Consultation outcome

Changes to the date of the first MOT test and research into other MOT enhancements

Updated 25 January 2024

Executive summary

The MOT test has been in place since the 1960s and the 3 year threshold for the first MOT test since the late 1960s. The MOT test was first introduced to assure the safety of a vehicle, in practice the effectiveness of safety-critical components such as tyres and brakes. In recent years, the concept of roadworthiness has expanded to encompass vehicle emissions and effects on the environment.

Since the MOT was introduced – and especially in recent years – there have been major advances in vehicle technology. These include the development of hybrid and electric vehicles; rapid progress in systems that automate actions such as parking or provide information to the driver. Looking to the future, rapid progress is being made in developing vehicles with self-driving features. It is therefore appropriate to consider whether changes need to be made to ensure that the system for assuring that vehicles are roadworthy remains fit for purpose.

This consultation document is seeking views on changes to roadworthiness testing. The first part considers the case for changing the date at which the first MOT is required and proposes that the date of the first MOT is changed from 3 to 4 years and some related changes. The second part of the consultation asks broader questions about the nature of the MOT – what is tested and how and the frequency of tests. We also ask whether there are other approaches that could achieve our road safety and environmental objectives.

You may wish to respond to both parts of the consultation or to only one part.

In this initial stage, we are seeking to identify the strengths and weaknesses of the current system, options for change and the issues that arise. Part 2 is a call for evidence on these matters. We will consult publicly on any detailed proposals that emerge from the review and produce impact assessments on any such proposals.

Many of the questions concern the linkages between developments in vehicle technology and MOT testing. To assist with the technical aspects of the review, the government is appointing a consultant to advise on the review and will draw on the expertise of industry groups from the motoring and garages sectors.

This consultation is only considering light vehicles. Heavy freight and passenger carrying vehicles are subject to annual roadworthiness tests starting from the year they are first registered plus additional requirements for regular maintenance inspections and on road enforcement by the Driver and Vehicle Standards Agency (DVSA).

Part 1. Timing of the first MOT and other proposals for change in 2023

The case for change

The MOT test was first introduced in 1960. Cars were first tested after 10 years. In 1967, this was changed so that the first test is carried out after 3 years. The test provides a basic level of assurance to drivers about the safety of their vehicles. It also provides a check of the emissions from a vehicle. During the Covid 19 pandemic, the requirement to obtain an MOT test certificate was suspended for 6 months.

Since the 1960s there have been major advances in vehicle manufacture. Vehicles are better built, making them more resilient to wear and tear. There are also huge advances in systems providing safety information to the driver. It is therefore appropriate to consider whether an MOT test on 3-year-old vehicles remains necessary.

There are already different dates in parts of the UK for the first MOT test. In Great Britain cars, vans and motorcycles are first tested after 3 years. In Northern Ireland the first test is at 4 years. There are also different practices in other European countries with some countries testing at 3 and others at 4 years.

Section 47 of the Road Traffic Act 1988 sets out when an MOT is first needed. It also, if Parliament agrees, enables Ministers to change the date of a first MOT for cars, vans and motorcycles from 3 years to another period (which cannot be more than 10 years).

The Department for Transport consulted in 2016 on extending the date of the first MOT test from 3 to 4 years but decided not to make the change at that time. Since 2017, when the government response to the consultation was published, there has continued to be rapid technological development in the automotive field including the growth in the use of alternatively fuelled vehicles.

One of the reasons why the department decided in 2017 not to proceed with changes to the date of the first MOT test was the age of some of the evidence base, especially in relation to the safety implications of the change. The department has therefore reviewed and updated the safety assessment originally carried out by TRL updating key input data on MOT failure rates and collisions.

In summary, fewer vehicles are failing MOT tests, there have been general reductions in the number of casualties in collisions involving cars and minor decreases in the proportion of collisions where vehicle defects are a factor.

MOT testing is carried out at testing stations which have been approved by the Driver and Vehicle Standards Agency (DVSA). There are about 23,400 approved testing stations in Great Britain. In 2021, these stations carried out more than 30 million tests including more than 2.6 million tests on 3-year-old cars.

Table 1 shows the vehicles that are in scope of the proposed change and the maximum current fees for MOT tests (in practice MOT testers often charge less than the maximum). Part of this fee (£2.05) is paid to the DVSA when a vehicle passes an MOT as a “slot fee” which supports DVSA’s operation and enforcement of the MOT system.

Table 1: MOT test fees

Class	Type of vehicle	Fee
1 & 2	Motorcycles	£29.65
	Motorcycles with sidecar (class 1 engine size up to 200 cm3)	£37.80
3	3 wheeled vehicles (up to 450kg unladen weight)	£37.80
4	Cars (up to 8 passenger seats) and 3 wheeled vehicles (up to 450kg unladen weight)	£54.85
	3 wheeled vehicles (over 450kg unladen weight)	£54.85
	Quads (max unladen weight 400kg – for goods vehicles 550 kg and max net power of 15w)	£54.85
	Dual purpose vehicles	£54.85
	Private hire vehicles and PSVs (up to 8 seats)	£54.85
	Goods vehicles up to 3,000kg (Design Gross Weight)	£54.85
7	Goods vehicles over 3,000kg up to 3,500 kg (Design Gross Weight)	£58.60

Note: The table does not cover vehicles such as ambulances, taxis and passenger vehicles which are tested from year 1.

Options for changing the date of the first MOT

The consultation seeks views on whether or not to change the period for vehicles requiring a first MOT. The options proposed are:

• option 0: no change, vehicles that currently require their first MOT at 3 years (see Table 1) will continue to do so
• option 1: increase the date at which a first MOT is required for the vehicles listed in Table 1 from 3 to 4 years
• option 2: increase the date at which a first MOT is required for the vehicles listed in Table 1 from 3 to 5 years

The government’s preference is for option 1.

Costs and benefits of changing the date of the first MOT

In 2018 the ONS reported that 78% of UK households owned 1 or more cars or vans so changes to the MOT are of interest to a significant proportion of the population. This is a proposal that would reduce the regulatory burden on members of the public and businesses that own cars. It is a principle of good regulation that legislation should be proportionate to the perceived problem or risk and justify the compliance costs imposed. In this case, the cost of complying with the requirement to have a vehicle tested at 3 years is around £100 million (range of £91 million - £117 million based on the 2.6 million tests carried out in 2021/22 and a fee of £35-£45).

Owners will still need to maintain their vehicle to a roadworthy standard and will, therefore, need to visit garages for servicing and maintenance. Preliminary information received from an industry body suggests that about half of car owners combine an MOT with a service, though further evidence is being sought during this consultation to provide a more complete data picture and to try and understand whether those that combine MOT and service may neglect servicing if there is not a 3 year MOT requirement.

If the proposed change led to some owners delaying the servicing of their cars (where they would previously have combined a service with an MOT) that would have an effect on garage income and potentially on vehicle safety and reliability. However, for newer cars this may be mitigated by the fact that many newer cars are serviced and the MOT carried out by dealerships rather than by MOT garages.

