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Response to Transport Select Committee
Call for Evidence
Licensing of Taxis & Private Hire Vehicles
Submitted by: Wayne Casey, Administration Officer
National Taxi Association
Date: 4th September 2025
Introduction
The National Taxi Association (NTA) is a representative body of taxi associations across England and Wales. We have been in existence since 1960.
The main objectives of the NTA are to promote the study of the service, aid in the maintenance of fair competition, and advise in the enactment of just, equitable, and constructive legislation, thereby protecting the vested interests of its members and secure the living standards and welfare of all who are engaged in the industry.
The NTA has a holistic view of the taxi trade and has been actively engaged in responding to a host of key issues that have affected the trade over many years, including the Transport Act (1985), the OFT Report (2003) and the Law Commission Report (2014).
Indeed the association have given evidence to the select committee in the past.
The association liaised with Northumbria Constabulary in respect of ‘Operation Sanctuary’, a widespread investigation into Sexual Exploitation in the Northumbria Police area through our former vice chairman Chris Chandler.
Locals are either best placed to decide, or they are not. It’s a simple concept.
Either the government rules that they should decide a national system of taxi and private hire licensing, or they allow local authorities to determine what they desire for their locality.
The association firmly believe as a predominantly local service both taxis and private hire should be licensed locally in the area they choose to operate, in essence we believe locals are best placed to decide.
If it is national, then a national centralised system of licensing is needed, like with PSV’s, or they leave it to local authorities.
Sadly both systems have negatives.
Local Authorities
The government has allowed the creation of large local authorities, North Yorkshire being a current example, although Durham is similar.
Whilst we have no opinion on the creation of these huge authorities, we do have opinion upon the results in concern to taxi licensing, particularly the reduction in numbers of licensing staff that has obvious effects upon enforcement.
North Yorkshire Council now effectively covers the former areas of Craven, Hambleton, Harrogate, Richmondshire, Ryedale, Scarborough, and Selby. The trade in each area is obviously different, with Scarborough being a seaside town and holiday destination, trade tends to be seasonal for example.
Our members have advised that Scarborough and Whitby have become honeypot areas, in much the same way Durham City became a honeypot area when Durham Council became one vast authority in 2009 (comprised of the former areas of Chester-le-Street, Derwentside, Durham (City), Easington, Sedgefield, Teesdale and Wear Valley).
The results of the above scenario leads to areas being deprived of licensed vehicles.
However, the association feels there is neglect, hackney carriage drivers are governed via byelaws, not conditions and numerous areas have neglected this.
Current law does not allow local authorities to rezone areas after it has de-zoned, we believe this should be altered to give unitary authorities that option. The law commission stated in their extensive report into the taxi and private hire trade in 2014 in recommendation 57;
‘Licensing authorities should have a more flexible power to introduce and remove taxi licensing zones. This power would permit removal or introduction of zones within a licensing
district. The power should be subject to consultation and a statutory public interest test.’
Taxis and private hire, on the whole tend to be a localised business, however, the association believe a key question which needs addressed is why do licensees seek other authorities to license them?
Some local authorities have limited vehicle testing capacity and arrangements in their areas, thus the amount of time it can take to obtain a vehicle test can take months, not days. Ideally a local authority should be obligated to have numerous testing stations within their area, they should be consistent with the number of licenses they issue.
Some local authorities are slow in issuing driver licenses, thus leaving drivers unable to work due to local authority failings. Again, an applicant should be given a timescale upon when they can expect to receive a license and this should be broadly standardised across the country.
Whilst the above does not condone cross border hiring, it does point to our association realising there are differing reasons for it happening.
a. Do current licensing arrangements and tools enable local authorities to effectively regulate and oversee the taxi and private hire vehicle (PHV) sector across England, in terms of safety, accessibility and quality of service? If not, what improvements could be made?
Recommendation 11 of National Audit on Group-Based Child Sexual Exploitation and Abuse
Baroness Casey in June 2025 stated:
The Department for Transport should take immediate action to put a stop to ‘out of area taxis’ and bring in more rigorous statutory standards for local authority licensing and regulation of taxi drivers
From the above, it is obvious that current arrangements are not working.
The association do believe local authorities have the necessary powers should they wish to use them, to regulate and oversee their locally licensed taxi/PH trade within their area, but obviously local authorities only have power over licenses they issue.
The problem of cross border hiring has always been here to a certain degree; however the deregulation act 2015 does appear to have compounded the problem.
It is therefore the opinion of the association that the 2015 deregulation act, in respect of taxis and private hire, should be rescinded.
The problem arises when private hire operators license themselves remotely, the driver and vehicle must also license themselves remotely if they wish to work for that same private hire operator.
The above leads on to the questions you pose in b, e and g.
b. What is the impact on the travelling public and drivers of variation between licensing authorities? Is reform needed to bring greater standardisation?
If a driver doesn’t have a good topographical knowledge of the area where they are licensed this can obviously be a negative for the travelling public.
The vehicle requirements of a rural area are not automatically suited to a major city; conversely, a standardized approach to vehicle licensing is not a reasonable option going forward.
