Simplifying driving licence upgrade and motorcycle test rules: response to consultation
Updated 14 July 2021
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Executive summary
The Department for Transport (DfT) in conjunction with the Driver and Vehicle Standards Agency (DVSA) and the Driver and Vehicle Licensing Agency (DVLA) sought views on the Department’s proposals to:
- change the way some driving licences are upgraded from automatic to manual entitlement when a driver passes certain driving tests
- reduce the size of motorcycles that can be used for the A2 category motorcycle test, as measured by the cubic capacity of their engine.
The overall reaction to the proposals was positive. Ministers have taken into consideration all the comments made. To implement the proposals will require amendments to regulations and we will seek to do this as soon as possible.
Questions asked
1. Do you agree with the proposal to change licence upgrades?
Under this proposal a driver who passes a B+E, C1, C1+E, D1 or D1+E test using a vehicle with a semi-automatic or automatic transmission, would get both the automatic and manual entitlement for that sub-category provided that they already hold a manual entitlement for category B, C or D, or a sub category thereof.
2. Do you think this proposal would have any effect on road safety?
Is there any significant road safety issue in carrying forward a driver’s manual entitlement for one type of vehicle to another, when they pass a test using an automatic vehicle?
3. Do you have any information on the costs, or benefits to industry or society that you think would come from this proposal?
This helps us to understand any broader impacts of the proposal to change licence entitlement upgrades.
4. If you have a business that would be affected by this proposal, please tell us whether you think it would have an overall cost or benefit.
This helps us to understand the specific impact on businesses of the proposal to change licence upgrades.
5. Do you agree with our proposal to allow drivers to retrospectively claim manual entitlement if they have the corresponding automatic entitlement and a manual entitlement for another category?
This helps us to decide if drivers should be able to claim new entitlements on the basis of those they already hold, rather than take a test.
6. Do you agree that car and trailer tests (B+E) should be included with the change to licence upgrades?
The previous change to licence upgrade arrangements related to large vehicles. This proposal covers the ‘sub-categories’ of those vehicles and also the car and trailer test. This question checks that people agree that this proposal can reasonably include car and trailer tests.
7. Do you agree with the proposal to reduce the minimum test vehicle requirement for category A2 motorcycles?
The proposal is to reduce the size of motorcycles that can be used for the A2 category test from 395cc to 245cc, provided they meet the power output and other criteria.
8. Do you think that this proposal (reduction in A2 MTV) would have any impact on road safety?
This helps us understand if there is any road safety issue with implementing this proposal.
9. Do you have any information on the costs, or benefits, to industry or society which you think would come from the proposal?
This will help us to understand if there are any broader costs or benefits to the proposal to reduce the A2 MTV.
10. If you have a business that would be affected by this proposal, please tell us whether you think it would have an overall cost or benefit.
This will help us to understand the specific impacts on businesses of the proposal to reduce the A2 MTV.
Introduction
On 9 February 2021, DVSA published an online consultation on amendments to the law concerning driving licence upgrades and the motorcycle test. The consultation ran until 22 March.
The consultation set out the government’s proposals to change the licence entitlements that are granted when a driver, who is already able to drive a car, lorry or bus, or minibus with a manual gearbox, passes another test in one of the following categories using a vehicle with automatic transmission. The categories are:
- car and trailer - B+E
- medium sized lorries - C1
- medium sized lorries and a trailer - C1+E
- minibuses - D1
- minibuses and a trailer - D1+E
It also set out a proposal to reduce the MTV requirement for the motorcycles that can be used to take the A2 category rider test. Bringing the engine capacity down from 395cc to 245cc – provided that the motorcycle meets the other requirements to be classed in the A2 category.
General observations
1,266 responses were received via the online consultation, along with 10 by email.
