Written evidence submitted by the Chartered Institution of Highways and Transportation (CIHT) (RSS0130)

The Chartered Institution of Highways and Transportation (CIHT) is a charity, learned society and membership body, with over 10,000 members across 12 UK regions and several international groups. CIHT represents and qualifies professionals who plan, design, build, manage, maintain and operate transport and infrastructure. 

Q1. 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? 

Yes, the targets are ambitious and will be challenging to achieve, however they provide an essential focus and incentive for action. They represent a step in the right direction, although the longer‑term ambition should ultimately be Vision Zero, supported by mode‑ and user‑specific casualty‑reduction targets.

While the ambition of the proposed targets - a 65% reduction in KSIs and a 70% reduction in child KSIs by 2035 - is positive and aligns with the long‑term direction of travel, it is important to recognise the limitations of the underlying data.

The only consistently reliable road casualty statistic is the number of fatalities, as serious injuries remain significantly under‑reported. Unless resources are committed to substantially improving the accuracy of road casualty data - such as through systematic cross‑referencing with NHS records and insurance claims - the confidence with which KSI‑based targets can be monitored will remain constrained. Misclassification of injury severity levels, including but not limited to serious and slight injuries, has been a persistent issue in a number of countries[1][2][3], including the UK[4]. This reinforces the point that systematic cross-referencing between transport authorities, police, healthcare systems, and insurance records is necessary for the improvement of the reliability and accuracy of road casualty data.

The scale of the challenge should not be understated. Achieving these reductions will require a significant shift in public attitudes toward dangerous and irresponsible driving. There are also concerns about the suitability of the proposed 2022–2024 baseline, as changes in Department for Transport (DfT) data formats, the inclusion of publicly reported data, and system changes within Greater Manchester Police (GMP) and other forces have not yet been fully accounted for or acknowledged.

Transport for London has already committed to a zero‑fatality target by 2041[5], demonstrating the level of ambition needed and reinforcing the message that death and serious injury on the roads are unacceptable outcomes. Increasing the national targets beyond 65% and 70% could further strengthen focus and drive progress toward reducing KSIs.  Any increase in target ambition should be contingent on a parallel, time‑bound plan to improve casualty data quality and baselining.

Additionally, progress in in-vehicle safety technology has the potential to significantly decrease vehicle-occupant KSIs, and, to a lesser extent, KSI casualties as pedestrians, cyclists, micromobility users, moped/motorcycle users and equestrians.  Those groups – often referred to collectively as vulnerable users - would benefit from a vehicle fleet having more usage of autonomous braking, lane assist and detection technologies especially, but the collective benefit for all road users is likely to fall a long way short of the 65% KSI target without substantial enhancements to overall system-wide safety such as national changes to speed limits, more compatible with the safe system approach. 

Even if rapid legislation is progressed to mandate a General Safety Regulation-equivalent technology package on all new cars – or even higher protection in terms of the way Intelligent Speed Assist is applied – the roll out to the UK fleet over the period of the RSS application is uncertain and older vehicles will remain with much lesser protection. Financial incentives – such as scrappage schemes – can be extremely powerful; a previous scheme made a substantive contribution to the halving of UK road death in the decade 2000-2010, so decisions on vehicle technology need to include the application and incentives to accelerate take-up. 

The stronger the benefit to in-vehicle protection compared to other groups of road users could result in a further growth in the gap between the trends in KSIs among vulnerable road users and those seen for vehicle occupants. Therefore, monitoring frameworks of KSI reduction should distinguish between user groups to prevent unequal outcomes.  This would reflect good practice in safety governance for highway changes where overall targets to improve safety as a result of an intervention must not benefit one group at the expense of another. 

Q2. Are governance, delivery and resourcing arrangements across Government departments and key partners strong enough to achieve these targets?

At present, governance, delivery, and resourcing arrangements do not appear strong enough to achieve the proposed targets. It remains unclear how the ambitions will be funded or supported by coordinated national action.

Achieving reductions of this scale is difficult to imagine without interventions such as national changes to speed limits - similar to the recent approach taken in Wales for 30 mph roads[6] - or a strategic programme to review rural speed limits at scale.

Progress will also depend on the rapid adoption of EU‑compliant General Safety Regulation (GSR) vehicle standards - without firm national commitment to these measures, the delivery pathway for meeting the targets remains uncertain.

Achieving the proposed reductions in casualties requires action far beyond the remit of Government departments and key partners alone. The Strategy would have benefited from providing greater clarity on how the whole of Government will contribute to casualty reduction.

With the NHS under pressure, limited funding available, and low economic growth, the Government appears to have limited capacity to provide the level of funding that would be necessary to support the scale of change implied by a 65% reduction in KSIs.

Recent disbanding of specialist police teams, including in London, illustrates the challenge of sustaining the enforcement and investigation capacity required. While the establishment of the Road Safety Investigation Branch and the Road Safety Board is welcome, these efforts must be matched by sufficient support at local level.

Local authorities, particularly those with rural networks, need increased and sustained capital and revenue funding. Capital investment is essential for new interventions, while revenue funding is critical for maintaining road signs, markings and other infrastructure.

Recent changes to central government funding have favoured densely populated areas, leaving authorities with rural networks - who often face higher KSI rates - with fewer resources.

Overall, without stronger cross‑government ownership, adequate funding and clearer delivery structures, the arrangements in place are unlikely to achieve the Strategy’s ambitious targets.

Q3. Are the measures set out in the Strategy collectively sufficient to deliver its targets? What further measures, if any, would strengthen its impact?

While the Strategy sets out a range of measures, they are unlikely to be sufficient on their own to achieve the proposed casualty‑reduction targets. A key concern is the absence of dedicated, sustained, funding. Without this, local authorities and other partners cannot plan or deliver the level of intervention required.

Achieving the targets will also require stronger cross‑government ownership. Responsibility for reducing casualties should not sit solely with the Department for Transport - all departments and ministers whose policies influence road safety must contribute. This will require leadership and clear effective messaging regarding changes such as national-level speed limit alterations that are proven to be popular with the majority of people, but which are inaccurately portrayed as unpopular by a vocal minority.