Safety impacts

The main potential costs arising from the proposal are in relation to safety and environmental impacts. As a vehicle would undergo a longer period between being built and its first MOT under the proposal, it is reasonable to expect that the vehicle would be more likely to fail its first MOT. In data provided by DVSA, for most of the vehicles in scope, it can be observed that the initial failure rate of vehicles increases with the vehicle age. For Class 4 vehicles in 2019, this rose from 14% for 3-year-old vehicles to 16% for 4-year-old vehicles. It is anticipated that an increase in the number of vehicles operating with vehicle defects for a longer duration could lead to an increase in the number of vehicle defect-related collisions. In 2019, there were some 1,455 casualties in collisions where a vehicle defect contributory factor was listed for the vehicles identified in scope of this proposal, 20 of which were fatal and 333 and 1,102 were either serious or slight respectively ^{[footnote 1]}:

The 2016 consultation presented an estimate of the possible safety impacts of changing the date of the first MOT test from 3 to 4 years. This was based on 2011 Transport Research Laboratory (TRL) 3 analysis adjusted to 2015 casualty levels. DfT has now carried out an updated analysis to assess the relationship between the number of MOT failures for cars and the frequency of collisions caused by vehicle defects. We have recreated the original approach undertaken by TRL to validate against their estimates and have since updated key input data around more recent MOT failure rates and collisions to assess the effects of changing the date of the first MOT under the proposals. The updated analysis confirms that altering the first date of the MOT will have much less of an effect than it would have done in 2016.

Table 2: Estimates of impact from changing the date of the first MOT for the vehicles identified in scope to 4 years

MOT Test Frequency	Predicted additional casualties involving: Class 1*	Predicted additional casualties involving: Class 2	Predicted additional casualties involving: Class 4	Predicted additional casualties involving: Class 7	All casualties**
Option 1 (first test at 4 years)
Fatal	0 - 0	0 - 0	0 - 1	0 - 0	0 - 1
Serious	1 - 4	0 - 2	3 - 10	0 - 0	4 - 16
Slight	2 - 7	0 - 1	10 - 39	1 - 2	12 - 48
All*	3 - 11	1 - 3	12 - 50	1 - 2	16 - 65

Table 3: Estimates of impact from changing the date of the first MOT for the vehicles identified in scope to 5 years

MOT Test Frequency	Predicted additional casualties involving: Class 1*	Predicted additional casualties involving: Class 2	Predicted additional casualties involving: Class 4	Predicted additional casualties involving: Class 7	All casualties**
Option 2 (first test at 5 years)
Fatal	0 - 0	0 - 0	0 - 1	0 - 0	0 - 2
Serious	1 - 6	1 - 3	5 - 20	0 - 1	7 - 30
Slight	3 - 10	0 - 2	20 - 78	1 - 4	24 - 94
All**	4 - 17	1 - 4	25 - 100	1 - 4	31 – 126

*For a definition on classes, see Table 1

**Numbers may not sum to totals due to rounding

The lower estimated impact than in the previous analysis seems to be due to several factors: there has been a 20% reduction in the initial MOT failure rate compared to that seen in 2009 data, there have been general reductions in the number of casualties in collisions involving these vehicles in scope of these proposals since 2009, around 31.5%; there have been some decrease since 2010 (around 7%) in the proportion of vehicles in scope involved in collisions where vehicle defects were identified as a contributory factor in the collision. Table 4 shows the defects which were identified as contributing to collisions in 2019 for class 4 vehicles (which includes cars). Collisions may have more than one contributory factor.

Table 4: Vehicle defects as contributory factors to collisions in cars in 2019, STATS19

	Fatal	Serious	Slight	All
Vehicle defects	15	171	557	743
Tyres illegal, defective or under inflated	8	79	222	309
Defective lights or indicators	0	9	37	46
Defective brakes	3	59	194	256
Defective steering or suspension	2	26	104	132
Defective or missing mirrors	0	1	4	5
Overloaded or poorly loaded vehicle or trailer	2	6	16	24

The impact of the proposals will be affected by the extent to which motorists continue to have their vehicles serviced and respond to alerts of safety issues from the systems with their vehicles. This in turn will be affected by the motorists’ knowledge of their vehicle’s safety features and whether they are willing to follow government advice in order to protect themselves and their passengers.

The 2016 consultation noted that measures had already been introduced in relation to tyres which are critically important to the safety of vehicles. These included mandatory tyre pressure monitoring and minimum performance standards for new tyres for grip on wet roads. Such measures are likely to have contributed to the continuing improvement in road safety.

The 2016 consultation noted that light vans typically have significantly higher mileage than cars, at year 3 a car has on average done around 32,000 miles while vans have done more than 70,000 miles. In 2021 the average mileage at year 3 for class 4 was 25,379  and for class 7 (vans between 3 and 3.5 tonnes it was 58,539. This is potentially significant because MOT failure rates increase for vehicles which do more miles.

Our new assessment shows that progress in reducing the safety risks of vehicle defects is continuing.

Environmental impacts

We have also considered the potential impact of the proposal on emissions of pollutants from cars. The annual mortality of human-made air pollution in the UK is roughly equivalent to between 28,000 and 36,000 deaths every year. Road transport is estimated to contribute 12.4% of primary particulate matter and 33.6% of nitrogen oxides. From Air pollution: applying All Our Health

The MOT test for petrol engines tests carbon monoxide and hydrocarbons at fast idle and idle. Emission tests for diesel engines measure smoke opacity at full throttle position. Detailed information on the emissions testing is set out in the DVSA publication: In Service Exhaust Emission Standards for Road Vehicles. Table 5 shows the reported data on vehicles failing the emissions tests for those vehicles tested in 2019.

Table 5: Vehicles failing the emissions tests in 2019

Emission test	Initial failures	Failures as percentage of total initial failures
Hydrocarbons (HC)	57,622	0.58%
Carbon Monoxide (CO)	198,186	1.98%
Diesel smoke (opacity)	118,351	1.18%
Other emissions-related failures	730,138	7.29%
Total emissions initial failures	1,104,297	11.03%
Total initial failures (for any reason)	10,010,559	30.18%

Note: The total number of tests (33,168, 939) from the data provided by DVSA differ to that used elsewhere in the IA analysis and should be treated with caution, until reconciled ahead of the final stage. Therefore, the percentages are more likely to be robust compared to absolute numbers in this table.

Following the change in the regulations, it could be expected that those vehicles that would have failed their initial MOT due to the emissions being produced would continue to pollute at higher levels until this is picked up in their first MOT. Statistics produced by the department show that in 2021, the average grams emitted per kilometre travelled by cars and vans are 120g/km and 198g/km respectively.

While not all vehicles fail their MOT based on emissions, internal analysis has predicted that the MOT failure rate for cars could increase from 31.9% to 32.2 – 33.2% under option 1 and 32.6 – 34.5% under option 2. If the level of emissions failures of MOT remains the same, this could result in the level of emissions produced by failing vehicles increasing by a similar amount. Estimates of the increase in emissions failures are provided in table 6. Also included in the table is the total number of failures associated with the broad emissions category to give an upper bound on the estimates.

Table 6: Estimated increases in emissions failures

Emission	MOTs conducted in 2019	Initial failures estimated due to emissions - current (2019)	Initial failures estimated due to emissions - option 1	Initial failures estimated due to emissions - option 2
Hydrocarbons (HC)	31,844,172	58,484	59,077 – 60,858	59,667 – 63,218
Carbon Monoxide (CO)	31,844,172	201,151	203,190 – 209,315	205,219 – 217,433
Diesel smoke (opacity)	31,844,172	120,121	121,339 – 124,997	122,551 – 129,845
Other emissions-related failures	31,844,172	741,060	748,572 – 771,137	756,049 – 801,047
Total emissions failures	31,844,172	1,120,816	1,132,177 – 1,166,306	1,143,486 – 1,211,543

Notes:
- total emissions failures are the sum of the previous 4 rows to estimate all emissions-related failures. This has been estimated using modelling undertaken on DVSA MOT data. A single vehicle may have more than one emissions failure which will lead to some double counting at present - the number of MOTs conducted in 2019 will be different to that in Table 5 due to a data discrepancy which will be investigated in parallel with the consultation. The number here is used to ensure comparability with the safety analysis, and uses the percentages estimated in Table 5 to inform the estimated emissions failures

Impact on garages

Increasing the date at which a first MOT is required, will mean that the 23,400 garages approved as MOT test stations will lose revenue. Based on historical registration data combined with vehicle forecasts, increasing the date to 4 years would result in fewer annual tests, range of 1.36 million to 2.97 million fewer tests due to changes in future vehicle registration. Applying the various MOT fee to each vehicle type this equates to an annual loss of revenue to garages of £56.3 million-123.6 million (once DVSA’s slot revenue is deducted).

