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Council-licensed private hire, outside London
Private Hire Courtesy Car and Replacement Vehicle for Council-Licensed Drivers
If your private hire vehicle is off the road after a non-fault accident, a standard courtesy car will not keep you working. You need a replacement your own licensing authority will plate, insured for hire and reward, and built to that council's conditions. CityGrip arranges recovery, storage, repair and a licensed replacement, and deals with the other side's insurer for you.
- Licensed plated replacement
- Hire & reward literate
- Loss of earnings recovered
- ULEZ / ZEC screened
24/7
UK response
Recovery dispatch and live claim handlers, 365 days a year.
Response
<60m
First contact SLA
Cost
£0
Upfront to driver
Reviewed: Written & reviewed by: CityGrip Editorial Team (City Grip Ltd)Applies to: Private hire drivers licensed by local councils outside Londonবাংলায় পড়ুন
Can a private hire driver use a courtesy car for bookings?
Not usually. A standard private hire courtesy car from a garage or insurer is unplated and insured for social, domestic and pleasure use, so it cannot lawfully carry paying passengers. Outside London you need a replacement your own council will licence and plate, insured for hire and reward, and matching that authority's vehicle conditions. Where another driver was at fault, we can arrange a like-for-like private hire replacement car on credit hire, subject to liability and eligibility, so you keep taking bookings while yours is repaired.
Key points
- Section 46 of the Local Government (Miscellaneous Provisions) Act 1976 requires three separate licences for lawful private hire outside London: the vehicle under section 48, the driver under section 51 and the operator under section 55.
- Dittah v Birmingham City Council [1993] RTR 356 established the triple licensing rule: for any hiring, the operator, driver and vehicle licences must all be issued by the same licensing authority.
- Section 50(3) of the 1976 Act requires the proprietor to report accident damage materially affecting the vehicle's safety, performance or appearance to the district council within 72 hours.
- Section 48 requires the council to issue a plate or disc for each licensed private hire vehicle, and the vehicle may not be used unless that plate is displayed as the council prescribes.
- The Deregulation Act 2015 set three years as the standard private hire driver licence term and five years for a private hire operator licence.
- Seven charging Clean Air Zones operate in England (Bath, Birmingham, Bradford, Bristol, Portsmouth, Sheffield and Tyneside). Taxis and private hire vehicles must be Euro 6 diesel or Euro 4 petrol to avoid a charge.
- Greater Manchester's charging Clean Air Zone was scrapped in January 2025 in favour of an investment-led plan agreed with government.
- Licensing authorities must have regard to the Statutory Taxi and Private Hire Vehicle Standards issued on 21 July 2020 under section 177 of the Policing and Crime Act 2017.
Why a standard courtesy car cannot lawfully do private hire work
The courtesy car that most repairers and insurers offer is a small hatchback handed over on an ordinary private motor policy. It is a perfectly good car for the school run and it is close to useless for a licensed driver. Under section 46 of the Local Government (Miscellaneous Provisions) Act 1976, no person may use a vehicle as a private hire vehicle in a controlled district without a current vehicle licence under section 48. Section 48 requires the district council to issue a plate or disc identifying that vehicle as a private hire vehicle, and the proprietor may not use it in the district unless that plate is displayed in the manner the council prescribes by condition. A courtesy car carries no plate, so it is not a licensed private hire vehicle, whatever the hire paperwork calls it.
Insurance is the second wall. Ordinary cover is written for social, domestic and pleasure use, which does not extend to carrying paying passengers. Private hire work needs hire and reward cover, a different class of use altogether, and a courtesy car issued on a garage or insurer trade policy will almost never carry it. If you take a booking in an unplated car on social, domestic and pleasure cover, you are not simply risking a licensing penalty. You are potentially driving without effective insurance for the journey you are actually making, and an insurer can decline the claim if something goes wrong. That exposure sits on you personally, not on the person who handed you the keys.
