Corporate report

Traffic Commissioners for Great Britain Annual Report 2024-25

Published 7 August 2025

1. Traffic Commissioners for Great Britain: Annual Report to the Secretary of State 2024 – 2025

1.1 (For the year ending 31 March 2025)

1.2 Annual report presented to the Secretary of State pursuant to Section 55 of the Public Passenger Vehicles Act 1981.

2. Foreword by the Senior Traffic Commissioner

This is my valedictory report as Senior Traffic Commissioner so I hope that readers will forgive the length of this foreword. It could have been so much longer, were it not for the endorsement of the Minister of State during the progress of the Bus Services Bill through the House of Lords:

“Traffic commissioners play an important and strategic role in the transport sector and, these days—principally but not wholly—in road use safety. I certainly refute completely any suggestion that there is an absence of enforcement; the Driver and Vehicle Standards Agency does that. Traffic commissioners are an admirably economic and cost-effective way of dispensing justice to bus operators and bus drivers—those who are licensed to provide these important and, indeed, safe services—in a way that is widely celebrated in the industry and regarded as far more effective than any other solution….

One of the reasons why is because it is not in the industry’s interest to have poor-quality operations competing with it; that is true in respect of both the goods sector and the passenger transport sector. When the traffic commissioners take enforcement action, including depriving drivers or operators of their licences or curtailing them, it is widely celebrated by those operators who do take account of the law and operate safely. That is what is important.”[1]

As the Traffic Commissioner function is potentially subject to yet another review, the Minister’s words provide a useful reminder of not only why we carry out this role, i.e. for the safety of road users, but also the importance of justice. As the Lady Chief Justice commented: “The rule of law is a fundamental constitutional principle which underpins an open, fair and peaceful society, where citizens and businesses can prosper”.

Any operator, driver, transport manager, or other party is entitled to justice. Let there be no doubt, Traffic Commissioners exercise judicial functions and as a consequence the role of Senior Traffic Commissioner is to provide judicial leadership not act as a line manager.

I have described the STC role as a challenging and often isolating role. To be effective, it requires support from colleagues, staff and stakeholders. In a welcome development, we are now publicly recognised as part of the family sponsored by DfT, no longer that embarrassing relative, sat in the corner.

One of the causes of isolation in this role can be a lack of shared understanding. The title does not help the public or others to understand the role and certainly not the link to the tribunal. As the “Guide to Judicial Conduct” explains, fair treatment does not mean treating everyone in the same way: it means treating people equally in comparable situations. When parties do not get the outcome they would like or expect, it is particularly important that they feel they were fairly treated, fully heard and fully understood. It is with that aim in mind that I have continued to maintain the statutory guidance and statutory directions and to professionalise the jurisdiction. It is of some relief to finally see that reflected in consolidated reference material for OTC staff, for which I have worked so hard.

So, the approach is not to treat operators as children. We recognise the complicated nature of transport businesses but also that those undertakings accept the basic obligations of an operator’s licence or as a transport manager when the application is made. GB’s achievements in road safety are underpinned by those obligations. Where there is evidence of non-compliance Traffic Commissioners provide a specialist tribunal which balances the interests of the party, against protecting the public and wider industry from unfair practices.

It is 25 years since the first female Traffic Commissioner was appointed, but steps to make the Bench more diverse have been hampered, in part because there is only one work pattern. It is important to recognise that we are in competition with other tribunals. It is wrong to equate the required skills with those of retired magistrates. We will continue to struggle to recruit and retain, if changes are not realised.

I have repeatedly highlighted the working relationship with professional bodies and trade representatives, which was particularly evident when Great Britain needed it most. The role of the STC is to engage with stakeholders at the highest level. I have enjoyed productive working relations with the Chief Executives of the representative trade associations, who understand the value of natural justice. That same level of ready access is needed at Departmental level. 

The announcement at the end of my term gave me the opportunity to describe how humbling it is to have been able to influence change, particularly at times of crisis. I was struck by a recent entry in the CPT President’s Diary. I admire the measured way in which Paul Lynch not only commemorates those we lost during the Covid pandemic but also the many lessons, not least in how quickly things were done. He refers to the dedication and professionalism displayed by industry, to which I must add OTC staff members and their efforts to support both regulated industries and thereby the British public. I also take the opportunity to salute the pragmatism of local authority colleagues. It was a time where blocks and blockers were not permitted to stand in the way of the common good. We need to take some of this learning forward in the current era.

I can only hope that my successor’s tenure is less eventful than the last 8 years. It remains to be seen whether the service is more resilient and efficient as a result of its reorganisation. The appointment of a COO should ensure that it is more accountable.

Traffic commissioners have responded well to new challenges. The Freight Plan and the bus legislation will be no different. However, those relying on the jurisdiction are entitled to see barriers to improvement (which have been evident for over a decade) removed. A continued lack of real progress will provide a far more persuasive argument than any advocate in making the case for separation of the licensing and tribunal functions. I remain hopeful that the many positives of this jurisdiction can be retained.

As I pass the baton to Kevin Rooney, I cannot offer much that he does not already know. I can suggest one survival technique when moments of sanity are desired– frequent reference to the amusing lessons in Civil Service Mandarin authored by Martin Stanley. Translations include: 

On Deadlines:
In the New Year: by Easter, In the Spring: by 30 June, In the Summer: by 30 September or (if really desperate) by mid-October when Parliament resumes, In the Autumn: by Christmas, Around the end of the Year: by end-February.
My advice - always check the year.

Advice Please ! I don’t have a clue what to do with this.
Concerned A senior official is about to explode.
Disappointed Particularly devastating if used in conjunction with “concerned” and/or “surprised”. Surprised Signifies utter horror, disgust and fury.
Happy To Discuss there’s a whole lot more here than meets the eye & that I haven’t told you.
Hope This Is Helpful I’m well aware that it is not helpful at all. Please don’t contact me again.
Please do not hesitate to contact me please do not ever contact me again.
Thank you for bringing this to my attention I hoped nobody was going to mention that/find out about that.”
You may wish to consider Do this or else!

It has been an honour to serve. I wish my colleagues and stakeholders: safe travels!

3. Our purpose

The Traffic Commissioners for Great Britain (TCs) are independent regulators for the goods vehicle and public service vehicle (PSV) industries and their professional drivers.

Collectively, we act as a non-departmental tribunal and licensing authority, sponsored by the Department for Transport (DfT). Our mission is to promote safe, fair, efficient and reliable passenger and goods transport through effective licensing and regulation of the commercial vehicle industries.

Our shared vision is for traffic commissioners to be recognised by our stakeholders as providing proportionate, accountable, consistent and transparent decision-making - a model of independent regulation.

4. What we do

We work to keep Great Britain’s roads safe by licensing and regulating the commercial vehicle industries. With DfT, its agencies, the police and industry stakeholders we support the compliant, licensed operation of goods vehicles and PSVs. We do this by:

• publishing guidance and directions regarding the operator licensing regime and tribunal activities

• holding regulatory hearings to examine evidence and to take proportionate action to maintain safety standards and promote fair competition in the industry

• holding conduct hearings to examine evidence and to take proportionate action to ensure professional driving standards are upheld

• targeting tribunal resources so that the most serious cases are dealt with quickly and fairly

• delivering efficient, digital licensing services to responsible new applicants and compliant operators

• liaising with other regulatory bodies to identify and share knowledge around non- compliance

• educating and communicating with industry about the value of compliance and the licensing regime

Traffic commissioners seek to reduce regulatory burdens and support compliant businesses. The following statistics are unable to record the instances where the advice or assistance provided by individual traffic commissioners has resulted in improved compliance and road safety.

5. Overview: regulation & industry

5.1 Domestic freight (UK registered vehicles)

• c81% of domestic freight moved by road[2]

• 167 billion tonne-kilometres moved3

5.2 International freight (UK registered vehicles)

• 3.5 billion tonne-kilometres moved[3]

5.3 Local bus services

• 4 billion local bus service passenger journeys[4]

• 1.23 billion miles operated by local buses5

5.4 Employment

• 1.68 million people employed in Transport and Storage[5]

5.5 Our licensing work[6]

• 66,222 valid goods vehicle operator licences

• 376,044 goods vehicles authorised

• 5,280 valid PSV operator licences

• 87,992 PSV discs in issue

• 12,345 operator licence applications and variations determined

• 11,199 local bus registrations processed

5.6 Our regulatory work[6]

• 1,066 public inquiries determined

• 224 preliminary hearings held

• 38 Senior Team Leader (STL) interviews held

• 15,613 vocational driver cases closed

6. Performance against our strategic objectives for 2023-25

We set the current Traffic Commissioner Strategic Objectives at the start of the 2023 reporting year[7]. We continue to progress towards those overarching aims:

• To deliver a modern and effective operator licensing regime that ensures operators are fit to hold a licence whilst minimising the regulatory burden on the compliant.

