SJ's hidden debt: Nearly 100 million in unpaid compensation to passengers

1. Summary: The latent PDC debt

SJ's Service Quality Report 2024, presented in accordance with current regulations, provides a picture of the operation that seemingly focuses on customer dialogue and service management.[1] However, an in-depth analysis reveals a critical strategic lack of data transparency regarding extreme delay metrics (RT+20, RT+60, RT+120) and the total financial payment of delay compensation (PDC). This lack of information masks a significant unrealized debt to travelers: The latent PDC debt.

The analysis establishes that the operational environment in 2024 was exceptionally challenging, with Traffic Analysis reporting the lowest punctuality (RT+5) since statistics began to be published.[2] Especially in the long-distance segment, where the EU regulation governs PDC law, SJ's own figures indicated that only 59 percent of trains arrived on time.[3] By modeling the potential volume of PDC-eligible trips, based on the low punctuality, it becomes apparent that the total number of eligible trips far exceeds the 297,400 PDC cases handled that SJ reported.

The conclusion is that the take-up rate, the proportion of eligible passengers who actually apply for and receive compensation, is systematically low. This low take-up rate constitutes a tacit subsidy to SJ's commercial operations.

1.2 Calculations

To get an overview of all our calculations, they are compiled in this spreadsheet.

2. SJ's operational performance in 2024: A review of service quality and punctuality

2.1. The official picture: KPIs that hide financial responsibility

SJ's Service Quality Report 2024 focuses on customer relationships, sustainable value creation and service processes. In terms of customer satisfaction, a Customer Satisfaction Index (KSI) of 67 and a Net Promoter Score (NPS) of 5 were reported for 2024. These figures reflect a low level of overall customer satisfaction. However, the report emphasizes fast handling, with the 297,400 PDC cases during the year being handled with an average response time and payment within five working days.[4]

Regarding punctuality, SJ chooses to report in accordance with the industry standard RT+5, which means trains arriving no later than five minutes and 59 seconds after the timetable.[5] By focusing primarily on RT+5, a KPI structure is created that measures operational efficiency, but downplays the direct financial exposure. For long-haul passengers, a six-minute delay is rarely financially relevant under the legislation, while delays of 60 or 120 minutes directly trigger liability. The omission of frequency data for RT+60 and RT+120 minutes thus allows the focus to shift from the quantifiable financial risk to the broader (and less financially compelling) measure of service quality.

2.2. Industry Reality: 2024 – A Year of Record Low Punctuality

The operational baseline for 2024 was exceptionally weak, which accentuates the potential PDC debt. Traffic Analysis statistics confirm that the overall punctuality (RT+5) for all passenger trains operated in 2024 was 87.1 percent, marking the lowest annual record since the statistics began to be published. This was the second consecutive year that punctuality fell below 90 percent.[6] Within the long-distance train segment, punctuality was alarmingly low. Together, Tåg i Tid (TTT) and Trafikanalys reported that only 69.7 percent of long-distance trains arrived within RT+5.[7] SJ AB's own reported figure for long-distance trains was even lower, 59 percent.[8]

2.3. Regulatory framework PDC thresholds

SJ must navigate between two overlapping legal frameworks regarding delay compensation:

3. Quantitative Analysis: Potential PDC Volume

There are large amounts of public statistics on Swedish train traffic. With this data taken from Traffic Analysis and the Swedish Transport Administration, we can gain insights into how many passengers are entitled to compensation annually across Sweden.

3.1. Data basis

3.1.1 Train departures in 2024

Traffic analysis reports that there were a total of 1,002,329 completed trains in 2024.[10] Of these, 522,113 were short-haul, 396,492 medium-haul and 83,724 long-haul.

Of these 1,002,329 departures, 8,080 were eligible for PDC.

3.1.2 Total trips in 2024

Traffic analysis reported that a total of 252,000,000 trips were made in 2024.[11]

On average, we can then see that each completed trip (1,002,329) had 251 travelers (total trips / total departures).

3.2. Estimation of PDC-eligible departures with SJ

To create an estimate of how many of these departures are operated by SJ, we must first provide an estimate of SJ's market share.

According to SJ's sustainability report, they have 500,000 daily travelers, equivalent to 182,500,000 per year.[12] Traffic Analysis reports that in 2024, a total of 252,000,000 trips were made in Sweden.[13] This tells us that SJ accounted for approximately 72.4% of all train journeys in Sweden.

