Written evidence submitted by Transport for Greater
Manchester (TPV0157)

Who are we and why are we responding

This response has been submitted by Transport for Greater Manchester and has been developed in collaboration with Greater Manchester’s 10 Licensing Authorities[1] and the Greater Manchester Combined Authority.

Greater Manchester has recently undertaken a review around our current approach to taxi and private hire licensing, supported by a 12-week period of engagement with the taxi trade, wider stakeholders and other licensing authorities from outside of the city-region. The conclusions from this exercise will be reported in the Autumn.

If the committee requires any further detail on our submission, or the work of Greater Manchester in this space, we would be happy to put forward a witness to any future Oral Evidence session in relation to this inquiry.

Response to Call for Evidence Questions

1. 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?

No, current licensing arrangements do not enable local authorities to effectively regulate and oversee the taxi and private hire vehicle (PHV) sector.

Current legislation allows private hire vehicle owners and drivers to license out of the area, with licensing authorities in a different local authority area to the one in which they predominantly work, severing the link between drivers and the people and places they serve.

Department for Transport figures show that more than 11% of England’s private hire vehicles are licensed by one local authority, City of Wolverhampton Council, up from below 0.5% less than a decade ago. In Greater Manchester, nearly half (49%) of private hire vehicles are now licensed by authorities outside of its ten councils. The city-region’s ‘out of area’ figure of more than 12,000 has risen sharply from just under 7,000 in 2023.

This is why Greater Manchester has launched the ‘Backing our taxis: Local. Licensed. Trusted’ Campaign, which is calling on government for new laws to tackle out-of-area licensing.

2. What is the impact on the travelling public and drivers of variation between licensing authorities? Is reform needed to bring greater standardisation?

Inconsistent licensing standards across authorities can have a direct and tangible impact on the travelling public. Passengers may encounter varying levels of safety, vehicle quality, driver training, and customer service depending on where a driver and vehicle are licensed — not where it operates. This disparity creates confusion and undermines public confidence, as passengers cannot be assured that every taxi or private hire vehicle meets consistent baseline standards for safety, accessibility, and conduct.

These inconsistencies also complicate the process for raising concerns or complaints. Oversight and enforcement often fall to distant or unfamiliar authorities, making it harder for passengers to seek redress. Vulnerable passengers, particularly those with accessibility needs, may be disproportionately affected if vehicles licensed elsewhere fail to meet higher local standards designed to protect them. The lack of uniformity ultimately weakens efforts to deliver a cohesive, reliable, and trusted transport network.

While licensing standards in policy documents or licence conditions often do not vary significantly between licensing authorities, there is variation between authorities in relation to the implementation and enforcement of the policy standard. For example, most licensing authorities should be requiring a Group II medical assessment, however not every licensing authority will scrutinise and challenge when a driver has been assessed and signed off as meeting the Group II standard, even though there is information contained within the medical assessment form to indicate that they don’t meet this standard. Greater Manchester authorities have many examples of when they have had to challenge these assessments as the relevant doctor has either overlooked something or simply misunderstood, or in some cases have signed it fraudulently.

Other variances exist when authorities review licences and make decisions to either suspend or revoke a licence, and some authorities don’t conduct any proactive enforcement activity or address what they might consider to be minor breaches of licence conditions (e.g. stickers and plates not being attached properly). The more proactive and effective a licensing authority is at ensuring the policies and conditions that have been put in place for good reason are upheld, the more likely licensees are to move elsewhere.

Examples of how other regulatory effectiveness is undermined by variations in licensing standards include:

• Driver Proficiency Testing: Several Greater Manchester licensing authorities require new drivers to pass a taxi driver proficiency test via TfGM DriveSafe before being licensed. However, applicants can bypass this requirement by obtaining a licence from another authority in England or Wales that does not impose the same standard, while still operating in Greater Manchester.
• Vehicle Testing Frequency: Private cars in the UK average around 7,000 miles annually[2] and require an MOT once per year, with approximately 29% initially failing[3]. In contrast, taxi and private hire vehicles average 34,000 miles annually[4] — nearly five times more. To reflect this increased usage, many Greater Manchester authorities mandate at least biannual vehicle compliance tests. These tests often reveal serious faults (approx 48% fail with a major fault), justifying their frequency and supporting public safety. Yet, operators can license their vehicles with authorities that only require an annual externally provided MOT, regardless of mileage or passenger use. In addition to this, it is often the case that those authorities do not receive any initial failed MOT reports, as they only require the licence holder to submit a passed MOT certificate. If one of their vehicles fails an MOT test, they are not made aware and the vehicle continues to be used to carry the public. Within GM, in these circumstances, the vehicle licence would be temporarily suspended until the repairs were made and the vehicle was re-tested. This clearly impacts the licensee who is unable to work during the time of the suspension, and a significant reason why licensees choose not to license with authorities who conduct in house vehicle testing. This variance not only undermines safety but also creates cost disparities between licensing authorities – this then gives rise to an increased risk of 'licence shopping' with applicants licensing outside of the district in which they intend to predominantly operate.. There have even been recent cases of fraudulent MOT certificates being issued from authorised garages, for vehicles that were never tested.