The third wall is your operator and, if you work through an app, the platform. Section 46(1)(e) of the 1976 Act makes it an offence for an operator to despatch a vehicle as a private hire vehicle unless that vehicle holds a current vehicle licence and the driver holds a current driver's licence. Operators and booking platforms therefore hold your vehicle details on file and match the registration against the licence, the logbook and the insurance certificate before work is allocated. A car that is not on your licence and not on your operator's records will not be dispatched to you, which means a private hire courtesy car does not just fail the legal test, it fails the practical one too.
The three licences behind every lawful private hire booking
Outside London, private hire is regulated by district and unitary councils under Part II of the Local Government (Miscellaneous Provisions) Act 1976, not by Transport for London. The framework rests on three separate licences. Section 51 licenses the driver, section 48 licenses the vehicle, and section 55 licenses the operator who takes and despatches the bookings. All three have to be in force for a booking to be lawful. Lose any one of them and the job cannot be carried out legally, even if the other two are perfect. That is why an accident that takes your vehicle off the road stops your income immediately, and why replacing the car is not simply a convenience question but a licensing question.
The three licences also have to come from the same place. In Dittah v Birmingham City Council [1993] RTR 356 the courts confirmed what the trade calls the triple licensing rule, or the trinity of licences: for any given hiring, the operator licence, the driver licence and the vehicle licence must all be issued by the same licensing authority. You cannot bolt a vehicle plated by one council onto a driver badge and operator issued by another and expect the booking to stand up. This single point defeats a great many well-meaning replacement vehicle offers. A car plated by the authority next door is not a lawful substitute for your own plated vehicle, however clean, modern and available it happens to be.
Licence durations were standardised by the Deregulation Act 2015, which set three years as the standard term for a taxi or private hire driver's licence and five years for a private hire operator's licence, with shorter terms only justified on the facts of an individual case rather than by blanket policy. On top of that, licensing authorities must have regard to the Statutory Taxi and Private Hire Vehicle Standards issued by the Secretary of State on 21 July 2020 under section 177 of the Policing and Crime Act 2017, and a council that departs from them has to give clear reasons. The result is a national floor for safeguarding sitting under a patchwork of very local vehicle rules.
PCO DRIVERS
03
Section 3 of the walkthrough.
Your council's conditions decide what replacement you can actually drive
Section 48(2) of the 1976 Act sets the outline test. Before a council grants a vehicle licence it must be satisfied the vehicle is suitable in type, size and design for use as a private hire vehicle, is not of a design and appearance likely to make anyone think it is a hackney carriage, is in a suitable mechanical condition, is safe and comfortable, and carries insurance complying with Part VI of the Road Traffic Act 1988. Section 48(6) then lets the council attach any conditions it considers reasonably necessary, expressly including conditions requiring or prohibiting the display of signs on or from the vehicle. That single power is where the national picture fragments, because every authority writes its own conditions.
The practical spread is wide. Some authorities require a vehicle to be under three years old when first licensed, others allow first licensing up to around eight years, others up to ten, and some will keep licensing a compliant vehicle well into its teens on condition-based testing. Signage rules diverge just as sharply: some councils insist on rear door stickers warning that the vehicle is not insured unless pre-booked through an operator, some require a council-issued window wallet showing the plate number, registration, expiry date and passenger capacity, and some run exemptions for executive work. Department for Transport best practice guidance actually advises authorities not to impose blanket age limits and to use targeted emissions, safety and accessibility requirements instead, but that guidance is advisory and many councils still apply age policies.
Most authorities do have a route for exactly your situation, usually called a temporary vehicle or replacement vehicle policy. The shape varies but the pattern is recognisable: you apply for a temporary vehicle licence, the plate from the damaged vehicle normally has to be surrendered before a temporary vehicle can be plated, the substitute must be of similar type and class or better than the vehicle it replaces, and a current certificate of insurance covering private hire use must be produced. Time limits differ, with some councils working to a matter of weeks and others allowing up to around three months. Because none of this is uniform, the only safe instruction is to read your own council's conditions or ring its licensing team before you commit to any vehicle.