Similarly, the Strategy should outline clearer arrangements for monitoring progress. Previous tools, such as the Agilisys local authority performance dashboard[7], demonstrated the value of accessible oversight but were not maintained. A national delivery mandate, supported by ring‑fenced funding and regular performance monitoring - such as through the Road Safety Board - would strengthen accountability.

There is also a need for substantial investment in engineering and network‑wide risk reduction. Without sustained funding for infrastructure improvements, the Strategy relies too heavily on behaviour change and compliance alone.

The most conspicuous omission from the Road Safety Strategy (RSS) is Graduated Driver Licensing (GDL), which remains one of the most consistently evidenced interventions for reducing young driver collisions. The higher risk profile associated with young drivers suggests that additional restrictions and targeted interventions - especially in the first year of driving - would be beneficial. GDLs will be introduced in Northern Ireland in 2026[8].  The current DfT consultation on minimum period between obtaining a provisional licence and taking the test is welcome, but the potential benefit is small relative to the benefit of controls following gaining a full licence.

While the Road Safety Strategy provides an important first step, the wider delivery environment is constrained by a resource‑strapped local highway authority (LHA) community.

It is essential to have clear legislation, current guidance, and strong political leadership, all supported by solid evidence of effective approaches. At present, that evidence base is fragmented; the Road Safety Observatory was an important early attempt to address this and, in our view, was valuable despite low public awareness. In today’s AI-enabled environment, creating a successor Observatory may be more feasible, but it would require careful governance, transparency, and expert oversight, recognising that AI systems must be guided and quality‑assured to avoid reinforcing bias or weakening the evidence base. Poor or inconsistent guidance would also be a reputational risk, both within the Road Safety Community and more publicly. 

Education must form a more prominent part of the Strategy. Road users of all ages need to understand how to apply the Highway Code, particularly as street layouts evolve to support sustainable travel and prioritise pedestrians. Schools and community‑wide programmes should be included to ensure consistent messaging and these must be based on good practice for behavioural change which is unfortunately not the case for a large number of the current educational initiatives which rely on outdated and/or ill-informed perception of what alters behaviour.

In summary, while the Strategy contains positive elements, its impact would be significantly strengthened by dedicated funding, clearer cross‑government responsibility and leadership, robust monitoring, stronger engineering measures and a comprehensive approach to education and behaviour change.

Q4. Are the measures set out in the Strategy based on robust evidence?

Yes, many elements of the Strategy are grounded in evidence‑led approaches, which is encouraging. The inclusion of initiatives such as the Road Safety Investigation Branch is particularly positive, as it will help strengthen the evidence base and provide insight that has been lacking for some time especially the dispersed and uncoordinated expert work on collision investigation and prevention undertaken across Police, Strategic and Local Highway Authorities and many other bodies.

However, some limitations remain. For example, data on cycling collisions recorded by the police is known to be significantly lower than that captured by Hospital Accident and Emergency departments, even though police data is the primary source currently available. This discrepancy highlights the scale of under-reporting, even for serious injuries, and the importance of improving the consistency, completeness and integration of data sources moving forward.

Robust analysis of road traffic collision data is essential, both to understand trends and to assess the impact of interventions. ‘Before and after’ assessments can reveal what works well in practice, helping shape a more achievable and evidence driven programme of safety improvements.

Some of the case studies referenced in the Strategy offer valuable insight into implementation - for example, trials in America. In other areas, however, the Strategy refers primarily to future trials rather than drawing on existing evidence, which limits the strength of its conclusions.

One area where the potential to use collected records to prevent or mitigate collisions is currently constrained is the STATS19 road traffic collision data gathered in accordance with the DfT’s STATS20 requirements. The collected data contains information with high value to understand causation, and whether a comparable collision might be prevented in future. Those high-value elements are not made available to specialist road safety professionals working on new or improved roads or management of existing roads to determine what interventions might improve operational safety. The data collected for every collision includes

-         a free-text field to describe the location (for example A10, 75m west of junction with B314) and to describe in plain English how the collision occurred, for example ‘Driver of northbound Car1 suffered heart attack and car drifted into path of southbound HGV2’.

-         Additional information including Road Safety Factors[9] (previously Contributory Factors) where reported collisions can include one or more factors from a standard list to indicate whether aspects such as speed and road user errors are considered to have been relevant to the collision. These help specialist collision investigation and prevention professionals to identify and implement measures to prevent those collisions, as required by s39 of the Road Traffic Act (1988)[10].

At present while this information is collected by Police Authorities and collated by DfT for national availability to road safety professionals, those free-text fields and additional information are not widely available, meaning the potential to fully understand the causation – and potential prevention – of collisions, both individually and at larger scale, is undermined. The reason for restriction on data access is the sensitivity of information which might in very exceptional cases identify an individual involved in a collision. That reasoning is understood but the effect is that specialists, such as accredited professionals in the Society of Road Safety Auditors (a group within CIHT) are prevented from full analysis of collisions using data which was collected but which they are not able to obtain in most cases. CIHT recommends that a provision should be made to enable accredited registered professionals, such as members of the Society of Road Safety Auditors, to access and use those sensitive fields to prevent and mitigate injury from road traffic collisions.

Overall, while the Strategy incorporates several evidence-based components, further progress is needed to improve data quality and expand the use of robust evaluation. Doing so would help ensure that future measures are both well-targeted and demonstrably effective

Q5. 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?

Alongside Sweden, valuable lessons can be drawn from New Zealand and several Australian states that have adopted the Safe System approach. Their experience demonstrates that, while the Safe System framework provides a clear strategic foundation, implementation is far more challenging than is often assumed. This understanding is crucial for the UK, where awareness of the Safe System approach remains patchy[11].

Even in organisations that support the principles - local highway authorities, National Highways, transport services - the practical reality is that every operational activity must be aligned to the approach. This includes avoiding like‑for‑like replacement of non‑passive lamp columns in locations with a collision history; ensuring appropriate surfacing and drainage standards; maintaining signs and road markings to support the effective operation of Advanced Driver Assistance Systems (ADAS) technologies such as lane‑keeping assistance and Intelligent Speed Assistance (ISA); and maintaining strong oversight of developer‑led schemes.