In order to check that a range of people had responded to the consultation, respondents were asked to tell us if they are trainers, or members of the public, or representative organisations.
| Who you are | % of respondents |
|---|---|
| Prefer not to say | 2.24 |
| Other | 10.88 |
| Representative body | 1.68 |
| Motorcycle trainer | 13.68 |
| Bus or minibus trainer | 1.6 |
| Large goods vehicle trainer | 4.16 |
| Car and trailer trainer | 23.28 |
| Member of the public | 42.48 |
It should be noted that the ‘car and trailer trainer’ group will include both driving instructors, who would teach you how to drive a car, and those who specialise in teaching drivers how to tow trailers.
As there were two quite separate proposals, of interest to different groups of people, not all of the respondents completed each question. Others completed every question but indicated ‘no comment’ where they had no input to offer. This may also have had the effect of inflating the ‘neither agree nor disagree’ response rates shown in the following tables. For that reason, the actual number of respondents for each option has been given.
Among the representative organisations that provided comments were the Motorcycle Action Group, the Caravan and Camping Club, the Road Haulage Association, and the Chartered Institute of Logistics and Transportation in the UK. They all provided positive support for the proposals.
Ministers would like to thank everyone who contributed to this consultation.
Disclosure of information
As part of the consultation, DVSA said that, unless the respondents made clear that their responses were to be treated as confidential, at the end of the consultation period, it would publish some of the responses.
This report quotes comments only from respondents who have not requested confidentiality. However, the statistical analysis takes account of all the on-line replies.
Next steps
The new requirements will be implemented by making changes to the Motor Vehicles (Driving Licences) Regulations 1999, which apply to Great Britain.
Proposal 1: Licence upgrades – gaining a manual entitlement on passing an automatic test
Under this proposal drivers who already hold a manual entitlement for a car, lorry, bus or minibus, or a subcategory of one of those, who pass a test using a vehicle with automatic transmission for either a car and trailer (B+E), medium sized lorry (C1), minibus (D1), or C1 or D1 with a trailer, would gain both the automatic and the manual entitlements.
This would mean that their new entitlement would not be restricted to ‘automatics only’. It would recognise the fact that they had already passed a test for a manual vehicle, and not require them to take another test to lift a restriction.
Responses and considerations
Question 1. Do you agree with the proposal to change licence upgrades?
| Entitlement upgrade | Number of responses |
|---|---|
| Agree | 837 |
| Disagree | 287 |
| Neither agree nor disagree | 104 |
68.1% of respondents agreed with this proposal.
Some of the comments said that it makes sense to extend the licence issuing arrangements already in place for larger vehicles to the sub-categories. For example:
“Having the knowledge of how a manual clutch works is a transferable skill and should be recognised as such.”
Member of the public
“Will allow drivers to obtain additional entitlement without further needless testing which can be costly and time consuming.”
Member of the public
“Strongly agree. This is very sensible and will greatly assist training companies, particularly for car and trailer as many manufacturers of towing vehicles (4x4’s, pick ups etc) are moving more and more towards automatic transmission, limiting the choice of training vehicles.”
Car and trailer, lorry and minibus plus trailer trainer
“It has worked well in the bus industry, and I don’t see any problems with implementing this.”
Bus and minibus trainer
“It’s a logical step which, in my opinion, is long overdue.”
LGV trainer
However, some people said that road safety might be compromised because people might take time to get used to a gearbox on a vehicle if they had only driven automatic or semi-automatic transmission versions, and had not passed a manual test for that sub-category.
Question 2. Do you think this proposal would have any effect on road safety?
| Effect on road safety | Number of responses |
|---|---|
| Improve | 123 |
| Reduce | 315 |
| No significant impact | 755 |
It should be noted here that some respondents appear to have misunderstood the proposal as they thought that it applied to the full lorry and bus categories (C and D). For example, some of the comments referred to large vehicles and others to drivers having to learn how to use ‘split’ gearboxes. That may have adversely reduced the ‘in favour’ response.
Others made the point that gears are used in conjunction with brakes in large vehicles. Therefore, braking performance might be affected if someone failed to control the vehicle properly.
That comment could relate to large vehicles, but also to medium sized vehicles as they are heavier than cars. It could also apply to any inexperienced drivers learning to use a gearbox.
