TRANSPORT COMMITTEE INQUIRY Issue 2: DBS Update Service renewal mechanism
The DBS Update Service is fundamentally flawed in its renewal process. Currently, renewal is only possible via debit card payment, not direct debit.
Problems
l Debit cards expire or are replaced every 2-3 years, automatically causing renewal failures.
lWhen a payment fails, the driver’s update subscription lapses, requiring a full new DBS application - often leaving drivers unable to work during processing.
l DBS has claimed that direct debit payments are “more likely to fail”, but industry experience and financial data show the opposite to be true.
Proposed solution
l Introduce Direct Debit renewals for the DBS Update Service.
l Implement automated email AND SMS reminders before renewal deadlines.
These simple administrative reforms would preserve continuity, reduce bureaucracy, and support workforce stability.
Suggestion / summary:
The industry is not calling for reduced safeguarding - only for a fair, consistent and efficient system.
We urge the Home Office, the Disclosure and Barring Service, and the Department for Transport to:
1. Implement a single DBS framework for all licensed taxi/private hire work.
2. Enable Direct Debit renewals for the DBS Update Service.
Both actions would significantly reduce administrative burden, improve safeguarding continuity, and better support the drivers who provide essential transport services to schools, vulnerable people, and the wider public.
11. Devolution
We believe that the spirit of devolution is sound. The principle of reducing variations in licensing conditions, creating larger and more consistent working areas, and implementing clearer and more practical licensing policies are promising and necessary steps forward.
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For example, we have observed significant inconsistencies in how window tint restrictions are applied across different licensing areas. In one area, tint is regulated by a specific percentage of light transmission, while neighbouring authorities allow vehicles with “manufacturer’s standard glass”.
Where such percentage-based restrictions exist, they often rely on the use of light transmission meters to measure compliance. However, these devices have repeatedly been found to be inaccurate, uncalibrated, or incorrectly operated. This has resulted in unreliable readings that are frequently challenged. In some cases, the same person using the same device on the same vehicle has produced different results - highlighting the futility of applying such precise percentage conditions in practice.
We have even seen cases where vehicles failed compliance tests for being just 1.5% below the allowed tolerance - a difference imperceptible to the human eye and with no measurable impact on safety or visibility. In such instances, vehicle owners were forced to replace all windows at a cost of approximately £1,000, whilst undermining the vehicle’s original Type 1 approval status, despite reasonable alternative proposals being rejected.
The only suggested justification for such restrictive conditions is that enforcement officers should be able to see into vehicles as they pass. However, given that most enforcement takes place during daylight hours, and that vehicles typically pass at speeds of around 30 mph, this argument lacks logical or practical merit.
This issue has already been the subject of several judicial reviews involving local authorities, many of which subsequently removed such conditions without any impact on public safety. The matter has also been discussed in detail in Private Hire and Taxi Monthly (PHTM), notably in the July 2021 (Issue 346, p.6) and August 2021 (Issue 347, p.6) editions, where we fully explain the reasoning behind vehicle manufacturers’ adoption of tinted glass as standard.
Reduced services for the travelling public
However, we do have significant concerns regarding the broader proposals for devolution and the full amalgamation of existing local authorities. Experience from areas such as Bournemouth, Christchurch and Poole (BCP) and the new North Yorkshire Council has shown that such large-scale mergers can lead to inconsistent service provision and a lack of meaningful
NOVEMBER 2025 PHTM
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