ALL THINGS LICENSING
Article by Mike Smith, Senior Specialist for Licensing and Community Safety at Guildford Borough Council and Vice-Chair of the Institute of Licensing South East Region:
www.instituteoflicensing.org
Please note that this article represents my own views which are not presented as the views of the Institute of Licensing nor Guildford BC.
It has certainly been another busy month for licensing, with a raft of developments spanning national policy, technology and legal interpretation. In this month’s article, I begin with reflections on the Transport Committee’s First Report of Session 2026– 27, before turning to emerging concerns around app-based driver distraction, the next steps in implementing the Automated Vehicles Act 2024, and finally new guidance from the Institute of Licensing on private hire passenger contracts.
Taken together, these developments highlight a sector that continues to evolve at pace, with significant implications for regulators, the trade and the travelling public alike.
Raising the bar – or risking a race to the bottom?
The long-awaited intervention from the House of Commons Transport Committee into taxi and private hire licensing has landed. It does not pull its punches.
At its heart, the Committee’s First Report of Session 2026–27 is a recognition of what those of us in licensing have been grappling with for years: a fragmented, inconsistent system that struggles to balance local accountability with a national marketplace. With more than 260 licensing authorities operating across England, each applying different standards, the system has become patchwork at best, and, at worst, vulnerable to exploitation.
The Committee’s conclusions are clear: reform is necessary, but reform done badly could entrench the very problems it seeks to solve. In particular, the proposed move towards national minimum standards is welcomed, but only with a significant caveat: minimum must not mean mediocre.
This article explores the key findings of the report, and - crucially - what they mean for three core audiences: the public, licensing authorities and the trade.
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The core problem: fragmentation and inconsistency
As I and others have written many times, if there is one defining feature of the current licensing landscape, it is inconsistency. The Committee heard extensive evidence that standards vary dramatically across the country, covering everything from driver vetting and safeguarding training to specifications and enforcement practices.
vehicle
This variability is not new, nor is it entirely undesirable. Local areas differ, as do local conditions, and licensing authorities have traditionally exercised discretion to reflect those differences and to reflect the needs of their areas, such as mandatory CCTV. However, the Committee has concluded that the degree of variation has gone too far, creating what can only be described as a competitive regulatory environment.
In practical terms, this manifests in two key ways: l Differing thresholds for entry into the trade l Uneven safeguarding & public protection standards
The consequences are significant. Passengers cannot be assured of consistent safety standards. Drivers and operators may seek to minimise compliance costs by “shopping around” for a more permissive authority. And enforcement becomes increasingly difficult where activity crosses administrative boundaries.
National minimum standards: a necessary step; but not sufficient alone
The Government’s proposal to introduce national minimum standards is, on the face of it, a logical response. Establishing a baseline across all licensing authorities should, in theory, eliminate the worst disparities.
The Committee agrees…but only up to a point.
It explicitly warns against a “lowest common denominator” approach. Minimum standards, if set too low, risk becoming a ceiling rather than a floor.
The report therefore calls for:
l High, comprehensive baseline standards, particularly in areas relating to safety
l Minimal scope for variation, to reduce incentives for licence shopping
l Clarity on which areas demand absolute consistency (e.g. safeguarding)
JULY 2026 PHTM
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