According to the information CIHT gathered while preparing this response, designers and network managers across the UK often have only a limited understanding of the requirements needed to fully apply the Safe System approach. In addition, available budgets are not sufficient to implement these measures consistently, making it difficult for authorities to ensure that operational practices match the principles they support.

These international examples therefore underline that adopting the Safe System requires not only commitment to the principles but sustained investment, capability-building, and operational discipline if meaningful reductions in deaths and serious injuries are to be achieved.

While Sweden’s Safe System approach provides a strong foundation, there are several other international and UK examples that offer valuable lessons for reducing deaths and serious injuries. There is also the importance of comparing international approaches with approaches closer to home. A more detailed review of policies implemented in Scotland, Wales, and the Republic of Ireland would have been particularly useful, as both have introduced measures that could help identify what works well - and what does not - in contexts more comparable to England.

Qatar formally adopted the Safe System approach through its National Road Safety Strategy, launched in January 2013. Since then, all new highway and infrastructure projects are required to undergo Road Safety Audits (RSAs) at all stages of design, including concept, preliminary design, detailed design, and pre-opening.

A key strength of this approach is the early engagement of the RSA process. By reviewing schemes at the concept and preliminary stages, potential conflicts with Safe System principles - such as speed, roadside risk, vulnerable road user provision, and unforgiving design - can be identified and addressed before they become embedded in the design. This significantly reduces the cost and complexity of later changes and improves overall scheme safety performance.

If the UK were to further formalise early-stage RSA engagement explicitly aligned with Safe System principles, this could strengthen the practical delivery of Safe System objectives at project level. In particular, it would avoid the current common practice that by the first time a Road Safety Audit is undertaken, so much design development has been undertaken that there is reluctance to make substantive changes for cost or reputational reasons. Early involvement of road safety auditors in design options identification and evaluation could substantively reduce design re-work cost and make scheme delivery more efficient and more effective for road safety.

One recurring challenge observed internationally is where Safe System principles and existing design standards appear to conflict. In such cases, it can be difficult to communicate to designers and approving authorities why a ''standards compliant'' solution may not fully align with Safe System outcomes. This highlights the importance of ensuring that national standards are regularly reviewed and updated to reflect Safe System thinking, and that audit findings are given appropriate weight within approval processes.

In Qatar the benefits of procurement linked to road safety improvements is worth highlighting. The Roads Operations and Maintenance Department has adopted a new type of contract which helps promote the use of most up-to-date technological advancement in the field of the Road Safety. The contract is called "Performance Based Contract" where contracted companies are required to make recommendations on yearly basis. Adopting such a contract makes the contractor liable and brings out the best solutions to meet certain KPIs.

India’s road safety strategy, led by the Ministry of Road Transport and Highways (MoRTH), is built on the “4Es” framework - Education, Engineering, Enforcement, and Emergency Care - aimed at reducing road accidents and fatalities through a comprehensive and coordinated approach:

• Legislative & Policy Measures - India strengthened its regulatory framework through the Motor Vehicles (Amendment) Act (2019)[12], introducing higher penalties for violations such as speeding and drink driving, while also offering legal protection to Good Samaritans who assist accident victims. Complementing this is the National Road Safety Policy, which sets the direction for improving vehicle safety standards, road design, and public awareness. The establishment of the National Road Safety Board (NRSB) further supports evidence‑based policymaking and standard‑setting.
• Infrastructure & Engineering Improvements - To make roads inherently safer, MoRTH prioritizes the identification and rectification of accident‑prone “black spots” on national highways through structural redesigns and improved signage. Road Safety Audits are mandatory at every stage of highway development - from design to operation. Initiatives like Setu Bharatam aim to eliminate all railway level crossings on national highways by constructing overbridges and underpasses.
• Vehicle & Technology Safety Enhancements - India is advancing vehicle safety through programs like the New Car Assessment Program (NCAP), which assigns safety ratings based on crash tests. Mandatory safety features - such as airbags, ABS, and speed limiters - are now integral to vehicle manufacturing standards. Tools like the Integrated Road Accident Database (iRAD) support data-driven decision-making by capturing and analysing detailed accident information.
• Awareness, Education & Emergency Response - Road safety awareness is strengthened through annual nationwide campaigns such as National Road Safety Month/Week. To improve lifesaving response during the critical “Golden Hour,” India is piloting a Cashless Treatment Scheme for accident victims. Citizens who assist victims may also receive Good Samaritan Rewards, reinforcing a culture of responsibility and timely help.
• International Collaboration & State-Level Support - India partners with global institutions to enhance road safety outcomes. The State Support Programme, backed by the World Bank and Asian Development Bank, incentivises high‑fatality states to implement targeted safety interventions. Additionally, collaboration with the UN Road Safety Fund supports sustainable financing and capacity development in road safety management.

Internationally, Australia’s graduated driver licensing reforms were highlighted as having a positive impact on casualty reduction among young drivers. By contrast, evidence from the United States suggests that additional training for young drivers can, in some circumstances, lead to a slight increase in collisions - illustrating the need to consider cultural differences when applying international lessons. France raised the age limit for driving an e-scooter from 12 to 14; and increased the fines for riding on them with another person.[13]

The Scottish Government through Transport Scotland have also adopted the Safe System Approach.

Overall, while international best practice provides valuable guidance, policies must be adapted to the specific characteristics of the UK road network and user behaviour. A simpler, more accessible version of the Strategy - aimed at all bodies involved in road safety - would support this. Road Safety Audits (RSAs) should be the absolute minimum requirement. 

Clear identification of where current road layouts or organisational practices fall short, and honest acknowledgement of where action is or is not possible, would also strengthen the UK’s ability to apply learning effectively.

Q6. 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? 

CIHT recognises that reducing collisions involving new and novice drivers requires a considered, evidence‑led approach. Graduated Driver Licensing (GDL) has been extensively evaluated in the UK and internationally, and the available evidence suggests that a proportionate GDL framework - focused primarily on night‑time driving and passenger‑carriage restrictions during the first months after test‑pass - could make a meaningful contribution to reducing deaths and serious injuries among young drivers.