As noted above, there could be a further impact on garages if the change to the date of the first MOT leads to vehicle owners delaying servicing. This could arise because many owners combine the servicing of their car with an MOT.

Impact on government departments

DVSA administers the MOT scheme receiving a slot fee for every vehicle pass. Options 1 and 2 would reduce the number of tests carried out and therefore reduce the number of slot fees that DVSA receives. The expected total cost to DVSA of option 1 over ten years is £53.8 million, with a range of £53.1 million to £56.7 million. The equivalent cost of option 2 over ten years is £101.5 million, with a range of £100.9 million to £102.7 million.

When a driver pays vehicle excise duty, the Driver and Vehicle Licensing Agency (DVLA)’s system will check against the DVSA’s MOT system that the vehicle has a valid MOT in force. Under either option 1 or 2, DVLA would need to make changes to IT systems to reflect the new date the first MOT is due.

Other immediate proposals for enhancement of the existing system

The assessment above shows that there has been steady improvement with fewer vehicles failing MOT tests and fewer road casualties. The safety implications of a change to testing for the first time from 3 to 4 years are likely, therefore, to be very limited.

Furthermore, continuing technological progress means that it is likely that new cars will continue to be safer than in the past as improvements such as autonomous emergency braking systems are more widely adopted.

We are interested in views on measures that could be implemented alongside changes to the date of the first test in order to further enhance road safety and lower the environmental impact of road vehicles. For instance, notification that vehicle tax is due could be accompanied by reminders that the driver remains responsible for roadworthiness and advice to get a service.

Emissions from diesel vehicles

Another area that we believe it would be prudent to consider changing in 2023 is around emissions – in particular for the correct fitment and operation of emissions control equipment, including diesel particulate filters (DPFs). A DPF is a device fitted within the exhaust pipe of a diesel vehicle which filters particulate matter from exhaust gases. It does this by trapping solid particles while letting gaseous components escape. These filters enable significant reductions in emissions of particulate matter from diesel cars, reducing negative effects on air quality and thereby public health.

Poor maintenance of DPFs can affect performance and ultimately lead to the need for repairs. This has led to some diesel vehicle owners removing their DPFs to avoid repair costs, which is both illegal and will lead to excessive air pollution. Testing conducted by the Department for Transport has shown that the removal of a DPF can result in an increase in the number of particles being emitted from the exhaust by approximately 10,000 times.

Since February 2014 the inspection of the exhaust system of diesel vehicles carried out during the MOT test includes a visual inspection for the presence of a DPF. The current MOT includes provision to fail a vehicle where this equipment is not present or inoperative – but this is not easy to determine on many vehicles. The current smoke opacity test for diesel vehicles has also been found not to be sufficiently effective in detecting the removal of a DPF for modern vehicles. Given the significant air quality impacts, we are keen to ensure that testers are able to identify missing or defective DPFs.

We are therefore committed to implementing more effective testing of particulate emissions from diesel cars to allow for those which have excessive emissions to be identified. Other countries have implemented new ways of testing the tailpipe emissions of diesel vehicles to determine if DPFs are present and working – this is known as particulate number (PN) testing. The use of PN testing at annual vehicle inspections was introduced in the Netherlands and Belgium in July 2022. Germany and Switzerland are also planning to introduce similar requirements from January 2023.

Research conducted by the DfT into the use of PN testing equipment for the MOT concluded that it provided an effective means of identifying removed or damaged DPFs, with significant advantages over current testing methods. The DVSA is currently trialling PN testing equipment within select MOT test stations to better understand the practicality of wider roll-out. We welcome views in response to this consultation to inform our implementation of PN testing.

We believe that implementing PN testing is the right thing to do, but we are aware that there are some practical considerations that we must work through with stakeholders before we commit to when this should be implemented.

One of the practical issues we must overcome is how to encourage investment in this new equipment, whilst ensuring that we provide those motorists with in-scope vehicles (likely to be post 2013 diesel engine vehicles) with sufficient choice in where to get an MOT. In the past we have implemented this type of change by giving garages a period of time (for example, 2 years) to procure the equipment – with in-scope vehicles being required to go to a garage approved for PN testing in that time. We are interested in your views on this phased approach.

Public awareness and vehicle servicing

We recognise that, if we were to change the first MOT date to 4 years, this may mean that some motorists do not, unwittingly or otherwise, maintain their vehicle to the right standard. The DfT will accompany any such change with publicity to ensure that motorists are still aware of the obligations they have to keep their vehicle roadworthy. We would be interested in views on how such a campaign may be made most effective.

We are also aware that many motorists believe that their service regime covers all the points of the MOT and that, therefore, the MOT is superfluous. However, this is not always the case and some service products do not cover all the items in an MOT or include, for example, metered brake tests as an MOT would do. We believe that there is value in encouraging those offering service products to better ensure that the scope of the service does include all safety critical items (as an MOT does) and to be clear to consumers that this is the case. DfT will work with trade bodies to better do this, but will welcome views on what wider work may be useful.

Part 2. Call for evidence on changes to MOT testing

Introduction

Given the evolving vehicle market, the development of vehicles with self-driving features, and changing consumer habits, the current model of roadworthiness testing may need to change. The government is carrying out a review of MOT testing to consider whether the current approach could be improved to better achieve the objectives of improving road safety and maintaining environmental standards.

As a first step in the review, the government is seeking evidence from all interested parties. The review will consider both short and longer- term changes.

We welcome the views of individuals, groups, and organisations – particularly those involved in the motoring sector – who have specific interest in roadworthiness assurance. For example:

• vehicle manufacturers
• diagnostic/testing equipment manufacturers
• vehicle testing organisations
• trade bodies representing those in the motoring sector
• motorists and other road users
• vehicle owners and operators

In the past, the UK was bound by European Union law which limited our ability to make changes to roadworthiness testing. Since the UK has left the European Union, we have the ability to take a fundamental look at roadworthiness testing and to modernise it in light of developments in vehicle technologies and testing methodologies.

Nonetheless, the experience of other countries facing similar challenges is valuable and we note that the European Commission is carrying out a review of its own roadworthiness legislation including a public consultation between July and 28 September 2022.

Frequency of testing for different vehicles

We are considering if it is appropriate to move to testing every 2 years rather than every year, reflecting the progress in improving vehicle safety. There are differences between the different types of vehicles. We ask, therefore, for your views separately on cars, vans and motorbikes.

At present, cars, light goods vehicles (including vans) and motorbikes must have a first MOT after 3 years and then annually thereafter- see table 1 for the vehicles to which this applies. We would welcome views on whether the improvement in vehicle design and build quality and in-vehicle monitoring systems mean that vehicles can be tested less frequently

The arguments for and against changing the frequency of testing are whether improvement of vehicle design and build quality mean that the MOT testing regime can be relaxed with consequent savings to motorists. Or do there continue to be risks to road safety and to the environment that outweigh these savings?

Vehicles are more likely to fail an MOT test as they get older and develop significant problems. Failure rates increase significantly as vehicles get older (up to 14 years of age, before plateauing). 80% of MOTs are performed on vehicles less than 14 years old. The trend is similar for light and heavy vehicles (that is, older vehicles are more likely to fail. However, heavy vehicles have higher average failure rates.

