Flex Taxis has written a letter on cross-border app-based private hire operations, calling for national action to protect locally licensed taxi services and introduce mandatory geofencing. Dated 12 September 2026, the letter was written by the directors of Flex Taxis Ltd and addressed to Simon Lightwood MP, Parliamentary Under-Secretary of State and Minister for Buses and Local Transport at the Department for Transport.

Copies were also sent to Lewis Cocking MP, Councillor Corina Gander and Broxbourne Borough Council’s Licensing Services. The letter asks the Government to examine how immediate app bookings affect local licensing accountability, independent operators and the future of hackney carriages.

A quick app booking raises a wider question about local accountability

Passengers understandably value convenient booking, clear prices and short waiting times. The policy question is whether the licensing framework provides sufficient accountability where vehicles regularly work, rather than only where their licences were issued.

Government standards distinguish taxis, which can be hired at ranks or hailed in the street, from private hire vehicles, which must be pre-booked through a licensed operator. The standards also describe a triple licensing lock: the operator fulfilling a booking must use drivers and vehicles licensed by the same authority that granted its own licence (Department for Transport, 2020).

That lock does not require the pickup to take place inside the licensing authority's boundaries. Since the Deregulation Act 2015, operators have also been able to subcontract bookings to operators licensed by other authorities. A vehicle licensed elsewhere is therefore not operating unlawfully simply because it collects a passenger locally.

Uber serves Broxbourne without a Broxbourne licence

Uber does not hold a private hire operator's licence from Broxbourne Borough Council. The Council’s published guidance confirms that it does not license Uber as an operator (Broxbourne Borough Council, n.d.). Cross-border private hire bookings can be lawful under the current framework, provided the applicable booking and licensing requirements are met. Flex Taxis is asking the Government to examine the local accountability arising from these arrangements.

The Council does not have the same direct licensing control over drivers, vehicles and operators licensed elsewhere. Authorities must share relevant safeguarding and road safety concerns with the authority licensing a driver, which decides whether to suspend or revoke that licence (Department for Transport, 2023). Flex Taxis argues that these arrangements do not provide equivalent accountability to the community where services regularly operate.

Flex Taxis reports serious pressure on its business

In its representation, Flex Taxis reports an approximately 75% reduction in revenue, which it attributes to market pressure from Uber's widespread local availability. This is the company's own account; it is not an independently verified estimate of Uber's effect or a measure of losses across the national trade.

The company describes nearby drivers receiving immediate app bookings as an "invisible digital taxi rank". This is a campaign term for the practical effect of vehicles waiting for digitally generated demand, not a legal finding that an app booking amounts to taxi-rank activity.

The underlying concern deserves investigation: can smaller operators and independent taxi drivers remain viable when a platform serves local demand through licences issued elsewhere?

Government has recognised that licensing patterns can affect smaller operators

The Department for Transport's official statistics acknowledge that, under the current system, drivers may obtain a licence from an authority outside the area in which they mainly work (Department for Transport, 2026b). The same release shows the direction of the market: at 1 April 2026, England had 52,300 licensed taxis, down 7% since 2024, and 290,000 licensed private hire vehicles, up 13%.

The Department's consultation, published on 8 January 2026, acknowledges that drivers may license elsewhere to work for popular operators, and that this can reduce the pool available to operators licensed by the original authority (Department for Transport, 2026a). It sought views on moving licensing responsibility to larger local transport authorities, and closed on 1 April 2026.

Larger licensing areas could improve consistency and access to drivers. Flex Taxis argues that any reform should also examine where apps accept bookings and how authorities oversee vehicles regularly working across their boundaries.

Accessible taxis make this a passenger issue

Official figures for England at 1 April 2026 show that 54% of licensed taxis were wheelchair accessible, compared with 2% of licensed private hire vehicles (Department for Transport, 2026b).

These figures do not establish that app competition caused accessible vehicles to leave the trade. They do show why any assessment of taxi-service viability must include disabled passengers and the availability of suitable vehicles.

People who prefer telephone bookings or need assistance should also feature in policy decisions. Passenger choice depends on keeping useful alternatives available.

Geofencing should be assessed alongside its practical consequences

Geofencing uses location technology to restrict an app's activity within defined boundaries. Flex Taxis proposes preventing an operator from accepting or dispatching a pickup in an area where it does not hold an operator's licence.

In Broxbourne, this would have a direct effect, because Uber holds no licence from the borough council. National implementation would need to address operators holding multiple licences, subcontracted bookings and the licensing arrangements of the drivers and vehicles fulfilling each journey.

The proposal would apply to the operator responsible for the booking. A software supplier supporting a locally licensed business would not be treated as the operator merely because it provides the app.

Any assessment should test effects on waiting times, fares, rural coverage, accessible transport and empty return journeys. It should also explain how subcontracted bookings and journeys near boundaries would be handled.

