FAILURE TO PROTECT PUBLIC


The role of licensing authorities: a failure to enforce


This is not simply an industry issue - it is a regulatory failure.


Licensing authorities:


l License private hire operators as “fit and proper” l Yet fail to ensure compliance with consumer law l Do not require transparent pre-contract disclosures l Do not audit booking platforms adequately l Do not take enforcement action


This represents a nationwide failure to regulate operators as traders.


A second failure: duty to inform the public


Licensing authorities also have a duty to actively inform and protect the public. To illustrate what this should look like, I have produced a second visual: a public safety notice for Manchester City Council.


This notice clearly explains:


l That Manchester- licensed vehicles are subject to local enforcement and safety checks


lThat vehicles licensed by other authorities are not enforceable by Manchester City Council


l That regulation and safety standards may differ l That passengers should understand who is licensing their journey


This type of public-facing communication should be visible:


l At transport hubs l In the night-time economy


l Across digital platforms l At bus stops


Instead, such messaging is almost entirely absent.


The accountability gap The combined effect of these failures is stark: l Passengers are not informed at the point of booking


PHTM JUNE 2026


l They are not informed by public authorities l Enforcement responsibility is fragmented and unclear


This creates a system where journeys may be:


l Arranged by an operator in one area l Driven by a vehicle licensed in another area (if the booking is subcontracted)


l Taking place in a third area lWith no clear local accountability


The consequences for public safety This is not a theoretical concern.


It results in: l Reduced regulatory oversight l Limited local enforcement capability l Passenger confusion l Erosion of trust in the licensing system


Most importantly, it undermines the very purpose of licensing: public protection.


The need for national intervention


This issue requires urgent attention from: l The Department for Transport (DfT) l Transport Ministers


There must be:


l Clear direction that private hire operators comply with consumer law at the pre-contract stage


l Enforcement expectations placed on licensing authorities


l Recognition that transparency is fundamental to safety


Conclusion


The law is already in place. Operators must provide clear, prominent, pre-contract information. Licensing authorities must ensure they do.


The two accompanying visuals demonstrate:


1. What a legally compliant booking process should look like


2. How the public should be informed about cross- border risks.


What is missing is not legislation - but enforcement, leadership, and accountability.


Until that changes, passengers will continue to book journeys without knowing who is responsible for their safety.


And that is a failure that can no longer be ignored. 21 l National policymakers


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