The average age of cars in the UK is rising as people are keeping their cars for longer. In 2021 the average age of a car on UK roads was 8.4 years old, the highest since records began to be collected in 2000. The distribution of ages is shown in the chart about age of cars.

Age of cars in 2021	Amount of cars
Less than 3 years old	7,449,464
4-6 years old	7,128,037
7-9 years old	5,934,303
10-12 years old	4,652,423
More than 12 years	7,062,634

The government recognises that there continues to be concerns about the safety implications of changing the frequency of MOT testing, in particular in relation to safety-critical equipment such as brakes, tyre and lights. Vehicles are more likely to accumulate significant problems as they age and at higher mileages and more likely as a consequence to fail an MOT test. (However, this isn’t the case for the small number of vehicles over 20 years where MOT failure rates reduce to some extent. Anecdotally, this may be because there are significantly fewer of these vehicles and they are maintained as “classic cars” or vehicles of historical interest).

It is also the case that vehicles that do greater mileage than average are more likely to fail MOT tests. One consequence of changing the frequency of tests is that vehicles will have done more mileage between tests and therefore – in the absence of any other measures – be more likely to become unroadworthy and therefore fail their MOT which will be of particular significance in relation to brakes and tyres.

MOTs are part of the system that promotes road safety through measures that aim to make drivers, vehicles and roads safer. As with changes to the date of the first test, changing the frequency of testing might be balanced against other measures such as making the MOT test stricter or stronger advisory guidance to drivers. However, any consideration of making the MOT stricter will need to be considered carefully as it may increase costs to motorists, and result in components being replaced before they have reached the end of their safe working life – with the knock-on environmental impacts.

In Belgium, vehicles that pass the contrôle technique (equivalent to an MOT), have covered less than 100,000 Km and have been tested within its date limit and are less than 6 years old can be tested after 2 years whereas other vehicles must be tested annually.

MOTs are not needed for vehicles built or first registered more than 40 years ago provided no ‘substantial changes’ have been made to the vehicle in the last 30 years, for example replacing the chassis, body, axles or engine to change the way the vehicle works. This requirement was introduced in 2018 and replaced a previous legal position which exempted pre-1960 vehicles from the MOT test. It would be of interest to receive views on how the introduction of this change has worked and also whether the legislation or the guidance on this issue should be reviewed or updated.

Content of testing

We welcome views on the advantages and disadvantages of the current system of MOT testing and suggestions for improvement.

Environmental and emissions testing

Environmental emissions from petrol and diesel cars are a recognised health hazard because of their contribution to air pollution. Modern vehicles must meet stringent emissions standards before being placed on the market. The MOT test aims to check that cars continue to meet basic emissions requirements. As explained in Part 1, we are committed to strengthening the testing of emissions from diesel vehicles through the introduction of particulate number testing.

Whilst our proposals in Part 1 should significantly strengthen the testing of particulate emissions during the MOT, another pollutant of significant concern is NOx. The MOT test currently does not include a direct examination of the performance of NOx control systems on the vehicle and we understand that this can be difficult to fully assess without the engine under load. We would welcome any views or research on methods that could be applied within the MOT test to assess the performance of NOx control systems on both diesel and petrol vehicles.

Road transport is also a major contributor to emissions of carbon dioxide (CO2), a potent greenhouse gas (GHG). In 2020, road vehicles, consisting primarily of cars and vans, accounted for 21% of the UK’s total domestic CO2 emissions. Internal combustion engine (ICE) vehicles require the burning of fossil fuels, such as petrol or diesel, to operate. When burnt, this fossil fuel is converted into CO2 and other pollutants. It is widely understood that excess GHGs in our atmosphere, like CO2, are causing climate change.

Every new car and van sold is required to undergo emissions testing to establish how much CO2 it produces before it can legally be sold. The current test procedure is called the World Harmonised Light Vehicle Test Procedure (WLTP) and is conducted in official laboratories. Previous lab-based CO2 test procedures have demonstrated that the CO2 emission figures produced during the lab-based test procedure can vary significantly from real world CO2 emissions. This gap between lab-based and real world emission values has also been found to get worse over time. Therefore, there are challenges with the accuracy and reliability of using a lab-based CO2 test procedure, like the WLTP, for official CO2 results. The amount of CO2 produced is dependent on a number of factors including driver behaviour and environmental factors.

Since 2020 all new cars and vans sold are required to be fitted with on board fuel consumption devices. These devices can inform us how much fuel and/or energy is being consumed from ICE and hybrid vehicles. This data can then be used to calculate the actual CO2 emissions a vehicle has produced.

Understanding the level of CO2 emissions cars and vans produce in the real world, and how this can change over time, is vital in ensuring that the official lab-based procedures remain representative of real-world use, and therefore remain a useful tool that can drive CO2 emission reductions. We are seeking to understand whether the monitoring and recording of fuel/energy consumption data can be done via the MOT. This data collection exercise will be independent of the actual MOT procedure, will be fully compliant with UK General Data Protection Regulation (GDPR) requirements and will not feed into assessing whether a vehicle has passed or failed its MOT.

Vehicle noise also remains an issue of concern to many people. In addition to causing annoyance within communities, it can also have serious environmental health effects. Vehicles are required to meet strict noise limits before they are placed on the market and it is illegal to modify a vehicle’s silencer to make it noisier if being used on public roads. However, experience shows that some vehicles are fitted with noisier (or no) silencer and other modifications  that are noisier than desirable.

At MOT, vehicles are currently subject to a subjective examination of the noise level. The MOT could potentially be enhanced by a metered sound test, however, the environment within many MOT stations is likely to provide challenges for accurate and reproducible sound level measurement. For example, many garages have higher than average background noise levels or lack sufficient space to avoid interference from surfaces that might reflect sound. There is also a risk of nuisance to people living near an MOT testing station if changes increase noise levels produced by the centre.

We would be interested to get your views on what enhancements to the MOT could be made to tackle the issue of excessive vehicle noise and whether there are suitable technological solutions that would enable a metered sound level test to be undertaken in a typical MOT garage.

Vehicle disassembly

The current system is largely based on a visual inspection of the vehicle with some metered checks and does not allow vehicle disassembly. Many modern vehicles have panels fitted that can mean that safety critical items – such as exhaust after treatment components – cannot be inspected. Whilst it may seem straightforward to allow disassembly, it would make the test longer and, perhaps more significantly, could mean that fixings will be broken in the course of disassembly and/or panels will not be easily refitted – leading to potential damage to vehicles. We are keen to explore whether it is sensible to allow disassembly to ensure a robust examination – but if we do, how will we handle the issue of panels that are not easily removed or refitted or where fixings break?

Hybrid and electric vehicle testing

Hybrid and electric vehicles are an increasing presence on UK roads. This trend will accelerate as we move towards the phase out of the sale of new petrol and diesel cars and vans by 2030 and all new cars and vans being fully zero emission at the tailpipe from 2035. In 2021-22 there were more than 550,000 MOT tests on hybrid vehicles and 70,000 tests on electric vehicles.

There is now rapid uptake of electric vehicles meaning that more and more of these vehicles will be coming up for their first MOT in the next few years. In 2021, 327,000 plug-in vehicles (PiVs) were registered for the first time in the UK, an increase of 77% on 2020 and 303% on 2019. PiVs accounted for 14.7% of all UK new vehicle registrations in 2021.