Cross-border hiring, out-of-area licensing and your replacement
Cross-border hiring is now a normal feature of the trade rather than an oddity. A driver, vehicle and operator licensed by one authority can lawfully fulfil pre-booked work that begins or ends outside that authority's area, so a plate issued in one town regularly turns up working the streets of a city a long way away. City of Wolverhampton Council became the best known example after it opened an online application route, and it now licenses a very large number of private hire drivers, the overwhelming majority of whom live outside the city. The council has told MPs that current legislation prevents it refusing applications purely on residency grounds and has itself called for a uniform national regime with stronger enforcement powers.
For a driver whose car has just been written off or taken in for repair, cross-border working has one blunt consequence. The replacement has to be plated by the authority that issued your driver badge and that licenses your operator, not by the authority in whose streets you happen to earn your living. If you hold a Wolverhampton badge but work nightly in another city, a vehicle plated by that other city is no use to you, and a Wolverhampton plate is what you need even though no enforcement officer in Wolverhampton may ever see it. Enforcement officers in the area you actually work in can and do stop licensed vehicles, check plates, insurance and operator details, and report drivers back to their issuing authority.
There is live reform pressure in this space. A parliamentary inquiry into licensing and standards in the taxi and private hire sectors has run, the Department for Transport has signalled work on national licensing standards, and proposals for a national framework have been raised in the context of devolution legislation. None of that changes the position on the day your car is damaged. Until reform actually takes effect, the rules that bind you are your own licensing authority's conditions, read alongside the 1976 Act and the triple licensing rule. Plan your replacement around the authority on your badge, and treat anything you read about future national standards as background rather than as permission.
Clean Air Zones: making sure your replacement can work where you do
Seven charging Clean Air Zones currently operate in England: Bath, Birmingham, Bradford, Bristol, Portsmouth, Sheffield and Tyneside covering Newcastle and Gateshead. The classes differ, so Birmingham and Bristol operate class D zones that charge cars as well as commercial vehicles, Portsmouth runs a class B zone and Bath, Bradford, Sheffield and Tyneside run class C zones. What matters to you is that taxis and private hire vehicles are chargeable in every one of those zones regardless of class. The minimum standard for a taxi or private hire vehicle to avoid a charge is Euro 6 for diesel and Euro 4 for petrol, and charges apply every day of the year, so a non-compliant replacement quietly eats into your takings on every shift.
Greater Manchester is a useful counterexample and a common source of confusion. Plans for a charging Clean Air Zone across Greater Manchester were scrapped in January 2025 in favour of an investment-led plan agreed with government, so a Manchester-licensed driver faces no charging zone at home. That is not the end of the question, though, because plenty of drivers licensed in one region take airport runs and long pre-booked jobs into cities that do charge. If your normal working pattern takes you into Birmingham, Bradford, Sheffield or Tyneside, the replacement needs to clear the standard for those zones even if your own city has none.
Two separate tests are in play and it is worth keeping them apart. The Clean Air Zone test decides whether you pay a daily charge to drive in a particular city. Your licensing authority's own emissions and age policy decides whether the vehicle can be plated at all, and some councils set standards tighter than the zone requires. Charge levels, exemptions and local grant schemes change from year to year, so check the current position with the government's vehicle checker and with the relevant council rather than relying on a figure you saw quoted somewhere. When you speak to us, tell us which zones you actually work in and we will factor that into the specification of the private hire replacement car we source.
06PCO DRIVERSKey takeaway
Loss of earnings when you are a self-employed private hire driver
Almost every private hire driver is self-employed, which means there is no employer payslip to prove what the accident cost you. The evidence has to be built from your own records, and the earlier you start the stronger it is. The documents that carry weight are your weekly or monthly platform statements, operator settlement statements showing jobs completed and money paid across, invoices you have raised, bank statements showing income landing, and your self assessment tax returns or tax year overviews for the periods before the accident. A clean run of statements covering several months before the collision gives a much better baseline than a single week picked at random.
Loss of earnings is normally assessed on net loss, not gross takings. That means the calculation looks at the income you would have earned less the running costs you did not have to spend while the vehicle was off the road, typically fuel or charging and mileage-related wear. Costs that carried on regardless still count against you, so keep proof of anything you kept paying: vehicle finance or rental instalments, hire and reward insurance premiums, plate and badge fees, operator or circuit fees and app charges. There is also a duty to keep losses down. If a lawful, licensed replacement is available and you turn it away, an insurer will argue you should have taken it and limited the claim rather than sitting off the road.