• To promote and develop a safe road transport industry, which delivers compliance, fair competition and protects the environment.

As we bring these objectives to a close, we are in a position to report on what has been achieved against our priorities and how we sought to influence them, as follows:

6.1 Delivering a better service 

1. To continue our work with DVSA to deliver a licensing service, which is properly resourced and delivers the agreed service to our users.
2. To work with stakeholders to better understand the service required by the communities of Great Britain.

6.2 What was achieved:

DVSA Service Level Agreement (SLA) and Target Operating Model

The Traffic Commissioners maintain a working relationship with the DVSA, as the agency tasked with resourcing the Office of the Traffic Commissioner (OTC) in support of our statutory duties. It is to the credit of the current Chief Executive that this was maintained even during DVSA’s changes to the support services provided by staff in the Office of the Traffic Commissioner.

The SLA[8] with DVSA sets out the standards for the services to be delivered in our names. This is mainly through staff deployed to the OTC, and who have earned delegated functions. Previously, DVSA’s Business Plan targets have only included a target related to processing applications for goods operator licences. We are therefore pleased to note that DVSA have adopted additional measures relating to PSV licence applications and tribunal listings for the 2025/26 reporting year. In the interest of transparency, we would welcome the adoption of external reporting measures by DVSA that reflect the full range of services provided to us and service users.

The Traffic Commissioners set a service standard to determine goods and standard public service vehicle applications within an average of 35 working days. From the start of the 2023 reporting year to the end of the 2024/25 reporting year, the average determination time improved from 34 days to 31 days for goods applications and from 41 days to 34 days for PSV applications. We are pleased to see the sustained improvement in processing times, which enables businesses to commence operations more quickly and supports growth in the wider economy.

Performance for public inquiry cases listed within 12 weeks has not seen similar improvement, declining from 85% at the start of the 2023/24 reporting year to 82% at the end of the 2024/25 reporting year. This is largely due to issues in two offices, both affected by office moves or refurbishments in the period. The Traffic Commissioners need OTC managers to ensure that the service levels recover as quickly as possible, with clear remedial plans put in place.

The restructure of the OTC, referred to in the Annual Report of 2023/24, has now ended. As sometimes occurs with this type of exercise, the implementation has presented challenges and lessons must be learned to ensure that any future changes are properly developed and implemented. An independent audit was due to be completed in 2024 but has yet to be shared with Traffic Commissioners. There will inevitably be a requirement for further amendment to the model to ensure that the intended benefits can be realised and the service standards are met.

The transfer of the OTC from the Enforcement Directorate into its own standalone unit, under the management of a newly created Chief Operating Officer post, is a positive move. The business need was identified by the Function Review[9] and the legal risk raised with the Department in December 2023. There are other pressing recommendations which need to be brought forward. However, this new arrangement should ensure that the needs of the Traffic Commissioners are represented at an appropriate level.

Digital Improvements

Ongoing support has also been provided on the future development of the Vehicle Operator Licensing system. As it continues to evolve it is essential that the needs of both external and internal users are considered to ensure the service delivers on the priorities of all users and the statutory requirements set by Parliament.

As part of our drive to modernise our services so that operators can benefit from faster processing times, increased security and reduced administrative burdens, we have fully digitalised the continuation process that operators must follow every five years to legally continue their licence. We have also digitalised the process for adding and removing transport managers on a licence and, where possible, enabled operators to apply for the surrender of the licence using the self-service facility. We will continue to streamline the service in this way as we move into the new reporting year.

The Traffic Commissioners adopted a digital case bundling service in 2024, which has been successfully deployed across the hearing centres. We are now seeking to maximise the use of the service so that tribunal users have the opportunity to benefit from a fully digitalised service when presenting evidence and receiving case bundles. In the absence of bespoke instructions, the Western Hearing Centre has conducted a pilot where all tribunal users can work from digital documents. It has been important that we take these steps carefully to preserve the integrity of hearings and to ensure that no user is disadvantaged. As we expand the pilot to additional offices, we will continue to monitor the implementation closely to ensure it delivers benefits for tribunal users and enables more efficient use of limited tribunal resources.

Moving to this approach should enhance the sustainability of the OTC while reducing paper and postage costs. There will also be practical benefits to modernising the tribunal’s approach to hearings. If introduced correctly, it should ensure that all parties can effectively follow the proceedings.

Fees

The setting of fee levels is outside the control of Traffic Commissioners. As we stated in last year’s report, it is essential to accurately calculate the cost of providing individual services so that fees cover the reasonable costs of providing those services. Industry representatives widely recognise that the service can only be maintained and improved through a review of fees. It is also important to understand and anticipate the changing nature of the regulated industries.

The Commissioners believe it is important that costs are proportionate and reflect both the size of the business and the level of demand placed on the service. This was raised again in the Department for Transport’s Function Review[10]. We understand that proposals are being developed for when a consultation may be carried out and look forward to seeing these as soon as possible to ensure that an improved service funded through the proper recovery of cost can be achieved.

6.3 Legislative Change

3. Seek legislative change for an improved operator licensing system.

6.4 What was achieved:

Making the case for change

Traffic Commissioners have limited ability to effect legislative change. The Function Review of Traffic Commissioners published in 2023 identified several legislative changes that would improve the operator licensing regime and benefit both Traffic Commissioners and service users. However, progress on wider reform has been limited, partly due to the General Election in July 2024 and the introduction of other Government legislation.

The recent change in sponsorship arrangements presents an opportunity to progress this work. If we are to optimise the efficiency of the jurisdiction and realise the benefits of the previous reviews, it is important that recommendations for change are now taken forward.   

As reported last year, a good example of how reform can reduce costs for applicants and improve public understanding of the role of Traffic Commissioners relates to the grant of new Operating Centres for goods operators, which was identified in the 2015 Triennial Review[11] and again in the Function Review. The Department agreed that there was a case to improve the efficiency of the current process, particularly in relation to advertising requirements. Reform in this area would remove significant costs for industry and support growth.

The same review also recommended introducing a set of formal tribunal rules to standardise the processes leading up to and during Public Inquiry. It is of some regret that there is still no provision for PSV operators to obtain a form of ‘interim’ licence. That change would have enabled new bus and coach business to realise commercial opportunities more quickly, benefiting passengers and supporting environmental commitments.

Despite conclusions being reached on these last two items in 2020, no progress has been made. We would like to see this work taken forward to reduce the burden on responsible operators.

Traffic Commissioners and the OTC staff have contributed their expertise and knowledge during the development of the Bus Services (No.2) Bill, currently before the UK Parliament. The Bill introduces additional requirements for operators which, to achieve the intended policy outcomes, must be effectively regulated. Traffic Commissioners will work with DVSA and DfT to ensure that these changes are implemented successfully. The Bill also amends the process for the introduction of franchising schemes. In this context, the Traffic Commissioners have engaged with the Scottish and Welsh Governments on legislation relating to local bus services in their respective countries. It is essential that officials ensure that legislative changes are properly funded to avoid impacting current service levels.

Autonomous Vehicles

Traffic Commissioners have continued to monitor trials involving vehicles with safety drivers and have actively engaged with the work being led by the DfT and DVSA on the introduction of fully autonomous vehicles. This work is accelerating, and it is possible that there may be a future role for Traffic Commissioners in the licensing schemes for such vehicles. In this field the legal and regulatory expertise of Traffic Commissioners has supported the development of potential policy in this area and in the understanding of the legal rights which might be engaged. We look forward to replicating that type of working across other relevant policy areas. 

Electric Vehicles

The introduction of electric vehicles into the fleets of both PSV and goods vehicle operators continues. The Traffic Commissioners note that the supporting infrastructure across Great Britain needs to keep pace with this transition. We refer elsewhere to the narrow margins and increased costs of operation, which may contribute to a hesitancy in investment. 

