Why the UCG think the definition of plying-for-hire is central to London’s taxi future
- Perry Richardson
- Sep 23
- 3 min read
The United Cabbies Group (UCG) has told the Transport Committee that the future of the black cab trade depends on Parliament finally defining plying-for-hire in law.
The UCG submission argues that the lack of a statutory definition is the root cause of the problems facing licensed taxis in London. They say the rise of digital platforms has created a system where private hire vehicles (PHVs) can act like taxis, even though the law was meant to preserve a strict two-tier structure.
A right without protection
Licensed taxis are the only vehicles permitted to ply for hire. That right was intended to give the public access to a trusted, on-demand service with regulated fares. Drivers invest years of study in the Knowledge of London and self-fund the process to earn the badge that allows them to pick up passengers instantly from the street or at ranks.
The UCG claims this right has been steadily eroded. They say Transport for London (TfL) has allowed PHVs to adopt the same working practices as taxis through e-hailing, where bookings are made instantly via apps. In practice, PHVs wait near ranks or drive in busy areas until their app alerts them to a job. From a passenger’s perspective, this is little different from hailing a taxi.
The group points out that courts and regulators have long admitted plying-for-hire has no legal definition. In 1959, Justice Donovan said no comprehensive definition could be found in the decided cases. In 2015, TfL itself admitted it was ultimately a matter for the courts to interpret. The Law Commission also noted that key activities such as hailing and ranking are not defined in legislation.
Technology creating confusion
The UCG says that modern technology has deepened the problem. Terminology such as e-hailing, ride-hailing and instant booking has entered common use, yet none of these concepts appear in law. The result, they argue, is confusion in the market, with PHV operators exploiting loopholes to behave like taxis.
The group says TfL has often pointed to “blurring of the lines” between taxis and PHVs but has done little to prevent it. They accuse the regulator of favouring large operators and allowing the two-tier system to drift towards a one-tier market where PHVs enjoy the same benefits as taxis without the same obligations.
They argue that this shift has undermined investment in the Knowledge. For many years drivers questioned why they should dedicate up to four years of training for rights that can be imitated through an app in a matter of weeks.
What are the UCG calling for?
The UCG is calling for a statutory definition of plying-for-hire. They say the definition must confirm that only licensed taxis can ply for hire and that it should also cover key areas of practice:
inviting and attracting customers while driving or waiting;
use of ranks;
stopping in the street to pick up;
displaying availability; and
the use of technology to facilitate immediate hire.
They also want taxis and PHVs to be kept distinct and easily identifiable, removing any confusion for the public. In addition, they argue that enforcement must be consistent and properly resourced.
Why it matters
The group stresses that plying-for-hire is the foundation of the London taxi trade. It is the principle that supports a regulated fleet of accessible vehicles with meters set by TfL. It also underpins the wider industry including manufacturers, garages, fleet operators and meter suppliers.
The UCG warns that without legal protection, the privilege becomes meaningless, and the Knowledge risks losing its value. They argue that PHV apps offering near-instant hires have already driven down taxi driver numbers, with over 8,000 drivers leaving the trade in the last decade while PHV licences have surged past 100,000.
A crossroads for the trade
The UCG says London is now at a crossroads. Parliament must decide whether it wants a one-tier or two-tier system. If the intention remains a two-tier structure, then the law must make a clear distinction between taxi and PHV practices, backed by strong enforcement.
They point out that previous reports, including the 2019 Department for Transport Task and Finish Group, have already recommended a statutory definition. TfL itself admitted in its 2016 Action Plan that such a definition would remove ambiguity and protect the two-tier model.
For the UCG it’s define or continued decline. Without a legal framework, they argue, the black cab trade risks being absorbed into a system where its unique role and value are lost.
