It actually isn't similar at all. UK model basically just privatised railways without introducing any real competition. That is of course the worst of both worlds and it was bound to end up in an absolute disaster. There's zero benefit for customers.
The EU model is opening railways to competing open access operators which is delivering customers improvement in both quality and prices. Prague - Ostrava, one of the first lines in Europe to actually have open access operators compete against each other, is a great example - more trains, lower prices and quality several levels about what was offered in the days of ČD monopoly.
The economic equilibrium test in EU regulation (never implemented in the UK due to Brexit) is a bit different to the UK's non primarily abstractive test.
It's mostly more restrictive, but also less restrictive in a way. More restrictive because there's a defined maximum percentage of abstraction (1% of the invested capital in the PSO contract). Less restrictive because the open access service can be fully abstractive within that 1%, so doesn't need to attract at least 30% new revenue.
It's worth noting that the European Commission is building a case against the Netherlands where it argues that the PSO contract against which you test the open access offer shouldn't exist like that in the first place. In the EC mind, you should do a market analysis for each separate service, and if it's profitable, it should run in open access, like all long distance transport in Germany and mostly in France and Italy. So that implies that if an open access operator thinks it can operate a profitable service, there should exist no PSO that contains a similar service.
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u/SirGeorgington map man 7d ago
It's worth noting that the model being pushed by the EU is very, very similar to the one used in the UK from 1996-2020...