Written evidence submitted by Transport for London (RSS0079)

Executive Summary

Transport for London (TfL) is the integrated transport authority responsible for delivering the Mayor’s statutory Transport Strategy and its commitments on transport in London. We run the day-to-day operation of the capital’s public transport network, manage London’s main roads and are the strategic Highway Authority for the capital. We work closely with London Boroughs and provide annual funding to enable the management and improvement of the local highway network.

The safety of Londoners and visitors is our number one priority. We remain committed to Vision Zero and improving road safety across London.  

We welcome the publication of the national Road Safety Strategy. It represents a significant and positive step forward, demonstrating clear national leadership and a renewed commitment to tackling road danger. The timing is particularly valuable for us, as we are preparing to publish our own Vision Zero Action Plan 2 (the ‘Action Plan’), creating a strong opportunity for alignment and strengthened joint working.

We appreciate the comprehensive nature of the strategy and are encouraged that Government has addressed many of the areas where it holds the key levers for change. While some gaps remain, the strategy closely reflects the priorities we had hoped to see at a national level.

We welcome the opportunity to contribute evidence to the Transport Select Committee’s inquiry on the Road Safety Strategy and remain eager to work closely with the Government and partners to improve road safety standards across the capital and the UK.

In our forthcoming Action Plan, we outline several areas where TfL is seeking closer collaboration with Government in line with the national strategy’s direction. We are particularly pleased to see an ambitious national casualty reduction target and have aligned our proposed new interim target accordingly, signaling shared ambition and a commitment to partnership.

Asks of Government

Our response details a number of areas where we believe action is needed to further reduce road danger. These areas are explained fully in the response below and summarised here.

Some of these the Department for Transport have announced or are actively consulting on in the national Road Safety Strategy. 

Under the Safe System approach and in the areas where Government holds the strongest levers to drive change, our asks are as follows:

1. Safe Speeds

2. Safe Vehicles

3. Safe Behaviours

4. Driving and Riding for Work

5. Post Collision Response

Regarding enforcement, we urge the Government to encourage police forces to focus efforts and resources into road policing for the purpose of reducing road danger, not just for the purpose of denying criminals the use of the road. Enforcement to tackle dangerous and careless road user behaviour is a core policing responsibility. The specialist skills and resources needed to keep roads safe requires policing at a scale and level that is not currently being reached across the UK. Change is needed to achieve road safety.

We believe these areas of action would benefit road safety across the country and would welcome the opportunity to support the development and roll out of such change. 

Please find our responses to the questions below. 


START OF RESPONSE


Ambitions and evidence

a)     The strategy sets targets of a 65 per cent reduction in people killed or seriously injured (KSI), and a 70 per cent reduction in child KSIs, by 2035. Do these targets reflect the right level of ambition?

We welcome the national road danger reduction target and have aligned our own interim Vision Zero target with it to reflect shared ambition.

While we would have preferred Government to set a long-term Vision Zero goal, we see the new target as an important step that signals leadership and commitment to reducing harm.

Our assessments for London indicate that the target is highly ambitious — a positive signal that will help focus effort and highlight the scale of the challenge ahead.

b)    Are governance, delivery and resourcing arrangements across Government departments and key partners strong enough to achieve these targets?

The strategy outlines high‑level governance arrangements, including the establishment of a new Road Safety Board supported by an Expert Advisory Panel, as well as proposed monitoring arrangements which, on the surface, appear sufficient.

We look forward to seeing more detail as this develops — particularly around membership and how these structures will operate in practice.

The strategy provides limited detail on the governance and delivery of individual workstreams, and we would welcome further clarity as this develops.

We are also keen to understand how workstreams requiring collaboration across multiple Government departments — for example, enforcement (DfT and the Home Office) and work-related road risk (DfT, HSE, BEIS, the Home Office and others) — will be coordinated, particularly where issues such as the gig economy extend beyond road safety. We will follow with interest how this cross-government approach is structured and overseen.

We are also keen to understand whether there are further plans for engagement with devolved authorities, who are responsible for delivering, implementing, and enforcing measures on the ground.
 

c)     Are the measures set out in the Strategy collectively sufficient to deliver its targets? What further measures, if any, would strengthen its impact?