TRL’s 2013 work estimated that a GDL system could prevent around 4,471 casualties per year, representing a potential saving to society of £197m annually[14]. Complementing this, analysis by PACTS the same year identified a broader range of collision types - around 14,700 casualties and 230 fatalities annually - that could reasonably fall within the scope of GDL‑targeted measures[15]. While overall collision numbers have fallen since 2013, these findings continue to highlight the scale and severity of incidents involving new drivers, particularly during high‑risk conditions.

More recent work has continued to explore both the benefits and practical considerations of GDL. In 2022, TRL, commissioned by the RAC Foundation[16], examined concerns typically raised in public debate - including impacts on mobility, employment and access to education. Based on available evidence and stakeholder feedback, the review did not identify significant or systematic adverse effects associated with GDL in jurisdictions where it is already established. International experience suggests that well‑designed exemptions can ensure that essential mobility is maintained.

A critical issue to address is how to manage the very high‑risk period immediately after a young person passes their test. Evidence shows that collision risk halves within the first few hundred miles of independent driving, and then halves again over the following few months[17][18]. This rapid fall in risk - well documented in the GB new‑driver evidence base - demonstrates why Graduated Driver Licensing (GDL) measures focused on the first weeks and months post‑test are among the most effective interventions available.

The evidence demonstrates that most meaningful “learning” happens in the first 500 to 1,000 miles of unsupervised driving[19], and risk curves for every test‑pass age group show how steeply risk declines over time.

However, whilst it is recognised that novice driver risk reduces rapidly with experience, there remains limited statistical detail on whether this reduction applies equally across the specific high‑severity collision types that GDL aims to address. This reinforces the value of continued research and careful policy design, ensuring that any framework is appropriately calibrated and evidence‑based.

The CIHT acknowledges that views on GDL vary and that policy development must balance safety benefits with practical considerations for young people and their families. However, the evidence base - spanning a decade of research - indicates that a proportionate, time‑limited GDL framework could offer substantial safety benefits while supporting young drivers as they gain independent driving experience.

CIHT believes that it is possible to introduce measures which would improve safety outcomes for new drivers which would not completely prevent use by those who were most reliant on car transport. For example, specifying that there should be zero alcohol in the blood for any driver within two years of passing their test would reduce the risk to young driver and also reduce the adverse impact on others without preventing car use at certain times of the day etc. The mandatory fitting of black boxes (as used by insurance companies) for all new drivers would also promote safer behaviour.

Strengthening the Strategy with a GDL framework that controls exposure during this early phase - combined with evidence‑led support for new drivers rather than ineffective traditional measures - would offer one of the most powerful opportunities to reduce deaths and serious injuries involving new and novice drivers.

Introducing a minimum learning period for learner drivers is viewed as an important step toward reducing casualties. Ensuring that new drivers gain more experience over a longer timeframe - under supervision and with clear penalties for rule breaking - would help prepare them for real-world conditions.

A minimum learning period must be supported by defined requirements, such as a baseline number of supervised driving hours, and a curriculum that emphasises speed awareness and understanding what constitutes inappropriate speed. Additional measures - such as a onetime £50 Government issued voucher to encourage participation in a half day responsible driving course - could help reinforce safer behaviours during this high-risk stage of driving.

The current disparity between vehicle types also needs attention. For example, the Compulsory Basic Training (CBT) for motorcyclists provides only a few hours of on-road training before riders can use a vehicle capable of causing significant harm to its rider and to other road users, demonstrating the need for more consistent and rigorous training across all modes.

Overall, a structured, well designed minimum learning period, combined with enhanced training and clear behavioural expectations, would strengthen the safety of new drivers and reduce the likelihood of serious collisions.

Q7. What is the right approach to safe driving later in life? What safeguards are required to protect both safety and independence of older drivers?

People age at different rates, and the approach to supporting safe driving later in life must recognise this. A more thorough and coordinated system of assessing driving ability - linked closely with healthcare providers - would help ensure that older drivers remain safe while maintaining their independence for as long as possible.

Many older drivers already adjust their behaviour sensibly as their abilities change, but effective alternatives must be available for those who are no longer fit to drive. The current self‑reporting system is insufficient, and a more proactive framework is needed. Regular medical checks for drivers aged 70 and over - covering eyesight, reaction time and cognitive function - would help identify issues earlier, with targeted functional assessments introduced when concerns arise. Improving support for healthcare professionals is essential so they can confidently advise when an individual should stop driving. 

Crucially, however, we currently lack an effective screening process to identify the minority of older drivers who present genuinely higher risk[20]. Evidence shows that it is the lowest‑mileage drivers who experience increasing collision involvement after age 70[21]. Only when people reach 80, and/or do very limited mileage, does the ageing process and infrequent driving increase their risk[22]. The work by the Older Driver Taskforce[23], continues to improve understanding and dissemination of best practice.

Modern in‑vehicle technologies can mitigate some age‑related decline, but only where drivers understand and use them appropriately. Mandatory fitting of black boxes once a certain age is reached could also be used, as insurance companies will then take action as they won’t want to insure a dangerous driver.

Expanding public transport options is equally vital, particularly in rural areas where isolation can increase sharply once someone stops driving.

Ultimately, a balanced approach - combining medical assessment, targeted support, accessible alternatives, and Safe System‑aligned road design - offers the best means of protecting both safety and independence for older drivers.

Q8. What should the proposed work-related road safety charter require of organisations that employ people to drive or ride for work?

The proposed work-related road safety charter should set clear, practical and enforceable expectations for organisations whose employees drive or ride for work. As major employers, both government and industry must demonstrate leadership by prioritising work-related road risk and embedding strong safety practices throughout their operations, procurement processes and supply chains.