The campaign asks for evidence and a clear policy decision

Flex Taxis is calling for:

• A published assessment of cross-border app operations and their effects on local services.
• Consideration of geofencing, with passenger and driver impacts assessed openly.
• Clear enforcement responsibilities between licensing authorities.
• A plan to sustain accessible hackney carriage services and meaningful passenger choice.

To support the campaign, Freedom of Information requests have been prepared to seek government assessments, licensing guidance and local figures, including confirmation of which operators Broxbourne Borough Council licenses. These requests are intended to establish what authorities have examined and what evidence they hold.

Residents and drivers can support the campaign by asking their council and MP how reforms will protect service availability, accessibility and accountability. Documented changes in bookings, operating costs and unmet passenger needs will provide stronger evidence than general accusations.

What happens next for licensing reform

The Government's decision following its consultation will shape who licenses taxis and private hire vehicles in England and over what area. Flex Taxis is asking that the decision also address where operators may accept bookings, so that larger licensing areas do not simply widen the gap between where vehicles are licensed and where they work.

Frequently Asked Questions

Is Uber allowed to operate in Broxbourne?

Uber’s lack of a Broxbourne operator’s licence does not automatically make a local pickup unlawful. Cross-border bookings must satisfy the applicable licensing requirements, including the triple licensing lock for the operator fulfilling the booking.

Can a private hire driver pick up outside their licensing area?

A pickup outside a licensing area is not automatically unlawful; what matters is that the booking is taken by a licensed operator using drivers and vehicles licensed by the same authority. The Flex Taxis campaign seeks a change in policy rather than claiming every cross-border journey breaches existing law.

What is the triple licensing lock?

The triple licensing lock is the rule that a private hire operator must use drivers and vehicles licensed by the same authority that licensed the operator. It governs who licenses each part of a journey, not where the journey takes place.

What is the difference between a taxi and a private hire vehicle?

A taxi, or hackney carriage, can be hired at an authorised rank or hailed in the street where its licence permits, while a private hire vehicle must be pre-booked through a licensed operator.

Can councils stop out-of-area private hire vehicles working locally?

A council cannot assume that a pre-booked pickup is unlawful merely because the vehicle is licensed elsewhere. Its powers depend on the circumstances and applicable arrangements, including duties to report safeguarding and road safety concerns to the issuing authority.

Would geofencing ban taxi booking apps?

No. The Flex Taxis proposal would restrict where an operator could accept pickups, while allowing locally licensed businesses to continue using booking technology.

Local services need a place in the next licensing framework

The Government should assess whether the market can sustain convenient app bookings alongside accessible taxis and independent local operators. Flex Taxis is asking for published evidence and a clear decision about how those services will remain accountable and available.

References

Broxbourne Borough Council (n.d.) Hackney Carriage and Private Licensing. Available at: https://www.broxbourne.gov.uk/licensing/apply-taxi-private-hire-licence (Accessed: 4 October 2026).

Department for Transport (2023) Taxis and Private Hire Vehicles (Safeguarding and Road Safety) Act 2022: statutory guidance. Available at: https://www.gov.uk/government/publications/taxis-and-private-hire-vehicles-safeguarding-and-road-safety-act-2022/taxis-and-private-hire-vehicles-safeguarding-and-road-safety-act-2022 (Accessed: 4 October 2026).

Deregulation Act 2015, c. 20. Available at: https://www.legislation.gov.uk/ukpga/2015/20/contents (Accessed: 4 October 2026).

Department for Transport (2020) Statutory taxi and private hire vehicle standards. Last updated 25 November 2022. Available at: https://www.gov.uk/government/publications/statutory-taxi-and-private-hire-vehicle-standards/statutory-taxi-and-private-hire-vehicle-standards (Accessed: 4 October 2026).

Department for Transport (2026a) Local transport authorities and the licensing of taxis and private hire vehicles. Available at: https://www.gov.uk/government/consultations/local-transport-authorities-and-the-licensing-of-taxis-and-private-hire-vehicles (Accessed: 4 October 2026).

Department for Transport (2026b) Taxi and private hire vehicle statistics, England: 2026. Available at: https://www.gov.uk/government/statistics/taxi-and-private-hire-vehicle-statistics-england-2026/taxi-and-private-hire-vehicle-statistics-england-2026 (Accessed: 4 October 2026).

Flex Taxis Ltd (2026) Formal Policy Representation: Request for National Action on Invisible Digital Taxi Ranks and the Future of Hackney Carriages. Letter dated 12 September. Company-supplied campaign document.

Campaign organiser: Flex Taxis Ltd, https://www.flextaxis.com/

Disclaimer

This article presents Flex Taxis' campaign proposals and reported experience. It does not establish that any particular operator or journey is unlawful, or that one platform caused wider industry changes. It is not legal advice.

Posted: October 4, 2026