3. 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?

Introducing more stringent or standardised licensing conditions would have implications for both licensing authorities and operators. Currently, taxi and private hire vehicle (PHV) licensing operates largely on a cost-recovery basis, with fees structured to cover the costs of delivering the service provision, including the direct administration and enforcement costs as well as service overheads (which will naturally vary from authority to authority usually for reasons well beyond the control of the licensing service itself). Transitioning to a more rigorous or harmonised regime would require additional investment — not only in staffing and expertise, but critically in technology to streamline and modernise administrative processes. Enhanced digital systems would be essential to manage higher volumes, enable cross-authority verification, and support more efficient application and renewal workflows.

An example of where a more robust national framework could support better outcomes is around emission standards. Whilst best practice guidance currently references consideration of setting vehicle emissions policies, there is no clear expectation, and as a result some local authorities set emissions standards and others do not, further creating disparities of approach.

Standards and conditions are meaningless without effective implementation and ensuring compliance. This requires administration and oversight of that administration, high data quality, proactive monitoring of compliance with conditions and thorough investigations supported by sound decision making. Many authorities say they do certain things in their policy standards, but that does not necessarily mean that it is being done. Better oversight that LAs are applying their standards and quality checking their administration is required. For example, one operator in Greater Manchester has stated that a driver was able to obtain a licence with an authority by submitting a photograph of a takeaway menu in place of a medical certificate. On paper that authority will say that their standard is to require the Group II medical certificate – in practice a member of their staff can license a person without seeing a medical certificate. This would of course apply to DBS’s and the information contained on them.

Robust enforcement mechanisms are also vital. This includes resourcing proactive on-street compliance operations and ensuring vehicle checks are thorough and trusted — potentially through partnerships with accredited garages (although it should not be forgotten that the use of external garages requires additional costly administration to obtain all test results as these cannot access the relevant business systems to upload results).

These measures would help uphold high standards across the board, but the transition would require upfront funding and a re-evaluation of the current cost-recovery model to ensure long-term sustainability for authorities and fairness for operators.

While national harmonisation of standards presents a valuable opportunity for greater consistency, improved public confidence and improved support across the sector, its success depends on the reasonableness and appropriateness of those standards, and most importantly on their implementation and ensuring compliance with them. Current best practice guidance includes elements that are impractical or unrealistic, which can hinder effective regulation. Examples include:

• A recommendation for vehicles to undergo MOT testing only once per year and can be tested at any approved MOT station — insufficient given the higher mileage and wear of licensed vehicles and the lack of oversight involved with external provision.
• An expectation that licensing authorities ensure the availability of hackney carriages at all times — a factor outside their direct control.
• A requirement for licensing authorities to manage work-related risks for licensees — an obligation that extends beyond their statutory remit.

These examples place undue pressure on authorities and suggest a lack of meaningful engagement or understanding from those responsible for setting national standards. To realise the benefits of harmonisation, this approach must change and there must be greater scrutiny and oversight of how authorities are applying the standards that they publish. In addition, the Department for Transport (DfT) or an appointed body such as the Institute of Licensing (IoL) could support the sector by providing standardised materials — regularly updated — to assist with safeguarding training, and by setting national guidance for assessing applicant and licensee suitability, such as through adoption of the IoL Suitability Guidance[5].

However, a critical caveat remains: out-of-area operation. Many licensees operate predominantly outside the district in which they are licensed, often with little to no enforcement oversight from the issuing authority. This creates significant challenges for districts experiencing high volumes of externally licensed vehicles. The solution cannot simply be to expect all authorities to deliver compliance activity on a national footprint — this is neither reasonable nor achievable. Cross-district officer authorisation is not a viable alternative, especially given the disparity in resources and capacity between licensing authorities.

In effect this means that because of the existing scale of out of area operation, simply harmonising standards will not have sufficient impact to address the fundamental challenges currently presenting – as this would not introduce the incentive, or requirement, to license locally, while the challenges around enforcement would remain.

4. What steps should the Government take to address the challenges posed by cross-border licensing in the taxi and PHV sector?

