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Article · 11 min read
Protecting your TfL PHV licence after an accident: what to report and when
A TfL PHV licence is a PHV driver's livelihood. An accident that is mishandled or not properly reported can put the licence at risk independently of civil liability. This guide covers the reporting duties, timelines, and how to manage TfL's assessment.
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Protecting your TfL PHV licence after an accident: what to report and when
A TfL private hire vehicle (PHV) driver's licence is more than a document - it is the legal authority to earn a living from private hire work in London. TfL has the power to revoke, suspend or refuse to renew a PHV driver's licence where they are not satisfied that the driver is fit and proper. An accident, handled correctly, need not threaten that status. An accident that is mishandled, unreported where reporting was required, or that resulted in an endorsement or prosecution that was not disclosed, can lead to a formal review with potentially serious consequences.
This guide explains the TfL reporting obligations following an accident, what TfL actually assesses when they receive a report, how to document and present a non-fault accident to TfL, and how to work with an accident management company to protect your position.
What you must report to TfL and when
TfL's PHV driver licence conditions require a driver to notify TfL of any criminal conviction, caution, endorsement or fixed penalty notice within 21 days of the outcome. A road traffic accident that resulted in a fixed penalty notice, an endorsement, or a criminal charge - for example, a careless driving allegation, a failure-to-stop offence, or a defective-vehicle notice - must be reported within 21 days of the outcome (the notice, endorsement or charge).
Where an accident led to a police attendance and an immediate Fixed Penalty Notice being issued at the scene (for example for a non-endorsable offence like not wearing a seatbelt), that notice should be reported to TfL within 21 days. Where a prosecution is commenced by summons - typically weeks or months after the accident - the 21-day clock runs from the service of the summons.
A non-fault accident that resulted in no offence being alleged, no FPN and no prosecution does not of itself require notification to TfL under the standard licence conditions. However, where an accident was serious (involving injury to a third party) or where TfL is likely to become aware of it through police intelligence, proactive notification is recommended. Failure to self-report an event that TfL later learns about independently is treated by TfL as an aggravating factor in any fitness assessment.
Outside London, local authority PHV licensing conditions vary. Many councils require notification of any accident involving the licensed vehicle within 24 to 72 hours. Check the specific conditions attached to your local authority PHV licence and comply strictly with those requirements.
DETAIL
03
Section 3 of the walkthrough.
What TfL assesses when they receive an accident report
TfL's Private Hire Unit assesses PHV driver fitness using guidance developed in line with the Transport for London (Private Hire) Regulations 2001 and TfL's published licensing policy. The central question is whether the driver remains a fit and proper person to hold a licence. An accident report triggers a review of the driver's overall record, not just the single incident.
TfL's assessment looks at: the nature and circumstances of the accident; whether the driver was at fault; whether the driver complied with their reporting obligations (section 170 RTA, operator notification, TfL notification); whether any prosecution or endorsement followed; and the driver's overall traffic record including any previous accidents, endorsements or TfL regulatory actions.
A single, straightforward non-fault accident where the driver followed all reporting requirements and has a clean prior record is very unlikely to result in any adverse licensing action. TfL is not seeking to penalise drivers for circumstances beyond their control. The licensing framework is focused on conduct.
An at-fault accident, particularly one involving injury to a passenger or third party, or one where the driver failed to stop, failed to report, or faces a prosecution, is treated more seriously. TfL may call the driver for an interview before the licensing committee, request a DVLA driving licence check, and review the full file before deciding whether to take licensing action.
How to present a non-fault accident to TfL
If you need to report an accident to TfL - because it resulted in an endorsement, charge or FPN - prepare a clear, factual account of the incident that supports your non-fault position. The account should include: the date, time and location of the accident; a description of the collision circumstances; the police reference number if officers attended; the name and insurer of the at-fault driver; the outcome of any police investigation or prosecution; and your own compliance with section 170 duties.
Attach supporting documents where available: your accident management company's initial report, the police report or reference, the at-fault driver's details, and any dashcam or CCTV evidence. TfL's assessment is aided by clear documentation and a straightforward, honest account.
Do not speculate or theorise about the accident beyond the factual record. Do not comment on whether you believe the at-fault driver should be prosecuted. Present the facts as they are evidenced and let TfL draw their own conclusions.
DVLA reporting and licence endorsements
Separate from TfL, an accident resulting in penalty points or an endorsement on your driving licence must be managed with care. PHV drivers with certain levels of endorsement on their DVLA licence may be reviewed by TfL under their licensing policy. TfL has access to DVLA driver record information as part of the licence-renewal process.
If you receive an endorsement as a result of an accident (even a non-serious endorsement such as SP30 for a speed limit offence discovered during the collision investigation), notify TfL within 21 days. Do not wait for the renewal date.
Where a prosecution is contested - for example where you believe the allegations are wrong - you are entitled to defend the criminal charges in the magistrates' court. A specialist road traffic solicitor can advise on the defence. TfL will typically await the outcome of criminal proceedings before making a final licensing decision on a contested matter.
06DETAILKey takeaway
Working with an accident management company to protect your licence
An accident management company that works regularly with PHV drivers understands the TfL reporting framework alongside the civil claim. They can coordinate the evidential record - dashcam footage, police correspondence, the at-fault driver's details - in a way that supports both the civil claim and any TfL review.
Where TfL calls you for an interview, take the opportunity seriously. Attend punctually, bring your documentation, and answer questions honestly. If the review is in connection with a serious at-fault accident or a pattern of incidents, legal representation at the interview is advisable.
The most important protective factor is timely compliance with all reporting obligations. A driver who followed the letter of the regulations - reported to TfL within the required period, notified the operator, cooperated with police, and opened a proper insurance claim file - demonstrates the conduct expected of a fit and proper licence holder. That demonstration is itself the strongest protection your licence has.
Take action
If you have just been in a non-fault collision, the fastest way to protect your claim is to open the file with us inside the first hour. We dispatch recovery, lodge the relevant CCTV requests inside the retention window, and notify the third-party insurer for you.
We do not provide legal advice. This article is general guidance for UK drivers. Personal injury enquiries are referred only with your consent to authorised legal or regulated partners. Specific limits, retention windows and process steps may change; the position at the date of any individual collision will govern the handling of that claim.
Frequently asked questions
- Do I have to report a non-fault accident to TfL?
- Only if it resulted in a fixed penalty notice, endorsement, charge or conviction. A clean non-fault accident with no criminal or traffic enforcement outcome does not require mandatory TfL notification under the standard licence conditions, although voluntary disclosure is advisable where the accident was serious or TfL is likely to hear about it independently.
- TfL has written to me asking about an accident I did not report - what should I do?
- Respond promptly and honestly. Explain the circumstances of the accident, the reason it was not reported (if there was no obligation to do so), and provide all supporting documentation showing you acted correctly at the time. A failure to respond promptly to TfL is treated as an aggravating factor.
- Will TfL suspend my licence while they investigate?
- TfL has the power to immediately suspend a licence where they believe there is an immediate risk to public safety. For most accident-related reviews, TfL reviews the file before taking any action and gives the driver an opportunity to make representations. Immediate suspension is reserved for serious ongoing risk scenarios.
- My endorsements put me close to six points - will TfL revoke my licence?
- TfL's licensing policy considers endorsements as one factor among several. Six points does not automatically result in revocation; TfL assesses the nature of the offences, the driver's overall record, and the circumstances of the endorsements. However, approaching or exceeding the new-driver limit (six points in the first two years) or reaching 12 points (which triggers a DVLA totting-up ban) are significant flags in TfL's assessment.
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