However, other people said that the manual gears on the vehicles specifically under consideration here (medium sized lorries – category C1, and minibuses – category D1) are usually six speed; and very similar to those in many cars. For example one person said:
“Considering vehicles driven under C1 and D1 entitlements have gearboxes similar to standard cars, drivers with a manual entitlement on their car licence will have no problem operating the gears on these types of vehicles.”
Bus and minibus trainer
The following comments are representative of those people who objected:
“Operating gears correctly is a fundamental area of driving that can not be transferred safely.”
Driving instructor
“Driving a vehicle with manual gears requires different skills and they should be examined and approved before the candidate is given a manual licence.”
Member of the public
“Due to the proliferation of semi auto and fully automatic cars, I encounter through my work dozens of manual B licence holders whose last experience of a manual vehicle was their category B driving test. Sometimes this is several years ago. The loss of motor skills regarding clutch/gears needs to be seen to be believed.”
Other – training professional
Some people suggested that a driver’s ability to use gears should be confirmed by a trainer; or, that there should be a minimum period for holding a manual entitlement before the upgrade could be granted or claimed. For example:
“In principle it is a good idea, but there should be a requirement to have familiarisation training for the different applicable classes of vehicle, as each type of vehicle behaves differently with a manual and automatic gearbox.”
Member of the public
“…. I appreciate most lorries are auto or semi auto but a manual lorry gearbox is very different to a car gearbox. I do hope employers will provide training if a candidate passed in an auto lorry and is expected to drive a manual having only driven a manual car”
Approved driving instructor and Car and trailer instructor
“Provided they have at least three years experience in gears.”
Car and motorcycle trainer
It would certainly be expected of employers to ensure that their drivers are comfortable and confident in driving any vehicle provided to them. This would be necessary to comply with health and safety regulations.
However, it should be noted that no additional stipulations around training, the verification of skills, or the length of time an existing licence entitlement had been held, were applied when similar changes were introduced for large vehicles, in 2014.
Costs and benefits
The next questions asked about the costs or benefits to society, industry, and individual businesses.
These questions were asked in order to help DVSA and DVLA check that the proposal would be likely to have a positive effect. Also, to gather information that could help us to produce an impact analysis.
Question 3. Do you have any information on the costs, or benefits to industry or society that you think would come from this proposal?
With regard to the wider costs or benefits to industry respondents suggested that employers would benefit by having a more flexible driver workforce.
They also said that trainers would have a better choice of vehicles, especially more fuel-efficient automatics. Similarly a driver, hiring a vehicle for example, would have more choice.
Some people pointed out that it would reduce the number of tests that DVSA would need to conduct. Thereby reducing waiting times for others.
One indicated that their business could make good cost savings in terms of training for a manual test, and another indicated that the saving in time was key to them.
Comments included:
“This is a must, as most C1 vehicles in the marketplace are automatic now. However in the construction industry manuals are preferred; so we need the team to have the ability to drive either. Difficult to assign a cost but we have spent £4800 in the last 3 years on additional training and tests.”
Business owner in the construction industry
“I agree with …. the savings for companies, however savings comes by means of time as well and the fact that drivers would only need to take one test would be a huge saving both in time and money.”
Bus or minibus trainer
Others said that the number of accidents and incidents, especially bumps and scrapes, might increase if a driver struggled to control a manual vehicle when not familiar with the gearbox. They said that insurance costs might increase as a result.
A number of people suggested that this proposal might help to promote the use of electric vehicles, which almost always have automatic transmission.
This is because they would be happy to train in an automatic, knowing that they could drive a manual vehicle if required. That could help society shift towards more fuel efficient and cleaner transport.
Question 4. If you have a business that would be affected by this proposal, please tell us whether you think it would have an overall cost or benefit.
| Response | Number of responses |
|---|---|
| Cost | 74 |
| Benefit | 260 |
| No significant cost or benefit | 326 |
More respondents (39.4%) thought there would be a benefit to their business, than thought there would be a cost (11.2%).
Some training organisations said that they would save money because they wouldn’t need to have both manual and automatic vehicles. Others pointed to savings on clutch replacements and to savings on fuel.
