TRIPLE LOCK RULE
Cross-border working remains one of the most contentious issues in the taxi and private hire trade. A private hire vehicle can carry out a pre-booked journey outside their licensing area. But crossing a council boundary does not mean the licensing rules disappear. The key is how the journey was booked and who fulfilled it.
THE RULE IS CLEAR, BUT IS IT BEING FOLLOWED? Holden’s
answer also acknowledged that the
Government recognised that out-of-area working can make life difficult for licensing authorities, while pointing to its value where local drivers are unavailable. Those competing pressures are real. Passengers need reliable vehicles, and operators need enough drivers to meet demand.
The distinction matters. In November 2022, Gill Furniss Labour MP for Brightside and Hillsborough, asked the Secretary of State what steps were being taken to address cross-border working by private hire vehicles.
Responding on behalf of the DfT, Richard Holden stated:
“Taxis and private hire vehicles (PHVs) are permitted to undertake pre-booked work outside of the area in which they are licensed. PHVs are subject to a triple licensing lock; the operator fulfilling the request, the driver and vehicle must all be licensed by the same local authority.”
That is the rule at the heart of this debate. But that distinction is easily lost when attention falls on an out- of-area number plate. The plate tells where the vehicle is licensed – it does not tell which operator fulfilled the booking.
There is an important qualification: the Deregulation Act 2015 allows a licensed private hire operator to subcontract a booking to another licensed operator but the operator fulfilling it must use a driver and vehicle licensed by the same authority. So the operator that first accepted a passenger’s request may differ from the one that ultimately provided the car.
That makes the booking trail especially important: authorities need to establish which operator accepted the request, whether it was passed on, and which operator ultimately fulfilled it. Seeing a vehicle licensed elsewhere is grounds to ask questions, but it is not, on its own, proof that the triple lock has been broken.
For further clarity, the triple lock rule was challenged in the case of Skyline versus Milton Keynes, where the ruling judge clearly stated that the Deregulation Act did not remove the triple lock rule - it is still very much an active part of legislation.
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Yet the claim that cross-border working simply fills a gap in local supply deserves closer examination. If substantial numbers of drivers licensed in one area spend most of their working time waiting for bookings elsewhere, their absence may contribute to shortages back in the area that licensed them. It is too simple to assume that every out-of-area vehicle represents extra capacity.
Equally, that possibility cannot be established by looking at a vehicle’s plate alone; it requires evidence about where and how the vehicle works and which operator despatched them.
For local licensing teams, the difficulty is practical. An officer may encounter a vehicle operating daily in their district while the driver, vehicle and operator licences are held elsewhere. Checking the legal position can mean tracing booking records and seeking information from another authority. The public, meanwhile, may reasonably expect the council area in which a vehicle is working to be able to act when concerns arise.
This is why the industry needs a more precise discussion. Lawful cross-border journeys, predominant out-of-area working and breaches of the triple lock rule are related issues, but they are not the same issue. Treating every outside vehicle as unlawful weakens the argument for reform. Treating the existence of a legal route as the end of the matter overlooks the strain on local oversight.
The Government has stated the rule clearly. The next question is whether licensing authorities can reliably see how bookings are accepted, passed on and fulfilled - and investigate when the facts do not add up. If the triple lock is to command confidence, it must be more than a line in a ministerial answer. It must be a rule that can be checked in practice, enforced where breached and understood by everyone expected to follow it.
OCTOBER 2026 PHTM
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