Summary
These Regulations establish the licensing regime for London private hire vehicle (PHV) operators under the Private Hire Vehicles (London) Act 1998. They prescribe: application procedures and fees (£425 grant, £25 variation); licence durations and fees (£975 for 5 years or £375 for small operators with ≤2 vehicles); conditions including £5M public liability insurance, fare disclosure, CB radio prohibition, and notification of convictions/changes; extensive record-keeping requirements for bookings, vehicles, drivers, complaints, and lost property with prescribed retention periods; refund provisions for operators ceasing or transferring operations; and transitional temporary permit provisions.
Reason
This regulation exemplifies the regulatory burden that suppresses dynamic markets. The mandatory operator licensing creates an entry barrier that protects incumbents rather than serving genuine public interest. The £975 licence fee plus £425 application fee imposes substantial upfront costs on new entrants, particularly harmful to small operators and startups seeking to compete with established firms. The extensive record-keeping regime (booking records retained 6 months, vehicle/driver records 12 months, plus separate complaint and lost property records) imposes disproportionate administrative compliance costs that fall heaviest on smaller operators, creating a structural advantage for larger incumbents. The CB apparatus prohibition arbitrarily restricts operators from using a legitimate communication technology. While consumer protection justifications are cited, market mechanisms (reputation, liability law, insurance markets) would discipline operators more efficiently than bureaucratic record-keeping mandates. The graduated fee structure based on vehicle count further entrenches market concentration by making it more expensive to grow. This is retained EU-style regulation that has never received proper democratic scrutiny.