Written evidence submitted by Unite the Union Gatwick Taxi Branch (TPV0126)
Introduction
It is Unite’s view that the current licensing arrangements and tools are insufficient to effectively enable local authorities to regulate and oversee the taxi and PHV across England, and this impacts safety, accessibility and quality of service.
The previous Tory government have consecutively ignored recommendations from the Law Commission as well as the government-commissioned Task and Finish Group on Taxi and Private Hire Vehicle Licensing (2018) to implement crucial recommendations to improve safety and quality of services ([1]). This has resulted in a two-tier industry where there is a distinct imbalance in the licensing and regulating taxis (hackney cabs) and PHV.
In 2014, the Law Commission reviewed the legal framework surrounding taxis and PHVs across England and Wales. The review recommended that the government set out a new single legal framework for the regulation of taxis and PHVs. However, to date, the recommendations have not been implemented ([2]).
Similarly, in 2018 the Government commissioned Task and Finish Group on Taxi and PHV (TFG)([3]), to conduct a thorough review of the industry. The TFG report introduced a host of recommendations to improve safety and enforcement across the industry. Of these, recommendation no.11 would significantly address cross-border hiring. Again, the then Tory government, and subsequent governments failed to implement these recommendations.
There would have been an opportunity to rectify the enforcement and safety in the industry via the 2022 Taxis and Private Hire Vehicles (Safeguarding and Road Safety) Act 2022, however, this was a missed opportunity as the Act only addresses the issue of information sharing amongst licensing authorities and does not legislate on the use of that information.
Unite has lobbied the Labour Party over many years to include primary legislation to end cross-border hiring, and Labour committed to this in its 2017 and 2019 manifestos. To support the new Labour Government’s bold ambition to tackle gender-based violence, half violence against women and girls (VAWG), within the next ten years, this government should do what others have failed to do, seemingly:
Standardise training
Unite Gatwick Taxi Branch SE/6094, places passenger safety and wellbeing as a top priority, and we call for national standards for taxi and PHV, which will include standardised training for all.
Unite believes that all licensed drivers, as well as those involved in the determination of licensing, should undertake standardised accredited training with a focus on public safety, which also
includes training on gender-based violence, such as that which is being introduced in the current Bus Services Bill (No.2) ([4]).
Unite supports high standards of education in all aspects of the licensed drivers’ duty of care.
National standards
Unite – Gatwick Taxi Branch SE/6094 has long been calling for National standards. These would be standards that local authorities could enhance if they desired, to meet local requirements. Local authorities should have control over the operators, vehicles, and drivers that operate within their authority. This allows democratically elected authorities to reflect the local needs of the population and the future implementations of Local Transport Planning (LTP’s) to also have better informed knowledge of ranking requirements in Cities and Towns. Licensing authorities must also have the ability to impose additional requirements, where necessary.
Unite believe “local taxi boards/forums” made up of the licensing authority, trade representatives, the police and passenger representatives (including disability groups) should be responsible for the monitoring of supply and demand, with the remit of developing the trade in a progressive, safe and managed way. This would prevent abuse and exploitation, such as we have seen in Wolverhampton ([5]).
Since the Deregulation Act 2015, the number of licences given to PHV in Wolverhampton, has increased eightfold, a 383% increase in 2 years ([6]).
At the Gatwick Branch there are reports that in the past few months (from the beginning of 2025) there have been over 7 different licensing authority vehicles plying their trade within Gatwick and Crawley town Centre at any one time.
The Deregulation Act 2015 allows for taxi and PHV drivers to be licensed outside of the area they operate, which has prevented authorities from being able to control taxi and PHV drivers working in their area, known in the industry as cross-border hiring. This poses a significant risk to passengers and road users and lowers standards for the industry.
Unite recommends the following improvements for the industry:
Inconsistent licensing weakens local protections and makes it easier for criminal gangs, perpetrators and unscrupulous drivers to work as Hackney Carriage (Taxi)/PHV drivers and evade oversight. This is also highlighted in the recent 2025 Casey report on child sexual exploitation, where taxi drivers in Rochdale were identified as perpetrators;
“Girls were frequently moved around in cars and taxis, facilitated by poor taxi licensing arrangements, including taxis used by the local authority to carry vulnerable passengers”. – Casey Report 2025, pg. 62 ([7]).
