintenance of public roads
and their facilities, i.e. waiting platforms, bus lay -bys, etc. According to
the Administration, the maintenance of bus stop platforms on public
roads is the responsibility of the Transport Administration, as the
platforms are part of the road, but the approach to bus shelters varies
from region to region.
177. For bus stops with a shelter, notes about the manager of the shelter
(either the local authority of the Transport Administration) are entered in
the road register. The road register shows that most of the bus stops
with a shelter are maintained by local authorities, while about 250 bus
stops with a shelter ar e not maintained by anyone, i.e. they are neither
managed by a local authority nor by the Transport Administration.
178. The Transport Administration is trying to give the responsibility for
maintaining public transport infrastructure to local authorities.
According to the Transport Administration, local authorities that are
voting members of the public transport centres hav e more control over
the planning of the county route network than the state.
179. For the period 2021 –2024, the Transport Administration has signed
a total of 176 indefinite personal right of use contracts with local
authorities. Light traffic routes (262) and bus stops or shelters and
platforms (36) have mostly been the objects of the contracts. The
approach has mostly been applied to newer bus stops that are still
being built, which is why the practice has not been applied uniformly
across Estonia.
180. There is no clear division of responsibilities and tasks for the
economically viable organisation of county bus transport. Therefore, the
same task is at least partly performed by several authorities in practice,
the application of uniform principles across Estonia is not ensured, and
the competence to organise support services, in particular procureme nt,
is spread across different authorities.
Maintenance of public
transport
infrastructure requires
a clearer division of
responsibilities
between the parties
Photo 1. Bus stop with
fixtures

Source: Website of Lizmet OÜ
Did you know that…
the number of stops with
passenger boardings between
January and May 2024 is
12,223.
There are 269 car parks of
the Transport Administration.
There are 2,535 light traffic
paths in the road register, of
which 548 are owned by the
state.
Source: Data of the ticketing
system of Ridango AS, the Land
Board, the road register
Opinion of the
National Audit Office Platform
Shelter
Bus lay -by

Organisation of public transport (follow -up audit of county public transport)
41 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
181. In the opinion of the National Audit Office, the legality of the
administrative contract s concluded with public transport centres must
be reviewed and the administrative contracts renewed. At present, the
administrative contracts contain tasks for the delegation of which the
Public Transport Act does not provide a basis, so under the current law,
the Ministry of Regional Affairs and Agriculture should not assign such
tasks to the public transport centres.
182. In addition, the Ministry of Climate and the Ministry of Regional
Affairs and Agriculture should work together to consider how to divide
the responsibilities for mobility services, infrastructure and monitoring
so that public transport policy making in roa d, rail, water and air
transport is not fragmented between several areas of government and
the Ministry of Regional Affairs and Agriculture can organise public
transport comprehensively.
183. Recommendation of the National Audit Office to the Minister
of Regional Affairs and Agriculture and the Minister of
Infrastructure: prepare a proposal on how to divide the responsibilities
for mobility services, infrastructure and monitoring between the Ministry
of Climate and the Ministry of Regional Affairs and Agriculture, so that
public transport policy making in road, rail, water and air transport is not
fragmented between several areas of government, i.e. the responsibility
is clearly divided.
Response of the Minister of Regional Affairs and Agriculture: as we
amend the Public Transport Act, we will review the responsibilities and
tasks and, in cooperation with the Ministry of Climate, make proposals
to amend the Act accordingly.
Response of the Minister of Infrastructure: with the amendments to
the Government of the Republic Act and the Public Transport Act, the
Riigikogu has decided that from July 2023, two ministries will have
responsibilities related to public transport in addition to local
authorities: the Ministry of Regional Affairs and Agriculture and the
Ministry of Climate. The Ministry of Regional Affairs and Agriculture is
the main responsible authority and manager of public transport, and its
task is to develop and impl ement public transport policy (see also § 65 1
of the Government of the Republic Act and § 16 (1) 1 1 of the Public
Transport Act). Pursuant to the Public Transport Act, the Ministry of
Climate makes and implements the international public transport policy
(§ 17 (1) 1) of the Public Transport Act). In addition, pursuant to the
Government of the Republic A ct, the Ministry of Climate has been
granted the right to ‘empower’ the public transport sector in the field of
public transport infrastructure investments, as the Ministry of Climate
has been given general competence by law to invest in transport
infrastructure (§ 61 of the Government of the Republic Act).

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 42
Thus, it is only relatively recently that the Government of the Republic
has sought to change the division of the areas of government of
ministries, and the legislator has established this at the level of laws. In
managing public transport, the Ministry of Climate and the Ministry of
Regional Affairs and Agriculture must proceed from the tasks and
competences laid down in the Government of the Republic Act and the
Public Transport Act; the law does not provide for the possibility of
transferring the tasks a ssigned to the Ministry of Climate to the Ministry
of Regional Affairs and Agriculture, or vice versa.
The Ministry of Climate has also not seen the materialisation of the risk
that there is no will for cooperation as highlighted by the National Audit
Office. In order to mitigate the risks highlighted by the National Audit
Office in paragraph 157, the minis tries and agencies cooperate closely,
both on a daily basis and in the framework of case -based discussions,
as appropriate.
Comment of the National Audit Office: In the opinion of the National
Audit Office, the current wording of the Government of the Republic Act
and the Public Transport Act does not preclude ministers from
proposing amendments to the legislative acts in order to more clearly
delimit the tasks sh ared by the two ministries – those related to mobility
services, infrastructure and supervision . In the present case, the Ministry
of Climate plans the infrastructure, but the Ministry of Regional Affairs
and Agricultur e organises the passenger transport . However, it is not
clear how, for example, the Ministry of Climate ensures that passengers
start using the infrastructure. The National Audit Office considers it
important to emphasise that it must be clear who is ultimately
responsible for the overall s olution, i.e. the infrastructure and service,
and what levers are in place to achieve the objectives.
184. Recommendations of the National Audit Office to the Minister
of Regional Affairs and Agriculture:
• consider implementing the practice of joint organisation of support
services, including procurement, to achieve economies of scale,
concentrate currently dispersed competences in a single authority
and foster professional capacity building, among other things;
• analyse the tasks assigned to public transport centres by the
administrative contracts to make sure they are legitimate and
appropriate and that duplication of activities is avoided.
Response of the Minister of Regional Affairs and Agriculture: we
agree with the recommendation to assess the uniform organisation of
support services (e.g. ticketing systems). The review and renewal of the
administrative contracts with the public transport centres is on the
agenda of the Ministry. In connection with this, we will also give
attention to the centralisation of support services and review the tasks

