FAILURE TO PROTECT PUBLIC
CROSS-BORDER HIRING, CONSUMER LAW, & FAILURE OF LICENSING AUTHORITIES TO PROTECT THE PUBLIC
Article by Christopher Johnson Veteran London hackney driver
The fundamental duty of any licensing authority is clear: to protect the public. That duty sits at the heart of the private hire regulatory framework. Local authorities are entrusted not only to license drivers, vehicles, and operators, but to ensure that those they license comply with the law and operate in a manner that is safe, transparent and accountable.
However, what we are now witnessing across England is a systemic failure to uphold that duty.
The rise of cross-border hiring
Cross-border hiring is no longer an exception-it has become the norm.
Passengers booking a vehicle in one area are increasingly being supplied with drivers and vehicles licensed by entirely different authorities, sometimes many miles away. While this practice is lawful, it creates a regulatory disconnect with serious implications for public safety and accountability.
The issue is not simply cross-border hiring itself. The issue is that passengers are not being properly informed.
Private hire operators are “traders” - and the law is clear
Private hire operators are traders within the meaning of consumer protection law. That classification carries legal obligations, particularly at the pre-contract stage.
Under: l The Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 (CCRs)
l The Consumer Rights Act 2015 l The Digital Markets, Competition and Consumers Act 2024
Operators must provide material information:
l Clearly l Prominently l Before the consumer is bound by the contract
This is not guidance - it is law. 20
What compliance should look like - the passenger app
To demonstrate what
lawful compliance looks like in practice, I have produced a mock passenger app screen. It shows a passenger located in Manchester being offered a booking which is fulfilled by a Wolverhampton- licensed operator, driver and vehicle. Crucially, it clearly discloses: l The licensing auth- ority of the operator (Wolverhampton)
l The operator’s operat- ing centre address
l The driver’s licensing details l The vehicle registration and licensing authority l A clear consumer choice before accepting the booking
This is precisely what is required under Regulation 10 and Schedule 2 of the 2013 CCRs, alongside the transparency requirements of Section 68 of the Consumer Rights Act 2015.
It ensures that the passenger understands, before entering into the contract, who is providing the service and which authority is responsible for regulation and enforcement.
At present, no major operator app presents this information in a clear and prominent way.
The reality: a systemic failure of disclosure
In practice, passengers are not told: l Where the operator is licensed l Where the vehicle is licensed l Which authority is responsible for enforcement
This is a material omission under consumer law.
Passengers are therefore making transactional decisions without the key facts necessary to make an informed choice.
JUNE 2026 PHTM
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