Emissions from hybrid vehicles are not currently tested as part of the MOT. This is because of the practical issues involved in engaging the internal combustion engine rather than the battery pack in a garage setting. With hybrids becoming a larger proportion of the cars on the road, the lack of a check of the emissions performance of hybrids during MOTs is a significant issue which affects the ability to identify whether these newer vehicles are polluting or contributing to existing or new air quality issues. More information would be welcome on how these vehicles can be tested most effectively and any technologies that may facilitate this that could be tested in future. We are committed to working with manufacturers and other stakeholders to find practical solutions to this problem.

There are also other issues around these technologies that need further attention – for example a damaged battery could have safety implications if it fails in use. With ongoing technology advancements, data may increasingly be available to assess the health of the battery in an electric vehicle. Various companies are also exploring solutions to help assess and verify this state of health using an independent tool.’ The United Nations Economic Commission for Europe (UNECE) is carrying out work to consider requirements for accurate battery health monitors in vehicles. This could allow data to be accessible to owners or MOT centres. We welcome views on how the MOT should test the battery of an electric vehicle and other questions such as whether there are safety issues for MOT testers in dealing with these vehicles.

Zero emission vans are typically heavier than their petrol or diesel equivalents, due to the weight of their powertrains and to maintain their payload capabilities. This can take them over the current 3.5 tonne MOT testing threshold to about 4.25 tonnes. As a result, they are subject to the same roadworthiness testing as HGVs despite having the function and appearance of a van. Stakeholders are concerned that increasing uptake of zero emission vans, especially with rising demand in home deliveries, could apply pressure to heavy vehicle testing capacity. Whilst we would not want capacity pressures to stifle the transition to zero emissions, we need to assess the merits of increasing the MOT testing threshold against any safety considerations.

There is an increasing trend in vehicles that went into service with internal combustion engines being converted to electric. Initially this has tended to be for ‘high end’ vehicles, but it is becoming more mainstream. Such conversions require significant change to the vehicle mechanics – not just the power, but also systems such as braking and steering assistance may also need significant change. The government is considering whether something is needed to assure the safety of such conversions. The government is also considering whether there is scope to change the DVLA record to show the conversion has happened – potentially allowing the (currently) lower VED rate for electric vehicles, but such a change would ideally have some surety that the vehicle really had been converted. It has been suggested that the MOT could form a part of that solution. We are interested in views on such use of the MOT.

Vehicle safety recalls

DVSA oversees vehicle safety recalls. It ensures that manufacturers recall vehicles where safety or environmental defects have been found. Experience has shown that for some recalls – particularly as vehicles get older – the rectification rate is not as high as it could be, and this means that vehicles with potentially dangerous defects are still in use. At present having an outstanding (unrectified) vehicle safety recall is not an MOT failure.

Some data obtained from the trade is shared publicly as a part of the MOT History service (an on-line service to give the MOT history of vehicles) – but that data is not always up to date and is incomplete. The DVSA have been working to create systems where vehicle manufacturers can provide the DVSA data on vehicles that had recalls and still need to be fixed. This will enable DVSA to share this data on MOT documents, with MOT reminders and elsewhere. In time it could enable us to add an MOT failure for long-standing recalls that have not been fixed – but there are practical considerations that will need thinking through. We will be interested in views on this.

Vehicle crime and vehicle record integrity

One of the concerns about delaying the start of MOT testing beyond 3 years is that it might encourage an increase in mileage fraud (so that the odometer does not show the correct mileage) also known as “clocking”. It is a criminal offence to knowingly sell a car which has been “clocked”. The driver may not therefore have an accurate perception of how a vehicle has been used, and therefore its value – as mileage can provide a crude surrogate measure of how worn a car is, and therefore likely costs of repair or future servicing.

We welcome views on whether there would be benefits in introducing measures to reduce the likelihood of mileage fraud for example reporting mileages after servicing as well as part of the MOT test.

The MOT currently operates with a clear remit that testers should test “the vehicle in front of them” – whether that matches DVLA registration details or not. This approach minimises disruption to motorists should there be a mis-match in the record but it may sometimes be seen to “legitimise” stolen vehicles. It may also mean that opportunities are missed for government records to be updated where a vehicle has been very substantially updated. Examples have included vehicles converted to stretch-limousines that are still registered as ‘normal’ cars. In many countries a different approach is taken – where mismatches must be dealt with before a test can be conducted – ensuring the integrity of the government record and helping avoid some vehicle crime issues. We are interested in views on whether a change of approach would be worth considering.

Service to motorists

The MOT provides significant choice to motorists in Great Britain across 23,400 garages. This has advantages in making the MOT very accessible to the public. Furthermore, the fact that many MOT garages can also service and repair cars can provide a helpful ‘one stop’ service. However, the extent of the network can make test quality inconsistent, and there can be fraud in the system. The government is keen to identify ways that the system can be improved and ensure that these factors are balanced correctly.

To improve quality and reduce fraud, the DVSA has been rolling out equipment that automatically collects data in the test from the likes of brake testers and has piloted equipment that automatically photographs the test and identifies the vehicle.

However, whilst this type of equipment has these positive effects, it requires garages to invest. Currently, DVSA only requires that investment for new garages or change of ownership – effectively allowing ‘grandfather rights’ for most garages. This means that the rate of improvement is slow. Moving to a more aggressive roll-out would be positive for motorists but increase costs for garages – so we must think carefully about whether to do this.

DVSA conducts many enforcement checks at MOT garages and sometimes finds shortcomings in the quality of testing. The results of testing of individual testing stations are not currently published. DVSA is considering whether publishing the results of these could better drive good behaviours in garages by helping motorists know where to go for a good quality MOT.

Where DVSA does find problems with MOT testing it can take disciplinary action and, in very serious cases and/or those involving fraud, can elect to prosecute. In 2021/22 DVSA stopped 171 vehicle testing stations and 337 testers from testing. However, the rules of being an MOT tester or garage operator currently only allow a ban of up to 5 years. There have been cases where those found to have had serious wrongdoing do re-enter the scheme and start MOT testing again. There may be benefits in considering whether a more robust sanction scheme could improve how MOT testing is delivered. Options could include changing the length of the bans that DVSA can apply or, as is done in a number of other countries, preventing MOT testing being done from a garage site that has been used for fraudulent MOT activities.

At present where DVSA do find that an MOT was done incorrectly, then the previous (incorrect) MOT result still stands. The only exception to this is where a ‘reasonable’ MOT examination has clearly not been conducted and then  DVSA will correct its electronic record of MOTs by removing that MOT result. This situation could be confusing for a motorist wishing to buy a car where it may have a valid MOT showing – even though the DVSA have subsequently found that the vehicle did have defects that mean it should not have been issued with the MOT. We may therefore want to consider whether additional powers should be sought to allow DVSA to correct MOT results – including more routinely revoking MOTs that were issued incorrectly.

MOT approval criteria for garages and their testers are wholly focused around the technical delivery of the MOT, and do not consider wider factors such as customer service, value for money and wider service offerings. Feedback from motorists suggests that many motorists would like a system that better helps them know which garages are ‘good’. ‘Good’ in this context means more than just consistent delivery of the MOT. We must consider whether it is sensible to broaden the remit of what DVSA looks at to include these other factors, – so a more rounded view of the garage can be given to the public. Or whether the current focus on the test itself is right.

DVSA currently produces MOT reminders to help motorists get their MOT on time. However, over 30% of MOTs are still late. We are interested in ways of encouraging more motorists to get their MOT completed on time. For example, to encourage compliance, automatic penalties could be imposed for drivers of vehicles identified by cameras as using a vehicle without an MOT. However, this would not be straightforward to implement because, even if a vehicle has failed its MOT, drivers may legally drive the vehicle if their existing MOT certificate is still valid or, if the MOT has run out, to take the vehicle to have the failed defects fixed/ a pre-arranged MOT test. In such cases, the vehicle still must meet the minimum standards of roadworthiness at all times.

