Cross-border hiring and subcontracting for private hire firms

Cross-border hiring in private hire covers two different things: a car licensed by one council working in another council's area, and an operator passing a booking to a firm licensed somewhere else. Both are legal in England and Wales, within limits. This guide explains the triple licensing lock, the subcontracting rules in sections 55A and 55B of the Local Government (Miscellaneous Provisions) Act 1976, who's liable when a job is passed on, and what changed or was proposed in 2025 and 2026. London has its own licensing law and TfL rules, so check those separately.

Is cross-border hiring legal for private hire firms?

Yes, if the three licences match. Outside London, section 46(1)(e) of the 1976 Act says a licensed operator must not operate a vehicle as a private hire vehicle unless the vehicle has a current private hire vehicle licence and the driver a current private hire driver licence. Read with the rest of the Act, that means the operator, the driver and the car must all be licensed by the same council. The Supreme Court called this the "triple licensing lock" in 2025.

The journey itself can cross boundaries. The House of Commons Transport Committee's June 2026 report sums up the law: out-of-area working, where vehicles licensed by one authority work wholly or mainly in another, "is permitted under current legislation", provided the operator, driver and vehicle are all licensed by the same authority.

Hackney carriages are a different case. The Department for Transport's best practice guidance says taxi licence holders can carry pre-booked fares anywhere in England and Wales. Plying for hire is another matter. Bristol City Council tells drivers of hackney carriages licensed elsewhere that they can't work mainly in Bristol, use its ranks, wait at the roadside for customers or be hailed.

What does the Deregulation Act 2015 let you do?

Section 11 of the Deregulation Act 2015 inserted sections 55A and 55B into the 1976 Act, in force from 1 October 2015. Under section 55A, an operator who has accepted a booking in its own district may arrange for another person to provide a vehicle to carry it out, in four cases:

Three details matter in practice:

1. Section 55A(2) says it doesn't matter whether your contract with the passenger allows subcontracting.
2. Under section 55B(2), you aren't treated as operating the vehicle yourself, so the triple lock applies to the second operator's own licences, not to yours.
3. Under section 55B(3), you commit an offence if you pass a booking to an operator licensed by a council in England or Wales outside London who then uses an unlicensed car or driver, and you knew they would.

So you can't pass work to a firm and look the other way. If you know their car or driver isn't licensed by their council, the offence is yours too.

Who is liable when you pass a booking on?

You are. Section 56(1) of the 1976 Act says every contract for the hire of a licensed private hire vehicle "shall be deemed to be made with the operator who accepted the booking for that vehicle whether or not he himself provided the vehicle."

The Supreme Court looked at that section in D.E.L.T.A. Merseyside Ltd v Uber Britannia Ltd [2025] UKSC 31, decided on 29 July 2025. It held that section 56(1) is a deeming provision: it doesn't force operators to contract as principal, but it makes the operator who accepted the booking liable to the passenger whatever the mechanics of the hire. The court described its purpose as generating "real world" liability for the operator.

The paperwork and the safeguarding duty stay with you as well:

• Your council's record-keeping conditions under section 56 still apply to the booking you accepted. Our guide to operator record keeping sets out what goes in the record.
• The Statutory Taxi and Private Hire Vehicle Standards say operators may outsource booking and dispatch but "cannot pass on the obligation to protect children and vulnerable adults", and should be required to show the other company applies comparable protections.
• Some councils ask for more detail. Bristol's operator conditions require a register that includes the name of the person who took the booking and the person who dispatched the vehicle.

Why is out-of-area working controversial?

Because the council that licensed a car may be hundreds of miles from where it works, and only that council can act against it. The figures show the scale. The Department for Transport counted around 38,000 private hire vehicles licensed by Wolverhampton on 1 April 2026, 13.1% of all private hire vehicles in England and 135.4 licensed vehicles per 1,000 residents, more than four times the next highest authority. The DfT notes that this "reflects where vehicles are licensed, not necessarily where they operate."

The Transport Committee heard that nearly half (49%) of private hire vehicles in Greater Manchester are licensed by authorities outside its ten councils, according to Stockport Council's evidence. The Committee also quotes the Local Government Association's councillor handbook: a council can only take action against a vehicle or driver it has licensed, so against one licensed elsewhere it can do little more than complain to the home authority.

The Committee concluded that out-of-area working is "now a widespread feature" of the market, but that outright prohibition "would be impractical". It recommended the government bring forward a clear plan to curtail it and give drivers reasons to license where they work.

Councils can already cooperate. The statutory standards ask licensing authorities, where the need arises, to jointly authorise officers from other authorities so they can take enforcement action against licensees from outside their area.

What is the government changing?

Some of it is law and some is still a proposal. Here's where each piece stood on 9 October 2026:

Nothing in that list changes the subcontracting rules yet. The triple lock, sections 55A and 55B, and your liability under section 56 all apply today. If you're planning to work in a new area, our guide to expanding a taxi firm into a new town covers the licensing choices.

How do you subcontract a booking safely?

Treat every operator you pass work to as part of your own service, because in law it is.

1. Check the other operator's licence with their council, and that their cars and drivers are licensed by the same council.
2. Put the arrangement in writing: which jobs, prices, who the passenger deals with, and how complaints come back to you.
3. Ask for evidence of their safeguarding policy and staff checks, as the statutory standards expect.
4. Check their cars carry hire and reward insurance for private hire use.
5. Record on your own booking that the job was passed on, to whom, and when.
6. Tell the passenger which firm and car are coming, even though section 55A doesn't require their permission.
7. Don't pass a job on if you suspect the car or driver isn't properly licensed.

Dispatch AI is booking and dispatch software for taxi and private hire firms. Whichever system you use, the booking record should show when a job went to another operator and who that was. The rules on operator licences themselves are in our guide to getting a private hire operator licence, and the Statutory Taxi and Private Hire Vehicle Standards guide covers what councils expect of operators.