At present, however, a fundamental barrier is the lack of meaningful enforcement. The Health and Safety Executive (HSE) was advised at its formation that it could enforce driving for work injuries but did not have to - resulting in the position we see today, where HSE does not routinely enforce in this area.  This was explored by Transport Safety Commission’s 2015 Inquiry: UK Transport Safety: Who is Responsible? [24]

Likewise, police involvement is inconsistent; despite the fact that around one in three road deaths involves someone driving for work[25], police investigations into employer responsibility remain rare. Without the realistic prospect of enforcement, many employers do not take their duties seriously, and unsafe practices persist unchecked. A credible enforcement framework is therefore essential if the charter is to have any real impact. The government should consider higher driving offence penalties for professional drivers to support compliance. A fatality whilst driving for work should be subject to a Fatal Accident Inquiry.

The rise of the gig economy further underlines the urgency of stronger oversight. Research undertaken for PACTS[26] shows that the harm caused to others by gig economy riders and drivers is far greater than previously understood. This includes collisions involving poorly trained riders, illegal or unsafe electric motorcycles, and dangerous behaviours linked to unrealistic delivery pressures. These risks affect not only the workers themselves but also pedestrians, cyclists‑economy riders and drivers is far greater than previously understood. This includes collisions involving poorly trained riders, illegal or unsafe electric motorcycles, and dangerous behaviours linked to unrealistic delivery pressures. These risks affect not only the workers themselves but also pedestrians, cyclists and other road users. Properly policing these behaviours, particularly the widespread use of illegal vehicles and unsafe riding/parking practices, would require substantial investment, and widespread enforcement.

A robust charter that achieves compliance/adoption should therefore require organisations to:

• Maintain safe, roadworthy and properly equipped vehicles, with clear responsibilities for inspection, maintenance and defect reporting.
• Provide appropriate and ongoing training for all staff who drive or ride for work, with particular emphasis on hazard awareness, fatigue management, speed compliance, and the safe use of technology.
• Plan work realistically, ensuring delivery schedules, shift lengths and expectations do not incentivise unsafe driving or riding.
• Implement strong policies and monitoring systems covering mobile phone use, near miss reporting, vehicle loading, and driver behaviour, supported by clear consequences for noncompliance.
• Embed safety throughout procurement and contracting, ensuring that supply chain partners - including gig economy platforms - meet equivalent safety standards and cannot undercut responsible operators.
• Cooperate fully with enforcement authorities, including providing access to data and internal records when serious incidents occur.
• Hold clean licence records and ensure appropriate checks and testing where risk is higher, such as for riders using powered two-wheelers in urban areas.
• Mandatory fitting of ISA and the telemetry (‘black boxes’) which are used by insurance companies for all employer owned vehicles

Given the scale of work-related risk on UK roads, the charter must be accompanied by credible enforcement, transparent accountability mechanisms, and meaningful government commitment - otherwise, the burden - personal injury, loss of earnings, impacts on local economies - will continue to fall disproportionately on vulnerable road users and communities.

Q9. 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?

Fear of traffic danger is a major deterrent to walking, wheeling and cycling, even though the health benefits of active travel outweigh the risks by several orders of magnitude[27][28][29]. Despite this, public understanding of risk in the UK remains poor - cycling, in particular, is often perceived as far more dangerous than it is in reality, leading many people to avoid it altogether. The separate but linked personal safety fears that many people experience are also often founded on an exaggerated sense of the risk of harm. The two aspects of perceived risk have some scope for common prevention, such as effective lighting and improved place design. These misperceptions about risk undermine efforts to encourage healthier, more sustainable travel behaviours.

Normalising walking, wheeling, cycling and public transport requires creating environments that feel consistently safe, comfortable and intuitive. Because public transport journeys almost always involve an element of walking, wheeling or cycling at each end, improving active travel conditions is fundamental to shifting overall travel behaviour. Effective measures include:

• Protected cycle routes that physically separate cyclists from motor traffic
• High-quality, well-maintained footways, including smooth surfaces and adequate width
• Dropped kerbs, tactile paving and accessible crossings to support all users
• Safe, legible junctions and priority crossings
• Introduce traffic calming measures and adopt significantly lower, context-appropriate speed limits (such as default 20mph) in residential and mixed used areas.

Where these measures are implemented at scale, the impact is transformative. London demonstrates what is possible: sustained investment, clear political direction and high-quality design standards have delivered dramatic increases in cycling levels and made walking and wheeling more attractive and convenient without the associated increases in injury that might have been predicted from a large increase in cycle travel. However, provision across the rest of the UK remains far more uneven, with many towns and rural areas lacking safe, continuous networks.

Wales offers another powerful example. The Active Travel (Wales) Act[30] has prompted a significant cultural shift, embedding active travel planning into local authority responsibilities. Recent rural active travel routes, often alongside rural A and B roads, show how even small communities can provide safe, accessible links for residents and tourists alike. Early evidence suggests these routes are well used and widely welcomed.

Pedestrian and cycle journey times should be given greater consideration in cost benefit analysis for schemes[31]. Car journey time usually takes precedence which often results in longer routes or timings for pedestrians and cyclists. A change in identifying pedestrian journey time and reliability would encourage active travel options.

Overall, reducing fear and increasing confidence requires a combination of better public understanding of risk and high-quality infrastructure that visibly prioritises people over vehicles. When environments feel safe, predictable and designed around human movement, walking, wheeling and cycling become natural, mainstream choices for a far wider range of people. Improving safe links in rural areas - often overlooked in funding decisions - would support those communities where active travel options are currently limited.

Q10. What should reform of motorcycle training, testing and licensing look like in practice?

Reform of motorcycle training, testing and licensing should aim to create a clearer, safer and more progressive system that reflects the risks motorcyclists face, and the skills required to ride responsibly.

At present, riders can use a motorcycle for work with only a learner’s permit. Given the collision risk associated with certain machine types - a revised framework should ensure that higher risk vehicles - particularly those disproportionately represented in casualty statistics - are subject to more robust training and licensing requirements.

A more streamlined and coherent progression pathway is needed. The current route to a full motorcycle licence is often seen as complicated, with multiple tests and unclear steps. A structured training pathway, allowing riders to move from A2 to a full A licence through certified courses rather than multiple separate tests, would improve both accessibility and safety.