DVSA makes MOT results public through an online service – and this data is also available in bulk through an application programming interface (API). This data is available in real time – so users can see the data straight away. These services have proved very popular – for example for people considering whether to buy a particular car, but also to enable users of vehicles to check on their MOT status. They also largely make the paper MOT certificate unnecessary. We would welcome views on whether there is more DVSA can do in terms of making data available to achieve public good and whether a more formal move away from paper certificates could help combat fraud.

Service to garages

As well as conducting enforcement on MOT checks, DVSA also provides services to MOT garages in authorising new businesses, premises (garages) and testers.

To become an MOT tester, we have a system where a prospective tester must have a formal qualification in being an MOT tester – which will follow accredited training. In 2021 DVSA approved 577 new vehicle testing stations and 3915 new testers. Once an MOT tester is approved by DVSA – which involves DVSA witnessing their ability to test – a tester must complete annual development each year and pass an official exam. They have discretion over how this development is done. This process has been in place now since 2014, and there may be value in considering whether this process is still fit for now and the future. That consideration could consider the general approach – and we can look at schemes in other sectors (such as Driver CPC) and see if a more analogous approach would work better.

If we amend the MOT test to reflect technological innovation and the growth in green vehicles, testers will need to be trained in these changes. DfT’s Transport Labour Market and Skills Call for Views and Ideas, published in February 2022, sought views on the key issues for skills and the transport workforce. Many responses referred to the importance of adapting to technological change and taking advantage of the jobs and skills opportunities this creates. Electrification, green skills, digital and STEM were highlighted as areas of both challenge and opportunity for the transport sector. Alongside this, DfT set up a new industry-led taskforce, the Transport Employment and Skills Taskforce (TEST), made up of senior skills and employment experts from across the industry to identify future skills needs. It will address the challenges facing the industry and develop interventions to ensure we have a highly skilled, diverse workforce that is fit for the future. We would welcome views on how best to ensure MOT testers receive the critical training needed for test changes.

All of DVSA work is funded from a ‘slot fee’ that is charged for each test pass. This means that work DVSA does for authorisations of testers and garages is also funded in this way – so can ‘feel’ free to the immediate customer of that work. This could mean that insufficient preparation is put into that process. Changes to that regime could drive better behaviours and higher standards.

DVSA conducts a range of activities to support garages in testing to the right standards. That includes providing advice during enforcement visits, having a technical helpline for testers and designing the MOT digital service to try and help testers work to the right standards. However, DVSA recognise that there may be more and different ways that garages can be supported and would, again, welcome views on where this can be improved.

It is recognised that the majority of garage businesses are keen to work with DVSA as delivery partners for doing MOTs – and share common values in maintaining vehicles in safe condition. Unfortunately, there are a few garages in the system that do not work collaboratively with government. This can undermine the good reputation of the MOT system – and can undercut those that are trying to do the job right. Whilst there is no ‘right’ level for enforcement, it will be helpful to get a sense of whether those in the business feel that current levels and approaches to enforcement do protect those who do things right.

Costs and fees

For the MOT to keep pace with modern technology and to provide motorists with excellent service, it is important that we have an environment that encourages and facilitates investment in MOT stations. Additional or different testing requirements have the potential to increase the costs to garages. The maximum amount that a garage can charge for an MOT test has not changed since 2010 compared to a rise in CPI of about 34% between July 2010 and July 2022. If the maximum MOT fee had risen in line with this increase in CPI, it would now be £73.50. In practice, MOT testing is a highly competitive market and many MOT testing stations charge less than the maximum – often in the £35-45 price range. Whilst this may be good for consumers, it can put pressure on garages to test quickly or cut corners.

This consultation has suggested future changes to the MOT test might be made that would require investment by garages. DVSA has implemented previous changes that have required substantial new garage equipment by initially making them optional for garages. Garages that did not invest were not able to test vehicles that required that equipment. For example, this was done when diesel smoke metered test and catalytic convertor emissions test were introduced. That smoothed the investment profile for garages – but did mean that some motorists had to travel further.

We welcome comments and evidence from the MOT testing sector and others about the cost implications of changes to testing and whether changes are needed to the level of current MOT fees or to the basis of costs (for example, on whether the MOT fee cap should remain a maximum limit or should it become a guideline).

Longer term

The review will consider whether in the future it will still be appropriate to test roadworthiness periodically based on time (that is, annually), or if another model may be more effective. For example, as the fleet evolves and user-habits change, whether it would be more effective to monitor vehicle roadworthiness based on vehicle mileage or use. Such a change would present both challenges and opportunities in terms of vehicle taxation, which it will be important to consider.

For the long term, it will be necessary to look ahead to technologies and approaches that will be deployed in the vehicles of the future. There is already an increasing deployment of advanced driver-assistance systems (ADAS) to assist drivers with the potential that some new elements will be mandated for new vehicles in the future.

There is strong evidence that an increasing number of new vehicles contain some ADAS features as standard meaning that they will become more common as the vehicle parc is updated. Safety-related ADAS include pedestrian detection/avoidance, lane keeping assistance, traffic sign recognition, automatic emergency braking, blind spot detection, and driver monitoring systems. Drivers increasingly make use of such systems and need to have confidence that they are continuing to work as designed, or risk serious road safety incidents. ADAS systems differ from vehicles with self-driving features as they are intended to assist and support but the driver must still be engaged in the driving task. While these features can be very helpful from a road safety perspective, it is important that they function and are calibrated correctly.

At present ADAS systems, and even their terminology, are not standardised. This makes it difficult to assess accurately what percentage of vehicles are already fitted with such devices. However, internationally there is increasing consideration of how they should be regulated, and it is reasonable to expect that in future there will be further regulation in the UK. For instance, vehicles could be failed initially on an MOT if significant safety systems, like automatic emergency braking, are shown to be malfunctioning. The review of MOT testing will consider how government can be best placed in future to react to regulatory developments and the need to assure ADAS systems on an ongoing basis. This will include considering the role of garages and their relationship with vehicle manufacturers who produce, and through the software, have an ongoing role in a vehicle’s ADAS systems. We are particularly keen to work with industry and manufacturers on this so that the review can ensure that these technologies are properly maintained and tested.

Self-driving vehicles

Self-driving vehicles are those that are capable of driving themselves in at least some circumstances without the need for a driver to monitor or control the vehicle. Some self-driving vehicles may need a driver some of the time because they can only drive themselves on a motorway, others may never need a driver. The development and deployment of these vehicles has implications for a range of vehicle safety measures, including the MOT. Questions about responsibility for safety and roadworthiness must be considered, in particular for vehicles that never have a driver.

In January 2022, the Law Commission of England & Wales, and the Scottish Law Commission (“the Law Commissions”) concluded a multi-year review of the law relating to self-driving vehicles and made a series of recommendations to government. The review recommended that new legal entities should be created to support the clear and fair division of responsibilities for driving and other vehicle-related issues. The government’s response to the recommendations was published in August 20221. The department is developing a regulatory framework for self-driving vehicles based on the recommendations of the Law Commissions.

The government proposes to create new legal entities including:

• the authorised self-driving entity (ASDE), which will be responsible for the safe behaviour of a self-driving vehicle when it is driving itself throughout its lifetime, and

• the no-user-in-charge operator (NUiCO), which will be responsible for non-driving tasks such as insurance, roadworthiness, securing loads for vehicles that require no driver. Where the vehicle retains a driver some of the time, these non-driving tasks will be picked up by this individual, as is the case today.

