I am pleased to be able to share an important update on my long running campaign to ensure moped riders using their vehicles for commercial activity are properly licenced and regulated. I know this is a matter of ongoing concern for residents in Redhill - and increasingly elsewhere in the constituency too - where these riders have shown themselves to be unsafe on our roads and in our town centres.
After a good deal of engagement both in the Commons and directly with ministers, it is welcome to see that the Government now appears to be waking up to these concerns and weighing possible courses of action to tighten the current licencing regime. I have today submitted a response to the 'Improving moped and motorcycle training, testing and licensing' consultation which I believe reflects the concerns constituents have expressed and offers realistic suggestions as to what can be done to ensure moped riders engaging in commercial activity are properly licenced and regulated.
You can read my full submission below.
I welcome the opportunity to respond to this consultation on improving moped and motorcycle training, testing and licensing. I am responding as the Member of Parliament for Reigate, where residents have raised serious concerns with me about the behaviour of some learner moped and motorcycle riders undertaking commercial delivery work.
Their concern, which I share, is that the current licencing system allows people who have not passed a full moped or motorcycle test to undertake commercial activity, including food delivery and courier work, on the basis of a Compulsory Basic Training certificate and provisional licence entitlement. The essence of this submission is that this amounts to a significant gap in the current licensing framework which should be addressed as a matter of urgency.
This consultation rightly recognises that motorcyclists remain among the most vulnerable road users. In 2024, motorcyclists represented 21% of road fatalities and 20% of serious injuries despite accounting for only 1% of traffic. The consultation also states that per billion miles travelled, motorcyclists are over 40 times more likely to be killed or seriously injured than someone travelling by car. It seems self-evident then that Government must do more to ensure higher standards of safety and competence for this cohort.
I particularly welcome the fact that the consultation explicitly recognises the problem of “permanent learners”. DVSA’s own data shows that between March 2023 and March 2025, 77,000 learner riders repeated their CBT course, equivalent to 23% of the total certificates issued in that period. The consultation is clear that “CBT is not a substitute for a full motorcycle test” and that riders on a CBT have not demonstrated their competence to a DVSA examiner.
This is welcome clarification - CBT was introduced to ensure that a learner had reached a basic level of competence before being allowed to ride unaccompanied on the road. It was not intended to become a long-term alternative to passing a test. The current two-year validity period was intended to give learners time to gain experience and undertake further training before passing their practical test. The consultation itself notes that there is currently no limit on the number of times a person may take the CBT course.
That arrangement may be defensible for ordinary learner riders – those who are genuinely building up confidence and experience before taking a full test. I would suggest though that we have ample evidence that it is wholly inappropriate in cases where learner entitlement is being used as the basis for commercial work.
This is even more the case when we consider that many commercial riders will be dealing with extended hours on the road, riding in poor weather and darkness, navigating to unfamiliar addresses and an explicit pressure to complete jobs quickly.
In my constituency, residents primarily in the town of Redhill – but now increasingly in Reigate and Banstead too, have raised concerns about near misses, poor riding, dangerous manoeuvres and a growing sense that some riders are clearly not safe to be on the road at all. This consultation is a brilliant opportunity to grapple with the problem and ensure that moped and motorcycle riders who have not passed their full test should not be able to undertake commercial delivery work until they have proven that they can operate safely on our roads.
The law should of course continue to support ordinary learners. Someone using a moped or learner-legal motorcycle to practise, attend college, or build up experience before their test should not be unfairly penalised. However, commercial use should be treated differently. If the rider is using a moped or motorcycle for hire or reward, including platform-based food delivery or courier work, the public are entitled to expect a higher standard of proven competence.
For that reason, my principal recommendation is that the Government should introduce a clear rule that a person may not undertake commercial activity on a moped or motorcycle using only provisional licence entitlement and CBT certification. A rider should be required to hold the relevant full licence before undertaking commercial delivery, courier work, or other comparable work for hire or reward.
