Consultation outcome

Ukraine driving licence exchange

Updated 7 July 2023

Applies to England, Scotland and Wales

Foreword

The UK led the way in supporting Ukraine. Until the conflict is resolved, we will continue to do so. My department has been actively engaged in making the transition to life in the UK as seamless as possible for those arriving here under such difficult circumstances. Initiatives such as the Free Onward Travel Scheme have all made it easier for Ukrainians to travel and settle into UK life.

We recognise, however, that continuing this transition is not always straightforward, and one area where Ukrainian arrivals have to adapt is in motoring. The continued ability of Ukrainians to get around is integral to integrating, socialising, accessing healthcare and working during their time in the UK.

That is why we are proposing extending beyond the current 12-month period the time during which the holder of a Ukrainian driving licence is able to drive cars in Great Britain on that licence after the holder becomes resident. We are proposing an extension to match the current extended visa, to 3 years (36 months), at which point they would need to go through a UK driving test.

We recognise that this might have an impact, might not be the correct length of time and welcome feedback on the appropriate length of time. We are inviting comments on this proposal and providing the opportunity for consultation responders to also comment on whatever considerations they would like to provide on this proposal.

Richard Holden MP
Parliamentary Under Secretary of State

Introduction

The UK has been playing a leading role in supporting Ukraine and we will continue to do so until the conflict with Russia is concluded. The Department for Transport has been actively engaged in making the transition to life in the UK as seamless as possible for those arriving here under these difficult circumstances.

As part of this, we are proposing to extend beyond the standard twelve-month period the time during which the holder of a Ukrainian driving licence is treated as the holder of a licence authorising the driving of cars in GB after the holder becomes resident so that it matches the visa length they have been given (the Family, Sponsor and Extension visa schemes have all been given 3-years lengths). This will improve Ukrainian licence holders’ ability to get around and adapt to living in the UK as they will not need to exchange their licence or take a further test during the extended period in order to continue driving a manual car including any such vehicle, they brought with them to GB.

In Great Britain, we allow all those driving on non-UK, non-EEA driving licences who become resident, 12 months before we require them either to exchange their licences if eligible, or to take a driving test in order to continue driving here. As with some other countries, Great Britain has a driving licence exchange agreement with Ukraine, and Ukrainian driving licences can be exchanged for GB licences. However, only Ukrainian licences issued after 28 December 2021 specify the type of vehicle transmission that a driver passed their test in. Therefore, licences that were issued prior to this date can only be exchanged for a GB licence which restricts the driver to driving automatic vehicles. For those Ukrainians with licences issued before this date, to obtain a GB manual licence they must take a GB manual test.

This is a particular issue for those who have brought manual vehicles with them to the UK and may lose the right to drive them, despite planning to return home to Ukraine when it is safe to do so. Given the exceptional and temporary nature of Ukrainians’ residence in the UK under the Ukrainian Visa Schemes, the government is proposing to extend the current 12-month period of time during which the holder of a Ukrainian driving licence is treated as the holder of a licence authorising the driving of cars in GB.

The effect of this would be to extend the period of time after which a Ukrainian licence holder must exchange their licence, from the current 12-month period. This consultation seeks views on this proposed extension, sets out options for the length of the extension and provides the opportunity for other comments. This change can be made by secondary legislation.

The issue

For the first 12 months of being resident in GB, Ukrainians are able to use their Ukrainian licence in GB to drive all classes of small vehicles authorised by that licence, both automatic and/or manual vehicles (car), unless the licence shows a restriction.

In May 2021, legislation was put in place to allow a Ukrainian car licence to be exchanged for a GB licence without the need to take a GB driving test. This followed Ukrainian testing standards being assessed as equivalent to those in GB by the Driver and Vehicle Standards Agency. However, the law only allows drivers who took a test in Ukraine before 28 December 2021 to be issued with a GB licence to drive vehicles with automatic transmission when their Ukrainian licence is exchanged. This is because the Ukrainian driver licensing authority does not retain information to confirm whether a test was taken in a manual or automatic vehicle before this date.