Based on our own assessments for London, we believe the national target is highly ambitious — and we welcome that. Achieving it will require a very strong, collaborative effort across all partners.

At this stage, many of the actions set out in the strategy focus on consultation, exploration and reviewing evidence rather than setting out detailed, decisive steps for delivery. Given that 2035 is approaching quickly, these enabling actions will need to move forward at pace, with clear timelines, and be translated into robust and deliverable work plans in the near term if we are to meet the target.

We would welcome a better understanding of how this transition — from exploratory actions to concrete delivery plans — will be managed, and how the necessary workstreams will be developed and implemented at speed.

d)    Are the measures set out in the Strategy based on robust evidence?

Yes, we think the actions are largely evidence based and align well with our findings in London and with the priorities set out in our Action Plan. This includes measures such as work-related road risk, tackling illegal number plates which are used to evade enforcement, unregulated micromobility and high casualty rates among people walking and cycling.

Important areas where we feel stronger, more decisive national action was needed:

e)     The Government has said its strategy is informed by Sweden’s Safe System approach. What other international or UK examples offer the most relevant lessons for reducing deaths and serious injuries?

London is reducing road danger faster than the national trend. In particular, we have reduced the most severe collisions at the greatest rate. In 2024, road deaths in London were 19 per cent below the 2010-14 baseline (26 fewer people killed), compared with a ten per cent reduction nationally (excluding London). Independent analysis also shows that London is safer than many comparable cities, both nationally and internationally.

Core to our success has been measures including:

In Helsinki, policies for introducing safe speed limits led to a full year without road fatalities[3].

In Oslo, policies to reduce traffic in the city led to zero people killed while walking or cycling in 2019 and 2023[4].

In Brussels, the city centre was redesigned to prioritise sustainable transport and local access. Within just one year, collisions fell by 21 per cent[5].

 

Theme 1: Supporting road users 

f)      What measures would be most effective in reducing deaths and serious injuries involving new and novice drivers? What are the likely impacts of introducing a minimum learning period for learner drivers?

Research consistently shows that young and novice drivers face a disproportionately high collision risk due to their limited on-road experience, developing hazard perception and for younger drivers a greater propensity for risk-taking. Effective interventions should focus on eliminating or reducing exposure to high-risk situations and support of skill development.

Graduated Driving License (GDL) systems reduce risk by restricting the riskiest conditions for new drivers and introducing these in stages when the driver has more on-road experience.  The key measures shown to be most effective are a minimum learning period of no less than 6 months, passenger restrictions with particular focus on peer -aged passengers and night time driving restrictions. GDL is consistently cited as the most effective systemic intervention for reducing collisions involving novice drivers.

The strongest UK-specific evidence comes from deliberative research conducted by Ipsos for the RAC Foundation. This discussed a GDL model which included a mandatory minimum six month learning period before being eligible for a practical test. Although some international schemes prefer a longer supervised learning phase, as its generally considered safer, evidence does not clearly identify this to be the case. Instead, effectiveness appears to come from what happens during the learning period:

It would also be highly beneficial for road safety education more broadly to be taught as part of the UK National Curriculum, where education is consistent and relevant for each age group. In the majority of European countries there is a legal duty to provide traffic safety and mobility education. [6] Age-appropriate education of safety and road dangers will build young people’s knowledge, attitudes, decision making and risk awareness.

Studies highlight that driver capability is shaped long before licenses are obtained, through parental modelling and early education, as this strengthens safety knowledge and behaviour. Young people who internalise road safety norms early are more likely to become attentive passengers and cautious novice drivers, with greater understanding of danger and consequences. These young people will be greater equipped with the ability to resist peer pressure, a leading cause of danger on the roads, and know how to behave responsibly when issued with a driving license.

g)     What is the right approach to safe driving later in life? What safeguards are required to protect both safety and independence of older drivers?

Driving remains important for older adults in many parts of the UK. It enables access to essential services, supports independence, and prevents social isolation—especially in rural areas with limited public transport. In urban areas and larger cities, public transport services are more accessible so perhaps retaining the ability to drive is less of a concern and requirement to remain independent. Risk of collision does increase with age, although most older drivers remain safe. Health changes can be the primary cause for a decline in driving ability. The right approach therefore isn’t about restricting driving by age but supporting safe driving for as long as individuals are fit to drive, while ensuring timely interventions when age-related changes pose a safety risk.