The report further highlights that concerns about taxi licensing have been raised in “several past reviews as a facilitator of child sexual exploitation, and on which some action has been taken.[8]”
These horrific findings stigmatise the many law-abiding, decent taxi and private hire drivers who are undercut by different licensing laws and will terrify the general public and potentially impact their perception of safety in a Hackney Carriage (Taxi) / PHV. The Government must legislate for a level playing field, by requiring National Standards.
Unite supports the Casey report’s calls for rigorous, uniform Hackney Carriage (Taxi)/PHV licensing standards across all local authorities so that every Hackney Carriage (Taxi) or Private Hire Driver meets the same safeguarding thresholds, regardless of where they are licensed. This includes enhanced DBS background checks and mandatory accredited training including safeguarding.
These enhanced standards must apply to mandatory safeguarding training and stringent license vetting. This would support efforts to keep children including (SEND) – Special Educational Needs & Disabilities and vulnerable adults safe, as they represent a large proportion of service users who need Hackney Carriage (Taxis)/PHV to transport them safely to schools, hospital appointments and services.
Unite is pleased that this Government has accepted all 12 of Baroness Casey’s recommendations and the DfT has committed to legislating rapidly to tackle the issue, and strengthening statutory guidance in the interim. Unite will continue to monitor the legislative developments in this area, and we urge the Government
and DfT to include Unite Taxi Education and Unite’s cab sector as key stakeholders as this develops.
Safety
Unite - Gatwick Taxi branch SE/6094, accepts that there would be an increase in workload for those vetting drivers as authorities would need to perform more stringent background checks (e.g. enhanced DBS, right-to-work, medical fitness). Unite also accepts there would be increased responsibilities for continuous licence-holder monitoring, possibly via integration into a national licensing database, DBS Update Service and regular DVLA license checks. To ensure efficiency and sustainability of a more stringent licensing and enforcement regime,
Furthermore, licensing authorities will likely need to implement or enforce mandatory accredited training which must include safeguarding and safety training for all drivers. In (a) we discussed the benefits of mandatory training, and there should be a subsidy to support drivers to meet the cost of this training.
With respect to accessibility and vehicle and driver conduct, higher safety standards will likely result in increased costs for example, to install CCTV, in-vehicle emergency alert systems and any other related operational costs, Unite is concerned that this would put a further strain on drivers and we propose the cost of this is either deducted from licensing cost or subsidise.
Accessibility
To standardise accessibility, licensing authorities may need to require minimum levels of wheelchair-accessible vehicles or adapted services for disabled passengers.
Additionally, more proactive inspection and regulation will be needed to ensure accessibility standards are met (e.g. drivers assisting passengers properly, no refusals of service), and as above (in relation to safety), this will require more resourcing.
Driver Conduct
To monitor and enforce against driver (mis)conduct, licensing authorities will require stronger disciplinary powers, and there should be clearer, standardised frameworks and published information with explanations for dealing with misconduct. Technology could be used to monitor conduct, and this may require real-time incident tracking, including the ability for local authorities to have access to shared data systems that alert them to driver infractions in other regions (NR3).
While there are clear practical implications as stated above, the benefits here far outweigh the cost.
Benefits;
Unite – Gatwick Taxi branch SE/6094:
National powers of enforcement for local licensing enforcement officers so they can protect our communities and an end to cross-border hiring.
Cross-border hiring
Cross-border hiring in the taxi and private hire (PHV) industries is the practice whereby taxis or PHVs licensed by one licensing authority work wholly or predominantly in another licensing authority's area, i.e., Wolverhampton City Council. This is a key concern for Unite – Gatwick Taxi Branch. Our members in the industry have lobbied the Government, local licensing authorities and the Labour Party to end this practice.
We know from our engagement with DfT, local licensing authorities and police forces that cross-border hiring generates serious public safety issues, undermines local licensing regimes, and contributes to criminal activity as the practice restricts the enforcement capabilities of local licensing authorities, who have limited powers to enforce against out-of-town vehicles.
We note that in November 2017, the Metropolitan Police Service gave verbal evidence where they stated cross-border hiring “is the single largest risk to Policing nationally” ([9]).
The current legislation is not fit for purpose and enables the industry to be a ‘vehicle’ for criminal activity, including, but not limited to child sexual exploitation, human trafficking and modern-day slavery, sexual assault and gender-based violence and county lines drug trafficking.