6.5 Connecting Communities 

4. Support the delivery of improved local bus services and better journeys.

6.6 What was achieved:

Changes to Local Bus Services

The National Bus Strategy[12] aimed to improve local bus services across Great Britain, and this commitment has continued with the current Government with the introduction of the Bus Services (No. 2) Bill. The Traffic Commissioners have worked collaboratively with operators, local authorities and the DfT on the implementation of enhanced partnership and franchising schemes across England.

We provided support to the Greater Manchester Combined Authority and operators throughout the transition to franchising in the Greater Manchester area, which completed in January 2025. This included making arrangements for managing services that cross from areas under a Traffic Commissioner’s jurisdiction into franchised areas, in order to support downstream data consumers. As more authorities publish their intention to pursue franchising, we have engaged with them to assist in their transition. We look forward to continuing our work with these authorities to ensure a smooth transition.

We have continued to engage with the Scottish Government on legislative changes arising from the Transport (Scotland) Act 2019[13]. Secondary legislation has provided further clarity on the Government’s intention, and we will work with Scottish Government officials on the role of the Traffic Commissioner in establishing the panels required to consider franchising schemes in Scotland.

We also engaged with the devolved administration in Wales and at the very end of the reporting period (31st March 2025), the Welsh Government laid a new Bill before the Senedd. The proposals include delivering one network, one timetable and one ticket across Wales, with services shaped by local knowledge. The Bus Services (Wales) Bill outlines how through Transport for Wales, in close collaboration with local authorities and Corporate Joint Committees, bus services will be planned and co-ordinated at a national level and delivered principally through franchised contracts by private, third and public sector operators.

Bus Open Data

We have continued to work with DfT, KPMG and DVSA on helping operators to comply with the requirements, whilst intervening with those who have chosen not to do so. In this case, the expertise within the Traffic Commissioner’s Policy Team has been recognised.

As more operators comply with the legal requirements, the transparency of services will improve, supporting increased use of public transport. Reliable and accessible public transport continues to assist in carbon reduction, enhancing the lives of local residents and contributing to greater sustainability.

It has been concerning to note the number of local services registered with a Traffic Commissioner that have not operated for a number of years. These services have come to light only due to the work undertaken as part of the Bus Open Data initiative. Operators must take greater ownership in ensuring that their records are accurately maintained as services change, so that they provide greater assurance to the travelling public.

Performance Measurement

Work to review the Statutory Document outlining how a Traffic Commissioner may approach bus reliability and punctuality was delayed initially to allow the recovery of the industry following the pandemic, and subsequently due to the ongoing work on the Bus Open data and legislation. We hosted a stakeholder event in December 2024. It is frustrating that the consultation on the Statutory Document for England and Wales has been further delayed as there is a real wish amongst relevant Traffic Commissioners to innovate, based on the findings from that engagement.

6.7 Targeted Regulation 

5. Ensuring the efficient use of resources to deliver compliance across all sectors.

6.8 What was achieved:

Statutory Guidance and Statutory Directions

The Senior Traffic Commissioner has continued to regularly review the Statutory Guidance and Statutory Directions to ensure they remain relevant as the industry evolves, alongside developments in case law from the Upper Tribunal. In 2023, the Traffic Commissioners launched two public consultations and engaged informally with stakeholders throughout the period to gather input and ensure timely challenge on future initiatives.

As ever, changes primarily stem from Upper Tribunal rulings. It has been useful to incorporate developed precedents including confirmation of the status of the Statutory Documents and the reliance which Traffic Commissioners are entitled to place on them. These appellate decisions also provide greater clarity for operators on several key points, including the obligation to revoke a licence when a mandatory requirement is not met at the end of a period of grace and the ability of Traffic Commissioners to consider the same operator on multiple occasions. The Statutory Documents have also been updated to reflect current practices, including the digital-by-default approach, revisions to the list of transport manager responsibilities based on stakeholder feedback, and clarification on the treatment of subsidiary company finances.

The review into how a driver’s suitability is determined has also progressed. Several engagement calls were held with stakeholders to identify key issues for consideration. Preliminary findings informed a public consultation launched in April, which is scheduled to close at the end of May 2025. That recognises that we do need to hold email addresses of drivers, so guidance may be required on when to conduct a virtual hearing. The revision of disqualification thresholds is linked to a non-exhaustive list of negative and positive features, which can form part of the risk assessment of a drivers’ fitness. 

Assisting Enforcement Agencies to Target Activity

The Traffic Commissioners continue to work closely with various enforcement agencies to improve the quality of evidence provided by investigators. We have worked with the DVSA on the need to ensure appropriate lines of inquiry are followed during investigations. We have also contributed to the Roads Policing Review, which is currently being undertaken by the DfT and Home Office. The pilot CVU in Dorset, Devon and Cornwall is now operational. Funding has been secured for the scheme to issue officers with DVSA phones so that they can access to DVSA information to add to their own intelligence, leading to more effective targeting of non-compliant operators.

Whilst this work progresses, we also listened to feedback from the police on how we could make changes to documentation to support them in lodging statutory objections against applications where there are concerns about criminality or non-compliance. We have also developed a data sharing agreement with the National Police Chiefs’ Council (NPCC) to improve the exchange of relevant information. It is important that those bodies with the right to make statutory objections utilise the powers granted to them by parliament. We still see too few statutory objections made where the repute of the applicant is in question.

We look forward to the introduction of the Roads Policing Review improvements across Great Britain and to an increase in statutory objections submitted by the police.

Traffic Commissioners continue to support police forces in ensuring that coach companies taking football fans to matches in England and Wales comply with the voluntary guidelines that aim to ensure public order and safety. In 2023, we spoke at conferences organised by the Football Policing Unit, which helped raise awareness of the role of Traffic Commissioners and led to an increase in compliance-related referrals. We have also assisted the police by using our communication channels to share messages to operators and provide guidance for specific events, such as the FA Cup Final in 2024.

During this reporting year, we also presented at other events focusing on compliance and the role of Traffic Commissioners, including those organised by the British Transport Police and DfT.

6.9 Helping Businesses to be Compliant 

6. We will support those we regulate, to comply and grow; making engagement accessible so that operators and drivers are provided with the information they require to manage their licences and meet safety standards.

6.10 What was achieved:

Communication Initiatives

Last year we reported that updated guidance had been made available for both goods and PSV operators. Recognising the difficulty some users experience in locating relevant information on the GOV.UK platform, we have taken steps to improve accessibility by adding a dedicated link on our landing page to all publications we produce.

Service users often struggle to identify the correct address to send correspondence to within the OTC, this can result in delays affecting applications and licences. To address this, we have developed a tool designed to assist in identifying the correct address at the first attempt. 

We previously highlighted new communication campaigns and educational resources aimed particularly at service users who lack access to relevant information or compliance advice. Following a successful pilot, a campaign has now been launched to support operators identified as needing assistance to raise their standards and avoid public inquiry and the potential loss of their licence. This campaign is currently reaching over 4000 operators, offering guidance on how to operate their vehicles compliantly and safely. 

Additionally, we have used our communication channels to create a process for reminding operators benefitting from a Period of Grace of the steps they must take to ensure that their licence is not subject to mandatory revocation at the end of that period.

Section 19 Permits

Together with colleagues at the DfT, we recognise the need to provide updated guidance for operators holding permits issued under the Transport Act 1985. We have worked with DfT and the Community Transport Association to revise this guidance. On completion, it will serve as a valuable source of information for both applicants and operators.

Transport Managers for Light Goods Vehicle Operators

Operators of light goods vehicles who currently rely upon a transport manager with Acquired Rights were required to appoint a suitability qualified transport manager by the time those rights expired in law on 20 May 2025. Over the past two years, we have conducted a sustained messaging campaign to remind both operators and transport managers of this deadline. This culminated in targeted correspondence to those operators who had yet appointed a suitably qualified transport manager. Licences held by operators who have chosen not to take the necessary action may be revoked, affecting their ability to trade within the European Union.

Identify opportunities for the improved use of IT to assist operators to manage their operator’s licence.

Traffic Commissioners have worked closely with the DVSA to agree on priorities for the development of the Vehicle Operator Licensing (VOL) system, with the aim of improving the experience for service users. In addition to the digitisation work mentioned earlier, the Traffic Commissioners have advised on the development of a new messaging service within VOL. This service enables applicants and operators to correspond directly with OTC staff, making communicating quicker and reducing the risk of ‘lost’ emails by ensuring that all relevant messages are stored in a single repository.

