TAXI & PH BILL OBSERVATIONS
l These measures will create a modern, joined-up taxi and PHV system in which people are confident in their safety and experience wherever they travel, and where powers, data, and accountability sit in the right place to act when standards fall short.
Again, this appears to suggest the expansion of the NR3 database to include enforcement actions taken against licence
holders, alongside national
enforcement powers. However, this should not be confused with a single-tier system: taxis and private hire will remain two separate licence types.
Territorial extent and application
l The draft Bill will extend to England and Wales and apply to England only.
It is not entirely clear whether this is a drafting error or simply unclear wording, as it appears contradictory. The Bill will apply only to England, although it may later be mirrored or adopted by the Welsh Government. In truth, however, the Welsh Government is already ahead in this area, having worked on national standards and policies for some time. This could suggest that both systems may ultimately align or support one another.
Key facts
l The taxi and PHV sector is large and growing. As of 1 April 2024, there were 313,000 licensed vehicles and 381,100 licensed drivers in England, continuing a long-term upward
trend according to Government statistics published in 2024.
l Regulation outside London remains rooted in legislation dating back to the Town Police Clauses Act 1847, designed for locally operating horse- drawn vehicles.
For clarity, as previously stated, only hackney carriage (taxi) legislation originates from the Victorian-era 1847 Act. Private hire did not exist at that time - indeed, neither did the motor vehicle. The private hire sector emerged only after the invention of the telephone and was not regulated until 1976.
This point is not strictly referring to case law, although many examples do exist. Rather, it refers to the Plymouth Act, the Local Government (Miscellaneous Provisions) Act 1976, and the later- adopted London legislation of 1998, all of which vary in significant ways.
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For example, in London, a PHV is considered a private hire vehicle only when on duty, which is why only a roundel is required in the front and rear windows, and why a non-badge holder may drive the vehicle when it is off duty. Outside London, however, the principle is effectively “once licensed, always licensed”, meaning plates are required and the vehicle may only be driven by a licensed badge holder at any time.
l Licensing standards and practices vary widely between authorities, including decision-making, fees, conditions, and enforcement activity.
l While national standards are expected to improve consistency and reduce incentives for drivers and operators to license outside the areas in which they work, they are unlikely on their own to resolve the issue entirely.
As stated above, we have consistently argued that unless national standards also regulate licensing practices themselves, the reforms will achieve very little. It is encouraging to see these concerns reflected here.
lWithout a closer alignment between where licences are issued and where journeys take place, enforcement resources and activity remain misaligned, limiting effectiveness and under- mining public confidence.
lWeaknesses in regulation disproportionately affect groups with fewer transport alternatives, increasing equality and safety risks.
l According to Government statistics, 8% of taxi and PHV journeys in 2024 were for education purposes, many relating to SEND provision.
l Taxis and PHVs are disproportionately used by disabled people, women, lower-income house- holds, and those without access to a car.
l People with mobility difficulties make almost 70% more taxi or private hire journeys than those without. Women make around 25% more trips than men. People without access to a car make almost four times as many taxi or PH journeys, while households in the lowest income quintile make around 50% more journeys than higher- income households.
l Major safeguarding reviews, including those led by Baroness Casey, have identified taxi and PHV licensing as vulnerable to exploitation where oversight is inconsistent and information is not effectively shared.
JUNE 2026 PHTM
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