It is unconscionable that local licensing and its ability to ensure the safety of passengers, drivers and other road users is being undermined by cross-border hiring. The public expects that when they use Hackney Carriage (Taxi) and Private Hire services, they are doing so safely and have the protection and oversight from a local licensing authority. Cross-border hiring restricts the ability of licensing authorities to enforce effectively, set appropriate safety standards for drivers, vehicles and operators and can undermine the confidence the public have in the licensed Hackney Carriage (Taxi) and Private Hire trades within their area.
The TFG ([10])review of safety standards across the Taxi and PHV industry also looked at cross-border hiring. The review concluded with several recommendations, which included recommendation 11,([11]) which calls for legislation to effectively end cross border hiring.
Unite’s involvement in the DfT Taxi working group and the TFG engagement with licensing authorities, as well as police forces, has shown there is strong support for our proposals to tackle cross-border hiring and for national minimum (high) standards for the industry.
Unite – Gatwick Taxi branch SE/6094:
As previously discussed in (a) and (d), where we outlined Unite’s concerns over cross-border hiring, implementing start or finish requirements, where Hackney Carriage (Taxi)/PHV journeys are required to start or finished in the area they are licenced in, would effectively address the current issues with enforcement, passenger safety and safeguarding as well as support regulatory consistency across the industry.
Improved Regulatory Oversight and Accountability
When rides start or end outside the licensing area, local authorities cannot effectively monitor or enforce standards on out-of-area drivers. By requiring rides to start or finish within the licensing area, predominantly only locally licensed operators and drivers would be eligible to work in that area. Under these conditions, the local authority can more effectively enforce driver vetting, vehicle safety checks, and operational compliance.
Level Playing Field for Local Operators
Out-of-area drivers may operate under less stringent rules (e.g. cheaper licensing fees, less frequent inspections), undercutting local businesses. Ending cross-border hiring and requiring start or finish as described in the above section, would result in all drivers and operators working within a given area, following the same rules.
Enhanced Passenger Safety and Public Confidence
As has been exposed in the 2025 Casey report, cross-border hiring often involves inconsistent driver background checks and vehicle safety standards, which, as stated earlier has enabled sex offenders to abuse women and children in their Hackney Carriage (Taxi) or PHV. Requiring rides to start or end within the licensed area, ensures all drivers are vetted by the same authority. This way passengers benefit from known, trusted local regulation, improving safety and confidence.
Ending license shopping
As exposed in the various reports concerning Wolverhampton licensing practices, unscrupulous PHV drivers and operators exploit more permissive licensing regimes (a practice known as "license shopping"). If rides are restricted to within the licensed area, there is no incentive to be licensed elsewhere, discouraging drivers/operators from bypassing stricter local rules via regulatory arbitrage.
Traffic and Environmental Impact Control
Out-of-area vehicles increase traffic congestion, pollution and destroy LTPs with emphasis on Clean Air Zones regulation. Imposing licensing boundaries would help authorities plan fleet sizes and routes based on local needs. Unite believes reducing out-of-area operations helps manage urban mobility and emissions more effectively.
Clarified Liability and Complaint Resolution
It’s harder for passengers to raise and for licensing authorities to resolve passenger complaints or incidents involving out-of-area drivers. Keeping journeys within one licensing area simplifies accountability, as passengers and authorities would know which council is responsible for oversight and redress.
Unite believes start or finish is an effective way to mitigate the growing challenges of cross-border hiring in the taxi and PHV sector. Mandating rides start and finish in the licensed area helps by:
There have been major technological advances in the industry, with many taxi and private hire customers now preferring app-based services. This is coupled with significant and rapid growth in the number of private hire drivers and vehicles, which has exacerbated cross-border hiring concerns.
The rapid scale-up and oversaturation of these platforms have exposed gaps in safety, accessibility, and regulation, and arguably created unfair competition and poor working conditions.
Unite – Gatwick Taxi branch SE/6094:
A tougher regulatory framework, one that:
This would help rebalance the system in the interests of passengers, drivers, and public safety.
Safety & Oversight
Some platforms, such as Uber, Bolt, Veezu, have historically operated as though they’re outside traditional regulation, placing themselves as tech companies rather than Private Hire operators. This has created barriers for licensing authorities to effectively enforce safety standards on digital ride-hailing platforms.
