Triple-lock, national standards and enforcement: Wolverhampton Council reveals how cross-border taxi licensing can improve
- Perry Richardson
- Sep 20
- 4 min read
Updated: Sep 22
City of Wolverhampton Council has set out a detailed case for reform of taxi and private hire licensing, calling for uniform national standards to address the challenges created by cross-border operations.
The authority highlighted how the current system leaves councils unable to refuse applications on the basis of residency. Legally, applications can only be rejected if an applicant is not deemed fit and proper or fails to meet limited criteria. Wolverhampton has therefore seen its licence numbers surge dramatically in recent years, issuing more than 50,000 private hire licences, with 96% of those drivers living outside the city.
The Council said that this situation is not the result of encouraging applications, but instead reflects the efficiency of its online application system and the relative affordability of its fees. It argued that drivers from across England are drawn to apply in Wolverhampton because of these advantages, and that without national reform the problem of “licence shopping” will continue.
National uniform standards
In its submission, Wolverhampton was clear that minimum standards are not enough to solve the issue. The Council said that as long as variation exists between licensing authorities, there will be incentives for drivers to seek licences away from their home area. This, it added, creates an uneven playing field for the trade and raises public safety concerns, as enforcement resources are limited.
A fully uniform national system would ensure that the same requirements are applied everywhere, making the licensing process more consistent and transparent. This would also help address concerns around school transport. Wolverhampton noted that many drivers providing such services are not licensed in the areas where they actually operate, leading to questions about oversight and safeguarding.
Stronger enforcement powers
The Council has also pressed for significant changes to enforcement. At present, local compliance officers cannot stop vehicles themselves and must rely on police support, which comes at additional cost and pressure on police time. Wolverhampton argues that compliance officers should be given statutory powers to stop licensed and unlicensed vehicles, issue penalty notices for breaches such as plying for hire or using a defective vehicle, and suspend licences pending investigation.
It further recommended that licensing officers be empowered to suspend licences issued by other authorities, to prevent drivers who hold multiple licences from simply switching to a “back up” licence if action is taken against them. Courts and police should also play a greater role, with magistrates and crown courts able to revoke or suspend taxi licences at the point of sentencing, and police officers required to consider suspending licences as part of bail conditions.
To support national enforcement, Wolverhampton proposed the creation of a compliance intelligence board, alongside a mandatory information-sharing agreement between all licensing authorities. This would allow compliance officers across the country to share data, improving oversight and efficiency.
Calls to remove the triple lock
A central recommendation is the removal of the so-called “triple lock”, which requires the driver, vehicle and operator to all be licensed by the same authority. Wolverhampton said this system is inefficient, creates unnecessary duplication, and inflates costs for operators.
Instead, it suggested that any licensed operator should be permitted to take bookings for any licensed vehicle, driven by any licensed driver, regardless of licensing authority. This would allow drivers greater flexibility, particularly when their own vehicle is out of use following an accident, and reduce costs for operators who currently hold multiple licences with different councils.
The Council also highlighted that hackney carriages are already able to accept bookings from any licensed operator, further underlining the inconsistency in the current framework.
Strengthening records and safeguards
Concerns were also raised over the National Register of Refusals, Revocations and Suspensions (NR3S). Retention periods for records were reduced in 2022 from 25 years to 11, something Wolverhampton described as a weakening of public protection. It said this change could allow drivers removed from licensing in the past following serious complaints to reapply with relative ease, even where those complaints did not lead to criminal convictions.
The Council has urged the Government not only to restore the 25-year retention period, but to extend it further, ideally to 99 years, to close gaps that may otherwise allow unsuitable drivers back into the trade.
Towards a national regime
Wolverhampton’s evidence concluded that only a comprehensive national licensing system with uniform standards, shared enforcement powers, and consistent record-keeping would be able to properly address cross-border challenges.
It argued that such reforms would help reduce inefficiencies, protect public safety, and ensure that local authorities are not left dealing with the unintended consequences of modern, digital application systems that make it easy for drivers across England to seek out councils with lower barriers or quicker turnaround times.
The Council’s position is that a patchwork of local standards can no longer meet the needs of an increasingly nationalised trade, and that Government intervention is now necessary to ensure fairness, efficiency and safety across the sector
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