Introducing a clearer distinction between automatic and manual motorcycle licences - mirroring the car licensing system - could also help ensure that riders develop the relevant practical skills for the type of machine they intend to use.

There is a need for a strengthened and more consistent training standard; including enhanced theory and practical components, with an emphasis on the Highway Code, risk awareness and vehicle handling. Modernising the system would allow it to better reflect contemporary riding environments and technology.

Overall, a reformed motorcycle licensing regime should prioritise safety, clarity and progression, ensuring that riders receive comprehensive preparation before gaining access to more powerful machines. 

Q11. How can Government maximise the safety benefits of Advanced Driver Assistance Systems (ADAS) and ensure they are used safely and appropriately?

Maximising the safety benefits of Advanced Driver Assistance Systems (ADAS) requires ensuring that these technologies are both reliable in real‑world conditions and properly understood by the people who use them. ADAS must be able to perform consistently across the varied and complex situations drivers encounter every day. To support this, Government should introduce robust auditing and vetting processes for companies developing and deploying these systems, alongside clear mechanisms for reporting and addressing performance issues. Where systems are found to be ineffective or poorly suited to UK conditions, incentives and support may be needed to help manufacturers improve their performance.

Clear and up‑to‑date user training is also essential. As vehicles become increasingly automated, there is a risk that drivers may become less attentive or slower to respond to unexpected situations. Integrating comprehensive ADAS education into driver and rider training - emphasising the limitations of the technology and the continued need for active engagement - would help mitigate this risk.  Older drivers who, while benefitting from the roll out of ADAS, may find it, and any training, confusing – this would need to be addressed carefully.

Certain vehicles, such as those used for deliveries or passenger transport, stand to benefit considerably from appropriate ADAS fitment due to the nature of their operations. To ensure the technologies used in these fleets are effective, suitable testing frameworks should be established so that safety systems are properly evaluated before being installed and relied upon.

In 2015, Autonomous Emergency Braking (AEB) became a compulsory fitting for HGVs. This should have been game changing moment like the seatbelt laws, but it hasn't happened because many HGV drivers choose to switch the system off because it beeps at them when a car cuts in-front of them. It is also reported to over-react for example when approaching bridge supports angled to the road which are more difficult for the detection system to perceive clearly resulting in false detection of potential impact.  

With the system deactivated, there have been some devastating collisions involving HGVs running into stationary vehicles because the driver is not fully paying attention to their job. It is therefore essential for drivers to know that that if they deactivate a critical safety system, such as Autonomous Emergency Braking, on a vehicle fitted with these features, and is then involved in a collision whereby those features would have prevented it, the action of the driver may be reflected in the insurer’s evaluation of responsibility. 

Another issue which results from market positioning by the automotive industry is inconsistent form and application of ADAS elements. For example, cars with the same ADAS element such as Lane Keep Assist (LKA) can behave in very different ways in the same location, because the detection and activation settings very widely. Where safety schemes have involved omitted centre line markings on urban and rural roads to induce caution by drivers, some LKA systems correctly ignore the apparent lane positioning error, while others steer the car into an opposing vehicle. Requirements for more consistent and safe application of ADAS systems would reduce these inconsistencies across manufacturers and between models and contribute to prevented collisions.  Failure to achieve that position will result in drivers continuing to deactivate the systems, with a net adverse result for safety.

Overall, stronger oversight, clear user education and reliable performance testing are all necessary to ensure that ADAS contributes meaningfully to improving road safety across the UK.

Q12. 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? 

Strengthening vehicle safety standards requires a clearer national framework that prioritises interventions with the greatest proven safety benefits, while also addressing emerging risks linked to technology, vehicle design and user behaviour. From an evidence-led perspective, Advanced Driver Assistance Systems (ADAS) must form the backbone of future safety improvements.

Among these, Autonomous Emergency Braking (AEB) should be treated as the highest priority due to its consistently demonstrated ability to prevent collisions and reduce impact severity.

The implementation of Autonomous Emergency Braking (AEB) should be approached with caution for certain vehicle types. Evidence from a TfL‑commissioned study indicates that unnecessary or abrupt AEB activation on buses - particularly those carrying standing passengers - can increase the risk of injury to both standing and unbelted seated passengers[32]. For this reason, AEB on buses should be subject to a thorough risk assessment that weighs the potential harm prevented by stopping against the potential injury caused to passengers inside the vehicle.

Following AEB, Intelligent Speed Assistance (ISA) and Lane Keeping Assistance (LKA) represent the next most effective measures, helping drivers maintain safe speeds and prevent unintentional lane departures.

While headlamp glare is a widely reported concern and can be highly uncomfortable for drivers, its direct contribution to casualty numbers appears limited according to the data[33]. Nonetheless, the discomfort and visual stress caused by glare have broader implications: they can deter people - particularly older or more vulnerable individuals and those with certain neurological/neurodevelopmental conditions such as autism or migraine - from driving at night, thereby reducing their access to employment, education, medical care, social opportunities and essential services. Tackling headlamp glare remains important for ensuring equitable access and transport inclusion, even if its injury burden is comparatively small.

Vehicle size and mass present a more serious and growing safety concern. Larger, heavier vehicles - especially SUVs and some electric vehicles - can offer excellent occupant protection but impose significantly greater risks on pedestrians, cyclists and other road users. Many older or vulnerable drivers drive smaller cars hence sit closer to the ground and lower in the headlight envelope. SUV, LGV, HGV drivers sit higher and therefore above the envelope.

The Government should therefore consider mechanisms to price vehicle size appropriately, reflecting the wider societal externalities. Options could include:

• Adjusted vehicle taxation linked to mass and footprint
• Parking charges that scale with vehicle size
• Mobility pricing models that take account of vehicle impact, including for EVs (notably electric vehicle excise duty (EVED) systems)
• Incentivising smaller, safer and more space-efficient vehicle choices.

In parallel with regulatory measures, behavioural and cultural change must be part of any credible long-term approach. There is considerable value in deploying behavioural insights and smart communication strategies to reshape public attitudes towards vehicle choice, safe system principles‑term approach. There is considerable value in deploying behavioural insights and smart communication strategies to reshape public attitudes towards vehicle choice, safe system principles and road-user responsibility. Some commentators[34] have long argued for the power of insight driven behavioural design, including reframing messages to highlight counter‑intuitive risks - for example, that choosing an oversized vehicle may increase the danger posed to one’s own family in driveways, car parks and low speed environments.