With this estimate, we can assume that of the departures reported in the Traffic Analysis report on completed trains in 2024, 72.4% were completed by SJ. These are the figures you can see below.

Based on these assumptions, SJ had a total of 5,852 delayed trains in 2024 that reached the PDC limit.

3.2.1. Estimated PDC-eligible trips with SJ

With these 5,852 PDC-eligible departures, we can now get an estimate of how many passengers were entitled to compensation in 2024. With an average of 251 passengers per route, we can determine that the total number of PDC-eligible journeys on SJ trains is 1 471 174 (total amount of PDC eligible travel average amount of passengers per route).

3.3. Estimation of average ticket price for SJ-trains

SJ reports that they handled 297,400 PDC cases in 2024.[14] The total amount paid in MSEK, however, is completely missing from the Service Quality Report and other available sources. This strategic silence regarding the total amount paid is the most conclusive evidence that SJ avoids publicly quantifying the latent debt. This means that we must assume an estimated average price per ticket.

Pricing in Swedish passenger rail traffic is complex and varies greatly due to the dynamic pricing used by commercial operators, as well as the different subsidy levels in the procured traffic. In the absence of an official average price per distance segment, we have by taking sample on different trips within each category, it has been possible to assume reasonable average ticket prices (average prices) for a single trip in 2nd class.

Our method is based on the following segmentation, based on typical routes in SJ's and regional operators' traffic:

3.3.1. Short distance (under 150 km)

This segment primarily represents subsidized commuter traffic, such as Stockholm-Uppsala or Gothenburg-Alingsås. The price is low because the traffic is driven by regional tariffs and public utility goals of accessibility, rather than profit maximization.

3.3.2. Medium distance (around 300 km)

This segment acts as a bridge and covers trips such as Gothenburg-Karlstad or Stockholm-Örebro. Although some subsidy may apply, the revenue per kilometer must be higher than for Short Distance to cover longer operating costs.

3.3.3. Long distance (over 450 km)

This segment, which covers major long-distance lines such as Stockholm-Gothenburg and Stockholm-Malmö, is mainly operated commercially. The higher average price reflects the operator's need to maximize revenue (yield) through dynamic pricing to cover all costs, generate profit and finance future, capital-intensive investments in rolling stock.

4. Financial debt: Comparison between actual cases and SJ's reported cases

4.1. Calculation of potential monetary liability (MSEK)

Let's assume that an average ticket per route costs:

By weighting each ticket price against the number of trips made per route, we can calculate the price of an average ticket, regardless of the route (ticket price proportion of departures compared to total departures). With these assumptions, we get that an average ticket, purchased randomly between two locations in Sweden, is 271 SEK.

If we then add the reimbursement levels for each trip (assumption: short distance <150 km, medium and long distance >150 km), we get:

On average, a traveler who is entitled to compensation should receive SEK 84. Note that since the calculation has already weighted each ticket price based on the number of trips per route, the three amounts can be added together.

5. Economic Gap: Comparison between potential debt and actual payout

5.1. Review of actual payments and volume handled

SJ reports that they handled 297,400 PDC cases in 2024.[15] According to our calculations, this figure should be closer to 1,471,174. On average, only 20% of all passengers affected by a delay seek compensation for their journey. In 2024, over one million (1,173,774) SJ passengers went without the compensation to which they are legally entitled.

5.2. Calculation of potential monetary liability (MSEK)

Assuming an average PDC payment of SEK 84 and applying this to the number of PDC-eligible SJ passengers who never sought compensation (1,173,774), we can obtain an estimated PDC debt. The total PDC debt is then estimated at SEK 98.6 million in 2024. This represents the amount that SJ would have to pay out if all eligible passengers sought compensation.

5.3. The gap and the withdrawal rate

The comparison between the modelled potential PDC volume and the actual cases handled makes the latent debt visible. If the total volume of eligible trips amounts to around 1.5 million, and only 297,400 claims were handled, this indicates a take-up rate of around 20%. This confirms that the operator’s business model relies on the majority of consumers (around 80 percent in this case) never seeking the compensation they are legally entitled to.

6. The strategic silence: SJ's choice to avoid reporting

The analysis shows that SJ avoids reporting the key figures that directly correlate with the financial PDC debt, which is a means of minimizing payments and maintaining the latent debt.