This would be a targeted and moderate change but the benefit to the public would be considerable. It would not prevent new riders from learning, nor would it stop ordinary moped or motorcycle use on a provisional licence where that use is genuinely for learning, commuting or personal transport. It would simply recognise that commercial road use is different and where someone is using the road as a workplace, the rider should have passed the appropriate test.
This proposal is directly relevant to several parts of the consultation.
On Question 2, I support the principle of improving theory and hazard perception training as part of the CBT process. The consultation notes that learner riders do not currently need to have taken the motorcycle theory and hazard perception test before taking CBT, and that one option would be to require first-time road users to pass the test either as part of, or after, completing the CBT course. That is sensible - riders should have a strong understanding of the Highway Code, hazard perception, safe behaviour and the risks they pose both to themselves and to others before riding independently.
Nevertheless, better theory training cannot by itself resolve the commercial-use issue. The Government should therefore treat theory and hazard perception reform as a useful improvement to CBT, but not as a substitute for requiring a full licence where the rider is undertaking commercial work.
On Question 6, I agree that the current CBT validity framework should be reconsidered. The consultation is right to examine whether the two-year period, combined with unlimited repeat CBTs, is creating a class of permanent learners. A shorter validity period, or other restrictions on repeated CBT use, may help encourage progression to full licensing. However, there is a risk that a broad change to CBT validity could penalise ordinary learners while still failing to address the main risk in the commercial delivery sector.
For that reason, I would urge the Government not to rely solely on changing CBT validity periods. The more precise reform – one which I have been calling for at every opportunity - would be to distinguish between ordinary learner use and commercial use. A person who wishes to continue learning should have a workable path to do so while a person who wishes to earn money from riding on public roads should be expected to pass the relevant test beforehand.
On Question 7, I strongly support the creation of a digital CBT platform. The consultation notes that the current paper-based system can be time-consuming, open to human error, and vulnerable to delays in updating records. It also states that a digital approach would improve data quality, security and accuracy, and reduce opportunities for fraudulent certificates being used.
A digital platform should also be designed with enforcement in mind. It should allow the police, insurers and, where appropriate, employers or delivery platforms to verify entitlement quickly and accurately. If the Government accepts the principle that commercial riders should require a full licence, then digital verification will be essential. It should not be possible for a delivery platform to rely on a paper certificate. The system should make it simple to establish whether a rider has CBT only, or whether they hold the relevant full licence for the vehicle and work being undertaken.
On Question 8, I recognise that a full-licence requirement for commercial moped and motorcycle work would have an impact on some employers, workers and delivery platforms. Some riders would need to take further training and pass their test before continuing to work in that sector. Some businesses would clearly need to strengthen their verification systems. I am clear though that those are proportionate consequences when set against the wider road safety issues involved.
I am delighted that the Government has chosen to take a long overdue look at this issue and will support any way I can with the delivery of the following essential reforms:
The first and most essential is the creation of a legal prohibition on undertaking commercial activity on a moped or motorcycle using only provisional licence entitlement and CBT certification. This must be backed up by a clear definition of commercial activity, including the carriage of goods or passengers for hire or reward, courier work, food delivery and platform-mediated delivery work. The lack of such a definition has been previously cited as a barrier to reform, and I am keen that the Government not be blocked at the same barrier twice!
New rules must also be backed by enforcement, I would therefore argue for the establishment of a clear duty on employers, operators and delivery platforms to verify that riders using mopeds or motorcycles for commercial work hold the relevant full licence. This can be done through a digital CBT and licensing verification system to support enforcement by police, insurers and businesses.
This approach would be consistent with the objectives of the consultation. The Government is seeking to modernise a system that has not kept pace with changing rider behaviour, new technology and the growth of the gig economy. The consultation itself recognises that why people use motorcycles has changed, including their use in the food delivery sector – it is clear that the licensing framework should reflect that change.
I hope that these suggestions are given serious consideration. I believe they represent a real chance for the Government to make our roads and town centres safer as well as support responsible businesses and riders.
Rebecca Paul MP
Member of Parliament for Reigate