Overall, a modernised vehicle safety framework should: -

• Prioritise AEB, ISA and LKA as core mandatory technologies
• Address headlamp glare through improved standards and compliance
• Confront the externalities of vehicle size through pricing, planning and regulation
• Align infrastructure and vehicle standards so that ADAS performs reliably and consistently in real-world UK conditions ‑world UK conditions
• Use behavioural science to shift social norms around vehicle choice, risk and responsibility

With these elements in place, Government can build a more coherent, equitable and Safe System aligned approach - ensuring that vehicle safety improvements benefit all road users, not just vehicle occupants.

Q13. 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? 

Evidence consistently shows that lower speeds – in both urban and rural locations - reduce both the likelihood and severity of collisions. This must form the backbone of any modernised national guidance. In practice, however, achieving the Strategy’s targets will not be possible without national default speed‑limit changes, similar to the approach taken in Wales where the urban default was reduced from 30mph to 20mph. Comparable national action in England - including revised defaults on rural B, C and unclassified roads - would create far greater consistency and deliver substantial casualty reductions.  This will require education, compliance and enforcement.

There would be benefits in modelling data to illustrate what the scale of intervention required will be to meet 2035 targets. Tools such as iRAP can add value, provided their limitations are openly recognised, particularly their treatment of roads in isolated segments rather than as functioning routes.

Overall, a revised national framework should combine:

• Clearer default limits,
• Stronger national direction, and
• Better analytical tools that reflect whole‑route characteristics.

Local authorities should retain the ability to tailor limits, but this must sit within a more coherent, evidence‑led national structure. Without national leadership, progress will remain slow, fragmented and insufficient to meet long‑term safety ambitions.

Q14. What measures would be most effective in improving safety on rural roads, and is the Strategy’s proposed approach sufficient?

Improving safety on rural roads requires a much more decisive shift toward speed management, recognising that physical re‑engineering of the network can only ever reach a very small proportion of roads within the next decade.

Rural roads account for a disproportionately high share of fatal and serious collisions, yet the network is vast, dispersed and expensive to upgrade. In practice, only a tiny percentage of routes can be redesigned or rebuilt over a 10‑year period. As a result, speed and vehicle technologies will have to do the heavy lifting if the Strategy’s casualty‑reduction ambitions are to be met.

Lower and more consistent speeds are essential. Too many drivers continue to interpret the posted limit as a safe operating speed regardless of context, and behaviour rarely adapts sufficiently to bends, sightlines or changing roadside environments – more education of drivers is required on this issue. A modernised approach must therefore combine lower default limits on rural roads with a huge expansion of average‑speed enforcement, which remains one of the most effective and publicly accepted tools for achieving compliance. Without far more widespread and visible enforcement, changes to limits alone will not deliver the reductions needed.

The current national speed limit of 60mph (with its accepted enforcement threshold of 10% + 2mph i.e. 68mph) is often incompatible with a Safe System approach which requires fatal and serious injury potential to be eliminated where practicable.  A driver making an error of judgement when pulling out of an uncontrolled side road at a T-junction into the path of a vehicle travelling at 68mph is very likely to suffer fatal or serious injuries. Junctions cannot all be readily or affordably amended but speeds can be readily changed. Even modest speed reductions have disproportionate benefits in severity of injury.

Vehicle technology also has a critical role. Intelligent Speed Assistance (ISA) has the potential to support safer, more consistent speeds on rural routes, particularly where road geometry or variable conditions can quickly turn high‑speed travel into a high‑risk scenario. Even if only a relatively small proportion of the fleet is equipped with ISA in the short term, those vehicles will effectively act as rolling speed governors, smoothing traffic speeds and helping to set safer norms across the network. When combined with stronger behaviour‑change messaging, ISA offers a major, currently under‑used opportunity to reduce both the likelihood and severity of rural crashes.

While safe‑system‑aligned engineering - such as improved delineation, shoulder treatments, junction upgrades and clearer road markings - remains important, it is unrealistic to expect these measures alone to achieve meaningful change across such an extensive network within 10 years. The Strategy must therefore place far greater emphasis on scalable, system‑wide interventions, particularly those that influence speeds and vehicle behaviour with immediate effect.

Although effective enforcement of existing limits can deliver meaningful collision reduction without lowering speed limits, the Strategy’s current approach does not go far enough and must robustly consider nationally led reductions in rural default speed limits, supported by:

• A transformational increase in average‑speed enforcement capacity, and
• Accelerated deployment and uptake of ISA‑enabled vehicles, alongside other proven technologies.

Without these core elements, progress will remain slow, uneven and inadequate to deliver the scale of casualty reduction required by 2035.

Q15. What scope is there for road design and maintenance to further improve safety?

There remains significant scope for both road design and maintenance to contribute to improved safety, but this requires a shift in thinking. The longstanding assumption that ‘standards‑compliance = safe’ needs to be replaced with a more realistic understanding that ‘consistent and self‑explaining = safe(ish)’. Most of the road network already exists and cannot be fundamentally redesigned within the next decade, so the focus must shift from wholesale engineering to making existing roads more predictable, understandable and forgiving.

Design changes that enhance consistency - clearer cues, more intuitive layouts and alignment that matches driver expectation - can reduce error, but the scale of the rural network means only a tiny proportion can be re‑engineered in the near term. As a result, the greatest untapped opportunity lies in maintenance, particularly where modern, data‑driven approaches can significantly improve safety outcomes.

There is substantial scope for intelligent asset management. For example, gully performance varies enormously, yet cleansing is typically carried out at a uniform frequency. Monitoring silt accumulation at each gully - using sensor data or periodic volumetric assessment - would allow cleansing to be tailored: some assets require attention multiple times a year, while others may only need cleaning once every five years. This targeted approach reduces flooding risk, improves skid resistance and directly supports safer speeds.