Drivers who rent or lease their vehicle from a fleet sit in a slightly different position. You may not own the damaged car, but you may still be liable under the rental agreement while it is off the road, and you may face a deposit or excess exposure. Keep the rental or lease agreement, the schedule of charges and any correspondence from the fleet operator, because those documents establish what the accident genuinely cost you. None of this guarantees recovery. Loss of earnings, credit hire and replacement vehicle costs all depend on liability being established against the other driver, on the losses being evidenced, and on the amounts being reasonable and proportionate.
How we run a non-fault private hire claim from first call to repair
CityGrip Accident Claims is an accident management company. When you call us after a non-fault accident we take control of the practical work: recovery of the damaged vehicle from the roadside, secure storage so it is not sitting on the street accumulating risk, an independent engineer inspection to record the damage and value, and coordination of the repair with an approved repairer. We also handle correspondence with the third-party insurer, which is the part most drivers find hardest to manage around a shift pattern. You do not need to chase adjusters between airport runs, and you do not need to accept the first offer that lands in your inbox.
On the vehicle itself, the aim is a like-for-like licensed replacement rather than a generic private hire courtesy car. That means a vehicle we can get plated by your licensing authority under its temporary or replacement vehicle policy, insured for hire and reward, meeting your council's conditions on age, type, size and signage, and compliant with the emissions standards for the zones you work in. Where liability rests clearly with the other driver, this is normally arranged on a credit hire basis so you are not funding it out of pocket, with the cost pursued from the at-fault insurer. Availability, eligibility and liability always qualify what can be provided, and we will tell you plainly if your case does not support it.
Two boundaries are worth stating clearly. We do not handle personal injury in house. If you or a passenger has been hurt, we can refer the injury element to authorised legal partners, and we only do that with your separate written consent, never automatically as part of the vehicle claim. Second, we work on transparent, low fees precisely because the trade has grown wary of arrangements that quietly erode what the claimant ends up with. If you want the wider comparison between credit hire and a standard courtesy car, our general replacement vehicle pages cover it, and London drivers holding TfL licences should use our dedicated PCO pages instead, since the licensing framework there is entirely different from the one described here.
Step by step
What to do next
- 1Make the scene safe and capture the evidence. Stop, check whether anyone is hurt and move to safety if you can. Take the other driver's name, address, vehicle registration and insurer details, and photograph both vehicles, the damage, the road layout and any signage or road markings. If passengers were on board, note the booking reference from your operator or app so the journey can be evidenced later. Get dashcam footage saved and backed up before it overwrites, and report the collision to the police if the road is blocked, someone is injured or details were not exchanged.
- 2Report the accident to your licensing authority within 72 hours. Section 50(3) of the Local Government (Miscellaneous Provisions) Act 1976 requires the proprietor of a licensed vehicle to report to the district council any accident causing damage that materially affects the safety, performance or appearance of the vehicle, or the comfort or convenience of passengers carried in it. The report must be made as soon as reasonably practicable and in any event within 72 hours. Check your own council's preferred method, because some require a specific form or email address, and keep a copy of what you send and the date you sent it.
- 3Tell your operator and any booking platform straight away. Your operator cannot lawfully despatch work to a vehicle that is not licensed and insured, so let them know the car is off the road before your next shift. If you drive through an app, update the account so you are not marked as available in a vehicle that is unusable. When a replacement is arranged, you will need to add its registration, vehicle licence and insurance certificate to both the operator's records and the platform account before work can be allocated to it. Building that in early avoids losing further days once the replacement is physically ready.
- 4Call CityGrip before you accept any courtesy car. Ring us before signing for a vehicle offered by a repairer, broker or insurer. Once you have accepted an unplated private hire courtesy car, you have effectively taken a vehicle you cannot work in, and it can complicate the argument for a proper licensed replacement later. Tell us which council issued your badge and vehicle plate, who your operator is, which platforms you drive on, the vehicle you normally drive and the areas you cover. That is the information we need to specify a replacement that will actually get plated and put you back on bookings.
