ALL THINGS LICENSING
New right to work duties for private hire operators
One of the most significant regulatory changes facing the sector arrives on 1 October 2026. From that date, private hire operators will be required to undertake their own right to work checks before engaging drivers.
Until now, many operators have largely relied upon checks undertaken by licensing authorities during the licensing process.
The Government has concluded that clearer accountability is required, particularly in relation to platform-based operating models. Under the new arrangements, responsibility for preventing illegal working will be shared between operators and licensing authorities.
Operators who fail to comply may face enforcement action and potentially significant civil penalties. This change will require operators to review recruitment and onboarding processes urgently. Operators should ensure staff are appropriately trained, acceptable documentation is understood and compliant record- keeping systems are established. For larger operators and digital platforms, implementation may be relatively straightforward, but smaller operators may face additional administrative burdens.
Drivers should also expect increased scrutiny during the onboarding process and may be asked to provide documentation directly to operators, even where the licensing authority has already carried out similar checks.
Authorities will need to communicate clearly with operators regarding their respective responsibilities and ensure there is no misunderstanding about the separate nature of operator and licensing authority checks.
The change may reduce any perception that right to work compliance rests solely with licensing authorities. However, authorities are still likely to face questions and complaints where issues arise, with operators who do not conduct their responsibilities properly likely to fall foul of the fit and proper test.
Conclusion
A common theme links all of these developments: the taxi and private hire sector is becoming increasingly complex, increasingly regulated and increasingly interconnected with wider public policy objectives.
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From autonomous vehicles and safeguarding expectations to immigration compliance, the role of licensing is evolving far beyond its traditional foundations. Both the trade and licensing authorities must remain adaptable, informed and willing to respond to change.
For drivers and operators, professionalism, compliance and continual learning have never been more important. For licensing authorities, maintaining consistent standards whilst embracing innovation will remain a delicate balancing act.
There is no better opportunity to remain abreast of these developments than by engaging with the sector’s leading professional bodies and events. The Institute of Licensing’s Taxi and Private Hire Conference in October will once again bring together licensing practitioners, legal experts, industry representatives and policy makers to discuss the challenges and opportunities facing the trade.
With topics ranging from safeguarding and enforcement through to technological innovation and legislative reform, the conference promises valuable insight for anyone involved in the sector. I would strongly encourage both licensing officers and members of the trade to attend if possible.
As always, I would also encourage everyone involved in licensing to engage with the excellent work of the Institute of Licensing. The training, guidance and professional networks provided by the Institute remain invaluable resources as we navigate what promises to be another fascinating period of change for our profession.
For further information on the Institute’s work and upcoming events, including the Taxi and Private Hire Conference....
visit:
www.instituteoflicensing.org OCTOBER 2026 PHTM
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