A Ukrainian licence holder who exchanges their licence for a GB licence but is restricted to driving automatic vehicles, can upgrade this by taking a manual practical test for which they would not be required to pass a GB theory test.

The current requirement for a holder of a Ukrainian driving licence who is resident in GB to exchange it for a GB licence after 12 months to continue driving without passing a GB test, has specific impacts on Ukrainian licence holders who have arrived as part of schemes to provide refuge from the current conflict.

The restriction to entitlement to drive vehicles with automatic transmission is not unique to the exchange arrangement for Ukrainian licence holders. It is also applied to driving licence exchange arrangements with other countries that do not hold information to confirm the type of vehicle in which a test was taken. However, evidence from representations received by the Department for Transport and its agencies suggests that a number of those arriving here because of the conflict have fled with their own car.

The Ukrainian licencing authority, until 28 December 2021, did not record the transmission of the vehicle presented for test and would award a successful test candidate for both manual and automatic vehicles. This information is now recorded, and a successful test candidate is awarded either an automatic licence or manual licence. Many of these licence holders own a car with manual transmission.

In these circumstances, the requirement to exchange and the issue of a GB licence restricted to vehicles with automatic transmission, means the majority of individuals would no longer be able to drive their vehicle in GB.

To continue driving, they would need to either dispose of their existing car and incur the cost of acquiring a new vehicle with automatic transmission or incur the £62 cost of a GB manual driving test. This would be in addition to the £43 cost of exchanging their Ukraine licence and assumes a first-time pass. Evidence from representations also suggests that even those without their own car may on exchange lose the ability to drive cars they have been given use of by their hosts.

These issues are of course faced by other holders of foreign licences living in GB, including asylum seekers and refugee groups. However, the circumstances of Ukrainians in GB because of the conflict may be distinct. It is unlikely that large numbers from other refugee groups will have arrived in GB with their own car and, unlike those who have come to live in GB for other reasons (e.g. to take up employment or join family), Ukraine licence-holders fleeing the conflict are unlikely to have had the opportunity to plan for the driving licence issues they now face.

Also, typically those arriving under the Ukraine visa schemes (Family, Sponsor and Extension) are allowed to stay for up to 3 years with the intention that they return to Ukraine as soon as circumstances allow. Other schemes such as the Afghan Citizens Resettlement Scheme and the British National Overseas Visa Scheme for those from Hong Kong provide for the applicant to remain permanently.

In this context, the requirement to exchange a Ukrainian licence and then apply for its reinstatement on return to Ukraine (exchangeable driving licences have to be surrendered on application for a GB licence and, if exchanged, are returned to the issuing authority) represents a potentially unnecessary burden. Any Ukrainian that stays in GB beyond the time period of their Ukraine scheme visa and who had passed their test in Ukraine before 28 December 2021 would be expected to then undergo a manual practical test should they want a manual entitlement licence.

Proposed intervention

The government is proposing to extend the period of time during which the holder of a Ukrainian driving licence is treated as the holder of a licence authorising the driving of cars up to 3,500kg in GB. And, therefore, the time after which a Ukrainian licence must be exchanged for a GB licence if the Ukrainian licence holder wishes to continue driving in GB without taking a test.

This period of time is currently 12 months after the licence holder becomes resident. This consultation seeks views on this proposed extension, sets out options for the length of the extension and provides the opportunity for other comments. We are not seeking to allow them to drive on their Ukrainian licence indefinitely. This change can be made by secondary legislation.

We are provisionally proposing that this increase should match the length of the visa they have been given (Family, Sponsor and Extension visa schemes), increasing the period from the current 12 months (1 year) to 36 months (3 years). This would allow Ukrainian licence holders to continue using their Ukrainian licence in GB for a longer time period, or, up to the point in time at which they either leave the UK or their visa expires.

This extension would only apply to Category B (Car). Licences in other categories are not being considered at this time.

Questions

The following questions are included here so you can read them in the context of this document. To respond to the questions, see the Ways to respond section of the GOV.UK home page for this call for evidence.

Question

Do you agree or disagree with our proposal of extending the eligibility period of time for which Ukrainian licence holders, arriving from the Russian conflict, may drive cars within GB?