- 5Check your council's temporary vehicle policy and get the replacement plated. Ask your licensing authority for its temporary or replacement vehicle procedure and read the conditions before the vehicle is delivered. Expect to surrender the plate from the damaged vehicle before a substitute can be plated, to show a certificate of insurance covering private hire use, and to provide the V5C or a letter of authority from the vehicle's owner. Confirm the maximum period the council will allow, whether the substitute must match or better the class of the original, and what signage must be fitted. We can prepare the documentation pack with you.
- 6Confirm emissions compliance for every zone you work in. Before the replacement is confirmed, check it against the government's Clean Air Zone vehicle checker for each city you drive into, not just the one you are licensed in. For taxis and private hire vehicles the standard is Euro 6 for diesel and Euro 4 for petrol. Separately, check your own council's emissions and age policy for licensing, because some authorities set a tighter standard than the charging zone does. If your work regularly takes you into Birmingham, Bradford, Bristol, Sheffield or Tyneside, say so at the outset so the specification allows for it.
- 7Start your loss of earnings record from day one. Download your platform and operator statements for at least the three to six months before the accident and keep them somewhere safe, along with bank statements and your most recent self assessment return or tax year overview. From the date of the accident, log every day the vehicle is off the road, every shift you could not work and every fixed cost you still had to pay, including finance or rental instalments, insurance, plate and badge fees and operator charges. Contemporaneous records carry far more weight than a reconstruction produced months later.
Related PCO pages
PCO accident claims hub →
The full picture for TfL-licensed London private hire drivers.
Accident in a hired PCO car →Who claims what when you rent or rent-to-buy your vehicle.
PCO replacement car →A licensed, plated replacement so you can keep working.
PCO loss of earnings →Evidencing and recovering self-employed income.
PCO courtesy car →What you are offered versus what you are entitled to.
PCO car written off →Total loss, valuations and rent-to-buy consequences.
TfL licence & accidents →Notification duties and licence risk after an incident.
Minicab & PHV hub →The wider UK private hire vertical.
Frequently asked questions
- Can I use my insurer's courtesy car to keep doing private hire bookings?
- Almost certainly not. A standard courtesy car has no private hire vehicle plate, and section 46 of the Local Government (Miscellaneous Provisions) Act 1976 makes it an offence to use an unlicensed vehicle as a private hire vehicle in a controlled district. It will also be insured for social, domestic and pleasure use rather than hire and reward, so carrying paying passengers could leave you without effective cover. Your operator or app cannot lawfully despatch work to it either, because the registration will not match your licensed vehicle. If you are non-fault, ask about a licensed replacement instead before accepting anything.
- What is the difference between a private hire courtesy car and a private hire replacement car?
- People use both phrases loosely, but the practical difference is licensing. A courtesy car is a stopgap vehicle lent by a repairer or insurer on ordinary cover, unplated, and fine for personal use only. A private hire replacement car is specified to keep you working: your licensing authority can plate it under its temporary vehicle policy, it carries hire and reward insurance, it meets that council's conditions on age, type and signage, and it can be added to your operator and platform records. Where another driver is at fault, the replacement is usually arranged on credit hire, subject to liability and eligibility.
- Does the replacement have to be licensed by the same council that issued my badge?
- Yes. The triple licensing rule confirmed in Dittah v Birmingham City Council [1993] RTR 356 means that for any given hiring, the operator licence, the driver licence and the vehicle licence must all be issued by the same licensing authority. A vehicle plated by a neighbouring council cannot lawfully be used against your badge and your operator's licence. That is why we ask which authority issued your licences before sourcing anything, and why we work through your own council's temporary or replacement vehicle process rather than simply supplying whatever plated car happens to be nearest.
- I hold a Wolverhampton licence but work in another city. Whose rules apply to my replacement?