Organisation of public transport (follow -up audit of county public transport)
43 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
assigned to public transport centres. We will start work on the renewal of
the administrative contracts already this year and plan to finalise them
in the course of the next year.
185. Recommendation of the National Audit Office to the Minister
of Infrastructure: in cooperation with the Ministry of Regional Affairs
and Agriculture, agree on the management of bus stops along state
roads and their fixtures, so that it is clear who is responsible for the
maintenance of bus stops and, if necessary, for bringing them i nto
compliance with requirements, and implement the principles developed
uniformly throughout Estonia.
Response of the Minister of Infrastructure: as we pointed out in our
previous response, the Ministry of Regional Affairs and Agriculture is the
main responsible authority and manager of public transport, whose
tasks include developing and implementing public transport policy, and
the Ministry of Cli mate has the overall competence for transport
investments, including investments in public transport infrastructure. At
the same time, it makes sense that the Ministry of Regional Affairs and
Agriculture also has the competence and the right to deal with public
transport investments, as this is essentially part of the implementation
of the public transport policy, and § 24 of the Public Transport Act also
provides for the possibility to finance the construction, r enewal or
management of objects of infrastructure from the earmarked subsidy for
public transport allocated in the state budget.
Pursuant to the Government of the Republic Act, the responsibility of the
Ministry of Climate for the state’s public transport investments is
broader, which is why the Public Transport Act also grants the
authorisation to deal with public transport infrast ructure investments. At
the same time, the legislator has left investment in public transport
within the area of government of both ministries as well as local
authorities, so that it can be managed and designed in the most
effective way in cooperation. Su ch combined competence also makes it
possible to use the funding sources available to public transport
authorities, including external funding, more efficiently and reduce the
risk that, for example, time -critical public transport infrastructure
constructi on or improvement is delayed due to the exhaustion of the
budgetary possibilities of one authority, if the respective task was
stipulated only in the area of competence and responsibility of a single
authority. This flexibility in the management of public transport
infrastructure is therefore also in the direct interest of passengers.
In addition, we would like to clarify that the maintenance of the waiting
platforms of the bus stops of county and long -distance routes by state
roads and their compliance with the accessibility requirements is
generally managed by the Transport Administration under § 17 1 of the
Public Transport Act. Bus stops, which only serve urban or county routes

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 44
operated by the local authority, may also be located alongside state
roads, for example, if they are located in a settlement and are very
frequently used, and where the roads leading to the bus stop are local
roads the maintenance of which is managed by the local authority. In
such cases, it may be practical for the local a uthority, by agreement with
the Transport Administration, to manage the maintenance of the
platforms in order to better meet the needs of organising local life.
There are also many ‘hybri d’ stops used by long -distance and/or county,
urban and/or municipality services, where the competent authorities
have agreed to ensure that the stop is managed according to the
specific needs of the regular bus routes .
Thus, the management of bus stops on state roads is organised
according to the current legal basis, with the competent parties being
the Transport Administration and the local authority of the
administrative territory concerned, and this allows for a better reflection
of local circumstances and ne eds. The agreement between the Minister
of Infrastructure and the Minister of Regional Affairs and Agriculture
recommended by the National Audit Office cannot replace the
competences already provided for by law.
Comment of the National Audit Office: based on the comments of
the Ministry of Climate, the National Audit Office has amended
paragraph 167 regarding the role of the Ministry of Regional Affairs and
Agriculture in making small -scale investments. The National Audit Office
notes that although t he Ministry of Regional Affairs and Agriculture and
the Ministry of Climate are both investing in public transport
infrastructure, it is not clear from the legislation which ministry is
responsible for which investments and where the border between large
and small -scale public transport investments lies. See also the comment
of the National Audit Office on shared responsibility in paragraph 183.
The National Audit Office points out that the competences for the
maintenance of bus stops are not clearly enough divided at present, and
although according to the Public Transport Act the manager of the
object of infrastructure is responsible for the maintenance of the object,
it is often not even clear who the manager is. In the case of bus stops,
responsibility is shared between two ministries – the Ministry of Climate
deals with investments in bus stops and the Ministry of Regional Affairs
and Agriculture uses the bus stop to provide a service – and local
authorities. The current wide margin of interpretation of competences
creates disagreements between public transport authorities and the
possibility to refuse to carry out tasks related to the maintenance of bus
stops. In addition, it is difficu lt for the passenger to understand who to
contact and in which cases in order to obtain or give information about
a stop. At the same time, all information on problems with service
quality should be brought together in one place.

Organisation of public transport (follow -up audit of county public transport)
45 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
Supervision of public transport centres is obstructed by
a lack of clarity on the content of tasks in contracts and
funding applications
186. Supervision of administrative contracts helps to prevent the abuse
or waste of resources and to make sure that the contract is being
performed according to the agreed terms.
187. The National Audit Office examined whether the Ministry of
Regional Affairs and Agriculture supervises the performance of the tasks
entrusted to the public transport centres by the administrative contracts.
188. Administrative supervision was carried out by the Transport
Administration until the transfer of the public transport supervision
tasks (except for inspection of the right to travel, compliance with the
route permits for long -distance, county and internati onal bus services)
to the Ministry of Regional Affairs and Agriculture. The employees who
supervised the performance of the administrative contracts stayed in
the Transport Administration, although the tasks moved to the Ministry
of Regional Affairs and Ag riculture.
189. At present, the Ministry of Regional Affairs and Agriculture
exercises little supervision over the organisation of public transport. On
a few occasions in 2024, the Ministry has supervised the performance of
the tasks set in the administrative contracts 9 by checking whether the
names and locations of stops are correct in the public transport register,
which is used by the portal peatus .ee, Google maps and others.
9 According to the administrative contracts concluded with the public transport centres,
the public transport centres are responsible for ensuring, together with the carriers, the
availability of the necessary information at bus stops and the sale of tickets on public
county bus routes, a nd for submitting data to the public transport register.
Criterion

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 46
190. As a possible solution, the Ministry of Regional Affairs and
Agriculture sees delegating at the level of law, the supervision of the
performance of public service contracts concluded in long -distance,
county, municipality and urban transport and the supervision of the
compliance of public transport vehicles in bus and coach transport to
the Transport Administratio n, because the competence is available
there.
191. According to the Transport Administration, the exercise of
supervision and requiring compliance with administrative contracts is
obstructed in their practice by the fact that the activities are not
unambiguously understandable, which means that the tasks the
performance of which can be required at all is not clear.
192. In addition, the public transport centres only have to carry out the
tasks for which the Ministry of Regional Affairs and Agriculture has
allocated funds. However, the costs for which the money is requested,
including the tasks that the public transport ce ntres would have to
perform under the administrative contract, have not been specifically
outlined in the applications filed by public transport centres to receive
subsidies for public bus services. Therefore, the public transport centres
have a certain di scretion on how to use the money allocated to them.
193. There are many examples that all the costs that must be planned
for the performance of the tasks provided for in the administrative
contracts cannot be detailed in the applications for subsidies. For
example, only five public transport centres have identified the cost of
changing timetables in 2023 in their applications, and four public
transport centres have identified the cost of ro ute studies.
194. This is well illustrated by the requirement to display information at
bus stops. Some public transport centres put the information up at all
stops, but others have made their own arrangements that information is
only displayed at stops with a certain numbe r of service users. The
Ministry of Regional Affairs and Agriculture believes that timetable
information should be kept up to date at all stops. During the
supervision of administrative contracts, the Transport Administration
pointed out that the public tr ansport centres were not fulfilling their
obligation because, in the opinion of the centres, no money had been
allocated for this.
195. The supervision of the activities of the public transport centres by
the Ministry of Regional Affairs and Agriculture is weak and this is why
there is no assurance that the administrative contracts are being
performed as agreed in the terms of the contract. The Ministry of
Regional Affairs and Agriculture does not have a defined procedure or
human resources to supervise the activities of the public transport
centres.
Did you know that…
Government of the Republic
Regulation No 17 of
26.02.2016 “Procedure for
subsidising public transport
from the state budget,
reporting on the use of
subsidies and repayment
subsidies” has been
established to regulate the
procedure for applying for
subsidie s from the state
budget and reporting on the
use of subsidies. The audit
revealed that the content of
the regulation is misleading,
outdated and does not
provide a clear overview of
how funding for public
transport is actually to be
applied for from the st ate
budget, nor how the use of
subsidies is reported and
verified in practice. .
Source: Government of the
Republic Regulation No 17
“Procedure for subsidising public
transport from the state budget,
reporting on the use of subsidies
and repayment subsidies”.
Opinion of the
National Audit Office

