Traffic Commissioners increasing use of ‘Propose to Revoke’ letters

16 July 2025

The Office of the Traffic Commissioner (OTC) appears to have recently shifted its approach to issuing ‘Propose to Revoke’ (PTR) letters. We are now seeing operators receive PTR letters shortly after a DVSA Maintenance Investigation Visit (MIVR) and/or a Traffic Examination Visit (TEVR) where the outcome was deemed “unsatisfactory” or flagged as “report to the OTC.”

In other words, more cases where maintenance systems are found lacking or tachograph compliance systems are found wanting by the DVSA are now being met with a formal letter proposing revocation of the Operator’s Licence, without first calling a Public Inquiry. This marks a change from the practice over the past 40+ years, where such issues would typically be addressed at a Public Inquiry. This new tactic may be an attempt to clear a backlog of cases by testing whether the operator is prepared to continue holding their licence.

It is important to note that the Traffic Commissioner cannot revoke a licence without giving the operator the opportunity for a Public Inquiry. This new approach does not remove that right but instead requires the operator to proactively request a hearing, rather than assuming one will be scheduled.

If you receive a PTR letter and do not request a Public Inquiry or fail to respond adequately to the highlighted shortcomings to the satisfaction of the Traffic Commissioner, your operator’s licence could be revoked without further warning. This would require an immediate cessation of operations, without the opportunity to contest the decision before the Commissioner.

The Office of the Traffic Commissioner is increasingly focusing on operators with repeated or significant failings in their compliance systems. They are acting swiftly and, rather than issuing reminders or requesting additional information, they are moving directly to propose revocation.

When responding to an MIVR or TEVR, it is crucial that your response is comprehensive, robust, and timely. Given the OTC’s enhanced enforcement approach, even seemingly minor observations by the DVSA should be addressed in detail at the earliest opportunity. Prompt remedial action is essential to protect your operator’s licence.

If you receive one of these PTR letters, we strongly recommend seeking legal advice promptly, as these letters come with strict deadlines, after which revocation can proceed without further warning. If you are unsure of how to respond, your first action should be to request a Public Inquiry—since the Traffic Commissioner is obligated to grant this request, it prevents summary revocation.

If you need guidance on how to respond, please contact the Regulatory Team at Backhouse Jones.

This article was written by Lucy Grainger.