It is essential that we know who we are regulating and communicating with at all times. We have encountered instances where correspondence was believed to be with the ‘operator’ but later turned out to be with a contracted consultant. To address this, we have overseen enhancements of VOL that ensure individuals contracted to represent applicants and operators can be clearly identified. The terms of usage have been updated to warn users of the potential consequences if the facility is misused.

Balancing regulatory work with education at national and regional level.

We remain committed to ongoing engagement with the regulated industries. This is achieved through speaking at events and by holding regular meetings with the transport and other trade associations. These events not only provide an opportunity to educate participants maintaining compliance but also allow us to gain valuable insights into the challenges facing the industry and how we may regulate more effectively.

Supporting innovation within the industry

For too long, some well-meaning operators have been let down by those they have contracted their maintenance arrangements to, believing these providers would ensure the safety of their fleet. In response, we have worked with stakeholders to develop the Maintenance Providers Rating Scheme, which enables operators to assess the competence and capability of their service providers, particularly in relation to vehicle maintenance standards. This scheme was launched in May 2025 following a successful trial with Daimler and DAF Trucks.

7. Summaries from England, Scotland and Wales

7.1 As in previous years we have collated the collective observations of the Traffic Commissioners into defined narrative sections. Adopting this format, the following sections again combine those themes and observations of the Commissioners.

7.2 Traffic Commissioners for England

Sarah Bell, Tim Blackmore, Miles Dorrington, David Mullan, Kevin Rooney, Richard Turfitt

State of the Industry

Heavy goods vehicles, buses, and coaches continue to play a vital role in the movement of people and goods across Great Britain, forming the backbone of both the economy and public life.

The Traffic Commissioners remain committed to ensuring that these services are delivered safely, fairly, and in compliance with legal and environmental standards—while minimising unnecessary regulatory burden on responsible operators.

The Commissioners have identified common themes arising from public inquiries and hearings over the past year. These insights are intended to help operators understand regulatory expectations and avoid enforcement action, reinforcing a culture of compliance and continuous improvement across the industry and to inform others.

This summary concludes with broader observations on emerging issues and challenges currently impacting the sector.

Road Safety

Improved vehicle technology and other interventions have helped to reduce the numbers of killed and seriously injured where the vehicle involved was a HGV from 1682 in 2014 to 1115 in 2023, and for a PSV from 1210 to 899 in the same period[14]. This figure is still too high and shows the continued need for well-resourced and effective regulation of the industries by Traffic Commissioners.     

Fair Competition

​Fair competition is a cornerstone of the Traffic Commissioners’ regulatory framework and a key for maintaining the health and integrity of the transport industry.

For this reason it forms part of the Commissioners’ core objective to “promote and develop a safe road transport industry, which delivers compliance, fair competition, and protects the environment.”

By ensuring that all operators are held to consistent standards, the Commissioners help create a level playing field. The level playing field is designed to reward those who invest in safety, professionalism, and compliance, and take action against those who seek unfair advantage through non-compliance.

For instance, in March 2025, the Traffic Commissioner for the West of England refused an application for a restricted goods vehicle operator’s licence after the applicant failed to disclose previous licensing history. The Commissioner found that the previous licence had been surrendered under questionable circumstances, and that the new application was an attempt to continue the previous business without addressing the compliance failures that led to the original licence being surrendered. By attempting to re-enter the market without resolving outstanding regulatory issues, the applicant sought to gain an unfair advantage over operators who follow the rules. This undermines the level playing field that the licensing system is designed to uphold.

Driver Employment

One area where some operators attempt to circumvent fair competition is through the way they engage drivers. The Traffic Commissioners have previously observed that certain operators struggle to maintain proper oversight and control of their drivers due to the nature of these employment arrangements, an issue that continues to persist.

This concern was highlighted in a recent West Midlands case, where it was found that only one of the operator’s five drivers was directly employed. The remaining four were paid through service companies, reportedly at the drivers’ request. This arrangement was deemed to provide the operator with an unfair commercial advantage. As a result, the licence was revoked.

Maintenance

A well-maintained vehicle is less likely to suffer mechanical failure, reducing the risk of collisions caused by defective brakes, tyres, steering, or lighting systems. A robust maintenance regime depends on drivers carrying out risk-based walkaround checks, prompt defect reporting, and regular, scheduled preventative maintenance inspections.

Many operators rely on external maintenance providers to carry out these inspections. The increase in maintenance costs including components, has been significant. Some operators mistakenly believe that using external providers transfers their legal responsibility. Under the terms of an operator’s licence, it remains the operator’s duty to ensure that all vehicles are kept in a fit and serviceable condition, regardless of who carries out the maintenance on the vehicles.

This was illustrated in another case, where an operator failed to carry out brake performance assessments during safety inspections. Vehicles were also presented with dangerous defects, such as loose wheel nuts.

Recognising that maintenance is a significant issue for industry, the Traffic Commissioners have supported the launch of the Maintenance Provision Rating Scheme (MPRS). The initiative is designed to enhance standards and professional practices within the commercial vehicle maintenance sector. The scheme is expected to support the sector’s growth by providing reassurance to operators and enabling the identification of high-quality maintenance providers.

Drivers’ Hours

​Compliance with drivers’ hours rules is a critical component of an operator’s safety system, helping to prevent fatigue-related incidents, protect public safety, and ensure fair working conditions for professional drivers. Operators need to make sure that the law is complied with as a minimum and to ensure that their drivers are able to drive safely.

A notable case in the West of England involved a director who was identified as a serial offender over a seven-year period. As a result, the operator’s licence was suspended for nearly three months. The transport manager was disqualified for ten years and is required to retake the Certificate of Professional Competence before returning to the role. Two drivers also faced sanctions: one had their vocational entitlement revoked and disqualified from holding the entitlement for a year, and the other was suspended for one month.

Non-compliance with drivers’ hours often indicates inadequate management systems, which can affect broader compliance as demonstrated in this East of England case. During the hearing, the director admitted that vehicles had not been specified for years, had been driven without a driver card inserted, and that both Vehicle Units and driver cards had not been downloaded for considerable periods. The Commissioner deemed the case to fall within the “serious” category. It was only on receipt of onerous undertakings, that the Commissioner was able to draw back from revoking the licence and instead curtailed it for a period.

Financial Standing

​The Traffic Commissioners have noted reports highlighting the significant financial challenges currently facing Great Britain’s heavy goods vehicle (HGV) industry, with insolvencies becoming an increasing concern.

This has led to cases such as one recently heard by a Traffic Commissioner, in which an applicant failed to disclose their previous insolvency history. Licensing staff identified linked entities with substantial outstanding debts. The applicant’s decision to prioritise payments to “critical suppliers” over tax liabilities was deemed by the Commissioner to constitute unfair competition, leading to the conclusion that the applicant was unfit to hold an operator’s licence.

Bridge Strikes

In 2020, following a high number of bridge strikes across the country, the Senior Traffic Commissioner, issued a letter to all operators to remind them of their responsibilities as operators of large vehicles.

According to Network Rail, there were 1,532 railway bridge strikes in the UK between April 2023 and March 2024. This represents the lowest figure in five years, a 4% decrease from the previous year, yet there is still more that can be done.

In October 2024, the Senior Traffic Commissioner reissued guidance to operators of large vehicles, underscoring some control measures to prevent bridge strikes. The guidance highlighted the societal costs of such incidents, which continue to pose serious safety risks and financial burdens, including infrastructure damage, service disruptions, and potential regulatory penalties. This updated guidance also now forms part of a suite of communications issued to new licence holders upon the grant of their operator’s licence.

This issue has been addressed in regulatory proceedings, such as a case where an operator’s vehicle was involved in a bridge strike after being improperly allocated to a driver. The Traffic Commissioner for the West of England issued a formal warning in that instance. However, the incident had substantial financial repercussions for the business, ultimately resulting in the operator failing to meet financial standing requirements and the revocation of their licence.

Restricted Licence Holders

Unlike standard licence holders, restricted licence operators are not required to appoint a professionally competent transport manager. As a result, the full responsibility for ensuring compliance with operator licensing requirements rests solely with the operator.

The absence of a Certificate of Professional Competence (CPC) holder can increase the risk of compliance gaps and reduce operational oversight. It is therefore essential that restricted licence holders take proactive steps to understand and meet their obligations, including maintaining roadworthiness, managing drivers effectively, and keeping accurate records.