Organisation of public transport (follow -up audit of county public transport)
47 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
196. In addition, requiring the performance of the administrative
contracts is obstructed by the vague connection between the tasks and
the financing, i.e. the tasks for the performance of which the public
transport centres have been given money and the amount of the money
are not clear.
197. In the opinion of the National Audit Office, the applications for
subsidies for public route transport should be reviewed, if only because
the regulation that regulates the calculation of the need for the
subsidies for public transport allocated from the state budget, the
submission of the relevant applications and the inspection of the use of
subsidies from the state budget has not yet been upda ted. When
reviewing applications, the Ministry of Regional Affairs and Agriculture
must ensure that the practices of performance of the administrative
contracts by the public transport centres are consistent everywhere and
that the information provided in the applications is sufficiently detailed
to avoid disputes during the supervision of the performance of a n
administrative contract.
198. Recommendations of the National Audit Office to the Minister
of Regional Affairs and Agriculture:
• distinguish the costs listed under other costs in the applications for
subsidies for public route trasport filed by public transport centres
so that money is allocated in the budget for the performance of all
the tasks stipulated in the administrative contract s;
• develop a policy and work plan for the annual supervision of the
performance of administrative contracts.
Response of the Minister of Regional Affairs and Agriculture: the
costs of the public transport centres themselves and other projects and
activities are broken down in great detail in the applications submitted
by the public transport centres to the Ministry of Regional Affairs and
Agriculture. All cost lines are rev iewed one by one and their necessity is
assessed when the applications are reviewed with the Ministry of
Regional Affairs and Agriculture and the public transport centres. We will
review the adm inistrative contracts with public transport centres to
ensure that the budget corresponds to the tasks to be carried out.
We agree that supervision of public transport centres is weak. Making
supervision more efficient includes regular inspection of the
performance of the obligations assigned in the administrative contracts
and in -depth audits of the subsidies allocated to the public transport
centres. We will apply for separate resources to carry out these tasks.

/digitally signed/

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 48
Ines Metsalu -Nurminen
Director of Audit, Audit Department

Organisation of public transport (follow -up audit of county public transport)
49 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
Recommendations made by National Audit Office and
responses of the auditees
Based on the audit, the National Audit Office made a number of recommendations to the Ministry of
Regional Affairs and Agriculture and the Ministry of Climate. The Minister of Infrastructure and the
Minister of Regional Affairs and Agriculture sent their r esponses to the recommendations of the
National Audit Office between 29.09. –01.10.2025. Saaremaa Municipality Government sent its
comments on audit report.
General comments on audit report
Opinion of the Saaremaa Municipality Government on the draft audit report:
Reading the topics covered in the audit and dealing with public transport issues on a daily basis, one of the major
bottlenecks is the IT capacity of the state. This concerns several areas from analytics to route planning and demand –
responsive solutions. S aaremaa analyses passenger mobility trends on a continuous basis, but today’s solutions require a lot
of time resources, which could be more efficiently covered with modern IT solutions.
In 2026, we plan to launch a procurement to find a partner to carry out a new mobility survey covering the whole Saare
County in 2027.
In paragraph 74, it would make sense if the Ministry of Regional Affairs and Agriculture created a functioning coordination
system to link the timetables of commercial and public county routes.
Returning to paragraph 70: in 2025, the Ministry of Regional Affairs and Agriculture suggested that public transport centres
could merge into regional public transport centres, but it would be sensible instead (paragraph 74) to create a capacity
within the structure of the Ministry of Regional Affairs and Agriculture that could integrate the timetables of the counties
into a whole. This paragraph is already supported by paragraph 57 (the Ministry of Regional Affairs and Agriculture issues
route licences for long -distance bus services).
We support the idea, which we have already communicated to the Ministry of Regional Affairs and Agriculture, to implement
a single ticketing system throughout Estonia (on urban and county buses, trams, trains, ferries, airplanes and commercial
services), w hich would make it easier for passengers to choose their desired route between the start and end points and
would support the use of public transport more broadly.
Paragraph 101 – responsible stop owner: the state (Transport Administration) or local authority. The state should define
more clearly the legal conditions for the management and maintenance of bus stops.
Paragraph 182 – mobility services under one ministry!
The state should centralise ICT tasks and ticketing solutions in the state as a whole. The state could integrate central view s
on different transport connections (bus, train, ferry , plane) so that people can plan journeys, book and buy tickets and
monitor timetables in real time, as people want to use more and more services on a streaming platform/app in the future.
Improve and standardise data collection so that data analyses can be made easier and similar. The objective is to reduce
manual work in data collection and move towards artificial intelligence (AI) or automatic data transmission. The transfer to
paid publi c transport showed that local authorities or public transport centres could not/were not allowed to use the
personal data in national databases and the latter had to request the existing personal data and enter them manually again
in order to obtain travel fare concessions, even though all the data were available in the national databases. The end result
was a heavy workload and compliance with the required data security rules may have been overlooked in data processing.
Saaremaa Municipality as the manager of county public transport has considered and assessed whether it would be
sensible to centralise procurement and support services under one authority or to join a public transport centre instead.
Today, Saaremaa Munici pality manages public transport for the whole Saaremaa County (15 merged local authorities plus
Muhu Municipality). Saaremaa Municipality has already established additional capacities in the ICT, legal, administration,
transport, finance, supervision, comm unication, roads, social and educational services, support services, development,
construction and planning areas, which creates cost efficiency and ensures sufficient organisational support for the proper
performance of tasks. The Civitta survey shows tha t satisfaction with public transport varies widely by county, while
satisfaction in Saaremaa is already slightly higher. The survey also shows that Saaremaa has a good average bus occupancy
rate (23%), which is also one of the highest in Estonia. The trans fer of the Saare management model to a public transport
centre will not give substantial savings, as someone will still have to stay on the island to coordinate this area. At the sa me
time, by moving jobs out of the municipality, the public transport centr e will have to deal with other topics and support

