The role of operators, in delivering this direction, was raised by David Summers, Highland Council, as a potential gap—
...there is a provision in the bill to allow ministers to instruct local authorities to introduce a smart ticketing scheme, but there is no power to allow local authorities to instruct operators to participate, so the ministerial instruction gets stuck halfway.
Rural Economy and Connectivity Committee 19 September 2018, David Summers, contrib. 52, http://www.scottish.parliament.uk/parliamentarybusiness/report.aspx?