Until such time as new legislation is passed, registered keepers and/or operators of self-driving vehicles will be responsible for their roadworthiness and MOTs. Once regulations enable the creation of new legal entities, these responsibilities will apply to the driver or the NUiCO.

The Law Commissions concluded that ‘existing roadworthiness offences should continue to apply to the [driver or NUiCO] but highlighted the importance of regulation allowing these offences to apply to the ASDE at a later date.

Development of more sophisticated self-driving vehicles and more effective self-diagnostic systems may also enable a degree of ‘self-testing’. As this ‘self-testing’ capability develops, it may become increasingly difficult for the driver, or an operator of the vehicle, to bear responsibility for the vehicle’s roadworthiness. The ASDE might have a better understanding of the vehicle’s roadworthiness such that it is simpler and safer to hold the ASDE responsible.

However, this ‘self-testing’ functionality may be limited to certain systems. It is difficult to see how a vehicle’s tyre tread could be assessed reliably by an onboard system without human involvement. Even once self-testing becomes a reality, it may not be appropriate to transfer full responsibility for roadworthiness to the ASDE.

The Centre for Connected and Autonomous Vehicles (CCAV) CAVPASS programme is examining these issues, alongside others related to the safety and cyber security of vehicles with self-driving features. A better understanding of the likely future scenarios will improve future legislation. This may impact how and in what way we should test these vehicles and who is accountable for this. We would be highly interested in views on this.

Consultation questions

General

1. Are you responding as:

• an individual or
• on behalf of an organisation?

2. (For individuals) Do you have a vehicle or vehicles that require MOT testing?

• yes
• no

3. What vehicle are you referring to during your response?

• motorcycle
• car
• van
• other

4. (For organisations) what is the size of your business by the number of employees?

• 1-9
• 10-49
• 50-249
• 250+

5. Do you work or own a company that carries out MOT testing?

• yes
• no

Questions relating to part 1: Changing the date of the first MOT and other proposals for change in 2023

For all respondents

1. In your view, should the date of the first MOT

• remain at 3 years
• move from 3 to 4 years
• move from 3 to 5 years

2. Please explain why you hold this view.

3. In your view, should changes be introduced alongside changing the date of the first MOT test to mitigate any effects on road safety (for example, re brake and tyre wear) or polluting emissions

• additional safety information campaigns for drivers
• additional odometer checks)?
• DfT publicity to ensure that motorists keep their vehicles safe ahead of the date of first MOT test?
• ensure vehicle service packages include items that are also covered in the MOT
• other (please specify)

4. As part of this package of change, we are proposing to move to particulate number (PN) testing as a more robust emissions assessment for modern diesel vehicles. Do you believe that this is the correct approach, and why?

5. Do you have any views on how we should implement PN Testing (likely to be post 2013 diesel engine vehicles) such as phasing in the requirement for garages to invest in PN testing equipment?

For companies that carry out MOT testing

6. How would your business be affected by changes to the date of the first MOT test?

7. To what extent is it fair to assume that any fall in the number of MOTs will free up garage staff and allow them to complete other tasks?

• completely unfair
• unfair
• uncertain
• fair
• completely fair
• don’t know

8. To what extent does your business rely on MOTs for custom?

• completely reliant
• somewhat reliant
• not reliant
• don’t know

9. Do you have staff purely dedicated to MOT testing?

• yes
• no
• don’t know

10. If yes, what percentage of your employees are only MOT testers?

For individuals who own cars, motorbikes and vans

11. How do you usually seek your vehicle’s annual servicing and MOT?

• my vehicle gets serviced and its MOT together
• my vehicle gets serviced and its MOT at different points
• I don’t usually get my vehicle serviced
• unsure

12. To what extent would you continue to undertake servicing of your vehicle annually despite not being prompted to by an MOT?

• very unlikely
• unlikely
• uncertain
• likely
• very likely

For businesses with a vehicle fleet

13. How would your business be affected by changes to the date of the first MOT test?

Questions relating to part 2: Call for evidence on changes to MOT testing

General

1. What do you think are the advantages of the current system of requiring vehicles to undergo an annual MOT test:

• road safety
• environmental protection
• fewer breakdowns
• other advantages
• there are no advantages
• unsure

2. Why do you hold this view?

Frequency of testing

3. In your view, should MOT tests for cars be required:

• annually (from the time the car is 3 years old)
• every 2 years (from the time the car is 3 years old)
• every 2 years (from the time the car is 3 years old up to 10 years and annually thereafter
• other (please specify)?

4. Please could you explain your view further? (150 words max)

5. In your view, should MOT tests for motorbikes be required:

• annually (from the time the motorbike is 3 years old)
• every 2 years (from the time the motorbike is 3 years old)
• every 2 years from the time the motorbike is 3 years old up to 10 years and annually thereafter
• other (please specify)?

6. Please could you explain your view further? (150 words max)

7. In your view, should light goods vehicles up to 3.5 tonnes be required:

• annually (from the time the vehicle is 3 years old) that is, no change
• every 2 years from the time the vehicle is 3 years old
• every 2 years from the time the vehicle is 3 years old up to 10 years and annually thereafter
• other (please specify)

8. Please could you explain your view further? (150 words max)

9. What effect do think that any move to less frequent MOTs could have on:

• road safety
• the environment
• vehicle crime
• consumer protection
• any other factor
• I can’t think of any effects of having less frequent MOT testing

Please provide any evidence that supports your view.

10. If MOT frequency is reduced, to what extent do you think vehicles are more or less likely to be maintained to legal standards:

• much more likely
• more likely
• no change
• less likely
• much less likely
• don’t know

11. Why do you think this (include any evidence that supports your view)? (150 words max)

12. In your view, if you believe that your vehicle had a fault, either through a warning light or your own knowledge, before it’s MOT due date, how likely would you seek a repair of your vehicle?

• very likely
• likely
• unsure
• unlikely
• very unlikely
• don’t know

13. What measures should we introduce to mitigate the risks of less frequent MOT testing (tick all the choices that reflect your view)?

• allowing testers to remove panels to check that vehicle emission reduction systems in traditional (internal combustion engine) cars are present and in working order or to identify other safety issues
• service reminder at 2 and 3 year licensing point
• changes to MOT advisories for brakes and tyres (where a tester warns the owner of issues which need attention but are not severe enough to mean an MOT failure)
• communications from government with vehicle tax reminders about significance of servicing, tyre and brake reminders
• I don’t consider there to be any increased risks of less frequent MOTs so therefore no mitigations are required
• other (please specify)

Testing of specific vehicles

14. How does the MOT (or other roadworthiness testing) need to change to accommodate the differences between electric and hybrid vehicles and traditional internal combustion engine vehicles?

15. If garages only wish to maintain and test electric vehicles, do you think we should allow authorisation without the equipment needed for testing internal combustion engines?

16. Goods vehicles typically have higher mileage than cars / motorbikes and will therefore have more wear and tear, what specific mitigating measures for large vans should we consider? (for example, MOT tests for vans could be required every 50,000 miles)

17. In your view, should the exemption for historic vehicles need to be reviewed? Why?

Content of testing

18. What changes do you think should be made to elements of the current MOT test for cars, motorbikes and vans? This could be elements that should be added to or removed from the current test or tested in other ways:

• alternative ways of testing the main failure items such as brakes and tyres
• other actions to ensure the emission control technology fitted to cars is operating correctly
• enhanced testing of noise emissions
• testing of window tinting
• change approach on advisory standards (tyres, brakes near safety critical levels)
• other (specify)

19. Please explain the reasons for the change you suggest .

20. Are there methods that could be applied at the MOT test to assess the performance of NOx control systems on petrol and diesel vehicles?

