From
the Department for Transport - how things are
becoming simpler changing for operators of train service, and train drivers, in the
UK▸ and across borders. A long piece - here is the summary section
Summary
EU» -based railway undertakings
If you are an EU-based operator, and have not already applied for UK documentation, you need to apply to the Office of Rail and Road (ORR» ) for documentation to run services in Great Britain. You need to obtain the necessary documentation by 31 January 2022.
You need to prepare and allow enough time to apply for and obtain this documentation.
UK-based railway undertakings
Certificates and licences issued in the UK, other than those issued for the Channel Tunnel, will not be valid in the EU from 1 January 2021.
Operators of cross-border services through the Channel Tunnel can continue to operate for a limited period with UK-issued operator licences, safety certificates and safety authorisations but the continued validity of this documentation is subject to compliance with the requirements set out in Regulation (EU) 2020/2222. However, this recognition is time limited, so it is important that cross-border entities and operators take the necessary steps to ensure they have the necessary documentation once that period has elapsed.