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issues, which are well covered by the municipality’s budget, day -to-day work and presence. Therefore, in summary,
Saaremaa, Hiiumaa and Muhu municipalities do not see the merger as practical, because the islands have many
specificities that relate to both maritime and air transport. On the islands, there are currently no local routes that cross
county borders or duplication in public transport, so the cross -use of public transport is mainly by ferry and air. The main
strengths in Saaremaa, Muhu and Hiiumaa are the high level of local competence and a rational management line, which
ensures the operationality of the service and a high level of local situational awareness. In many cases, changes to service
arrangements need to be made quickly in the school yea r, during crowded events or other occasions, as the start of school
or changes to the work schedules of companies can require crucial changes in regional timetables and travel needs.
All in all, the municipalities of Saaremaa, Muhu and Hiiumaa consider it expedient to continue with the current model of
public transport administration on the big islands in order to ensure a sustainable management of high -quality local public
transport. The shared view of the municipalities is that combining the management of public transport on the islands will
not create economic, social or logistical benefits and will not create any advantages in management. In our opinion,
centralisation would create more bureaucracy, more layers of management, a loss of local expertise, less user -friendly and
operational services, and weaken the accessibility of services in the region.
Response of the Minister of Regional Affairs and Agriculture:
All in all, the Ministry of Regional Affairs and Agriculture welcomes the recommendations made by the National Audit Office
and considers that the audit of the organisation of public transport supports the resolution of the problems raised by the
public transport reform initiated by the Ministry in 2024 and the implementation of the suggested solutions.
The Ministry of Regional Affairs and Agriculture does not consider it necessary to develop a separate procedure for data
sharing, as it has provided public transport centres with a practical solution in the form of a web -based software for
analysing the ro ute network, which can display relevant statistics and mobility data in different layers of maps to assess the
impact of route network changes. The report on the use of stops, based on validation data from county routes, will be ready
for use by public tra nsport centres in the near future. We will then continue to analyse other indicators based on the
validation data, using the Power BI tool, which helps study the available data dynamically and better assess the feasibility of
the routes.
The development of service level standards is underway and a single network of routes is already being developed as part of
the mobility reform. It is planned to change the definitions of routes and services and the related rules of conduct with an
amendme nt to the Public Transport Act in order to divide responsibility and funding principles more clearly.

Recommendations of the National Audit
Office
Responses of auditees
Route network design
44. Recommendation of the National Audit Office
to the Minister of Regional Development and
Agriculture: develop a procedure for sharing data
with public transport centres in order to study the
mobility needs of people who use public transport as
well as those who do not.
paragraphs 29 –39

Response of the Minister of Regional Affairs and Agriculture:
We produce regular annual reviews, which we share with the public
transport centres. The report on the use of stops, based on
validation data from county routes, will be ready for use by public
transport centres in the near future. We will then continue to
analyse other indicators based on the validation data, using the
Power BI tool, which helps study the available data dynamically
and better assess the feasibility of the routes.
In addition, the Ministry of Regional Affairs and Agriculture has
provided the public transport centres with a n online route network
analysis software, which can display different data, such as the
location of people’s places of residence, schools and
kindergartens, as map layers. We also plan to add validation data,
i.e. the usage of stops, as a data layer. As new data are generated,
we add new data layers to the analysis software. In addition, there
is the possibility to use mobile positioning data.
The Ministry of Regional Affairs and Agriculture does not consider
it necessary to develop additional procedures, as all information
exchange runs smoothly on a day -to-day basis and, as new IT

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51 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
solutions become available, these tools will immediately be made
available to the public transport centres.
Route network design
76. Recommendations of the National Audit
Office to the Minister of Regional Affairs and
Agriculture:
• ensure the functioning of a single nationwide
public transport service covering different modes
of transport (including ferry, train, county and local
bus services), which also includes the creation of
a central timetable coordination system;
• if the use of the current public transport model
continues, amend the public law contracts with
the public transport centres so that they have the
right to manage transport beyond their own
county’s borders.
paragraphs 45 –72

Response of the Minister of Regional Affairs and Agriculture:
We also see the need for nationwide coordination of all modes of
transport. The plan is to resolve the hierarchy of routes and the
nationwide timetable coordination system by amending the Public
Transport Act. The administrative contracts with the public
transport centres will also be reviewed, while the current
administrative contracts do not prohibit the opening of cross –
border routes by the public transport centres.
Comment of the National Audit Office: The National Audit
Office points out that the public transport centres are competent
to manage those public functions that are entrusted to them by
the administrative contracts. At present, the Ministry has not
delegated the management of long -distance bus services to the
public transport centre in the administrative contracts, the Ministry
has this option.
Route network funding
129. Recommendations of the National Audit
Office to the Minister of Regional Affairs and
Agriculture:
• set standards for public transport service levels
and implement them uniformly across Estonia;
• develop the principles for managing and financing
DRT to make county public transport more
sustainable;
• agree, in cooperation with local authorities, on the
unambiguous content and distribution of county
bus, long -distance, local authority and on -demand
services, and on the principles of financing.
paragraphs 109 –123

Response of the Minister of Regional Affairs and Agriculture:
the goal of the Ministry of Regional Affairs and Agriculture is that
the service level standards ensure support for the implementation
of the public transport reform. The development of service level
standards is underway and the planned deadline is next year. A
pilot project for demand -responsive transport is underway in
Saaremaa, and an analysis of the results of this project can be
used as a basis for drawing up more general principles for the
management of demand -responsive transport . However, the
management of demand -responsive transport may not always be a
more sustainable solution, because it serves a small number of
passengers at a time. It is planned to change the definitions of
routes and services with an amendment to the Public Transport
Act in order to divide responsibility and fun ding principles more
clearly.
Route network funding
155. Recommendations of the National Audit
Office to the Minister of Regional Affairs and
Agriculture:
• identify options for reducing the funding shortfall
and assess the impact of possible actions to be
taken for this purpose on the use of public
transport, including analyse impacts if county bus
routes and concessions were reduced and DRT
was developed;
• develop funding rules to clarify the economic
considerations on which public money will not be
used to subsidise the continued operation of
routes.
paragraphs 130 –150

Response of the Minister of Regional Affairs and Agriculture:
we will analyse ways to generate additional revenue and optimise
costs in public transport. The activities of the public transport
reform are also aimed at the development of a cost -eff icient
funding model. The co -creation activities of the public transport
reform are currently underway in seven counties in order to
analyse changes to the route network. In order to reduce the costs
of bus traffic, it is advisable to optimise the route network and to
discontinue departures with low occupancy rates, or to replace
these routes with on -demand services where possible.
Management of public transport
185. Recommendation of the National Audit
Office to the Minister of Regional Affairs and
Agriculture and the Minister of Infrastructure:

Response of the Minister of Regional Affairs and Agriculture:
as we amend the Public Transport Act, we will review the

