THE HIDDEN OPERATOR
Cross-border dispatching illustrates the issue starkly. A vehicle licensed by one authority may lawfully undertake a journey in another area, yet enforcement approaches and local regulatory priorities can differ.
Without pre-booking and pre-contract operator disclosure, passengers cannot assess these factors or make informed choices. Transparency is therefore not a theoretical nicety but a functional safeguard.
Knowledge of the contracting operator enables accountability,
supports consumer choice, and
reinforces the regulatory system designed to protect passengers - particularly those who are vulnerable.
Enforcement gaps, not legal gaps
The relevant legal principles are clear and long- established. Comparable transparency requirements are enforced across numerous digital marketplaces. The challenge re: private hire appears to stem less from legislative deficiency and more from regulatory hesitation in confronting platform-based operational models.
Where private hire operator allocation occurs only after booking confirmation, tension arises with statutory pre-contract consumer disclosure duties.
Conversely, if the operator is known earlier in the
process (at the pre-contract stage), withholding that information becomes difficult to justify.
Regulators - including trading standards authorities and the Competition and Markets Authority - already possess enforcement tools capable of addressing this issue.
A straightforward & proportionate solution The remedy is neither complex nor burdensome.
Before confirming a booking, platforms ought to be required, as a condition of their licence, to display the registered operating licence address, contact details, and the licensing authority regulating the trip.
Such disclosure would align platform practices with existing consumer law, strengthen public confidence, and enhance regulatory coherence without impeding innovation.
Ride-hailing has delivered substantial mobility benefits: convenience, accessibility, and expanded transport choice. Yet innovation must operate alongside transparency and consumer law. Passengers are entitled to know who stands behind the service they are purchasing.
The legal framework is already in place. The question is: why hasn’t it been meaningfully applied?
PHTM MARCH 2026
25
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