As set out in answers above, Greater Manchester is of the view that the current approach to taxi and private hire licensing is insufficient and the current scale of out-of-area operation presents significant challenges in regard to the enforcement of standards – and the ability of our licensing authorities to ensure public safety. A licensing authority can only be confident in the application of processes and enforcement of conditions and standards, including data quality assurance, when they have clear oversight of these processes and decisions, and management of the staff employed to deliver them.

The ability of licensees to obtain licences from authorities with lower standards — often at lower cost — also fundamentally risks the viability of other licensing authorities. This is because as the percentage of licensees operating in an area but licensed elsewhere increases, the number of licensees licensed within the district will reduce, and taking account of minimal staffing levels and overheads to operate, the fees for the remaining licensees will need to be increased to recover costs, resulting in a vicious circle of ever increasing risk from licensee displacement.

To address the challenges of licence shopping and cross-border licensing in the taxi and PHV sector, the Government should adopt a holistic and strategic approach that balances the needs of local communities, operators, and passengers while promoting fairness and public safety.

These issues are not new. In 2014, the Law Commission conducted a comprehensive review of taxi and PHV regulation, recommending significant legislative reform[6]. That need remains urgent. The Government should seize the opportunity presented by the English Devolution Bill currently progressing through Parliament to deliver the legislative change required.

Wider opportunities to tackle problems presented by cross-border operation include:

• Harmonisation of Standards and Conditions: The Government must explore the feasibility of creating minimum national standards for driver vetting, vehicle safety, and insurance requirements. While local flexibility should be retained where appropriate, a common baseline would promote consistency and reduce the incentive for ‘regulatory shopping’.
• Joint Enforcement Protocols: Establish collaborative and financially fair frameworks for enforcement between neighbouring authorities. This may include reciprocal recognition of licence conditions, shared intelligence on non-compliance, and coordinated on-street operations to uphold standards across borders.
• Funding and Resource Support: Recognising the increased burden on authorities navigating these issues, the Government should consider targeted funding for technology upgrades, training, and additional staff needed to manage the transition and ongoing cross-border complexities.
• Ongoing Review and Adaptation: As market dynamics and technology continue to evolve, government should commit to periodic review of the cross-border licensing framework, ensuring regulations remain effective and responsive to new challenges.

5. 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?

Local authorities must be empowered with the ability to deliver a truly joined-up, reliable, and trusted transport network, so that taxis and private hire vehicles form an integrated part of the public transport offer. At present, the coexistence of two competing regulatory regimes—one where authorities have little or no control or oversight over the number of vehicles operating within their areas, or the standards to which they are held—produces deeply fragmented outcomes.

This fragmentation leaves a vacuum in oversight and can reduce the sector to a "wild west" environment, where inconsistent standards and unchecked growth undermine both public safety and trust. Without comprehensive powers to regulate both numbers and operational standards, authorities are unable to create the cohesive, accountable system passengers expect and deserve.

The operation of app-based-only-operators also needs to be reviewed to consider if and how they can adequately ensure that the person driving the licensed vehicle is properly licensed. Traditionally, private hire operators used radios to stay in almost constant contact with their drivers. Today, this is no longer the case, but there has been no national guidance on what constitutes adequate checks by operators during the time the vehicle is being used.

The lack of controls on the numbers of private hire drivers and vehicles can also present problems, especially for transport authorities. In large urban areas, the congestion caused by over-saturation of the local market should not be underestimated, making it very challenging to manage the road network, especially at night and during key events and busy seasonal periods. Aside from the congestion and air quality issues this presents, it can also create a safety issue as blue light services struggle to attend calls, and passengers struggle to get home safely or have to wait significant periods for a booked vehicle that is a relatively short distance away simply because the road network is too congested. Licensing authorities require the ability to limit the number of private hires operating within their area in order to address these issues.

6. How are digital ride-hailing platforms impacting standards in the sector, and is further regulation in this area required?

Yes, national legislation underpinning taxi licensing dates to the early twentieth century. It does not take account of the profound change that has taken place within the industry in recent years with the rise of ride-hailing platforms.

Large digital ride-hailing platform operators have supported some positive development within the sector, including practices that support public safety, e.g. clear communication to customers of vehicle and driver information in respect of booking ahead of arrival. These measures are valued by passengers and regulators, and such measures have since been adopted by more traditional area-based operators.

However large digital ride-hailing platform operators have been a significant facilitator in allowing the growth of out of town licensing, reducing the ability of licensing authorities to effectively regulate. Action to address the issues arising from licensees that operate predominantly outside of the district in which they are licensed, would address the majority of concerns around large digital ride-hailing platform operators.