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Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 52
prepare a proposal on how to divide the
responsibilities for mobility services, infrastructure
and monitoring between the Ministry of Climate and
the Ministry of Regional Affairs and Agriculture, so
that public transport policy making in road, rail, water
and air transport is not fragmented between several
areas of government, i.e. the responsibility is clearly
divided.
paragraphs 158 –179
responsibilities and tasks and, in cooperation with the Ministry of
Climate, make proposals to amend the Act accordingly.
Response of the Minister of Infrastructure: with the
amendments to the Government of the Republic Act and the
Public Transport Act, the Riigikogu has decided that from July
2023, two ministries will have responsibilities related to public
transport in addition to local authorities: the Ministry of Regional
Affairs and Agriculture and the Ministry of Climate. The Ministry of
Regional Affairs and Agriculture is the main responsible authority
and manager of public transport, and its task is to develop and
implement public transport policy (see also § 6 51 of the
Government of the Republic Act and § 16 (1) 1 1) of the Public
Transport Act). Pursuant to the Public Transport Act, the Ministry
of Climate makes and implements the international public
transport policy (§ 17 (1) 1) of the Public Transport Act). In addition,
pursuant to the Government of the Republic Act, the Ministry of
Climate has been granted the right to ‘empower’ the public
transport sector in the field of public transport infrastructure
investments, as the Ministry of Climate has been given general
competence by law to invest in transport infrastructure (§ 61 of the
Government of the Republic Act).
Thus, it is only relatively recently that the Government of the
Republic has sought to change the division of the areas of
government of ministries, and the legislator has established this at
the level of laws. In managing public transport, the Ministry of
Climate and the Ministry of Regional Affairs and Agriculture must
proceed from the tasks and competences laid down in the
Government of the Republic Act and the Public Transport Act; the
law does not provide for the possibility of transferring the tasks
assigned to the Ministry of Climate to the Ministry of Regional
Affairs and Agriculture, or vice versa.
The Ministry of Climate has also not seen the materialisation of
the risk that there is no will for cooperation as highlighted by the
National Audit Office. In order to mitigate the risks highlighted by
the National Audit Office in paragraph 157, the minis tries and
agencies cooperate closely, both on a daily basis and in the
framework of case -based discussions, as appropriate.
Comment of the National Audit Office: In the opinion of the
National Audit Office, the current wording of the Government of
the Republic Act and the Public Transport Act does not preclude
ministers from proposing amendments to the legislative acts in
order to more clearly delimit the tasks sh ared by the two ministries
– those related to mobility services, infrastructure and supervision .
In the present case, the Ministry of Climate plans the
infrastructure, but the Ministry of Regional Affairs and Agricultur e
manages the carriage of passengers. However, it is not clear how,
for example, the Ministry of Climate ensures that passengers start
using the infrastructure. The National Audit Office considers it
important to emphasise that it must be clear who is ulti mately
responsible for the overall solution, i.e. the infrastructure and
service, and what levers are in place to achieve the objectives.
Management of public transport
184. Recommendations of the National Audit
Office to the Minister of Regional Affairs and
Agriculture:

Response of the Minister of Regional Affairs and Agriculture:
we agree with the recommendation to assess the uniform
management of support services (e.g. ticketing systems). The

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53 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
• consider implementing the practice of joint
management of support services, including
procurement, to achieve economies of scale,
concentrate currently dispersed competences in a
single authority and foster professional capacity
building, among other thing s;
• analyse the tasks assigned to public transport
centres by the public law contracts to make sure
they are legitimate and appropriate and that
duplication of activities is avoided.
paragraphs 158 –168
review and renewal of the public law contracts with the public
transport centres is on the agenda of the Ministry. In connection
with this, we will also give attention to the centralisation of support
services and review the tasks assigned to public transp ort centres.
We will start work on the renewal of the public law contracts
already this year and plan to finalise them in the course of the next
year.
Management of public transport
185. Recommendation of the National Audit
Office to the Minister of Infrastructure: in
cooperation with the Ministry of Regional Affairs and
Agriculture, agree on the management of bus stops
along state roads and their fixtures, so that it is clear
who is responsible for the maintenance of bus stops
and, if necessary, for bringing them i nto compliance
with requirements, and implement the principles
developed uniformly throughout Estonia.
paragraphs 174 –179

Response of the Minister of Infrastructure: as we pointed out
in our previous response, the Ministry of Regional Affairs and
Agriculture is the main responsible authority and manager of
public transport, whose tasks include developing and
implementing public transport policy, and the Ministry of Cli mate
has the overall competence for transport investments, including
investments in public transport infrastructure. At the same time, it
makes sense that the Ministry of Regional Affairs and Agriculture
also has the competence and the right to deal with p ublic
transport investments, as this is essentially part of the
implementation of the public transport policy, and § 24 of the
Public Transport Act also provides for the possibility to finance the
construction, renewal or management of objects of infrastru cture
from the earmarked subsidy for public transport allocated in the
state budget.
Pursuant to the Government of the Republic Act, the responsibility
of the Ministry of Climate for the state’s public transport
investments is broader, which is why the Public Transport Act also
grants the authorisation to deal with public transport infrast ructure
investments. At the same time, the legislator has left investment in
public transport within the area of government of both ministries
as well as local authorities, so that it can be managed and
designed in the most effective way in cooperation. Su ch combined
competence also makes it possible to use the funding sources
available to public transport authorities, including external funding,
more efficiently and reduce the risk that, for example, time -critical
public transport infrastructure constructi on or improvement is
delayed due to the exhaustion of the budgetary possibilities of one
authority, if the respective task was stipulated only in the area of
competence and responsibility of a single authority. This flexibility
in the management of public transport infrastructure is therefore
also in the direct interest of passengers.
In addition, we would like to clarify that the maintenance of the
waiting platforms of the bus stops of county and long -distance
routes by state roads and their compliance with the accessibility
requirements is generally managed by the Transport
Administration under § 17 1 of the Public Transport Act. Bus stops,
which only serve urban or county routes operated by the local
authority, may also be located alongside state roads, for example,
if they are located in a settlement and are very frequently used,
and where the roads leading to the bus stop are local roads the
maintenance of which is managed by the local authority. In such
cases, it may be practical for the local authority, by agreement with

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Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 54
the Transport Administration, to manage the maintenance of the
platforms in order to better meet the needs of organising local life.
There are also many ‘hybrid’ stops used by long -distance and/or
county, urban and/or municipality services, where the compe tent
authorities have agreed to ensure that the stop is managed
according to the specific needs of the regular bus routes .
Thus, the management of bus stops on state roads is organised
according to the current legal basis, with the competent parties
being the Transport Administration and the local authority of the
administrative territory concerned, and this allows for a better
reflection of local circumstances and nee ds. The agreement
between the Minister of Infrastructure and the Minister of
Regional Affairs and Agriculture recommended by the National
Audit Office cannot replace the competences already provided for
by law.

Comment of the National Audit Office: Based on the comments
of the Ministry of Climate, the National Audit Office has amended
paragraph 167 regarding the role of the Ministry of Regional
Affairs and Agriculture in making small -scale investments. The
National Audit Office notes that although t he Ministry of Regional
Affairs and Agriculture and the Ministry of Climate are both
investing in public transport infrastructure, it is not clear from the
legislation which ministry is responsible for which investments and
where the border between large and small -scale public transport
investments lies. See also the comment of the National Audit
Office on shared responsibility in paragraph 183.
The National Audit Office points out that the competences for the
maintenance of bus stops are not clearly enough divided at
present, and although according to the Public Transport Act the
manager of the object of infrastructure is responsible for the
maintenance of the object, it is often not even clear who the
manager is. In the case of bus stops, responsibility is shared
between two ministries – the Ministry of Climate deals with
investments in bus stops and the Ministry of Regional Affairs and
Agricultu re uses the bus stop to provide a service – and local
authorities. The current wide margin of interpretation of
competences creates disagreements between public transport
authorities and the possibility to refuse to carry out tasks related
to the maintenance of bus stops. In addition, it is difficu lt for the
passenger to understand who to contact and in which cases in
order to obtain or give information about a stop. At the same time,
all information on problems with service quality should be brought
togeth er in one place.
Organisation of supervision
198. Recommendations of the National Audit
Office to the Minister of Regional Affairs and
Agriculture:
• distinguish the costs listed under other costs in
the applications for subsidies for public regular
services filed by public transport centres so that
money is allocated in the budget for the
performance of all the tasks stipulated in the
public law contra ct;

Response of the Minister of Regional Affairs and Agriculture:
the costs of the public transport centres themselves and other
projects and activities are broken down in great detail in the
applications submitted by the public transport centres to the
Ministry of Regional Affairs and Agriculture. All cost lines are
reviewed one by one and their necessity is assessed when the
applications are reviewed with the Ministry of Regional Affairs and
Agriculture and the public transport centres. We will review the
adm inistrative contracts with public transport centres to ensure
that the budget corresponds to the tasks to be carried out.