Similarly, materials selection should be based on evidence of risk and performance rather than historic convention. High‑friction surfacing is often over‑specified, while more fundamental interventions - such as ensuring adequate drainage, selecting surfaces with the right macrotexture, or addressing edge deterioration - can have greater benefits at lower cost. Good drainage, in particular, plays a dual role: it reduces skidding risk and helps ADAS systems read the road more reliably.

Lighting also warrants a more nuanced approach. In many rural contexts, less lighting - when paired with lower speeds and clear visual cues - can improve attentiveness and reduce glare. However, lighting also has an equity dimension: poor or inconsistent lighting environments can disproportionately deter older drivers, reducing accessibility and independence. Any modernised approach must therefore balance safety, inclusion and environmental considerations.

Overall, road design still offers opportunities for targeted improvement, but maintenance is where the biggest gains can be achieved at scale. Ensuring surfaces, markings, edges and drainage are consistently maintained can significantly reduce risk and enhance the performance of technologies such as ISA and lane‑keeping systems.

In summary, while engineering remains important, the most substantial and scalable safety gains over the next decade will come from smarter, risk‑led maintenance and asset management, delivered alongside the speed‑management measures and improved vehicle technologies outlined earlier.

Q16. What measures would most improve compliance and deterrence in relation to motoring offences? Which such offences have the biggest impacts on collision and casualty rates?

Improving compliance and deterrence in relation to motoring offences depends primarily on the likelihood of detection, far more than the severity of penalties. Automated detection technologies, including CCTV combined with AI to identify offences such as seatbelt non-use and hand-held mobile phone use, offer scalable, low-cost enforcement that can rapidly shift public perception from 'I probably won't get caught' to 'I will be caught if I do this.'

For the most extreme and persistent offenders, stronger consequences remain essential. The principle of '12 points and you're out' should be applied consistently, without routine exceptions for 'exceptional hardship.' Allowing repeat offenders to retain licences on hardship grounds undermines deterrence and encourages continued high-risk behaviour.

There is also a strong case for greater tailoring of fines to income. Current fixed penalties disproportionately impact lower-income drivers while offering limited deterrence for wealthy offenders. Income-linked fines, as used in several European jurisdictions, would ensure fairer, more effective sanctions.

Distraction and driver impairment are a major risk on the road; for the latter the Road Traffic Act (1988) could be amended to allow random drink and drug tests.  Currently the requirement to carry out a test is only if the driver has committed an offence, been in an accident or the officer has reason to suspect an offence. This creates a legal loophole to avoid prosecution.

Overall, improved compliance requires significantly enhanced detection, consistent sanctions for high-risk offenders, income-related fines to ensure equal deterrence across society, and smarter data-led targeting of enforcement activity where high-harm offences are most prevalent.

Education and targeted communications should be strategically timed to complement enforcement activity, helping drivers understand both the risks associated with dangerous behaviours and the likelihood of being detected. Ongoing issues such as mobile phone use while driving which, although partly mitigated through advances in hands-free technology, continues to pose a significant safety risk.

There is a need to accelerate reforms to the Home Office Type Approval (HOTA) process to enable more flexible and widespread deployment of enforcement technologies.

Consistent and visible enforcement plays a vital role in changing behaviour.

Certain offences, particularly speed-related violations that cause serious injuries or fatalities, should carry far more severe consequences and be treated with the gravity they deserve.

Overall, enhancing compliance will require not only improved enforcement tools and data but also a cultural shift in how society views dangerous driving and the responsibility drivers bear for the consequences of their actions.

Q17. 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?

Deterring dangerous driving requires sanctions that are both meaningful and proportionate to the harm caused. The current system of penalty points is often insufficient, and more immediate and impactful measures - such as temporary licence suspensions or vehicle impoundment - could offer a far stronger deterrent. These approaches are viewed as being better aligned with the seriousness of behaviours that place other road users at significant risk.

However, evidence from TRL[35] has highlighted an important limitation: many commonly used approaches to deterrence simply do not work, and in some cases can even make driver behaviour worse. Shock tactics - long a staple of road safety campaigns - are a clear example; rather than reducing high-risk behaviour, they can provoke defensive reactions, denial, or disengagement. By contrast, interventions that create emotional engagement, such as stories that humanise victims or that support drivers in reflecting on their own habits in a non‑judgemental way, have been found to be far more effective in shifting behaviour over the long term.

This gap between “what feels intuitive” and “what actually works” in behaviour change is well recognised across the criminal justice system - and road safety is no exception. There is therefore a strong case for improving political and policymaker understanding of the behavioural evidence base to avoid repeating ineffective strategies. Without this, national direction may continue to prioritise highly visible but low impact measures at the expense of those shown to meaningfully reduce harm.

Merely installing speed limit signs does not significantly influence most drivers - to promote adherence and safer driving habits, visible police enforcement and adjustments to road conditions are necessary. Overall, an effective sanctioning framework should combine:

• High likelihood of detection and consistent follow through - the single strongest factor in behaviour change.

• Sanctions that are timely and proportionate, with meaningful impacts for persistent or high-risk offenders.
• Income linked penalties to ensure fair and effective deterrence across all income groups. Based on a stated choice experiment involving professional drivers in Hong Kong, evidence indicated that the likelihood of detection, timely sanctions, and income-linked penalties are significant determinants of driver compliance.[36]
• Clear public understanding of why sanctions matter, emphasising the real-world consequences of dangerous driving.
• Evidence-led behavioural approaches, drawing on TRL findings to prioritise interventions that engage people emotionally and avoid those proven to be ineffective or counterproductive.
• Sanctions should reflect not only the outcomes of dangerous driving but the behaviour itself. In cases where dangerous driving results in death custodial sentences and lifetime driving bans should be more routinely applied.

Together, these elements support a more consistent, impactful and evidence‑based approach - one capable of driving meaningful reductions in dangerous behaviour and improving long‑term road safety outcomes.

Overall, there is a clear appetite for a sanctioning framework that is more consistent, more impactful, and more firmly grounded in the principle that driving is a privilege that carries significant responsibility.

March 2026

Endnotes