Some of the fuller replies said:
“Due to the cost saving for fuel I would estimate a benefit of between £500 to £1000 per annum plus currently a clutch tends to be replaced every 12 to 18 months at a cost of approximately £2,000’.”
Car and trailer trainer
“The cost benefit would be £5000 per year which is gained by the operation efficiency.”
HGV trainer
“Save clutch changes from reverse training when they struggle to get it. At £1k a time to change and one client can kill it in a session it would be a risk reduction.”
Medium and large vehicle trainer
Some trainers who already use automatic vehicles have said that they would expect an increase in the number of trainees, but others have said that, because of the proposal for retrospectively claiming entitlements, they might have fewer trainees.
Overall, in terms of costs or benefits, some respondents see a risk to road safety and point out that any injury or death would eclipse any economic gain. However, most respondents see some small benefits to test candidates, to training companies, and to wider industry and society.
Little substantive evidence to inform a substantive impact assessment was provided. However, it is clear that most of the costs and benefits are indirect and are relatively small in monetised terms. Some off-set each other. Therefore a ‘De-minimis’ approach has been taken. It indicates that the net present value to business, starting in 2021, and evaluated over 10 years might be in the region of £4.9 million. This is achieved through the direct saving in DVSA test fees.
Retrospective entitlements and the car and trailer category
The final two questions on this proposal checked if people were content for it to apply retrospectively and for it to apply to the car and trailer category.
When changes were made in 2014 drivers were allowed to claim manual entitlements if they already held the other relevant entitlements. They could do this by writing to DVLA
It is proposed to use the same mechanism to allow drivers to claim entitlements with these changes.
The consultation specifically asked if people were content for this proposal to apply to cars and trailers. This was because the previous changes had applied to large vehicles, which tend to be driven by professional drivers.
In contrast, the car and trailer category is more associated with recreational use.
Question 5. Do you agree with our proposal to allow drivers to retrospectively claim manual entitlement if they have the corresponding automatic entitlement and a manual entitlement for another category?
| Response | Number of responses |
|---|---|
| Agree | 744 |
| Disagree | 297 |
| Neither agree nor disagree | 137 |
63% of respondents agreed that drivers should be allowed to claim manual entitlements retrospectively.
Generally, people felt it was fair that if you could get the manual upgrade after passing a test then you should be able to get it if you have already taken the relevant tests.
However, some people said that you should always pass a test of competence to get the licence entitlement.
Typical comments were:
“Grandfather rights would reduce costs to existing drivers, reduce waiting times for tests; very important at this time.”
Car and trailer trainer
“If people’s circumstances change e.g. moves to another employment where the vehicles are manual and the last workplace had automatic vehicles that person can get on with their job without further tests, costs and waiting, especially now after the pandemic.”
Car and trailer trainer
“It is illogical to impose a restriction in the first place given that it has been abolished in the higher categories C and D it would be totally illogical and unfair to remove the restriction and not make it retrospective.”
Car and trailer trainer
“This is what happened with cat C and D. It really helped bus drivers to diversify into coach work.”
Anonymous
“90+% of my students know that the easy option is Automatic. But most want to learn properly. The law should support their effort and willingness to be road safe.”
Driving instructor
Some respondents suggested an assessment or verified training. Others suggested that a more automatic process should be used to issue the licences:
“I think a driving assessment should be carried out, not a test but an assessment with feedback.”
Approved driving instructor
“This shows a refreshing sign of pragmatism! Although can’t this be done automatically without requiring drivers to write (how archaic!) to the DVLA?”
Car instructor
The issue with these suggestions is that trainers would have to link into DVLA in order to confirm which drivers had completed their training or assessment. Also, issuing new licences to all drivers that could claim the upgrade would be quite burdensome and costly.
It could have associated logistical difficulties, including in mis-delivered licences, and could increase the risk of fraud.
Question 6. Do you agree that car and trailer tests (B+E)should be included with the change to licence upgrades?
| Response | Number of responses |
|---|---|
| Agree | 854 |
| Disagree | 213 |
| Neither agree nor disagree | 105 |
73% of respondents agreed the proposal should apply to the car and trailer test.