Many older drivers already modify their driving (avoiding night driving, peak hours, long trips). This type of voluntary self-regulation can be supported by assessments and education and helps people stay safe for longer.

Improved medical assessment pathways, which entail strengthening GP involvement, clearer DVLA guidance, and referral to mobility centres when needed would support fairer, more accurate assessments, along with mandatory eyesight checks, will assist in safeguarding to protect drivers and other road users while retaining independence of older drivers.

h)    What should the proposed work-related road safety charter require of organisations that employ people to drive or ride for work?

Charter Applicability

The existing best practice standards and schemes tackling work-related road risk focus mainly on large fleet operators, traditional employment models and heavy vehicles such as trucks. For the new national charter to be effective, it must be scalable, practical and meaningful for everyone — including small operators, grey fleet users and the gig economy.

Schemes such as FORS and CLOCS have succeeded largely because they are mandated through public sector supply chains. To achieve meaningful adoption, the new charter will need similar levers. For example, engaging commercial sectors such as hospitality so restaurants and retailers ensure they contract companies that actively manage work-related road risk and sector supply chains. To achieve meaningful adoption, the new charter will need similar levers. For example, engaging commercial sectors such as hospitality so restaurants and retailers ensure they contract companies that actively manage work related‑road risk.

Content

The new charter should set out clear, evidence‑led guidance across core areas including vehicle safety standards, maintenance and vehicle checks, travel policy and modal choice, driver and rider competency and training, health and fitness, drugs and alcohol policies, mobile‑phone use and safe app design, routing and scheduling, safe loads and equipment, collision reporting, and driver/rider monitoring and behaviour. Specific requirements should be developed in partnership with industry to ensure practicality and effectiveness.

Effectiveness

The charter should include a clear mechanism for monitoring uptake, assessing compliance, and evaluating effectiveness over time, so that progress can be measured and improvements made where needed.

We see the charter as a strong step in the right direction and welcome its introduction; however, we believe that legislative change will ultimately be more effective and is likely to be required to deliver meaningful, sustained progress.

We also wish to highlight the particular challenges in the gig economy, especially those related to degree of control and substitution rights. The charter should consider how these issues can be addressed and whether voluntary measures are sufficient, or if legislative intervention will ultimately be necessary.

i)       To what extent does fear of traffic danger deter certain modes of travel, particularly walking and cycling, and what measures would be most effective in addressing this?

There is clear evidence that fear of traffic deters active travel, with our research showing too much traffic being the third most commonly cited barrier to walking more in London (around one fifth of Londoners) and fear of collisions and traffic being fourth and fifth most commonly cited respectively. For cycling, road danger is the primary barrier to more people cycling, with 82 per cent of non-cyclists in London citing it as a deterrent[7].

The most effective methods of addressing this deterrent are reducing overall traffic volumes, re-allocating road space to provide segregated infrastructure for people walking and cycling that provides priority over motor vehicles, and lowering speeds. These approaches are encompassed by the Healthy Streets Approach that underpins the London Mayor’s Transport Strategy, and also supports other sustainable modes, including delivering bus priority to encourage mode shift.

Traffic reduction is the most effective of these methods, as well as often being low cost due to the lack of need of extensive physical infrastructure. The evidence in London shows that LTNs significantly reduce traffic in their scheme areas, and those living inside them complete 62 minutes more walking and 43 minutes more cycling per week five years post installation[8].

TfL’s strategic cycle network is comprised of segregated and low traffic cycle routes to ensure users feel safe from traffic. It has been expanded from 90km in 2016 to over 430km by the end of 2025. Daily cycle journey stages have risen by 42 per cent from 2016 to 2025, reflecting the importance of this network to enable people to cycle[9].