Accessibility
Private Hire Vehicles (PHVs) often lack wheelchair-accessible vehicles (just 0.7 % in London), and disabled passengers, even those with assistance dogs, are sometimes turned away. All drivers should undertake accredited training which includes wheelchair accessibility and assistance training.
Driver Rights & Conduct
Unite is concerned that platform drivers operate under gig‑economy conditions, with uncertainties over income, algorithmic pricing, low transparency on fare-setting, employment rights and limited welfare protections. Unite believes that there should be a requirement for platforms to disclose fare calculations, algorithms, and dynamic pricing models, so drivers and passengers can understand fair charging terms. Platforms should be barred from banning communication between drivers and passengers on fare issues.
Unite joins other unions in calling for national licensing standards to include driver welfare protections such as CCTV/audio, fair fare transparency, minimum earnings safeguards, and Hackney Carriage & Private Hire Vehicle caps to prevent over-saturation. Licensing standards should protect drivers themselves, for example, the installation of CCTV, ensuring operator safety policies, and setting fair working conditions.
Market Practices & Consequences
Unite – Gatwick Taxi Branch is concerned that ride-hailing companies have significantly undercut traditional taxi/private hire fares leading to plummeting earnings for licensed Hackney Carriage (Taxi) and PHV operators, market consolidation, and the decline of traditional Hackney Carriage (Taxi)/PHV firms.
In cities like Leeds, Liverpool, Manchester, Newcastle, Sheffield and other large towns, Hackney Carriage (Taxi) drivers warn that oversupply of PHVs is creating "wild west" driving conditions with long shifts, reckless behaviour, and safety risks under economic pressure.
Current UK law treats PHV operators (including app-based platforms) as responsible for bookings and operations, not just intermediaries, and they must meet operator licence requirements. While licensing authorities are required to share safety concerns across regions, licensing/regulatory frameworks vary widely across local authorities, leading to a regulatory patchwork.
Again, Unite maintains that standardised national licensing conditions where all PHV operators, including those on digital platforms, should be subjected to the same rigorous standards governing driver vetting, safeguarding training, safety practices, data protection, and incident reporting.
To address congestion, driver earnings collapse, and road safety, localised transport authorities, including devolved mayoral sectors of the uk should have the power to cap PHV numbers and control the sprawl of platforms in local markets.
Every local authority has their own complaints procedure and most act on complaints in a timely fashion. Unfortunately, not all complaints can be trusted and a more robust investigation standard should be adopted by all authorities.
The NR3 system has now been adopted by every authority. Its use has identified drivers who have been revoked, suspended or refused by one local authority applying to another local authorities.
Unite is concerned about the implications for Hackney Carriage (Taxi) and PHV licensing, which are likely to emerge when autonomous vehicles (L3 to L4 and upwards to L5), more specifically autonomous taxis (L5), are rolled out. Unite is aware of plans to rollout driverless taxis in London by 2026, and we are disappointed that, as the leading transport union, we were not invited to stakeholder discussions as the plan developed.
Implications for licensing authorities
Unite believes this rollout will directly impact Hackney Carriage (Taxi) & PHV licensing authorities. The current licensing framework assumes a human driver. Most licensing regimes under the UK’s Town, Police Clauses Act 1847, Local Misc Provisions Act 1976 (Sec.2) and London Private Hire Act 1998 maintain that Hackney Carriage (Taxi)/PHV laws centre on the driver’s background checks, conduct, and training.
Autonomous Vehicles will shift liability to the operator, manufacturer or remote operator/controller, and as such, licensing will need to evolve to focus on system performance, data logs, software updates, and remote oversight. There is also a risk that the regulatory focus will shift from driver compliance to system integrity and cybersecurity. This will put a burden on resources and may require more funding, and as we have said in the previous sections of this paper, licensing resources are already overstretched.
Furthermore, vehicle licensing will become more complex as autonomous vehicles (L4 to L5), will require more rigorous pre-deployment testing and ongoing performance audits, real-time data sharing with licensing authorities (e.g. accident reports, disengagements) and strict maintenance and software update protocols. Consequently, licensing authorities may need technical staff or agencies to certify autonomous vehicle performance, including AI decision-making audits.
Implications for accessibility standards
As with Hackney Carriage (Taxis) and all other forms of passenger transport, autonomous vehicles must accommodate users with mobility problems, yet currently, many autonomous vehicle trials lack accessible design (e.g. wheelchair access, audio prompts). Without a human driver to assist, autonomous vehicles will need built-in accessibility protocols, such as, automated ramps/lifts, voice/visual aids and real-time remote customer service agents.