There was quite widespread support for this proposal. A cross-section of responses said:
“Common sense. The test is looking at competence of towing and manoeuvring a trailer, not driving a car.”
Member of the public
“Drivers must demonstrate the ability to drive a manual transmission as well as control vehicle speed while towing trailers. This is done by correctly using the brakes along with the gears. It takes practice to become proficient when driving and pulling trailers with these types of vehicles.”
Anonymous
“the relative numbers of people in these categories are small, most people will drive what they feel comfortable in, if a driver struggles with gears even if they have the entitlement they will mostly always veer towards automatic vehicles, that is my experience anyway.”
LGV trainer
Some people suggested that the manual licence should be held for a certain period of time before the upgrade could be applied to them. However, as there is no way of telling how much use has been made of an existing entitlement, it is not clear what benefit would be gained from such a restriction.
The decision
After taking all views into account the government has decided to introduce this proposal.
When the law is changed, candidates who hold a manual license for either a car, lorry, bus or minibus will get manual and automatic entitlements when they pass a test using a vehicle with automatic transmission for:
- car and trailer (B+E)
- medium sized lorry (C1)
- medium sized lorry and trailer (C1+E)
- minibus (D1)
- minibus and trailer (D1+E)
Proposal 2: Reducing the size of motorcycles that can be used for the A2 category test.
The law sets the MTV requirement for the vehicles that can be used on a practical driving or riding test.
For the A2 category that is currently 395cc, provided also that the power output is at least 20kW, but does not exceed 35kW. This proposal reduces the engine size to 245cc.
This will mean that people can use motorcycles for the A2 test that they feel more comfortable riding.
Responses and considerations
Question 7. Do you agree with the proposal to reduce the minimum test vehicle requirement for category A2 motorcycles?
| Response | Number of responses |
|---|---|
| Agree | 791 |
| Disagree | 137 |
| Neither agree nor disagree | 249 |
67.2% of respondents agreed that this measure ought to be introduced.
Some of the comments in favour were:
“The current limitations are outdated and do not properly reflect the motorcycles available on the market”
Anonymous
“This would benefit both the motor trade and allow younger riders to have a more relaxed progress up the power and size range.”
Motorcycle trainer
“I agree as this will make the A2 category more accessible to a wider range of riders. There is the potential for people testing on a bike that just meets the MTVs then going on to ride a machine at the other end of the spectrum. However, I don’t think there is sufficient differences in performance for this to be a concern. The benefits outweigh the disadvantages in this case.”
Member of the public
“Many people are put off taking post CBT training and testing because of vehicle weight. This addresses the issue and should encourage much needed training beyond CBT.”
Motorcycle trainer
“An excellent and long overdue idea. This would encourage people to ride smaller commuter style bikes, as well as offer a safer and more practical solution for physically smaller or weaker individuals. Strongly support this.”
Motorcycle training organisation
“A 250cc motorcycle (unlike the other restricted capacities of 50cc and 125cc) has similar performance to a typical car and is easily capable of keeping up with traffic, overtaking manoeuvres, etc. Thus, is a perfectly reasonable capacity for licencing riders for the A2 category.”
Member of the public
“Reducing the MTV requirements to a 250cc would benefit the smaller person in that they would safely be able to put a foot on the ground when they are stationary.”
“Experience has shown me that due to the size of the current machines being used for A2 tests some trainees’ are doing 2 or 3 CBT renewals because they don’t feel confident enough to ride a bigger machine or they cannot find one small enough.”
Motorcycle trainer
And some of the comments against were:
“Minimum test requirement of A2 should be closer to maximum power output of vehicle the rider could eventually ride when purchasing a bike. An A2 rider could for instance ride a 660 Triumph Trident as a first bike, a million miles away from a 250cc Honda CRF or similar.”
Member of the public
“A 245cc bike generally does not create a significantly different riding experience from a typical 125cc (learner-legal) and does not represent a sufficient step-up to warrant a separate licence in my opinion.”
