WHO LICENSED THAT DRIVER?


And could it explain how its failure to do so was consistent with its legal obligations towards disabled people?


The council’s response did not answer those questions. What it did instead was rather more instructive.


It opened by pointing out that Bolt’s licence was granted in October 2021, and that the licensing conditions cited in the complaint were only adopted in October 2025, applying to licences granted after that date. Bolt, the council argued, was not therefore subject to those conditions.


point a consumer is deciding whether to book is itself an unlawful commercial practice.


Now ask a simple question: would an average consumer standing in London and opening the Bolt app want to know which licensing authority regulates the driver and vehicle about to be sent to them? Of course they would. That information is directly material to their decision. It determines where they can complain if something goes wrong. It determines which authority is responsible for ensuring the driver has been properly vetted and the vehicle properly inspected. It is precisely the kind of information that consumer protection legislation was designed to ensure they receive.


Bolt does not provide it. The cross-border booking architecture makes it structurally impossible for consumers to know this before they commit. The information does not exist at the point of booking because no driver has yet been identified. By the time a driver accepts the job, the consumer is already committed. By the time the journey is complete, most consumers have moved on. And for the consumer who wants to complain - particularly a disabled consumer who has been failed - the information they need is simply not there.


The complaint and the response


I raised formal complaints with Wolverhampton City Council in May 2026, asking a series of direct questions. Had the council considered whether its licensing framework allowed a disabled consumer to identify the relevant authority following a cancellation? What conditions, if any,


required


disclosure of which authority governed the driver? Had it assessed whether the Bolt booking architecture complied with consumer protection law? Had it considered using its powers to require that disclosure?


PHTM JULY 2026


It is worth pausing on that argument, because it reveals something fundamental about how the council has approached this complaint.


That distinction - between a 2021 licence and a 2025 policy - is a piece of internal licensing administration. It lives entirely within Wolverhampton’s regulatory machinery. It does not exist anywhere in the world for the average consumer. A member of the public who looks at Wolverhampton City Council’s website sees a licensing policy. They see a framework. They see conditions that the council has put in place to govern the operators it licenses. They have no means of knowing, and no reason to suspect, that a currently operating national platform is exempt from those standards because of the year in which its licence was first granted. Nothing tells them. Not the council’s website, not the Bolt app, not anything in the booking process.


The average consumer is entitled to assume that a licensed operator is operating under the authority’s current standards. Any other assumption would make a nonsense of consumer protection and licensing policy. If an authority publishes a licensing framework that sets out what consumers can expect from its licensed operators, and certain operators are in fact operating under an older version of that framework without anyone being told, that gap is itself a transparency failure. The council offered this distinction as a defence. On examination, it is part of the problem.


The response went on to note that Wolverhampton was the first authority in the country to adopt certain accessibility conditions, and that this demonstrated the council was effectively discharging its duties. Good practice in one area does not discharge a specific, identified failure in another. The complaint concerned what was happening to consumers using the platform now. The council’s pride in its policy development did not address that.


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