A statutory national set of rules and regulations will end councils from having any control over the vehicles they license, the association believe locals are best placed to decide and amend local policies to suit local conditions and individual circumstance.
Some areas impose colour policies on vehicles; these are often for good reason. For example Sunderland has a policy where all Hackney Carriages must be white in colour whereas private hire can be any colour except white – thus there is a clear distinction between Hackney Carriages and private hire.
The policy of Sunderland Council has been nullified by ‘out of area’ private hire vehicles, painted white, sitting in Sunderland, waiting for work due to the ‘cross border’ situation.
In respect of driver licensing there is a broadly standard approach to medicals and DBS checks, in respect of the safety of the travelling public the association support this.
The association believe there should be a clear standardised definition and approach in respect of the fitness and propriety of both existing and prospective licensees.
c. What would be the practical implications for licensing authorities and operators of more stringent or standardised licensing conditions in respect of safety, accessibility, vehicles and driver conduct?
The association believe that every licensed driver should be subject to the same standard requirements countrywide.
Licensed operators will undoubtedly express concern that more stringent standards will affect the number of new drivers entering the taxi and PHV trade, however, the safety of the public trumps that of operators.
The same stringent standards will be welcomed by most licensing authorities and customers.
Local authorities whose licensing model is to license anything that moves will suffer a reduction in numbers, but that reduction will be alleviated in a positive way by drivers licensing in the areas they live. However, this would not effectively be an issue as addressed in the following question.
d. What steps should the Government take to address the challenges posed by cross-border licensing in the taxi and PHV sector?
Our association believe the government has two scenarios to halt the practice of cross border hiring.
The first would be that Local Authorities should be required to pose the question of ‘area of intended use’ when licensing PHVs. If an applicant states another area outside of the licensed area, the local authority must refuse the application, additionally, if a vehicle is found to be used, the majority of the time, in another area, the licenses involved should be revoked.
Whilst there will undoubtedly be times when a vehicle is hired into another licensing area, the vehicle should be used the majority of the time in the area where it is licensed. The emphasis should be based around right to roam, not the right to stay.
The second would be to consider section 21 of the Civic Government (Scotland) Act 1982 and particularly the Scottish Governments best practice guidance towards cross border hiring.
e. What would effective reform look like in terms of enforcement, passenger safety and safeguarding, and regulatory consistency? Is there a role for regional transport authorities?
The funding model for taxis and private hire is broadly that the function should be (but not necessarily) funded by the licensees.
It is reasonably obvious for each license an area is deprived of (due to licensees licensing themselves in other areas), it’s the license holders in the area they return to that are paying for enforcement. Change would result in licensing departments being properly funded.
f. How are digital ride-hailing platforms impacting standards in the sector, and is further regulation in this area required?
Standards in respect of the driver and vehicle are obviously set by the licensing authority not the ride hailing platform.
The difficulty is by permitting the cross border situation the law allows a driver to effectively search the country for the local authority with the lowest standards.
Thus you have a situation where a driver adhering to high standards set by a local authority has to compete with the lower standards brought in by the ‘out of town’ licensed driver.
Ride hailing platforms should be made to ‘geofence’ areas of operation.
g. How effective, accessible, and trusted are complaints and incident reporting systems in the taxi and private hire vehicle (PHV) sector, for both passengers and drivers?
The association believe this differs from area to area.
Some local authorities have limited the times when licensing staff are available; some insist drivers can only see them ‘face to face’ by pre-arranged appointment.
Some will reply to emails within 10 working days.
In terms of complaints from customers, some advise the passenger to firstly complain direct to the company involved.
It goes without saying that the passenger will naturally presume the vehicle and driver are licensed by the local authority area where they hired the taxi / PHV, in cases where the vehicle is licensed elsewhere we suggest a complaint will be difficult.
h. How effective is the National Register for Revocations, Refusals and Suspensions (NR3S). in supporting consistent licensing decisions across local authorities? What barriers, if any, are limiting its use or impact?
The association support the National Register but are obviously unable to comment upon its effectiveness.
i. What are the implications for taxi and PHV licensing of the future rollout of autonomous vehicles?
Current law describes both a private hire vehicle and hackney carriage as vehicles that are provided with the services of a driver.
The association would envisage autonomous vehicles to have separate legislation; however, our members have pointed out to us that such vehicles would be unable to cater for many sections of our society, be these people with disabilities, special needs or anyone who would need assistance.
The implications are that autonomous vehicles will be suitable for the able bodied, but unsuitable for those suggested above.
The expense of such vehicles would presumably prohibit ownership by the vast majority of individual licensees; therefore a monopoly would be created.
Who would regulate fares and the maintenance of such vehicle and how would such decisions be arrived upon?
Operation Sanctuary: Dozens of taxi drivers suspended - BBC News
Durham street branded 'Wild West' by fed up emergency services - Chronicle Live
[ARCHIVED CONTENT] Taxi and Private Hire Services - Law Commission
Chapter 3 – enforcement - Taxi and private hire car licensing: guidance - third edition - gov.scot
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Think of how stupid the average person is, and realize half of them are stupider than that.
George Carlin
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