While local authorities retain some control over the numbers of licensed taxis operating within their jurisdictions, this regulatory grip has been undermined by the rapid growth of private hire vehicles—particularly those backed by ride-hailing platforms. These platforms, leveraging technology, have in effect created a virtual taxi rank, allowing passengers to summon vehicles instantly and with remarkable convenience. As a result, traditional taxis, even where their numbers are regulated, find themselves outcompeted by private hire alternatives that can operate at a greater scale, often without being subject to the same local restrictions or quality standards. This dynamic further fragments the market and erodes the effectiveness of local authority oversight, as private hire vehicles proliferate in response to demand, rather than within the boundaries of coordinated, locally-managed transport planning.

Action to address the issues arising from licensees that operate predominantly outside of the district in which they are licensed, would address the majority of concerns around large digital ride-hailing platform operators.

7. 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?

Ride-hailing platforms have developed user-friendly digital incident reporting systems to manage complaints that have been effective at collating and quickly responding to issues. Licensing reforms could help more authorities to emulate this approach.

Our local experience is that systems and processes are known and trusted by trade and customers. Established relationships are in place with both Hackney and Private Hire trade, with many districts facilitating proactive meetings between licensing authorities and trade representatives. Generally, licensing services have a good track record of responding to concerns raised, and generally licensees are attentive to their responsibilities to consider and respond to complaints. The largest concern expressed by both trade and passengers is the relative lack of control the local authority has over vehicles/drivers licensed out of area and the perceived unfairness and inconsistency this can result in.

8. 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 National Register for Revocations, Refusals and Suspensions (NR3S) was introduced to improve consistency and transparency in licensing decisions across local authorities, reducing the risk that unsuitable drivers could evade sanctions simply by applying elsewhere. In theory, NR3S should be a powerful tool to support public safety: it enables licensing authorities to access shared information, helping to prevent drivers with a known history of misconduct or safety concerns from working in other areas.

However, the effectiveness of NR3S in practice is constrained by several barriers. Firstly, its use is not yet universal or fully embedded across all licensing authorities, resulting in patchy coverage and potential gaps where problematic drivers could slip through the net. There are also variations in how rigorously different authorities check and update the register, which can undermine its reliability as a comprehensive safeguard. Data protection concerns and administrative burdens may further discourage frequent or consistent use, particularly among smaller or resource-strapped authorities.

Another challenge is the alignment of standards and definitions: authorities may have differing interpretations of what constitutes a revocation or refusal, meaning that the information recorded on NR3S may not always be directly comparable or actionable in another jurisdiction. 

For example, Greater Manchester (GM) is aware of an instance where one of its licensing authorities received a referral about a driver who voluntarily surrendered their license elsewhere. Upon further investigation, it was discovered that the incident involved a serious sexual assault. Consequently, that driver's licence was formally revoked by the GM authority placing the driver on the National Register. Without this record, the driver could have applied for a license elsewhere without restriction.

The Greater Manchester Authorities are concerned that other authorities may accept the surrender of a licence instead of conducting formal revocations and placement on the National Register, thereby impacting public safety.

As a result, while NR3S represents a step in the right direction for safeguarding passengers and raising standards, its full potential will only be realised if participation is made mandatory, technical systems are streamlined, and support is provided for effective data sharing and interpretation.

9. What are the implications for taxi and PHV licensing of the future rollout of autonomous vehicles?

One of the most significant implications of the widespread adoption of autonomous vehicles in the taxi and PHV sectors is the potential for substantial job losses. The transition away from human drivers threatens the livelihoods of thousands who currently depend on this trade, raising social and economic questions. Moreover, without agreed national standards and robust enforcement on vehicle numbers and operational practices, there is a real risk that autonomous fleets could proliferate unchecked, creating serious challenges for city regions tasked with planning and managing an efficient, integrated transport network.

These difficulties are heightened by the fact that taxis and PHVs are a lifeline for many of the most vulnerable members of society. Older adults, people with disabilities, and others who rely on door-to-door accessible transport may find themselves disadvantaged if the human element is lost. The unique reassurance, adaptability, and assistance provided by a professional driver cannot, at present, be replicated by autonomous technology.

For many, the human touch is not just a preference but a necessity for safe and reliable travel. For example, at present, licensed drivers are expected to provide reasonable assistance to passengers and are encouraged to support public safety through reporting of activities observed that give rise to safeguarding concerns or suspicions of criminal activity, informed by safeguarding training. There is a danger that this could be lost.

In this context, it is vital that any move towards autonomous vehicles in the sector is considered holistically, with careful attention paid to the social, economic, and accessibility impacts, as well as to the regulatory frameworks required to support a fair, safe, and inclusive transport system for all.

September 2025

Endnotes