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55 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
• develop a policy and work plan for the annual
supervision of the performance of public law
contracts.
paragraphs 186 –194
We agree that supervision of public transport centres is weak.
Making supervision more efficient includes regular inspection of
the performance of the obligations assigned in the administrative
contracts and in -depth audits of the subsidies allocated to the
public transport centres. We will apply for separate resources to
carry out these tasks.

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Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 56
Characterisation of audit

Purpose of audit
The objective of the audit was to find out whether the changes in the organisation and financing of
county bus services that have taken place after the audit “County Public Transport” of the National Audit
Office published in 2021 have ensured that the route network is accessible to people and meets their
needs.
The audit sought to answer two main questions:
• Does the management of bus services in counties ensure a route network is accessible to people
and meets their needs?
• Is the funding of public transport sufficient for the preservation and development of the current
route network?
Assessment criteria
In the opinion of the National Audit Office, the organisation of county bus routes has ensured that the
route network is accessible to people and meets their needs, provided that the actual mobility needs of
people have been regularly identified with mobility studies and these studies have been used as a basis
for de veloping timetables. The use of public transport is also more attractive to people if the
organisation of the county bus service includes demand -responsive transport , combines different
modes of transport, ensures convenient accessibility for people with special needs, and provides access
infrastructure at transfer points for journeys involving county bus services and other modes .
In the opinion of the National Audit Office, the financing of public transport makes it possible to
preserve and develop the current route network, provided that targets connected to the budget have
been approved for development; the amount of money needed to maintain the status quo is known; a
list of necessary investments for the development of facilities (bus stops, car parks, access roads) on
the county bus routes has been established; and the planned basic funding corresponds to the cost of
preserving and developing public transport. If there is a budget shortfall, funding solutions have been
developed, including proposals for cuts, a plan to increase fare revenue, etc. for the region; the use of
the route network, including the number of passengers, and the economic viability of the routes have
been analysed; the results of the analysis have been used to optimise the network and to consider
alternative transport options ( demand -responsive transport , taxi service or social transport).
Responsibilities an d tasks have been defined for a more cost -eff icient organisation of county bus
services and they are not duplicated by the parties.
Scope of audit
The auditees included the Ministry of Regional Affairs and Agriculture, the Transport Administration, the
public transport centres and the local authorities of Saaremaa and Hiiumaa. Procedural steps were also
taken in AS Eesti Liinirongid (Elron). The audi t covered the period 2021 –2024.

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57 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
Focus of audit
The analysis of timetables used the data from the public transport register on departures from stops to
calculate the number of departures in the area of the public transport centre at the beginning of the
working day (07:00 –08:30) to counties where the wo rkplaces are located and at the end of the working
day (17:00 –19:00) to counties where homes are located. The data on the jobs and counties of the
employed people were obtained from the data on people’s place of residence and place of work in the
census of 2021.
Using the travel planning tools Google Maps and Peatus.ee, the following was clarified for one to three
routes with transfers starting from the region of each public transport centre: how much time will
getting from point A to point B take when compared to a car, how long is the waiting time for transfers,
whether and how can information on the fare for the entire route be obtained and whether a single
ticket can be used on different modes of transport. A total of 20 routes were analysed and the data of
the routes in Google Maps and Peatus.ee were mostly similar.
In order to identify modes of mobility combined with county bus services, data was collected on bus
stops, light traffic paths and car parks, and spatial data analysis was carried out . The original plan was
to take the coordinates of stops, light traffic paths and car parks from the road register. A comparison
of the stops data from the public transport register, the road register and the Ridango ticketing system
showed that the number of stops differs (see Table 3). Therefore, it was decided to use the dat a from
the ticketing system on boardings at stops from January to May 2024 for the analysis. More up -to-date
data were requested from the Ministry of Regional Affairs and Agriculture, but the Ministry was still in
the early stages of analysing the data.
Table 3. Number of stops based on data from the public transport register, road register and ticketing
system
Public transport register Road register Data of the ticketing system
Number of stops 11,522 15,708 12,223
Source: Public Transport Register, Transport Administration’s map “Use of stops” and Road Register
At least all the stops on state roads are also in the road register. Comprehensive nationwide data on
stops are available in the public transport register. However, the downside of the data in the public
transport register is that it shows active stops, i.e. you cannot see the ones that are not in use. A stop is
sometimes entered in the public transport register before it is actually built.
According to the Transport Administration, the light traffic paths along state roads are well mapped in
the road register, but the light traffic paths of local authorities are not. The map layer of car parks used
in the analysis, where the car parks are represented as dots, was obtained from the map layer of the
Land Board (extract made on 03.02.2025). According to the Land Registry, there are 2,234 car parks
(478 private car parks, 952 car parks in the case of which it is not specified whether they are private,
municipal or Transport Administration’s car parks). There are more car parks on the map layer of the
Land Board than in the road register of the Transport Administration. In addition to the road register,
the data of the Land Board also includes private car parks.
In order to find out how many bus stops are close to light traffic paths and car parks, buffers of the
following sizes were created around each bus stop: 1 m, 10 m, 50 m, 100 m, 200 m, 500 m, 1000 m.
In addition to the sources already described, the following documents were used in the audit:

