Automated Vehicles regulations clarify consent requirement for taxi & PH services

New secondary legislation under the Automated Vehicles Act 2024 provides further detail on the permitting regime for automated passenger services (APS), with particular emphasis on the role of local licensing authorities where services resemble taxis or private hire vehicles.

Section 85 of the Act establishes that certain automated passenger services—specifically those that operate in a way comparable to taxi or private hire services—are subject to a consent requirement from relevant licensing authorities.

Section 85 of the Automated Vehicles Act 2024 provides that the “appropriate national authority” must obtain the consent of each licensing authority in whose area the service may be provided before granting a permit.

The recently published regulations governing APS permits make this position explicit in operational terms. They confirm that:

the appropriate national authority may not grant a permit without the consent of each licensing authority in whose area the service may be provided under the proposed permit.

This reflects the structure set out in the primary legislation and places it clearly within the procedural framework for determining permit applications.

Role of licensing authorities

Under the APS regime, automated vehicle services are authorised through a national permitting system rather than through existing taxi or private hire licensing legislation. However, section 85 ensures that local authorities retain a defined role where services fall within the scope of taxi- or PHV-like activity.

In practical terms, this means:

• each relevant licensing authority must be identified as part of a permit application;

• consent must be obtained from all such authorities before a permit can be granted;

• absence of consent from any one authority prevents the grant of the permit.

This applies irrespective of whether the proposed service operates across one or multiple local authority areas.

Interaction with existing licensing frameworks

The APS framework operates separately from taxi and private hire vehicle licensing regimes. Nonetheless, the consent requirement links the two systems by requiring local authority agreement where there is functional similarity in service provision.

The regulations therefore do not replicate taxi or PHV licensing controls, but they do require local authorities to assess and determine whether to consent to the operation of relevant automated services within their areas.

Institute of Licensing response

The Institute of Licensing has addressed these provisions in its consultation response on the automated vehicles regulatory framework. The response highlights the importance of clearly defining the role of licensing authorities and ensuring that their involvement is maintained where automated services overlap with established taxi and private hire functions.

It also notes the need for clarity in how consent decisions will operate in practice, particularly for services spanning multiple licensing areas.