The key sentence here says that between Sept 2020 and March 2023 the data suggests short ticket, sandwich ticket, expired railcard.
You should be able to get that same ticket purchase history data out of the system yourself and look at it to see why they might think this.
If you used any e-tickets, they'll also have timestamps showing when and where those tickets were presented.
Similarly if tickets were collected from machines, they'll be able to check when and where they were collected.
Do you have a continuous railcard purchase history over this period?
It is not unusual for them to provide no details and to encourage you to incriminate yourself voluntarily.
They may also make simplifying assumptions such as that every journey listed as Wembley was really Bicester North.
I wouldn't provide details at this stage but if it goes further and they send you details of specific trips, evidence of a work meeting at Wembley would be helpful in undermining that assumption.
"Sandwich" - two journeys with a ticketless gap between them would be the most interesting for you to explain.
As AlterEgo says, the burden of proof lies with them, and if they want to proceed with any allegations they'll have to be specific.
From what you've said though for the occasion you were stopped, I think they could have a good shot at a RORA 5(3)(a) offence.
Your problem is that to persuade them to offer you a settlement in lieu of prosecution for that one offence, you might have to be able to satisfy them over your travel history.
You should be able to get that same ticket purchase history data out of the system yourself and look at it to see why they might think this.
If you used any e-tickets, they'll also have timestamps showing when and where those tickets were presented.
Similarly if tickets were collected from machines, they'll be able to check when and where they were collected.
Do you have a continuous railcard purchase history over this period?
It is not unusual for them to provide no details and to encourage you to incriminate yourself voluntarily.
They may also make simplifying assumptions such as that every journey listed as Wembley was really Bicester North.
I wouldn't provide details at this stage but if it goes further and they send you details of specific trips, evidence of a work meeting at Wembley would be helpful in undermining that assumption.
"Sandwich" - two journeys with a ticketless gap between them would be the most interesting for you to explain.
As AlterEgo says, the burden of proof lies with them, and if they want to proceed with any allegations they'll have to be specific.
From what you've said though for the occasion you were stopped, I think they could have a good shot at a RORA 5(3)(a) offence.
Your problem is that to persuade them to offer you a settlement in lieu of prosecution for that one offence, you might have to be able to satisfy them over your travel history.