For example, this West Midlands case involved a restricted licence holder with a prior history of public inquiry. The inquiry revealed that the operator had been operating beyond the authorised vehicle limit and had failed to maintain written maintenance records. The Commissioner rejected the director’s plea of ignorance, citing Upper Tribunal guidance, and proceeded to revoke the licence and impose a six-month disqualification.

In a case before the North West Traffic Commissioner, an operator, whose licence had been granted following a public inquiry, faced a revocation proposal within a year due to inadequate financial standing. The operator offered undertakings to provide financial evidence and an independent compliance audit but submitted them late. Subsequently, a roadside inspection led to an immediate prohibition, prompting a DVSA maintenance investigation rated as unsatisfactory. The operator failed to respond to both the DVSA and the Traffic Commissioner’s correspondence, including a call to a public inquiry, which they also did not attend. Due to this persistent lack of engagement, the Commissioner revoked the licence and imposed a seven-year disqualification.

Driver Conduct

The Traffic Commissioners continue to assess the fitness of thousands of vocational drivers following referrals from the Secretary of State. Drivers of large commercial vehicles are regarded as professional drivers and are therefore held to a higher standard of conduct.

For example, a car driver who commits two speeding offences may receive a £100 fine and three penalty points for each offence. However, if those same offences are committed in a commercial vehicle, the starting point is typically a referral to a conduct hearing, where a six-week suspension may be imposed, often resulting in a loss of earnings.

One such case involved a driver who struck a bridge and was subsequently convicted of driving without due care and attention. The court imposed a fine and costs whilst endorsing the driver’s licence with five penalty points. At the conduct hearing, the incident was described as a genuine error during a period of personal difficulty that had affected the driver’s concentration. Nonetheless, professional drivers are expected to remain fully aware and in control of their vehicles at all times, given the inherent risks associated with their size and nature. As a result, the driver was suspended for a period of two months.

Misuse of Digital Systems

The report against Strategic Objectives outlines the steps the Traffic Commissioners have taken to modernise the jurisdiction, including the transition to digital services. While these changes offer significant benefits, they also present new challenges, such as the potential misuse of the Vehicle Operator Licensing (VOL) system.

One case in the South East of England, an operator’s business was sold along with access to their VOL login credentials. The Commissioner emphasised that the VOL self-service portal provides operators, transport managers, applicants, and their representatives with valuable tools for timely communication and updates. However, this access must not be abused. The VOL terms and conditions clearly state that each user must apply for access in their own name, using their own username and password, which must never be shared. As a result of the misuse in this case, the operator’s licence was revoked, and a disqualification was imposed.

Appeals

The Upper Tribunal has previously cautioned against using legal processes as a tactic to delay regulatory outcomes, particularly where there are risks to road safety or unfair consequences for compliant operators. Applicants sign up to the basic requirements of an operator’s licence. They and existing operators are provided with considerable published guidance as well as access to the Senior Traffic Commissioner’s statutory guidance and statutory directions to the traffic commissioners. These are transport businesses operating in an increasingly sophisticated trading environment, who must be capable of managing their operations, drivers, vehicles, maintenance and records. The safety achievements in Great Britain rely on those requirements. Whilst the right to appeal is vital, the law requires requests for stays to be balanced against the need to protect the public and uphold confidence in the licensing system. The Senior Traffic Commissioner has updated guidance on stays, following clarification of that long-standing case law.

7.3 Wider Industry Context

Economic Impact

The Traffic Commissioners are aware of the challenges facing the sector, including rising operational and labour costs, as well as increasing market competition, all of which place pressure on already narrow profit margins.

These margins are impacted when things go wrong. We commented earlier on the need for further work to reduce those killed and seriously injured on Great Britain’s roads. A single fatality resulting from a road traffic collision carries significant economic and social consequences. Transport Scotland estimated in 2020 that the cost of a single road death was almost £2.2 million, and this figure is likely to have increased since then. Some of these costs are obvious such as medical expenses and property damage. Others are less so such as pain, suffering and emotional distress experienced by the victims’ families and communities and the loss of productivity to the UK economy.

Despite these challenges, the sector continues to offer substantial employment opportunities, with competitive salaries, particularly for experienced drivers. Recent reports indicate that salaries for goods vehicle drivers have risen notably, reflecting the sustained high demand for skilled professionals.

Security Concerns

The economic concerns on the transport industry are reflected in the findings of the All-Party Parliamentary Group’s report, Securing Our Supply Chains. The report highlights a significant rise in organised crime groups targeting HGVs, with estimated losses to the UK economy exceeding £1 billion since 2020. Thefts from lorries have resulted in substantial financial damage, including lost contracts, increased insurance premiums, driver welfare challenges, and a decline in investment across the UK logistics sector.

The Traffic Commissioners fully support the report’s recommendations and are committed to working in coordination with enforcement agencies to strengthen preventative measures and improve security outcomes for the industry.

Driver Shortage

The HGV sector continues to face a significant driver shortage, which poses a sustained challenge to the resilience and efficiency of road transport operations across Great Britain. A recent industry report estimates that 200,000 new lorry drivers will be needed over the next five years to meet demand.

While government and industry-led initiatives have helped stabilise the situation since the peak of the crisis in 2021, recruitment and retention remain critical concerns. The Traffic Commissioners recognise the importance of maintaining high professional standards while also supporting efforts to attract and retain qualified drivers. This includes ensuring that vocational drivers are treated fairly and consistently, and that licensing and regulatory processes remain efficient and proportionate.

7.4 Traffic Commissioner for Scotland

Richard Turfitt

It has been a pleasure and a privilege to oversee the regulation of road transport industries within Scotland. As was communicated to me during various training and engagement events which I attended since her departure, the loss of Claire Gilmore is still keenly felt.

Recruitment for a replacement was inevitably halted by the General Election, but there are wider lessons for how public appointment processes should be applied to what is essentially a judicial and leadership post. The significant regulatory and judicial responsibilities which directly impact public safety and the wider transport industry, require the recruitment process to be robust, but it must also be transparent and based on a firm understanding of what the judicial obligations entail. The law does not permit for Traffic Commissioners to be treated as equivalent to Non-executive Directors, serving at will.

It would be wrong to conclude (as some commentators have suggested) that the traffic area has been left without effective regulation. I hope operators and Transport Managers who attended events organised by industry representative bodies in Paisley and Grangemouth will agree.

I have continued to travel to Scotland as often as other duties allowed and spent some of my weekends on trains and at Stansted airport. Whilst I have dealt with regulatory, section 19 and punctuality cases, the majority of work has been undertaken by the Deputy Traffic Commissioners for Scotland, Hugh Olson and Kenneth Young. They have busy careers at the Bar, so I am grateful to them and the OTC team based in Edinburgh, for continuing the work to maintain standards. Scotland piloted ‘online’ driver conduct hearings dealing with high-risk drivers during Covid. Those hearings are not always appropriate, particularly where vulnerable parties are involved and we will continue to ensure the accessibility and fairness of our proceedings. Through the hard work of OTC staff, I have been able to take the decision to list cases away from the tribunal centre in Edinburgh with the aim of better supporting the communities and industries of Scotland.

I share the observations of colleagues more fully set out in the report from the English areas, but resulting from discussions amongst the Traffic Commissioner Board. I am concerned at the reduction in regulatory cases on referral from enforcement officers. The geographical distances between examiners are evident in parts of Scotland and present a real challenge to the completion of investigations. That is the more acute since the reorganisation of the DVSA Enforcement Directorate.

The move to provide greater resilience through bus registrations being relocated to Leeds was well reasoned and was necessary, following DVSA’s reorganisation of staff allocated to the Office of the Traffic Commissioner. However, the full impact of its operating model on all parts of Great Britain was not anticipated. It is regrettable that the pressures on the centralised team in Leeds were not disclosed at the time. The Vehicle Operator Licensing system is still not in state to deal with applications even in the English areas (currently the Local Authorities listed on VOL do not match changes in local government). There was no additional resource to take on the responsibility of Scottish bus registrations from March 2024. The question of funding for work in Scotland has yet to be resolved.