Thus, licensing authorities should mandate universal design standards for autonomous taxis as a licensing condition. However, this element should NOT be localised fully. The required standards should be governed by the Department for Transport, working with Local Authorities, representative trade unions, and taking advice as how best their recommendations can suit the needs, without burdensome prohibitive costs being borne from such move. Those affected most likely being the small towns and villages and some cities.
Insurance & Liability Oversight
With human error removed, fault in accidents may shift to vehicle manufacturers, software providers, fleet operators or remote operators/controllers. Therefore, licensing authorities may need to mandate comprehensive insurance coverage for systemic or software failure. This may result in licensing overlapping with insurance regulation and product liability law, blurring lines between traffic law and consumer protection.
Operational & Zoning Controls
Unite is concerned that autonomous vehicles may worsen congestion if widely adopted without coordination. To abate this, local authorities may need to geo-fence certain areas (e.g. pedestrian zones, school zones) and impose fleet caps. Unite warns that autonomous taxis may force a shift toward LTPs via licensing, where mobility and environmental goals are embedded in licence conditions.
Is legislation fit for purpose?
The Automated Vehicles Act 2024 gives a legal framework for self-driving approval and outlines who’s liable when a vehicle is in self-driving mode (L4/L5). But it doesn’t yet fully address Hackney Carriage (Taxi)/PHV licensing reform, accessibility enforcement and local authority powers over AV fleets.
September 2025
Endnotes
[1] This was a group made up of a broad cross-party and cross-sector selection of organisations and individuals including the Local Government Association, the Institute of Licensing and key unions.
Task and Finish Group on Taxi and Private Hire Vehicle Licensing. 2018. Taxi and Private Hire Vehicle Licensing: Steps towards a safer and more robust system. Available at: https://assets.publishing.service.gov.uk/ media/60085e35e90e073ecce20064/taxi-and-phvworking-
group-report-document.pdf
[2] Law Commission. 2014. “Taxi and Private Hire Services.” Available at: https://lawcom.gov.uk/project/taxi-andprivate-hire-services/
[3] Task and Finish Group on Taxi and Private Hire Vehicle Licensing. 2018. Taxi and Private Hire Vehicle Licensing: Steps towards a safer and more robust system. Available at: https://assets.publishing.service.gov.uk/
media/60085e35e90e073ecce20064/taxi-and-phvworking-
group-report-document.pdf.
[4] The Bus Services Bill (No.2) introduces mandatory bus staff training and byelaw-making powers
The bill would require mandatory training for bus staff to help them assist disabled passengers, and to deal with onboard crime and anti-social behaviour. The bill would also give local transport authorities in England the power to introduce byelaws to deal with fare evasion and onboard anti-social behaviour, and the power to issue penalty charge notices to enforce such powers.
[5] BBC News: Wolverhampton taxi drivers accused of serious sex crimes. 14th February 2019. Link: https://www.bbc.co.uk/news/uk-england-birmingham-45474296#:~:text=Taxi%20drivers%20licensed%20by%20a,leave%20the%20public%20at%20risk.
[6] BBC News: Why is my taxi from another city? 18th July 2018. Link: https://www.bbc.co.uk/news/uk-england-birmingham-44849364
[7] National Audit on Group-Based Child Sexual Exploitation and Abuse. Baroness Casey of Blackstock DBE CB June 2025. Link: https://assets.publishing.service.gov.uk/media/685559d05225e4ed0bf3ce54/National_Audit_on_Group-based_Child_Sexual_Exploitation_and_Abuse.pdf
[8] Ibid, page 138.
[9] Transport for London Taxi and Private Hire - Cross Border Hiring – Proposals for Legislative Change
[10] https://www.gov.uk/government/publications/taxi-and-private-hire-vehicle-licensing-recommendations-for-a-safer-and-more-robust-system
[11] Recommendation 11 of the Taxi Task and Finishing Group: Government should legislate that all taxi and PHV journeys should start and/or end within the area for which the driver, vehicle and operator are licensed. Appropriate measures should be in place to allow specialist services such as chauffeur and disability transport services to continue to operate cross border. Operators should not be restricted from applying for and holding licences with multiple authorities, subject to them meeting both national standards and any additional requirements imposed by the relevant licensing authority.
[12] Ibid.