OUT-OF-AREA-WORKING
particularly those using digital dispatch platforms or multi-district driver networks, licensing authorities may look closely at whether the operator is genuinely exercising control over the bookings it accepts. Where an operator cannot clearly demonstrate how bookings are accepted, recorded and allocated, regulators may question whether the operational model preserves the statutory structure intended by Parliament.
The position of taxi drivers
The position of hackney carriage drivers differs in an important respect. HC licences remain tied to the authority that issued them. While taxis may undertake pre-booked journeys outside their licensing district, they generally may not ply for hire beyond it.
A taxi driver licensed in one authority cannot lawfully accept street hails in another district. Doing so may amount to unlawful plying for hire and expose the driver to both criminal enforcement and licensing action.
In areas where significant numbers of out-of-area PHVs operate, this distinction can create tension between the taxi and PH sectors, particularly where licensing standards differ between authorities and cross-border activity is perceived as creating an uneven competitive environment.
Why licensing authorities remain concerned
For authorities, out-of-area working presents practical regulatory challenges. Licensing officers have direct control only over the drivers and vehicles they license. When vehicles licensed elsewhere operate extensively in the district, enforcement becomes more complicated. Complaints, safeguarding concerns or compliance issues must often be referred back to the authority that issued the licence. This can delay regulatory action and reduce the immediacy of local oversight.
Where large numbers of vehicles operate within a district without being licensed there, authorities may feel their regulatory framework is being undermined. As a result, cross-border operations are frequently viewed through the lens of public protection rather than market competition.
Improving compliance in practice
For operators and drivers engaged in cross-border work, clarity in the booking structure is essential. Bookings must be demonstrably accepted by the correct licensed operator, and records should clearly
PHTM JULY 2026
identify when the booking was accepted and which driver was allocated.
Drivers should ensure that all work undertaken is routed through their licensed operator rather than accepted directly from passengers. Even informal arrangements can create legal difficulty where the statutory booking structure is bypassed.
For operators using app-based dispatch systems, it is particularly important that the technology preserves the legal framework rather than obscuring it. Digital convenience does not alter the statutory requirements governing private hire bookings.
The direction of regulatory reform
Out-of-area working has attracted increasing national attention. Government consultations and industry dis- cussions have explored reforms aimed at improving regulatory oversight where cross-border operations occur.
Proposals have included stronger data-sharing
arrangements between licensing authorities, greater consistency in national licensing standards and reforms addressing how operators manage bookings fulfilled across district boundaries. While comprehensive reform has not yet been implemented, the issue remains firmly on the policy agenda.
A continuing point of tension in the sector
Out-of-area working reflects a structural tension within the licensing system. Passenger demand increasingly operates on a national and digital basis, while regulation remains rooted in local authority licensing. The law permits cross-border hiring, but only within the statutory structure governing how bookings are accepted and allocated. Drivers and operators who work within that framework can operate lawfully across authority boundaries; those who treat cross-border working as an unregulated space risk attracting regulatory scrutiny.
Out-of-area operations frequently give rise to complex questions concerning operator control, booking structures and regulatory compliance. I specialise in transport regulatory and licensing law and regularly represent drivers and operators before licensing sub- committees and Magistrates' Courts. Where issues arise involving investigation, licence review, refusal, suspension, or revocation, early specialist advice can assist in addressing the regulatory concerns being raised. Those facing such proceedings are welcome to make contact for advice or representation.
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