The changes introduced by the Local Transport Act 2008 mean that support from the other parts of the jurisdiction is limited, as are the STC’s powers of deployment. I have only now been appointed as acting Traffic Commissioner and continue to feel some frustration that advice was not acted upon by previous DfT officials. The absence of a traffic commissioner has directly delayed the update of punctuality guidance and directions. I am pleased that our expert policy team has continued to liaise with Scottish Government and to offer their expertise in the development of new legislation to improve bus services.

We continue to benefit from the support of many from across our industries, their representatives and government officials, without which much of the work would not have been possible, particularly during the period without a full-time Traffic Commissioner in place. I look forward to that new appointment and to assisting them with all that I have learned during my care-taking period. What I can say is that the role requires effective support, which is tailored to the need of the post, not imposed by another entity. On that note, my final thanks must be to the staff supporting the traffic area.

7.5 Traffic Commissioner for Wales

Victoria Davies

I am pleased to report that the situation regarding staffing and support in Wales has improved since my contribution last year. At that time there was a transitional arrangement in place involving all Welsh Hearing centre cases being managed and clerked by staff based in Golborne in the North of England. That was because the re-structure of OTC resulted in the loss of dedicated bilingual staff who had been recruited to support me in Wales. I referred then to a DVSA recruitment campaign for four bilingual staff members to be based in Wales. That campaign was partially successful, resulting in the appointment of two permanent bilingual caseworkers based in my Pontypridd office. That has greatly improved the efficiency and effectiveness of the service provided to those attending public inquiry hearings.  However, despite re-launching the recruitment campaign for a bilingual hearing centre manager, the DVSA was unable to recruit. Following discussion with Welsh Government officials, it was agreed that the Welsh language requirement for that role should be lowered to attract candidates who were willing to undertake Welsh language training. I am pleased to report that an experienced OTC staff member, who had been carrying out that role temporarily since the re-structure, was successfully appointed to that position following a third recruitment campaign.

An important aspect of my role as the Traffic Commissioner for Wales (and reflected in the funding provided by the Welsh Government) is engaging with the bus and freight industries, local authorities and other interested parties throughout Wales. I have previously reported on discussions with Welsh Government officials and Ministers about how I might develop this work but have been hampered in this due to the lack of staff to support that work. Following Peter Hearn’s appointment as OTC’s new Chief Operating Officer, I discussed this concern with him and am pleased that Peter recognised that need and has taken steps to address it. A new post of OTC Engagement Manager for Wales has been created, and I look forward to taking this work forward with them in the coming months. I am keen to connect with sectors of the PSV and HGV industries in Wales which have, historically, been harder to reach but which would benefit most from direct engagement and education. This increased focus on education will help to promote better compliance and so reduce the need for public inquiries. 

Despite those resourcing issues, I have managed to meet face to face with the industries I regulate and other key stakeholders in Wales this year. I have spoken at conferences and events organised by the Road Haulage Association, the Confederation of Passenger Transport Cymru and the Wales Road Transport Advisory Group. I have engaged with Welsh Government, Department for Transport and OTC policy officials on proposals for legislative reform in Wales in relation to bus franchising and bus registrations which will impact on my statutory functions and anticipate further engagement as the Bus Services (Wales) Bill progresses through the Senedd.

I commented last year on the need for improved engagement between DfT and the Welsh Government, specifically in the context of my functions, which was one of the recommendations of the Traffic Commissioner Function Review report in 2023. Unfortunately, that work was not progressed by the DfT officials in the relevant sponsorship team. I am hopeful that the new arrangements for supporting the Traffic Commissioners within DfT and OTC, with Peter Hearn in post as the new Chief Operating Officer, with responsibility for improved relationships with the Welsh and Scottish Governments, will lead to much better engagement and a shared understanding at a strategic level.

My Traffic Commissioner colleagues in England have commented earlier in this Report on common themes arising from public inquiries and hearings over the past year. I echo their comments, particularly as to fair competition being the cornerstone of the Traffic Commissioners’ regulatory framework which is key for maintaining the health and integrity of the transport industry. I have dealt with cases in Wales this year where there has been a clear attempt by existing operators and by applicants for new licences to circumvent fair competition and to gain an unfair advantage over operators who do follow the rules. An example was a case involving an operator deliberately operating more vehicles than it was authorised for, resulting in the revocation of its licence and disqualification of the company and its directors from holding an operator’s licence.

On a more positive note, I was delighted once again this year to sit as a Judge on the Microlise Driver of the Year Awards panel. Those awards recognise the exceptional performance and dedication of commercial drivers in Great Britain. It was an honour to be able to appreciate the nominees and winners for the work that they do – they are the backbone of the transport industry.

8. Acknowledgements

We noted last year that the loss of two salaried Traffic Commissioners had been keenly felt but the appointment of two Deputy Traffic Commissioners would help to mitigate their loss. Deputy Traffic Commissioners have an important role in providing support to the full-time Traffic Commissioners ensuring that applications and cases can continue during period of absences and providing an alternative view for Traffic Commissioners to reflect upon. The loss of experienced Deputy Traffic Commissioners can be as keenly felt as that for Traffic Commissioners; the loss of Laura Thomas during this year is an example of this. She brought an expertise to the Deputy role that will be hard to replace.

During this reporting year we saw a change in the sponsorship arrangements provided by the Department to the Traffic Commissioners. Until January 2025 this support was provided by a dedicated team sat within the Department. The appointment of Peter Hearn as the Chief Operating Officer for the Office of the Traffic Commissioner has enabled that support to be made more readily accessible to Traffic Commissioners. This recognises the importance of how closer working relationships can help to accelerate improvements for service users. The last five years have allowed us to develop a better understanding of the type of support required by a modern and functioning jurisdiction. We welcome Peter to his new role and look forward to him removing some of the barriers to change.   

We also noted last year the vital contribution that individual members of staff in the Office of the Traffic Commissioner and the impact resulting from the significant loss of staff during that reporting year. We again take this opportunity to recognise how the public benefits directly from skilled scrutiny, from staff members who are able to process applications in a way that allows transport businesses to meet the needs of passengers and consumers, whilst we ensure that dangerous and criminal elements are excluded at the application stage or by the swift and thorough preparation of tribunal cases. Posts must be filled quickly, and staff must be provided with the support to enable them to carry out their important roles and the Chief Operating Officer role will help to provide that support.

As we enter our 95th year of the Traffic Commissioner role, we recognise other associations within the transport and safety space. In the past year one of our major stakeholders, the Road Transport Association, celebrated its 80th anniversary. That milestone was also reached by the Institute of Transport Administration. It was followed by the 70th anniversary of the Transport Association, the 25th year of Transport for London (following a long tradition of public service to the capital) and the 20th of the Health and Safety Lawyers’ Association. Brake, the road safety charity, was established 30 years ago. In addition, the requirement to take a driving test was introduced 90 years ago. Transport and safety management are niche areas. There are other and some even older bodies but each champion and recognises the benefits of expertise in these fields, seeking to support stakeholders and safe operations.

9. Assurance Statement

In accordance with the Regulators’ Code, the Traffic Commissioners for Great Britain support the principles of the Growth Duty contained in section 108 of the Deregulation Act 2015. The Traffic Commissioners recognise their responsibility to have regard to the desirability of promoting economic growth while exercising their relevant functions.

The Traffic Commissioners have reviewed their functions and determined that, while they are in scope of the Growth Duty as regulators, tribunal and other civil proceedings are excluded from this duty under Section 111(2)(b)(ii) of the Deregulation Act 2015. Accordingly, this assurance statement applies to all regulatory functions except those constituting civil proceedings.

During the reporting period, the Traffic Commissioners have taken steps to ensure that their policies and decisions support fair competition and reduce unnecessary burdens on compliant operators, while maintaining public safety and environmental standards. Engagement with stakeholders and internal reviews have supported this approach.

The Traffic Commissioners will continue to monitor their compliance with the Growth Duty and ensure that the distinction between in-scope and out-of-scope functions is clearly maintained.

This Assurance Statement reflects our well-established governance arrangements and assists in identifying areas where support might be improved. The concept of ‘support’ implies the provision of assistance, not something which is imposed. Following the reorganisation of support functions, the tripartite liaison needs to better recognise the expertise of Traffic Commissioners and place sufficient weight on our concerns. The Traffic Commissioners’ Audit and Risk sub-committee previously identified the need for more formal reporting processes whereby higher-level risks are communicated to the sponsoring Department. That facility was utilised in December 2023 and again at the close of this reporting year.    