Other key measures within the Healthy Streets Approach that reduce fear of traffic and enable more active travel include school streets, bus and cycle only high streets, and new signalised or zebra pedestrian crossings. London has over 800 school streets and has seen an increase in the proportion of walking trips to primary schools from 53 per cent over the time period 2012/13 – 2016/17 to 63 per cent across the three years 2022/23 – 2024/25. Bus and cycle only streets also support active travel whilst reducing road danger, for example after restricting private motor traffic on Stoke Newington Church Street, Hackney subsequently saw an increase in walking by 16 per cent and cycling by 38 per cent on the street[10].

j)       What should reform of motorcycle training, testing and licensing look like in practice?

In London, motorcycles are – and consistently have been – the highest risk mode of transport on London’s roads, both to their riders and to other road users involved in road collisions. People riding motorcycles make up 3.8 per cent vehicle mileage travelled but account for 22 per cent (2022-24) of people killed or seriously injured. They are also disproportionally involved in collisions that kill or seriously injure others on the road, particularly people walking.

We welcome the Government’s plans to consult on reforms to Category A motorcycle licensing and continue to advocate for urgent improvements to Compulsory Basic Training (CBT). Currently, 57 per cent of motorcyclists killed or seriously injured in London are riding low powered motorcycles (125cc or below), which can be used on a CBT. Implementing the recommendations from the 2016/17 DfT and DVSA consultation — particularly introducing a theory test and digitising the system — would be important steps toward improving rider safety.

We also support a wider review of the licensing framework. However, we strongly urge Government to ensure that rider safety remains the primary focus of any reforms, rather than prioritising ease of access or simplification.

Theme 2: Taking advantage of technology, data and innovation for safer vehicles and post collision care 

k)     How can Government maximise the safety benefits of Advanced Driver Assistance Systems (ADAS) and ensure they are used safely and appropriately?

No comment

l)       What is the right approach to strengthening vehicle safety standards? What measures should the Government prioritise in response to issues such as headlamp glare, increasing vehicle size and any broader issues not currently being considered by the Government’s consultation?

Government leadership on vehicle standards is essential. A national, consistent approach avoids a postcode lottery, provides clearer expectations for industry and consumers, and delivers safety benefits at scale. National government also holds the most effective levers, whereas local interventions are more limited, costly and time‑consuming. Proven measures like London’s Direct Vision Standard shows what can be achieved[11] and applying them nationally would ensure everyone benefits — not only those in London.

Vehicle technology has enormous potential to reduce road danger and should therefore be a top government priority:

 Theme 3: Ensuring infrastructure is safe

m)  How should evidence on the relationship between speed limits and safety influence new guidance? Does the Strategy strike the correct balance between a nationally-set direction and local decision-making regarding speed?

The evidence strongly supports a 20mph urban limit and stronger national leadership on this issue within the strategy would have been welcome. In the absence of a national default, implementing 20mph places a disproportionate burden on already resource-constrained local authorities, requiring significant funding, officer time and political effort to make changes street by street. This leads to patchy implementation, rising costs and the unnecessary politicisation of an evidence-based safety measure.

n)    What measures would be most effective in improving safety on rural roads, and is the Strategy’s proposed approach sufficient?

No comment

o)    What scope is there for road design and maintenance to further improve safety?

Road design has a key role in the safe systems approach in creating streets that can accommodate and forgive human error such that collisions do not result in fatal or serious injury. The commitment to the publication of Manual for Streets 3 is welcomed and provides an opportunity set out the latest thinking on designing safe streets.

Road design is important in all environments and must serve to help protect those who are most at risk. In urban environments such as London the largest proportion of people killed or seriously injured on the roads are those walking or cycling (59 per cent in 2024).

TfL’s suite of streets planning and design guidance supplements national guidance, and sets out how the Healthy Streets Approach should be used in designing high-quality streets that improve safety, including prioritising and protecting people walking and cycling. 

The evidence shows that improving the design of streets and implementing active travel infrastructure improves safety:

Theme 4: Robust enforcement to protect all road users

p)    What measures would most improve compliance and deterrence in relation to motoring offences?

Success requires three non‑negotiables: targeted investment in roads policing focused on reducing road harm, modernised training and technology and legal clarity that matches today’s roadside risks.