Member of the public
“It is pointless, the larger bikes are equally as light and manageable as the smaller category, we have never had a student put off by the CC or size of the A2/DAS bikes and have taught hundreds of women/smaller riders. As the bikes can be lowered/restricted very easily it would not be cost effective to add more bike to a fleet due to an even lower CC. There is nothing to be gained other than UK bike sales.”
Representative body or organisation
Question 8. Do you think that this proposal (reduction in A2 MTV) would have any impact on road safety?
| Response | Number of responses |
|---|---|
| Improve | 374 |
| Reduce | 133 |
| No significant impact | 592 |
Some of the safety factors mentioned are that learners would be able to use a motorcycle that they could handle more easily, and not ‘drop the bike’.
This would mean that riders would take the training necessary for them to take and pass the A2 test; rather than riding a 125cc moped or motorcycle and continuously renewing their compulsory basic training (CBT) certificate.
People said that this would benefit safety as it would mean that riders would be better trained, and therefore more competent, and safer. It would also mean that they could use a moped or motorcycle that could keep up with traffic, rather than feeling pressured and being overtaken.
The other view expressed is that reducing the MTV would allow candidates to take their test on a machine that is significantly smaller than the one that they might buy and use. A number of people said that this would be a risk and objected to the proposal as a result.
Costs and benefits
The next questions asked about the potential costs and benefits to industry and society and to individual businesses.
Question 9. Do you have any information on the costs, or benefits, to industry or society which you think would come from the proposal?
Question 10. If you have a business that would be affected by this proposal, please tell us whether you think it would have an overall cost or benefit.
| Response | Number of responses |
|---|---|
| Cost | 91 |
| Benefit | 208 |
| No significant cost or benefit | 317 |
Twice as many respondents said it would benefit their business than said it would create a cost.
On this topic, the comments made reflect the potential improvement in safety. People also suggested that because these motorcycles are particularly good for commuting and local deliveries it would benefit the environment if people used them more.
Motorcycle training schools made generally supportive comments.
They suggested that they might have to invest in a smaller motorcycle to cater for a new group of learners, who have not previously wanted to learn on a large motorcycle. This could cost them around £5000 per machine, but that would be recovered by providing more training courses.
It will be up to each motorcycle training organisation to decide whether to buy a 250cc machine to offer to its customers.
A comment that represents exactly this point is:
“I am a very small in effect one man training school, any extra income from this change would be offset by the cost of purchasing an extra smaller A2 machine, but it would allow increased client-based training for people who find my Cat A bikes with restrictors a little too big and heavy.”
Motorcycle instructor
Among the objections raised were some from trainers who thought that they would lose repeat CBT business. Also, some suggested that because many riders already have ample ‘on road experience, they would simply buy their own 250cc machine and take the A2 test without any further training.
Little evidence was provided that could be used to properly inform an impact assessment. And, since the effects on business are mostly indirect, a ‘De-minimis’ approach has been taken. It produced a net present value for businesses of £1.4 million over 10 years.
This was derived from slightly ‘increased amounts of A2 training, but took account of the need for businesses to recover any investment in an A2 motorcycle.
It is clear that some test candidates will benefit because they will be able to use a motorcycle that is more suitable for them at their test. Some motorcycle training schools might see increased business, particularly if they invest in a smaller motorcycle. Although the demand for repeated CBT courses might reduce.
DVSA believes that any road safety risks associated with this proposal will be quite limited. A rider would have been trained and would have demonstrated riding competence by passing their test.
However, every rider has to build their experience after passing their test and to ride a category A2 motorcycle the rider would still have to be at least 21 years old.
This proposal doesn’t require motorcycle training businesses to change the motorcycles that they use for their training. It will be up to them to adjust to the changed legislation according to how they best think fit. Therefore, the impact assessment for this proposal is also net zero.
The decision
After taking all these views into account the government has decided to introduce this proposal. Arrangements will be made to amend the regulations to reduce the MTV for A2 motorcycles to 245cc, with the other power requirements remaining as they are.