The Traffic Commissioners acknowledge the positive move in the separation of the Office of the Traffic Commissioner from the Enforcement Directorate of the DVSA and the appointment of a Chief Operating Officer. This will assist in mitigating the risk of legal challenge related to a perceived lack of independence of the Traffic Commissioner role with the enforcement agency. The long overdue updating of the legal Framework Document, which sets out the relationship between the Department for Transport (including Agencies) and the Traffic Commissioners, will further assist in addressing these concerns. A draft was supplied to DfT in February 2025, and it is important that progress is now made on the updating of this document.  

The escalated risk also referred to challenges in the recruitment of Traffic Commissioners. At the time we referred to the average period taken to hire civil servants across all departments, with security clearance taking up to an additional four months. The absence of a full-time Traffic Commissioner presents a real risk to the listing of safety-related cases and to the efficient determination of applications. The absence of a full-time Traffic Commissioner for Scotland is a particular risk due to the devolved legislation related to local bus services. The delay in appointing even an Acting Traffic Commissioner has not assisted. We remain hopeful that this vacancy will be filled by Autumn 2025 and lessons can be learned from how the recruitment process can be accelerated and improved in the future.       

We reported last year that the DVSA transformation of the support services provided by staff in the Office of the Traffic Commissioner presented a short-term risk in the delivery of those services. Although many of the services are recovering, the Traffic Commissioners are concerned with the longer-term effect to services related to driver conduct casework, the processing of local bus services and regulatory cases in some local hearing centres. The TC Board is regularly updated on the progress to alleviate these risks and expect OTC managers to ensure the return of the services to acceptable levels as soon as possible. However, the internal audit report on the management of that project has still not been supplied to Traffic Commissioners. 

Matters relating to the estate must be addressed and the full requirements of the Service Level Agreement with DVSA and the principles of the Equal Treatment Bench Book respected. We reported last year that five of the nine tribunal centres do not currently meet the agreed tribunal specification, mostly due to accessibility. This includes the lack of equipment to facilitate those people who are hard of hearing at tribunal. The tribunal centres are not currently compliant with the legal standards, and we are awaiting DVSA to take the appropriate action.

The licensing staff and North-Eastern tribunal have moved into a shared Government building. This was intended to deliver modern tribunal and office facilities. It is unclear why it was thought appropriate to agree to restrictions on visitors to such an extent that the concept of a fair and public hearing may be open to challenge. This is not acceptable in a modern tribunal.

We reported last year on concerns for the safety and working environment of those deployed to the Office of the Traffic Commissioner. The abuse of public-facing workers continues to attract a higher profile. We regret that those concerns extend to both Commissioners and OTC staff with physical incidents and on-line abuse continuing during the reporting period. Some progress has been made towards the necessary control measures, but this must clearly be a priority for the new Chief Operating Officer and DfT. Traffic Commissioners have set out explicit warnings in the Terms and Conditions for access to the Vehicle Operator Licensing business system, which operators and their representatives rely on to manage their operator licence details.

We continue to benefit from established data management processes. DfT previously provided support through the provision of the legally required Data Protection Officer (DPO). We are pleased to now have a permanent Data Protection Officer in place based within the Office of the Traffic Commissioner. This ensures that we comply with relevant data legislation and that our arrangements provide assurance to Traffic Commissioners as the independent data controllers and the service users that data is protected and managed appropriately.

The Traffic Commissioners have continued to support operators involved in the collective legal claim against several major truck manufacturers, following the European Commission’s findings that these companies colluded illegally on pricing and emissions technology. The Traffic Commissioner Information Access Team received over 1,000 requests for data during the reporting year, reflecting the scale of potential claimants and the importance of this issue to the road haulage sector.

Transparency Data: Information relating to the salaries, spending, gifts and hospitality of traffic commissioners is published on GOV.UK.

10. Provision of Support Services to the Traffic Commissioners

Paragraph 7 of Schedule 2 of the Public Passenger Vehicles Act 1981 provides that: “Subject to the approval of the Treasury, the Secretary of State may appoint such persons to act as officers and servants of a traffic commissioner as he considers appropriate”. This support is necessary in order to carry out our functions and is provided by the Driver and Vehicle Standards Agency (DVSA) and those DVSA staff who are deployed to the Office of the Traffic Commissioner.

It is important that the services the Traffic Commissioners may reasonably expect is set out and agreed by the relevant parties. The agreed level of services that the DVSA provide to the Traffic Commissioners, and by extension the regulated industries, is contained in a Service Level Agreement (SLA) that is regularly reviewed.  

10.1 Performance Measures

The SLA sets out 12 separate measures covering all aspects of our functions that the OTC will record and report on to the Traffic Commissioner Board. The table below shows the performance over the reporting year.   

We report quarterly performance on three of these measures due to their importance to those that we regulate.

Measure	Target	Performance
Public Inquiries to be listed to a date that is within 12 weeks of the decision to call the PI	95%	82%
Average processing time to determine applications for goods vehicle operator licences (or to provide interim authority) where a PI or Preliminary Hearing is not held	35 days	31 days
Average processing time to determine applications for PSV operator licences where a PI or Preliminary Hearing is not held	35 days	34 days

Traffic Commissioners are pleased that DVSA Board has now adopted all three of these measures as publicly reported business targets for the 2025/26 reporting year. Previously, only the target related to applications for goods licences had been included. However, Traffic Commissioners would like to see DVSA go further still and to ensure that service performance is transparent to all service users.

The SLA also covers a number of other important commitments to ensure the effective running of the support services. These include:

• ensuring that the legal requirement for the Traffic Commissioners’ independence is recognised and respected;

• defining service level standards to the Traffic Commissioners and their corresponding agreed service levels, in order to deliver a service to operators and applicants that can be relied upon as part of their business planning;

• assisting OTC staff by clearly defining their roles and responsibilities and avoiding a conflict of interest due to their employment by DVSA;

• setting out how data is handled and stored providing sufficient data assurance to Traffic Commissioners;

• assisting in the management of resources across the Office of the Traffic Commissioner;

• providing clearly defined targets that will deliver improved budget setting and Traffic Commissioner Strategic Objectives.

In addition to the administrative support provided by the OTC staff, the SLA details the support functions that are provided by the wider DVSA. These include the provision of IT, data handling, audit, risk and performance reporting and Estates and Facilities.    

As part of the commitment to Estates and Facilities, DVSA should carry out regular risk assessments of all accommodation for TCs and review them not more than every two years and in line with its statutory duties. This requires DVSA to go beyond its narrower interests, to consider what is required for fair hearings, which are accessible and meet the principles of the Equal Treatment Bench Book. Suitability of the accommodation, in particular with regard to the tribunal functions of the Traffic Commissioners, is required as are business continuity plans for each location, to be reviewed every six months. 

The SLA recognises that operator fees pay for the services provided, and in exchange DVSA will ensure that OTC has a workforce of the right size and shape, with the right skills to provide the following services now and in the future.

The DfT Accounting Officer is responsible for agreeing the budget required to fund the Traffic Commissioners’ regulatory activity with DVSA in January of each year. It is also essential for Traffic Commissioners to be provided with an accurate record of not only expenditure by DVSA but also the actual cost of the services provided to Traffic Commissioners, where this is not clear from the expenditure alone. A report containing this information for all schemes relevant to the income from the licensing fees and expenditure on the work of the Traffic Commissioners should be provided by DVSA at each Traffic Commissioner Board. A representative of DfT is invited to the quarterly OTC fees group and should provide assurances to the Traffic Commissioner Board that appropriate financial processes are being followed. That has not occurred. Traffic Commissioners repeat the request for the terms of the SLA to be adhered to and more transparent accounts made available, particularly there are moves to consider the reform of operator licence fees.

All the services that are detailed in the Service Level Agreement should be delivered to allow effective support to be provided to the Traffic Commissioners. We would encourage the Department for Transport to monitor delivery against the agreed Service Level Agreement.  