Question

Beyond the existing 12 month entitlement what length of time do you think is appropriate for this extension?

• up to 12 months
• greater than 12 months but no more than 24 months
• greater than 24 months but no more than 36 months
• the full Ukrainian scheme visa period of a maximum of 36 months
• another time period greater than 36 months (in months)

Rationale and potential impacts

Requiring Ukrainian refugees to get a GB driving licence when they already have a Ukrainian licence introduces an administrative and financial burden to Ukrainian arrivals, that could impact on their integration into GB and the ability to continue their lives smoothly (i.e. access employment, education, and health opportunities). To note, this does apply to other refugee groups who also face this barrier.

This requirement introduces processes that are potentially unnecessary for Ukrainians in the short term, given their stay in GB is not expected to be permanent. However, where a Ukrainian national stays in GB beyond their initial Home Office issued visa (potentially under indefinite leave to remain), they will be expected to follow standard processes to exchange their licence for a GB one.

The current requirement also makes it potentially more challenging for Ukrainians who have a driving related job or who need to drive in order to get to work from working for a short period of time (however, this might be offset by employers resolving this issue for their Ukrainian drivers), or for a longer period of time if they cannot afford the fees associated with getting a GB driving licence. Likewise, any Ukrainian who brought a manual vehicle to the UK, may face the additional burden of not having the right to drive it after 12 months. They could also potentially illegally drive in GB if they are unaware of this requirement.

The proposal would potentially remove the financial and administrative burden of licence exchange and issues relating to the restriction of GB driving entitlement to the driving of vehicles with automatic transmission. This is in line with the UK government’s aim to take action to reduce bureaucracy and support Ukrainian nationals wherever possible both during their time in the UK and to make returning to Ukraine as straightforward as possible.

There are, however, risks that by extending the period of time during which a Ukrainian licence holder is treated as the holder of a licence authorising the holder to drive cars in GB, motor insurance providers refuse to offer motor insurance or charge higher premiums to Ukrainian drivers that do not exchange their licence, as this is a risk that insurers have never previously priced against. Of course, treating Ukrainian licence holders as the holder of a licence authorising the driving of cars in GB for a longer period after becoming resident would not preclude them from choosing to exchange their licence earlier.

An extension could be argued to pose additional road safety risks, particularly given the issue around the unknown nature of tests for licences issued before 28 December 2021. However, compared to many other foreign licences, there is some reassurance in the fact that Ukraine’s driving test and licensing standards have been assessed as equivalent to those in GB and the right to use the licence will remain time limited in the line with the temporary nature of their intended stay.

The extent of potential benefits and risks is difficult to assess as exact numbers of Ukraine licence holders in GB is unknown. Figures obtained from DVLA driver records on 7 January 2023 show that from May 2021 to December 2022, 8,335 Ukraine driving licences were exchanged for a GB one. Of these, 4,961 were in the period following the Russian invasion from March to December 2022.

Figures published on 12 January 2023 show 155,500 Ukrainian nationals have so far arrived in the UK under one of the visa schemes and 23,000 have been granted an extension to an existing permission to stay because of the conflict. It is possible though that a significant number of these hold a Ukraine driving licence and could, under current rules, be approaching the point where they need to obtain a GB licence and so could benefit from an extension.

Also, if an extension is applied only to Ukraine licence holders, there is a potential for confusion for enforcement given the existing provision applies to all foreign licences issued outside the EEA and regardless of whether they are exchangeable or not. Any extension for Ukraine licences would need to be clearly communicated given that they would be treated differently, and the 12-month rule would remain in place for all other foreign licences.

It is possible that some Ukraine licence holders who are resident in GB are not here as part of the schemes (Family, Sponsor and Extension visa schemes) designed to give temporary refuge for those displaced by the conflict. However, it is expected that numbers will be low.

