WHO LICENSED THAT DRIVER?
The council then revealed that it had audited Bolt the previous day - one day after the complaint was received - and found no issues. It added, firmly, that it would not be conducting further audits simply because a complainant demanded it.
An audit conducted the day after a detailed complaint arrived, apparently without the specific questions being put to the operator and without any examination of the consumer law arguments raised, is not an investigation. It is the appearance of one. The complaint was closed on the basis of it.
Three laws and a one-line dismissal
The complaint argued, drawing on those three bodies of consumer protection legislation, that Bolt’s booking architecture was not meeting its legal obligations. The council’s response dealt with this by citing one provision of the oldest of the three pieces of legislation - a provision from 2013 - that excludes passenger transport contracts from certain pre-contract information requirements, and concluding on that basis that the other two bodies of law were “not relevant”.
No explanation was provided for that conclusion. No analysis of the 2015 or 2024 legislation appeared anywhere in the response. The reasoning appears to be that because one part of one older piece of legislation contains a transport exemption, newer and separately enacted consumer protection obligations simply disappear along with it.
That is not how the law works. Each piece of legislation is independent. An exemption in one statute does not automatically carry over into a different statute enacted years later, and certainly not into legislation passed in 2024 specifically to address the conduct of digital platforms. The 2015 transparency obligation applies to passenger transport contracts in exactly the same way as any other. The 2024 legislation, designed precisely for the kind of app-based commercial conduct this complaint concerns, contains no equivalent transport carve-out.
The issue is further complicated by Bolt’s own descriptions of its role. In its rider terms and conditions, Bolt presents itself as the provider of the transportation service. Yet in other documentation, it describes itself as an intermediary that merely connects passengers with drivers. Those positions are not obviously the same. Either way, the inconsistency raises legitimate
questions about whether consumers are being given a clear and transparent explanation of who is responsible for the service they are purchasing.
The complaint accordingly asked, at Stage 2, that the consumer law questions be referred to the council’s own legal department. These are statutory interpretation questions, they require legal advice, not a one-line assertion that two Acts of Parliament are irrelevant.
A register that doesn’t register
At one point in its response, the council referred to Wolverhampton’s public register of licences as evidence that consumers had access to sufficient information about its licensed operators. The council’s own Freedom of Information response, exhibited to the Stage 2 complaint, confirmed that the register does not include address details and that those details are not separately disclosed.
The complaint identified a failure to disclose the trader’s identity and location. The council pointed to a register. Its own FOI decision confirmed the register was deliberately kept without the information in question. A licensing authority cannot point to a register it has chosen to keep incomplete as evidence that its licensed operators are meeting their consumer transparency obligations.
Complain to the operator - seriously?
Perhaps the most telling passage in the council’s response concerned what a passenger left stranded by a cancellation should do. The council’s answer was that the consumer could complain to
Think about what that means in practice.
A consumer has just been let down by a regulated operator - having had their booking cancelled, been left without transport and, in some cases, been stranded with unmet accessibility needs. The council’s proposed route to
Bolt and
subsequently make enquiries about which licensing authority to contact.
accountability requires that
consumers go back to the operator that has just failed them, ask that operator to tell them who regulates it, and then take the information provided - if any - and pursue a separate complaint from there.
If a licensed operator has already failed in its obligations to a consumer, it is the last party from
JULY 2026 PHTM
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