NPHTA: WORKING FOR YOU Devolved licensing authorities
We understand the intention to create larger, more specialised licensing teams and departments. However: l Taxi licensing is only a small part of local authority responsibilities
l There is no clear evidence this restructuring will benefit the sector
l Larger authorities may reduce geographic boundaries, increasing out-of-area working
This proposal does not address licence shopping and may inadvertently worsen it.
National enforcement powers
We acknowledge proposals to expand enforcement powers, including allowing officers to suspend licences issued by other authorities.
While welcomed, it is important to note: l Most enforcement powers already exist under current legislation
l The proposed change primarily adds immediate suspension capability
The inclusion of compensation for incorrect enforcement decisions is a positive and necessary safeguard. However, these measures do not address the root causes of cross-border working.
Cross-border working & the Casey Report
We note the conclusions of the Casey Report linking cross-border working to the Deregulation Act 2015. This is inaccurate.
Key facts: l Cross-border working has been a major issue since before 2007
l The Berwick case (2007) triggered significant out- of-area licensing
l Rotherham findings in 2013 primarily implicated locally licensed drivers, the whole report predated the Deregulation Act
Child exploitation is a serious and longstanding issue, but its causes are complex and not linked to the 2015 Act. We do, however, welcome the Government’s com- mitment to addressing cross-border working as a priority.
Financial impact on the trade
It is highly unlikely these proposals will reduce costs. Instead, we anticipate: PHTM APRIL 2026
l Fees aligning with the highest current levels l Additional costs for rebranding, systems, training, and compliance
These costs will ultimately be passed on to drivers and passengers, reducing affordability and service availability.
How to address predominant out-of-area use The core issue is not standards - it is incentives.
To effectively reduce licence shopping: l Licensing must be consistent in cost and efficiency across authorities.
l High fees must not be used as a deterrent, as this harms both drivers and passengers
Proposed solution: “intended use” requirement
We strongly recommend introducing a statutory “intended use” requirement across all licensing authorities.
This would: l Require applicants to declare they
intend to primarily operate within the licensing area
l Pose the risk of loss of licence and/or prosecution for fraudulent declarations if they fail to comply with the declaration
l Not prevent legitimate occasional out-of-area work l Remove the viability and attractiveness or benefit of licences obtained solely for remote operation
This approach replaces inconsistent local policies with a clear national requirement, directly addressing the root cause of licence shopping.
Conclusion
While we support the ambition to improve consistency and transparency, the current proposals do not adequately address the fundamental issue of licence shopping or cross-border working.
Without tackling: l Licensing costs l Processing efficiency l Intended use of licences these reforms risk adding complexity and cost without delivering meaningful change.
We urge policymakers to focus on practical, targeted solutions that address the underlying incentives within the system.
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