6.1. Exclusion of financially critical KPIs

SJ chooses to focus on aspects of PDC handling that provide a positive picture of service quality: the volume of cases handled (297,400) and the fast processing time (five working days).[16] At the same time, data that would allow for external quantification of total debt is consistently excluded. These key figures are:

If SJ were to publish the exact RT+X metrics, the market would be able to immediately determine the total potential liability.

6.2. Friction as an economic barrier

The PDC system is based on the traveler actively taking the initiative and applying via a form on sj.se.[17] This is a crucial mechanism for maintaining the low drawdown rate. The statutory PDC debt is in practice transformed into an optional payment that is only realized if the traveler seeks compensation themselves.

The latent debt thus represents a form of unrealized economic benefit, or cost avoidance, for SJ. If the withdrawal rate is as low as 20 percent, the operator "saves" over 80 percent of its statutory debt. This avoided cost can be seen as a systematic subsidy financed by those passengers whose statutory rights are not realized, which helps to stabilize the company's finances in a year of record-low punctuality.

6.3. The debt loses legal force after three months

In order for the debt to be paid, the traveler must apply within three months of their trip. The statutory right to compensation automatically expires after three months if the traveler has not actively applied for compensation.[18] This short deadline constitutes a systematic factor that transforms the legal debt into a latent cost saving for SJ. After 90 days, any non-seeked claims are written off, which directly reduces the operator's expenditure needs.

7. Conclusion and Recommendations for Improved Governance

7.1. Financial and ethical conclusions

SJ's Service Quality Report 2024 shows that operational performance was unusually weak, with punctuality figures down to 59 percent RT+5 for the long-distance segment.[19] This weakness generates a massive potential PDC liability. By only reporting the cases handled (297,400) and withholding the total financial cost (MSEK) and the frequency of PDC-triggering delays (RT+X), SJ maintains a high level of latent liability. This liability is managed through passivity; the operator relies on a low withdrawal rate.

The low withdrawal rate, estimated at around 20 percent, poses a significant ethical challenge, as the operator systematically avoids paying the compensation to which passengers are legally entitled. The latent liability is not only a financial risk but represents an unaccounted subsidy to SJ's operations, which distorts the true cost of unpunctuality.

SJ's reporting of its "fast" handling of the few PDC applications that actually come in (which are paid out within five working days) thus functions as a PR measure that hides the fact that the massive latent financial liability is systematically withheld.

7.2. Recommendations from Klimra for increased transparency

To address this systemic lack of transparency and ensure that travelers' legal rights are fully met, the following measures are recommended:

8. Background and source material

Official reports and laws

Web sources

[1]: SJ AB - Service Quality Report 2024, retrieved: October 19, 2025.

[2]: Punctuality on railways - Traffic analysis, retrieved: October 19, 2025.

[3]: SJ AB - Service Quality Report 2024, retrieved: October 19, 2025. https://www.sj.se/om-sj/sa-styrs-sj/bolags-och-ersattningsrapporter

[4]: Ibid.

[5]: Ibid.

[6]: Punctuality on the railway - Traffic analysis, retrieved: October 20, 2025.

[7]: TTT annual report 2024 - Swedish Transport Administration Industry, retrieved: October 20, 2025.

[8]: SJ AB - Service Quality Report 2024, retrieved: October 19, 2025.

[9]: Swedish Consumer Agency - Delayed or cancelled train, retrieved: October 20, 2025.

[10]: Punctuality on the railway - Traffic analysis, retrieved: October 20, 2025, https://www.trafa.se/bantrafik/punktlighet-pa-jarnvag/

[11]: Ibid.

[12]: SJ AB Annual and Sustainability Report 2024, retrieved: October 21, 2025. https://www.sj.se/om-sj/finansiell-info

[13]: Punctuality on the railway - Traffic analysis, retrieved: October 20, 2025, https://www.trafa.se/bantrafik/punktlighet-pa-jarnvag/

[14]: SJ AB - Service Quality Report 2024, retrieved: October 19, 2025. https://www.sj.se/om-sj/sa-styrs-sj/bolags-och-ersattningsrapporter

[15]: Ibid.

[16]: Ibid.

[17]: Rights in the event of delay - SJ, retrieved: October 21, 2025. https://www.sj.se/om-sj/regler-och-villkor/rattigheter-vid-forsening

[18]: Regulation (EU) 2021/782 of the European Parliament and of the Council, retrieved: 21 October 2025.

[19]: SJ AB - Service Quality Report 2024, retrieved: October 19, 2025.