11. Statistics

11.1 Goods vehicle operators

Table 1:           Licences continued and in issue

Table 2:           Numbers of specified vehicles on licences

Table 3:           Applications for new licences and to vary existing licences

Table 4:           Results of opposed applications for new licences and for publishable variations to licences

Table 5:           Complaints against existing operating centres

Table 6:           Action taken at public inquiry for non-compliance

Table 7:           Results of unopposed new and variation applications heard at public inquiry

11.2 Public service vehicle operators

Table 8:           Licences continued and in issue

Table 9:           Discs in issue

Table 10:         Applications for new licences and to vary existing licences

Table 11:         Results of applications heard at public inquiry

Table 12:         Special Restricted public service vehicle operator licences

Table 15:         Number of Standard, Large and Community Bus Permits issued

Table 16:         Action taken at public inquiry for non-compliance (under the Public Passenger Vehicles Act 1981)

11.3 Local bus services

Table 13:         Live, new, variations and cancelled

Table 14:         Flexible bus registrations

Table 17:         Action taken against operators (under the Transport Acts 1985 and 2000)

11.4 Public Inquiries, Upper Tribunal Appeals, Driver Conduct & Impounding Hearings

Table 18:         Total number of completed Public Inquiries

Table 18a:       Total number of completed preliminary hearings and Senior Team Leader interviews

Table 19:         Public service vehicle and goods vehicle operator - Appeals to the Upper Tribunal

Table 20:         Large Goods Vehicle and Passenger Carrying Vehicle driver conduct cases - action against drivers

Table 21:         Applications for the return of impounded vehicles

Please note that some of the statistics set out in the tables are compiled manually by OTC staff. This can result in the potential for minor inaccuracies occurring within the statistics. To minimise the potential for inaccuracies the figures have been subject to a validation exercise undertaken by OTC managers who have provided the Traffic Commissioners with their assurance that the figures are accurate to the best of their knowledge. 

The statistics are a record of work undertaken in the 2024-25 reporting year, care should be taken when trying to compare data across reporting years. For example, an application may have been received in the last reporting year and then determined in this reporting year. Similarly, tables reporting the number of public inquiries held may not equal the sum of the columns which set out the regulatory action taken, this is because more than one action may be taken against an operator. In some cases, it is not possible to use the figures contained in some of the tables as a direct comparison to previous years due to a number of factors.

In particular, we draw attention to the following explanatory notes:

• Table 1: Goods vehicle operators – Licences continued and in issue. From the 2022-23 annual report the figures include Standard International licences issued to operators of Light Goods Vehicles.
• Table 2: Goods vehicle operators – Numbers of specified vehicles on licences. From the 2022-23 annual report the figures include Standard International licences issued to operators of Light Goods Vehicles.
  UK Licence for the Community replaced Community Licences in December 2020. Operators are also issued with an office copy and certified copies which have to be carried in vehicles on international journeys.
• Tables 3 and 4: Goods vehicle operators. The headings for columns C and D on Table 3 alongside columns E and F on Table 4 have been amended from “number of applications processed” to “number of applications determined” to make it clearer that an application is counted once it has been decided.
• Table 6: Goods vehicle operators – Action taken at public inquiry for non-compliance. The number of public inquiries held may not equal the sum of the columns which set out the regulatory action taken, this is because more than one action may be taken against an operator.
• Table 7: Goods vehicle operators – Results of unopposed new and variation applications heard at public inquiry. This table only shows applications that were heard at public inquiry. Some applications are heard at preliminary hearings, but these are not included in the figures in this table. Table 3 shows the total number of applications determined.
• Table 10: Public service vehicle operators – Applications for new licences and to vary existing licences. The figures for withdrawn applications included those treated as withdrawn because the fee had not been paid.
  The heading for columns C and D have been amended from “number of applications processed” to “number of applications determined” to make it clearer that an application is counted once it has been decided.
• Table 11: Public service vehicle operators – Results of applications heard at public inquiry. This table only shows applications heard at public inquiry. Some applications are heard at preliminary hearings, but these are not included in the figures in this tables. Table 10 shows the total number of applications determined.
• Table 13 and 14: Local Bus Service Registrations – It is not possible to draw direct comparisons across different reporting years for the following reasons.
  Prior to 2019-20 the total number of live local bus service registrations included an element of double-counting as services running in multiple local authority areas were recorded multiple times, e.g. a service running between the West Midlands and Staffordshire was presented as two services when it should have been counted as a single service. This has now been rectified.
  The implementation of the Bus Open Data requirements has identified a number of services that, although registered with a Traffic Commissioner, have not operated for some time. The OTC has carried out a data cleansing exercise to remove these services. This exercise has also identified services across Great Britain that were registered to entities that no longer held the correct licences.
  In addition, the Bus Services Act 2017 enables local authorities to take on the responsibility for registering local bus service registrations under an Enhanced Partnership Scheme or franchising scheme. The registration data for services operated wholly within an applicable scheme are now held by the local authority and have been removed from these data tables.

The number given for the total of live local bus registrations in 2023-24 was incorrect due to a calculation oversight. The figure given did not include services registered in Wales, which led to an underreported total. The corrected total number of live local bus registrations for 2023–24 is 10,581 and we have taken steps to update the relevant published materials to reflect this correction.
- Table 15: Number of standard, large and community bus permits issued – this table relates to permits issued under section 19 and section 22 of the Transport Act 1985.
The numbers of permits issued by local authorities or designated bodies cannot be verified. A small number of permit issuing bodies have been unable to provide returns, or have provided incomplete returns to the Traffic Commissioners. The figures provided for permits issued by the Traffic Commissioners are correct.
Data is also available on all valid, refused and revoked permits issued by the Traffic Commissioners within the last 5 years, this publication is updated on a weekly basis and is available here: https://www.gov.uk/government/publications/section-19-section-19-large-and-section-22-permits-issued-under-the-transport-act-1985 - Table 16: Public service vehicle operators – Action taken at public inquiry for non-compliance (Under the Public Passenger Vehicles Act 1981). The number of public inquiries held may not equal the sum of the columns which set out the regulatory action taken, this is because more than one action may be taken against an operator. - Table 17: Local bus services – Action taken against operators (under the Transport Act 1985 and 2000). The figures include all cases heard under section 26 of the Transport Act 1985 and section 155 of the Transport Act 2000. In addition to bus reliability this also includes cases related to The Public Service Vehicles (Open Data) (England) Regulations 2020.
In Scotland a penalty is imposed under Section 39 of the Transport (Scotland) Act 2001. - Table 19: Appeals to the Upper Tribunal - the number of appeals heard cannot be directly compared to the number of appeals made in the year, as some of the appeals heard will have been made in the previous year, and some may still be pending. - Table 20: Large Goods Vehicle and Passenger Carrying Vehicle driver conduct cases – Action against drivers. The figures for military drivers were first reported for the reporting year 2019-20. - Table 21: Applications for the return of impounded vehicles - the number of applications received and determined may be greater than the number of vehicles impounded as more than one application may be made for the return of a vehicle where there is a dispute regarding the ownership of a vehicle.

12. Contact Details

Further details about the commissioners and their other publications can be found at: https://www.gov.uk/government/organisations/traffic-commissioners

Queries regarding Statistics -       Email: tcco@otc.gov.uk

Address: Traffic Commissioners for Great Britain Corporate Office

Eastbrook

Shaftesbury Road

Cambridge

CB2 8BF

Media Enquiries -                          Email: pressoffice@otc.gov.uk

https://www.gov.uk/government/organisations/traffic-commissioners/about/media-enquiries

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[1] Bus Services (No.2) Bill debated in the House of Lords on 13 February 2025

[2] Department for Transport, Transport Statistics Great Britain: 2024  

[3] Department for Transport, International road freight activity data for quarter 4 2023 to quarter 3 2024

[4] Department for Transport, Annual bus statistics: year ending March 2024

[5] Office for National Statistics, EMP13: Employment by industry, 13 May 2025

[6] Figures represent the period 2024-25 as set out in the statistical section of this report.

[7] https://www.gov.uk/government/publications/traffic-commissioners-strategic-objectives-for-2023-to-2025

[8] https://www.gov.uk/government/publications/traffic-commissioners-service-level-agreement-sla-with-dvsa

[9] https://www.gov.uk/government/publications/traffic-commissioner-function-review-2021-to-2022

[10] https://www.gov.uk/government/consultations/review-of-traffic-commissioners-for-great-britain-function

[11] https://www.gov.uk/government/publications/triennial-review-of-traffic-commissioners-implementation-plan

[12] https://www.gov.uk/government/publications/bus-back-better

[13] https://www.transport.gov.scot/public-transport/buses/transport-scotland-act-2019-and-bus-services

[14] Report of casualties by road user type and vehicles involved, Great Britain 2023