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Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 58
• sectoral legislation, in particular Public Transport Act, and the related procedural information
(legislative intent, explanatory memoranda, verbatim reports, minutes of meetings);
• state budgets and state budget strategies, and their explanatory memoranda;
• the Road Maintenance Plan 2024 –2027 of the Transport Administration;
• Transport and Mobility Development Plan 2021 –2035 and Public Transport Programme 2025 –2028;
• administrative contracts between the Ministry of Regional Affairs and Agriculture and the public
transport centres;
• contract for the use of railway infrastructure between Elron and AS Eesti Raudtee;
• statutes of public transport centres;
• statutes of the Ministry of Climate, the Transport Administration, the Ministry of Regional Affairs and
Agriculture;
• reports on public regular passenger transport subsidies 01.01.2021 –31.12.2024;
• public service contracts between the public transport centres and public bus operators;
• the supervision analyses of the Transport Administration 01.01.2021 –01.07.2023 and the Ministry of
Regional Affairs and Agriculture 01.07.2023 –31.12.2024;
• studies of mobility needs of residents, mobility studies from 2021 –2024;
• decisions made on the basis of the study of alternative management models for public transport;
• accessibility analyses, including accessibility analysis of transport and the artificial environment;
• concept for the public transport reform, including the action plan;
• “Instructions for preparation of timetables” established by the Director General of the Transport
Administration on 03.01.2020;
• analyses of the use of subsidies 01.01.2021 –31.12.2024;
• proposal of public transport service level requirements to the Ministry of Regional Affairs and
Agriculture, legislation on fares, concessions, cost analyses, cost -benefit analyses of routes,
explanatory memoranda, and other documents;
• responses of public transport centres to the survey of the National Audit Office;
• stop usage data from the Ridango ticketing system as at 01.06.2024;
• road register data on bus stops as at 01.01.2025;
• division of settlement regions and data of the 2021 census from Statistics Estonia;
• open data in the public transport register.
Table 4. Interviews conducted during the audit and its preliminary explanation
Authority Interviewed Date of meeting
Ministry of Regional Affairs and
Agriculture
Andres Ruubas, Head of Public Transport Department
Hannes Luts, Adviser, Public Transport Department
Aini Proos, Adviser, Public Transport Department
26.09.2024
Ministry of Regional Affairs and
Agriculture
Andres Ruubas, Head of Public Transport Department
Hannes Luts, Adviser, Public Transport Department
06.11.2024
Transport Administration Martin Lengi, Director of Strategic Planning
Reet Reili, Director of Support Services
06.12.2024, 21.01.2025
Union of Estonian Automobile
Enterprises
Kersten Kattai, Director 20.11.2024
North -Estonian Public Transport Centre Andrus Nilisk, CEO 03.10.2024
Estonian Chamber of Disabled People Mari Puuram, Accessibility Advocacy Advisor 03.12.2024

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59 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
Ministry of Regional Affairs and
Agriculture
Andres Ruubas, Head of Public Transport Department
Aini Proos, Adviser, Public Transport Department
Pille Pikner, Area Manager, Public Transport
Department
Jaak Simon, Adviser, Public Transport Department
22.01.2025
Pärnu County Public Transport Centre Andrus Kärpuk, Director 06.02.2025
AS Eesti Liinirongid Jaagup Ainsalu, Mobility and Partnerships Manager 28.11.2024
Southeastern Public Transport Centre Sander Saar, Director 27.03.2025
Tartu County Public Transport Centre Maikl Aunapuu, Director 27.03.2025
North -Estonian Public Transport Centre Terje Villemi, Consultant, Development Department
Mikk Räli, Planner, Development Department
27.02.2025

Time of completion of audit
The audit procedures were finalised on 10.09.2025 .
Audit team
Audit Manager Silver Jakobson, auditors Silja Einberg, Meeli Saksing
Contact information
Further information on the audit is available from the Communication Unit of the National Audit Office
telephone: +372 640 0777; email: [email protected]
An electronic copy of the audit report (PDF) is available online at www.riigikontroll.ee .
A summary of the audit report is also available in English.
The number of the audit report in the record management system of the National Audit Office is 80143.
The postal address of the National Audit Office is:
Kiriku 2/4
15013 TALLINN
Telephone: +372 640 0700
[email protected]

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 60
Earlier audits of National Audit Office in the area of public
transport
25.02.2021 – County public transport services

All reports are available on the website of the National Audit Office at www.riigikontroll.ee .

Organisation of public transport (follow -up audit of county public transport)
61 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
Annex A. Main observations of the 2021 audit on county
public transport and their implementation
Observations of the National Audit
Office
Status in 2024
The public transport route network may not
meet the needs of all residents, as few
studies have been carried out to identify
actual mobility needs.
The clarification of mobility needs has improved: for the period 2021 –2024,
six public transport centres have either commissioned mobility studies, use
data from third -party work or have been involved in graduation theses. Four
public transport centres hav e carried out surveys. The three public transport
centres that responded that they had not commissioned surveys analyse
mobility needs themselves during their day -to-day work (except for the Valga
County Public Transport Centre).
For route planning, i.e. mainly for changing the routes and timetables, all
public transport centres analyse the validation data of the passengers and
the information received from the passengers (surveys, feedback,
suggestions), most of them also mentione d the information received from the
carriers and the local authorities. Mobile positioning, commuting, etc. data
describing the mobility patterns of the residents are mostly not used. Few
public transport centres have taken the people who do not use public
transport into account in their analyses. Based on the responses to the
survey, the North -Estonian Public Transport Centre, Southeastern Public
Transport Centre and Viljandi Public Transport Centre take into account the
location of points of interest and population, including mobile positioning
and commuting data in route planning . (See paragraphs 29 –34)
Convenient use of public transport is not
supported by bus and train timetables that
do not take each other into account, nor is
it facilitated by complex and fragmented
ticketing.
All the public transport centres are taking other modes of transport into
account when planning their county bus services and have tried to make
them compatible. The Ministry of Regional Affairs and Agriculture has
analysed the possibilities for connecting different modes of transport into a
coherent and functioning system, where transfers would be quick and
convenient. For example, fixed interval traffic, where vehicles depart at a
fixed interval, has been considered. A westbound fixed interval timetable h as
been tested in cooperation with Elron from 2025. At the same time, it must
be taken into account that the current instability and frequent changes in the
timetables of trains caused by frequent repairs of the rail infrastructure and
in the timetables of ferries that depend on the weather make linking them to
bus routes more difficult. There is no single ticketing system, which means
that passengers have to buy a separate ticket for each mode of transport.
(See paragraphs 45 –76.)
Free public transport has boosted demand
for travel, but has not increased the
number of commuters and has rather
increased the number of repeat users.
According to Statistics Estonia, the share of public transport users has been
on a downward trend over the last decade. Due to the COVID -19 crisis, the
use of public transport was severely restricted in the period 2020 –2021 and
the number of users fell fur ther. To date, the number of public transport users
has not reached the pre -crisis levels. (See paragraphs 1 –4.) The Ministry of
Regional Affairs and Agriculture estimates that bus ticket revenue will likely
fall in 2025 compared to 2024 due to the shift to paid public transport,
meaning that working -age people will use public transport less and prefer to
travel to work by car (see paragraph 145).
The basic level of the organisation of
county public transport has not been
agreed, i.e. there is no agreement on the
required number of passengers and
population in a region, or the cost to the
The Ministry of Regional Affairs and Agriculture has not set standards for
service levels, including a minimum baseline for the frequency of departures
that the state wants to guarantee. Although the public transport centres have
proposed service levels an d submitted them to the Ministry of Regional
Affairs and Agriculture in April 2024, there is still no agreement on where,

