My issue is that DfT are announcing this as if it's general (except for EMR), rather than acknowledging the existence of operators they don't manage. That language will mislead people and cause them to take alternatives that aren't part of the scheme, and hence give rise to conflict where it isn't necessary.This shouldn't be the passenger's problem to care about!
And I'm glad you've highlighted the viable and sensible solution.
My issue isn't particularly with the OAOs being excluded, but more the local concession operators like Elizabeth Line, Overground, Merseyrail, and also the devolved public operators ScotRail and TfW. I think it's appalling that they are not part of the scheme.
This is certainly a big step in the right direction, but there's still progress to be made in my view.
Operationally, this also risks leading to confusion where people re-route themselves, and a downstream leg of the journey relies on this (e.g. XC disruption in the Midlands, so someone travelling NE/SW goes via London using LNER and GWR).