- Your issuing authority's rules apply. Cross-border hiring is lawful, so a driver, vehicle and operator licensed by one council can fulfil pre-booked work elsewhere, and large numbers of drivers licensed in Wolverhampton work in other cities. But the replacement vehicle must be plated by the authority that issued your driver licence and licenses your operator, and it must meet that authority's vehicle conditions. Enforcement officers in the area you actually work in can still stop you and check the plate, insurance and operator details, then report back to your issuing council, so the paperwork has to be right.
- How long can I keep a temporary licensed replacement vehicle?
- It depends entirely on your licensing authority. Councils run their own temporary or replacement vehicle policies, and the maximum periods vary, with some working in weeks and others allowing up to around three months for a vehicle off the road after an accident. Most require the plate from the damaged vehicle to be surrendered before a substitute is plated, and returned again before the original or a new licence is issued. Check your own council's published conditions and, if the repair is going to run long, ask about an extension well before the temporary licence expires rather than afterwards.
- Will I be charged in a Clean Air Zone driving a replacement vehicle?
- Only if the replacement does not meet the standard. Seven charging Clean Air Zones operate in England: Bath, Birmingham, Bradford, Bristol, Portsmouth, Sheffield and Tyneside covering Newcastle and Gateshead. Taxis and private hire vehicles are chargeable in all of them, and the minimum standard to avoid a charge is Euro 6 for diesel or Euro 4 for petrol. Greater Manchester scrapped its charging zone in January 2025, so there is no charge there. Check any specific vehicle on the government's Clean Air Zone checker, and tell us which cities you work in so compliance is designed in from the start.
- Can I claim loss of earnings if I am self-employed on Uber, Bolt or a local circuit?
- You can put forward a loss of earnings claim, but it has to be evidenced and it is never guaranteed. The strongest evidence is a run of platform or operator statements covering several months before the accident, plus bank statements and your self assessment return or tax year overview. Loss is normally assessed net of the running costs you saved while off the road, so keep proof of the fixed costs you kept paying, such as finance or rental, insurance, plate and badge fees. There is also a duty to limit your losses, which is another reason to take a lawful licensed replacement when one is available.
- Do I really have to tell my council about the accident?
- Yes, if the damage is more than trivial. Section 50(3) of the Local Government (Miscellaneous Provisions) Act 1976 requires the proprietor of a licensed vehicle to report to the district council any accident causing damage that materially affects the safety, performance or appearance of the vehicle, or the comfort or convenience of passengers. The report must be made as soon as reasonably practicable and in any case within 72 hours. Failing to report can put your vehicle licence at risk and can complicate any application for a temporary replacement, so make the report early and keep a copy of it.
- What happens if the other driver's insurer disputes who was at fault?
- Liability disputes are common and they affect everything that follows, because a replacement vehicle, credit hire and loss of earnings all depend on establishing that the other driver was at fault. If liability is contested, the evidence you gathered at the scene becomes decisive: dashcam footage, photographs, independent witness details, the police reference if one exists and the booking record for the journey. We will tell you honestly where we think a case stands rather than putting you into arrangements the evidence will not support, and we will explain your options if the position looks genuinely split.
- Does CityGrip deal with injury claims for private hire drivers?
- We do not handle personal injury in house. CityGrip is an accident management company, so our work is recovery, secure storage, engineer inspection, repair coordination, licensed replacement vehicles and correspondence with the third-party insurer. If you or a passenger has been injured, we can refer that part to authorised legal partners, and we only make that referral with your separate written consent. It is never bundled automatically into the vehicle claim, and you are free to decline the referral and use your own solicitor while we continue managing the vehicle side for you.
Important notice for PCO drivers
Liability remains subject to the at-fault driver's insurer's assessment and the available evidence. Replacement vehicle, credit hire, recovery, storage, repair and loss of earnings support are subject to eligibility, the evidential record and reasonable need. We do not provide legal advice and we do not handle personal injury in-house: injury enquiries are referred only with your separate written consent to authorised legal or regulated partners. Information about TfL private hire licensing, Zero Emission Capable standards, vehicle age limits and notification duties is general guidance, not legal or licensing advice, and the position applying to your own licence at the relevant date will govern. Rental, rent-to-buy and finance terms vary between providers: always check the specific clauses in your own agreement.
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