Road safety considerations

The longer the conflict goes on in Ukraine, the longer arrivals will remain here and as weeks pass into months, so too will Ukrainians want to build some semblance of normality in their day to day lives. This will include working, getting around and travelling for leisure activities. Our rules on treating holders of foreign licences as holders of licences authorising driving in GB are designed predominantly for visitors or to give those who have moved to GB a generous grace period to sort out getting a GB driving licence (either via the test route, or exchange if eligible).

Without a GB test or licence, there is a risk from unfamiliarity with GB roads (driving on the left, using a right-hand drive car) and road signage, particularly from road signs which are written in English (rather than pictograms) which could increase the exposure of the number/frequency of crashes. Especially as we would expect more Ukrainians to want to drive the longer, they are with us.

However, it could be that the period of greatest risk is when they are first in GB, when they are already permitted to drive using their Ukrainian licence. In cases where a driving test in a manual vehicle is required after 12 months after becoming resident, there is the opportunity for an examiner to fully assess the driver’s capabilities on GB roads. If skills are not up to the required standard, then they would not be granted a GB manual licence. Any delay therefore to this testing opportunity could be seen by some to constitute a road safety risk.

There is also a risk that roadside enforcement may be negatively affected by extending the length of time the Ukrainian licences may be used in GB. For example, if the twelve-month period is extended, this could lead to Ukrainian driving licences being considered a better target for cloning or counterfeiting, because they are currently more difficult to check with the Ukrainian authorities. This could lead to issues with the enforcement of driving offences, driving bans or other rule breaking activities. Asking drivers to exchange their Ukrainian driving licences for GB licences brings them more readily into the scope of our driving enforcement regime.

Questions

The following questions are included here so you can read them in the context of this document. To respond to the questions, see the Ways to respond section of the GOV.UK home page for this call for evidence.

Question

What comments, if any, do you have on our suggested road safety considerations?

Question

Are there any other road safety consideration you would like to see included?

Question

Any other comments?

How to respond

The consultation period began on 4 April 2023 and will run until 2 May 2023. Please ensure that your response reaches us before the closing date.

See the Ways to respond section of the GOV.UK home page for this consultation for an online response form and other ways to respond.

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.

If you have any suggestions of others who may wish to be involved in this process, please contact us.

What will happen next

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

If you have questions about his consultation, please contact:

Road Safety Division,
Great Minster House,
33 Horseferry Road,
London, SW1P 4DR

Ukraine.Licences@dft.gov.uk

Full list of consultation questions

These questions are listed here to give you an overview of what we are asking. See the Ways to respond section of the GOV.UK home page for this consultation for an online response form and other ways to respond.

Question

Do you agree or disagree with our proposal of extending the eligibility period of time for which Ukrainian licence holders, arriving from the Russian conflict, may drive cars within GB?

Question

Beyond the existing 12 month entitlement what length of time do you think is appropriate for this extension?

• up to 12 months
• greater than 12 months but no more than 24 months
• greater than 24 months but no more than 36 months
• the full Ukrainian scheme visa period of a maximum of 36 months
• another time period greater than 36 months (in months)

Question

What comments, if any, do you have on our suggested road safety considerations?

Question

Are there any other road safety consideration you would like to see included?

Question

Any other comments?

Freedom of Information

Information provided in response to this consultation 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 2018 (DPA) and UK GDPR and in the majority of circumstances this will mean that your personal data will not be disclosed to third parties.

Data protection

In this consultation, we are asking for your name and email address, in case we need to contact you about your responses. You do not have to give us this personal information, but if you do provide it, we will use it only for the purpose of asking follow-up questions.

For organisations, we are in addition asking for a brief description of your organisation to better understand the relationship between your organisation’s work and the topic.

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, the department will, under data protection law, be the controller for this information.

If responding to this consultation online, your personal data will be processed on behalf of the department by SmartSurvey, which runs the survey collection software.

Your name and email address will not be shared with any other third parties, but your responses may be shared with a third party for the purposes of analysis.

We will not use your name or other personal details that could identify you when we report the results of the consultation. Any information you provide will be kept securely and destroyed within 12 months of the closing date. Any information provided through the online questionnaire will be moved to our internal systems within 2 months of the call for evidence period end date.

Consultation principles

The consultation is being conducted in line with the government’s key consultation principles.