Technology

 


HOTA
 

Ghost number plates

 

We welcome new measures in the national strategy to target the growing problem of illegal number plates and agree legislative and regulatory reform is needed, including introducing harsher penalties for suppliers selling illegal plates or failing to meet documentation requirements. Accountability for vehicle owners is also needed. We suggest introducing shared liability for registered keepers, not just drivers, where illegal plates are used.

 

Other measures include:
 

 

For enforcement and technology, we suggest:

 

 

Retention of Fixed Penalty Notice Revenue in Local Areas
 

 

DVLA Process Improvements

 

 

Public Safety and Scheme Integrity

 

NIP Farms

 

Increasing the Statutory Limiting Period for summary offences, such as speed

 

 

Court time and resource

 

Digitisation

 

Which such offences have the biggest impacts on collision and casualty rates?

52% of all fatal collisions between 2022-2024 were because of inappropriate speed for the conditions or speeding.


Drink/drug driving also has an impact. The National Police Chief’s Council Operation Limit (Christmas Drink/Drug Driving Campaign) ran from 1st–31st December 2025 and a total of 1738 breath tests were administered during the campaign. Statistics on the outcome of these are below:

 

Research shows that drivers using a mobile phone are up to four times more likely to be involved in a road traffic collision.[15] 

 

Similarly, occupants who fail to wear a seatbelt are significantly more likely to be killed or seriously injured in a crash. These reckless behaviours endanger not only the individuals involved but, critically, other road users.

 

Recent data highlights the urgency of addressing these behaviours: an estimated 50,000 instances of mobile phone use while driving occur daily in the UK, and around half a million motorists are observed driving without a seatbelt.  [16]

 

Priority offences of Dangerous and Careless Driving

 

Uninsured and unlicensed drivers pose a significant risk to other road users, with the MIB stating that every 20 minutes, someone is the victim of an uninsured or hit-and-run driver. They estimate that every day there is an average of 300,000 uninsured vehicles on UK roads. Uninsured and unlicensed drivers are statistically more likely to commit road traffic offences and be involved in fatal collisions.
 

q)    What role do the type and severity of sanctions play in deterring dangerous driving, and which sanctioning approaches are most effective at changing driver behaviour?

We urge the Government to consider increased guidance and governance around the use of the Exceptional Hardship defense to ensure that drivers are not able to escape punishment or use the defense on multiple occasions and to ensure that it is applied consistently across the CJS.

Speeding fixed penalties have not changed for over a decade, remaining at £100, despite other fixed penalty amounts, such as for mobile phone offences, increasing. Tougher sanctions, balanced with the need for education, are a strong deterrent for drivers. With many fixed penalty sanctions having been unchanged for several years, we encourage the Government to review the severity to ensure that the most dangerous offences are treated as such.

 

March 2026

Endnotes


[1] Safe speeds - Transport for London

[2] Low Traffic Neighbourhoods in London reduce road traffic injuries: a controlled before-and-after analysis (2012–2024) | Injury Prevention

[3] Achieving Vision Zero - Helsinki

[4] Achieving Vision Zero - Oslo

[5] Safer, cleaner and more lucrative: The Good Move plan transforms Brussels’ city center — but remains politically divisive – POLITICO

[6] ETSC-LEARN-Report-on-the-Status-of-Traffic-Safety-and-Mobility-Education-in-Europe.pdf

[7] https://content.tfl.gov.uk/cycling-action-plan.pdf

[8] https://content.tfl.gov.uk/tfl-impacts-of-low-traffic-neighbourhoods-feb-2024-acc.pdf

[9] https://tfl.gov.uk/corporate/publications-and-reports/travel-in-london-reports

[10] https://hackney.gov.uk/stoke-newington-ltn

[11] Vulnerable Road Users deaths and serious injuries in collisions with HGVs fall 50 per cent under Mayor's lorry safety scheme - Transport for London

[12] Vaccine-for-Vehicles.-Final-1.pdf

[13] https://findingspress.org/article/18226-cycling-injury-risk-in-london-impacts-of-road-characteristics-and-infrastructure

[14] https://content.tfl.gov.uk/cycling-action-plan.pdf

[15] https://www.brake.org.uk/get-involved/take-action/mybrake/knowledge-centre/mobile-phone-use

[16] https://www.ukroed.org.uk/distracted-driving-danger-warning/