‘UNIFYING’ BOTH TAXIS AND PHV: Hull City Council suggests ‘single-tier’ licensing system as part of national overhaul
- Perry Richardson
- 2 hours ago
- 4 min read

Hull City Council has urged to the Government to modernise England’s taxi and private hire licensing framework, describing current laws as outdated and inconsistent with how passengers now book and use services.
In a detailed submission to the Department for Transport, the council argues for a single-tier licensing system and new national standards that would simplify regulation, strengthen enforcement, and bring long-overdue consistency across the country.
The existing two-tier system, which separates hackney carriages from private hire vehicles, dates back decades. Under current law, only hackney carriages can legally be hailed or pick up passengers without a booking, while private hire vehicles must be pre-booked through a licensed operator. Hull City Council says this distinction no longer reflects the realities of a transport market dominated by mobile apps and integrated booking platforms.
Officials believe merging the two categories into one clear licence would remove public confusion and support more effective enforcement. The authority says passengers often do not understand the difference between a hackney carriage and a private hire car, particularly as both now operate through app-based systems that blur traditional boundaries.
“The view in Hull is that a single-tier system would unify the licensing of hackney carriages and private hire vehicles into one ‘taxi’ that could be hailed, ply for hire and be pre-booked, potentially simplifying the complex licensing system and making it easier for the public to understand.” the council said in its submission.
The need for national consistency
Hull’s licensing officers have repeatedly warned that local variations in licensing conditions have encouraged “licence shopping”, with drivers seeking permits from councils with less stringent requirements before working elsewhere. This cross-border issue has become a major problem across England, limiting councils’ ability to enforce standards and undermining public confidence.
Vehicles licensed outside Hull, the council notes, can regularly operate within its boundaries under their home authority’s conditions. This makes it difficult for enforcement officers to apply local standards or respond to complaints effectively. A unified national licensing framework would, the council says, create a level playing field for operators and improve passenger safety.
The council has already aligned its own policies with national guidance from the Institute of Licensing and the Department for Transport, including the 2022 Statutory Taxi and Private Hire Vehicle Standards and the 2023 Best Practice Guidance. However, Hull argues that guidance alone is insufficient and that the government must legislate to make such standards mandatory across all authorities.
Stronger enforcement powers
Hull is calling for expanded powers to enforce compliance against drivers and vehicles licensed elsewhere. The council supports the introduction of fixed penalty notices for minor breaches, which could help address common issues quickly without resorting to lengthy legal proceedings. Immediate suspension powers, it says, should still apply in cases where public safety is at risk.
Officials also recommend national rules on vehicle appearance and signage, helping passengers clearly identify licensed vehicles. A uniform system of markings, door signs, and roof lights would help eliminate confusion and reduce the risk of passengers entering unlicensed or unsafe vehicles.
Hull’s enforcement teams currently conduct joint roadside checks with Humberside Police, inspect vehicles at dedicated testing facilities, and provide comprehensive driver training. This includes safeguarding, equality and disability awareness, and a practical driving test focused on passenger service. Despite these efforts, officers say that inconsistent standards elsewhere undermine the benefits of such local work.
The rise of digital ride-hailing
Hull acknowledges that app-based ride-hailing has modernised the industry and improved transparency. Passengers now receive details of their driver, vehicle, and estimated arrival time before their trip begins, and digital feedback systems have improved accountability.
However, the council warns that these developments also expose weaknesses in existing legislation, which was written long before the emergence of digital booking platforms. Hull supports bringing ride-hailing platforms within the scope of updated taxi law but rejects creating a third licensing tier for app operators. The council believes that such services should simply be part of a combined single-tier model that recognises all licensed taxis as capable of pre-booked and immediate hire.
Accessibility and inclusion
Accessibility remains a key concern in Hull’s submission. The council says that national conditions would help all licensing authorities meet their duties under the Equality Act, providing disabled passengers with a consistent and reliable service across the country.
Locally, Hull’s hackney carriage proprietors have worked together to improve accessibility, particularly for passengers requiring wheelchair-accessible vehicles. The council highlights these partnerships as examples of best practice that could be replicated nationally. It also urges government to ensure that any future vehicle requirements or technology standards consider the needs of disabled passengers.
Cross-border hiring and data sharing
Hull recognises that cross-border hiring can benefit operators by giving them access to a wider pool of drivers. However, it says the current patchwork of local conditions, varying complaint systems, and limited data sharing make oversight difficult. The council already collaborates with neighbouring licensing teams and police forces, but warns that not all areas have the same level of cooperation or resources.
The council also makes regular use of the National Register of Licence Revocations and Refusals (NR3), a database designed to help licensing authorities share information about drivers who have had licences refused or revoked. While supportive of the system, Hull is calling for mandatory response times between councils to make the register more effective.
Preparing for autonomous taxis
Looking to the future, Hull references the newly introduced Automated Vehicles Act, which sets out how driverless passenger services will be permitted and monitored. The council suggests that as self-driving technology becomes more common, the logic for maintaining separate hackney and private hire categories will weaken further.
Officials caution that the arrival of driverless taxis will create new regulatory challenges around accessibility, maintenance, and passenger safety. They also note that automation could shift traditional driver roles towards vehicle supervision and customer care, requiring new forms of licensing and training.