The Russian Railway system1 is in the process of rapid legal, organisational and regulatory reform. This paper is based on a series of discussions with the Government on the reform plans and the progress in implementing reform. The conclusions are not intended to be interpreted as requirements or instructions on the next steps in the process. They instead aim to raise questions where, from observing difficult reform issues in other countries, the team believes further refinement might help the Russian regulatory reforms progress more effectively and in some cases avoid costly mistakes made in other countries. With these suggestions ...