WHO LICENSED THAT DRIVER?


has taken. To acknowledge the consumer protection failures identified in the complaint would be to acknowledge that its own licensing decisions were made without the scrutiny they required.


That does not make the council’s position legally defensible. It does help explain why a consumer transparency complaint received a response that reads, from first paragraph to last, as though it were written by the operator’s lawyers rather than by an independent regulator.


Why this matters beyond Wolverhampton


whom that consumer should be expected to obtain the information needed to


bring a regulatory


complaint. Directing an aggrieved passenger to the operator that has wronged them is not a consumer protection framework. It is an arrangement that protects the operator from scrutiny while leaving the passenger without any practical route to redress.


Consumer protection law exists precisely to prevent this. It places obligations on traders rather than consumers because Parliament understood that a person who has already been let down should not then be required to conduct their own investigation before they can exercise their rights. The council’s suggested approach turns that principle on its head entirely.


The question of whose interests are being served


Reading the council’s response as a whole, a pattern emerges that goes beyond any individual legal error. Throughout the letter, the council advances arguments on the operator’s behalf. It assumes the operator’s legal position to be correct without requiring the operator to demonstrate compliance. It constructs defences that the operator has not been asked to provide. It declines to engage with the arguments that contradict those defences.


There is a wider context to this that matters. Wolverhampton City Council licensed this operator. It renewed that licence. If it has done so without ever considering whether the operator complies with consumer protection law - law that a minister confirmed in Parliament in March 2026 forms part of the fit and proper assessment - then the council has a direct institutional interest in defending the position it


PHTM JULY 2026


Cross-border licensing is one of the most significant unresolved issues in private hire regulation. Drivers licensed by out-of-town authorities operate extensively in London and other major cities, under frameworks that were never designed for app-based national platforms operating across multiple licensing boundaries simultaneously. Passengers have no way of knowing which authority governs their journey. And when a formal, detailed complaint identifying the structural transparency failure at the centre of that arrangement is raised, the response - at least from one of the authorities at the heart of it - is to invoke distinctions no consumer could know, dismiss legislation that squarely applies, and suggest the consumer begins their search for accountability with the operator that has just failed them.


The Transport Select Committee, the Department for Transport, and the ministers responsible for private hire licensing policy have


correspondence. Parliamentary scrutiny has already established that consumer protection compliance is relevant to fit and proper assessments.


The question of whether operators are actually meeting those obligations - and whether the authorities that licence them have ever required them to - is now squarely on the record.


The average consumer opening an app to book a car is entitled to know who is responsible for the driver heading towards them. That is not a complicated demand. It is the most basic expectation of any regulated service. Consumer protection law has required it for years. The question is why, in 2026, it is still not happening - and why a licensing authority asked directly about it thinks the appropriate response is to defend the operator rather than protect the passenger.


all received this


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