21. Should we use the MOT to collect fuel and energy consumption data on cars and vans to help understand what CO2 emissions are being produced in the real world? (This will not impact on whether a vehicle passes or fails its MOT). Explain with clear reasoning why you are for or against this proposal.

22. What enhancements to the MOT could be made to tackle the issue of excessive vehicle noise and are there suitable technological solutions that would enable a metered sound level test to be undertaken in a typical MOT garage?

23. Do you agree with including hybrid vehicles within scope of MOT emissions testing? Please explain the reasons for your answer.

24. How can the emissions of hybrid vehicles be tested effectively at the MOT test given that their engines will not always be active in a stand-still position?

25. Should we explore options for assessing the health of an electric vehicle-specific components, for example, battery, motor?

26. Due to their heavier powertrains, should the current 3.5t weight limit for MOTs be increased to 4.25t for zero emission vans, removing the need for them being subject to HGV testing? Please explain your reasoning.

27. Should EV conversions (also known as retrofit) be checked at an MOT to verify that an EV conversion has taken place - enabling the DVLA to verify a conversion prior to amending the vehicle record (and VED rate). If this was introduced, do you think the check should be extended to check the safety of any conversion – in which case do you think additional training would be needed to ensure safety for MOT testers?

28. In your view, should we use the MOT to encourage drivers to have faults on recalled vehicles rectified?

29. Do you think we should move to failing vehicles at MOT where the vehicle has a longstanding recall that has not been rectified?

30. Do you think DfT should take additional measures to combat mileage fraud? If so, what should those be?

31. Do you believe that any apparent mismatches between the government licensing record for a vehicle and the vehicle presented for an MOT test should be dealt with before an MOT test is carried out? Explain your reasoning.

32. What approaches could be used to roll out of changes to the test where significant investment is required by MOT garages in new equipment or training?

Improving the MOT service

33. Do you believe that fraud in the system is a problem? What evidence or data do you have to support that view, and, if it is a problem, do you have any proposed solutions?

34. Should garages be required to have:

• equipment that automatically collects data in the test from the likes of brake testers
• take photographs at the test that identifies the vehicle (and share this with DVSA)?

35. How could investment in data collection and/or photographic equipment be encouraged (for example, DVSA could publish information on which garages have such equipment thereby encouraging consumers to prefer those garages)?

36. Do you think that the results of DVSA enforcement checks at MOT garages should be published to help motorists make informed choices on where they have their vehicle tested?

37. Do you think DVSA approvals of MOT garages should consider non-technical factors such as service to the consumer and wider service offerings?

38. Do you think government should do more to drive compliance with getting an MOT on time? What do you suggest and why?

39. Do you think the penalty levels for wrongdoing of MOT garages and testers should be more severe? Should other options be considered – such as banning MOT testing at a site where serious wrongdoing as occurred?

40. Where MOTs have been found to be done wrongly – do you think DVSA should be able to correct the record – including revoking MOTs incorrectly issued?

41. Do you have ideas for more MOT data that could be shared and what benefits it may bring?

Services to garages

42. Do you think the current approach to training and assessment for MOT testers works as well as it should? How can it be improved?

43. Do you think the approach and level of enforcement is right for keeping the MOT industry standards where they should be – and avoiding those that do the job right being undermined? How could the system be improved?

Costs and fees

44. Do you think the current regime encourages and facilitates investment in MOT testing stations? If not, what changes could improve this?

45. How might any negative effect on investment in MOT testing stations caused by reductions in MOT frequency be mitigated?

46. Evidence on the costs of any changes to the content of testing would be welcome.

Longer term

47. What alternatives might there be to assure roadworthiness of cars, vans and motorbikes that might replace or supplement the MOT?

48. To what extent do you agree/disagree with the following statement “the MOT system needs to change to include tests of new features/types of vehicles for example Advanced Driver Assistance Systems (ADAS)”

• strongly agree
• agree
• neither agree nor disagree
• disagree
• strongly disagree

49. Please could you explain your view further? (150 words max)

50. Should a vehicle fail an MOT if an ADAS safety feature, such as Advanced Emergency Braking (AEB), is indicated as malfunctioning by the vehicle? If so, should this be only for mandated features or include features fitted voluntarily?

51. In the longer term there could be the potential to use data from vehicles to continually monitor key roadworthiness features. At such a point do you still think that the periodic inspection of a vehicle is necessary?

52. Do you think automated systems could enable all safety critical systems and components to be checked without garage inspection?

53. What would a test for hydrogen powered vehicles need to look like?

Vehicles with self-driving features

54. At what point could the Authorised Self-Driving Entity (ASDE) take on responsibility for roadworthiness requirements, and for what elements should it be responsible?

55. What should the MOT test on vehicles with self-driving features, and how should these be tested?

56. Do any elements of the testing of self-driving features need to be addressed through a different mechanism?

What will happen next

A summary of responses, including the next steps, will be published within 3 months of the consultation closing on this page. Paper copies will be available on request.

If you have questions about his consultation, please contact:

MOT411consultation@dft.gov.uk

Annex A: Consultation principles

The consultation is being conducted in line with the government’s key consultation principles which are listed below. Further information is available at https://www.gov.uk/government/publications/consultation-principles-guidance

If you have any comments about the consultation process, please contact:

Consultation Co-ordinator

Department for Transport

Zone 1/29 Great Minster House

London SW1P 4DR

Email consultation@dft.gsi.gov.uk

How to respond

The consultation period began on 18 January 2023 and will run until 22 March 2023. Please ensure that your response reaches us before the closing date. If you would like further copies of this consultation document, it can be found at https://www.gov.uk/dft#consultations or you can contact MOT411consultation@dft.gov.uk if you need alternative formats (Braille, audio CD, etc.).

Electronic responses to this consultation would be preferred either by:

• responding to the online survey
• emailing your response to MOT411consultation@dft.gov.uk

If you are unable to respond electronically you can provide a response to the postal address of:

MOT Consultation

3rd Floor, Zone 19

Great Minster House

33 Horseferry Road

London SW1P 4DR

When responding, please state whether you are responding as an individual or representing the views of an organisation. If responding on behalf of a larger organisation, please make it clear who the organisation represents and, where applicable, how the views of members were assembled.

Freedom of Information

Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the Freedom of Information Act 2000 (FOIA) or the Environmental Information Regulations 2004.

If you want information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a statutory Code of Practice with which public authorities must comply and which deals, amongst other things, with obligations of confidence.

In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information, we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the department.

The department will process your personal data in accordance with the Data Protection Act (DPA) and in the majority of circumstances this will mean that your personal data will not be disclosed to third parties.

Data Protection

The Department for Transport (DfT) is carrying out this consultation to gather evidence on MOT testing. This consultation and the processing of personal data that it entails is necessary for the exercise of our functions as a government department. If your answers contain any information that allows you to be identified, DfT will, under data protection law, be the Controller for this information.

As part of this consultation, we’re asking for your name and email address. This is in case we need to ask you follow-up questions about any of your responses. You do not have to give us this personal information. If you do provide it, we will use it only for the purpose of asking follow-up questions.

DfT’s privacy policy has more information about your rights in relation to your personal data, how to complain and how to contact the Data Protection Officer. You can view it at https://www.gov.uk/government/organisations/department-for-transport/about/personal-information-charter.

To receive this information by telephone or post, contact us on 0300 330 3000 or write to:

Data Protection Officer

Department for Transport

Ashdown House

Sedlescombe Road North

St Leonards-on-Sea

TN37 7GA

Your information will be kept on a secure IT system within DfT and destroyed within 12 months after the consultation has been completed.

1. Internal analysis based on STATS19 data. ↩