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 62
state at which regular bus services should
be provided in counties.
how many people and how often the bus should reach as a minimum. The
proposal of the public transport centre includes, among other things, a basic
level that should meet the most basic mobility needs of the people who do
not own cars, i.e. their journeys t o centres. (See paragraphs 110 -117.)
The parties that organise public transport
have not agreed on criteria for deciding in
which regions more economically viable
alternatives to regular bus route transport
should be considered.
The public transport centres are making increasingly more routes or parts of
routes demand -responsive in order to save money. At the same time, the
state has so far not set clear rules for the organisation and financing of the
on-demand services. At present, it is not known at what point a route or a
part of a route becomes on -demand and whether demand -responsive
transport should be financed by the state or by local authorities. (See
paragraphs 121 –123; 137 –139.)
In some regions, the state also pays for
routes that are not necessary for the
operation of the county route network and
should be financed by the local authority.
The definition in the Public Transport Act,
which divides bus routes into county and
local r outes and determines whether the
state or the local authority pays for the
organisation of the route, can be
interpreted in different ways. In practice,
the definition of routes has been
approached on a case -by-case basis.
Although the Public Transport Act defines the different types of routes, i.e.
county, long -distance and municipal, the definition still leaves a wide margin
for interpretation. This means that, it is still not clear which routes must be
managed and finance d by the public transport centre and which by the local
authority. So far, public transport centres have interpreted the ownership of
the route services differently, which has caused an inequal situation and the
services of some local authorities are urban and municipality routes managed
and financed by the local authorities themselves, while the services of other
local authorities with similar characteristics are county routes financed by the
state. (See paragraphs 118 –120.)

Organisation of public transport (follow -up audit of county public transport)
63 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
Annex B. Summary of the survey National Audit Office
The National Audit Office carried out a survey of public transport centres to get a better overview of the
public transport sector. The survey was sent to all public transport centres and the municipalities of
Saaremaa and Hiiumaa. Public transport centres respond ed via the electronic survey platform
Netsurvey. All 11 recipients responded to the survey. There were 59 questions in total, most of which
were multiple -choice ones. The most important questions and the answers given are shown in Table 5.
Table 5. Summary of the survey sent to public transport centres
Question Possible responses
Number of
public transport
centres that
chose the
answer
Management of public transport and cooperation
What are the main shortcomings in the cooperation
between the organisers of different modes of public
transport? (different options could be selected)
Changes to the timetables of the organiser s of different
modes of public transport 7
Cooperation with the Ministry of Regional Affairs and
Agriculture 7
Other (cooperation with the Ministry of Regional Affairs
and Agriculture, public transport register not functioning
properly, lack of a single ticketing system, problems with
information exchange)
5
Does the public transport centre organise routes that
cross the border of the centre’s area of
management?
Yes 9
No 2
During the period 2020 –2024, were there any routes
planned to operate crossing the public transport
center’s service area that were ultimately not
launched?
Yes 9
No 2
Has the public transport centre considered merging
with other public transport centres? Yes 6
No 5
Why has the public transport centre not merged with
another public transport centre? (different options
could be selected)
The merger does not add value 6
The right to make decisions disappears in a larger
management area 3
Local authorities do not have the necessary support 3
What are the biggest problems for the public
transport centre in terms of funding the organisa tion
of public transport? (different options could be
selected)
Uncertainty of funding, no long -term goal 6
There is no money for route network development 3
Other (unequal funding of public transport centres, fuel
price increases, no service level standards) 3
Route network planning
Have any surveys been commissioned to identify
mobility needs?
Yes 6
No 5
Yes 5

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 64
Based on the surveys of mobility needs carried out
from 2020 –2024, have any changes been made to
the services?
No 5
Data sources used for route planning, i.e. which data
are mainly used to change the routes and timetables
of services (different options could be selected)
Passenger transport statistics, including occupancy of
routes 11
Input from passengers 11
Input from bus drivers 6
Input from local authority 8
Other (location of population, schools, institutions and
companies, train and long -distance bus timetables,
proposals from carriers)
9
Alternative travel options
Has the public transport centre offered demand –
responsive transport, including on -demand services,
from 2020 –2024?
Yes 11
No 0
Who funds the on -demand services organised by the
public transport centre (Ministry of Regional Affairs
and Agriculture, local authority, or other) (different
options could be selected)
Ministry of Regional Affairs and Agriculture 11
Local authority 6
Based on your experience, what are the advantages
of organising demand -responsive transport ,
including on -demand services? (different options
could be selected)
Cost of route kilometres saved 8
Providing people with a travel option 9
Other (providing a bigger volume of travel options,
reducing the environmental footprint) 3
Based on your experience, what are the
disadvantages of organising demand -responsive
transport , including on -demand services? (different
options could be selected)
Ordering demand -responsive transport is cumbersome
and information is not easy to access 8
Planning the service is cumbersome and people do not
understand it 4
Other (additional cost, additional reporting obligation, no
remuneration component for the carrier) 4
What modes of transport does the public transport
centre combine bus timetables with? (different
options could be selected)
Train 9
Ferry 5
Plane 2
Local routes 9
Long -distance routes (across county borders) 11
Route network optimisation
Has the public transport centre analysed the
economic feasibility of the network, including the
cost of running the services and the number of
passengers?
Yes 11
No 0
What changes have you made to the route network
based on the results of the economic feasibility
analyses? (different options could be selected)
The routes of services have been changed 5
Routes or parts of routes have been changed to on –
demand 9
Has the public transport centre developed criteria
for optimising the network?
Yes 7
No 4

Organisation of public transport (follow -up audit of county public transport)
65 Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025
Supervision
Does the public transport centre carry out
contractual supervision of carriers?
Yes, it does 11
No, it does not 0
What are the main problems or obstacles in
supervising carriers? (different options could be
selected)
Lack of resources (including people, time, money) 5
No processing rights 3
Other (credibility of complaints, problems with
passengers, accuracy of validation) 3
Organisation of infrastructure
Is the public transport centre aware of any problems
with the maintenance of bus stops?
Yes 11
No 0
Please describe any known problems with the
maintenance of bus stops? (different options could
be selected)
Winter maintenance, slippery, unploughed snow 4
Damaged untidy bus stop 6
Lack of bus stop facilities, e.g. a bench 3

Organisation of public transport (follow -up audit of county public transport)
Report of the National Audit Office to the Riigikogu , Tallinn, 13 October 2025 66
Annex C. Place of residence and place of work of employed
persons by region
Table 6. Employed people according to place of residence and place of work on 31.12.2021
Source: Statistics Estonia

County Employed people in
county
Place of work
In another county Tartu % Tallinn %
Harju County 312987 3.92% 2892 0.92 234,671 74.98
Tartu County 77366 15.65% 48805 63.1 7100 9.18
Ida -Viru County 55407 19.76% 546 0.99 6895 12.4
Pärnu County 39377 20.20% 617 1.57 4730 12.01
Viljandi County 20645 21.85% 793 3.84 1933 9.36
Saare County 14791 22.15% 260 1.76 2117 14.31
Lääne -Viru County 26969 27.21% 538 1.99 4162 15.4
Võru County 15220 28.90% 1106 7.27 1620 10.7
Lääne County 9386 30.50% 126 1.34 1760 18.8
Järva County 13501 30.79% 370 2.74 2030 15
Hiiu County 4182 32.76% 83 1.98 846 20.2
Valga County 11740 35.63% 1211 10.3 1204 10.3
Jõgeva County 12228 35.71% 1384 11.3 1280 10.5
Põlva County 10649 41.28% 1650 15.5 934 8.77
Rapla County 16074 44.94% 161 1.00 4482 27.9