TfL Yet to Clarify When a London Taxi Journey Officially Begins

Transport for London (TfL) is continuing to examine a long-running legal question over the precise moment a London black cab becomes officially “hired”, according to a recent response from Mayor Sadiq Khan that has renewed debate over taxi booking apps, fare calculation and passenger liability.

The issue was raised at City Hall by London Assembly Member Hina Bokhari, who questioned why the capital’s taxi regulator remains unable to provide a definitive interpretation of a legal principle that directly affects how fares are charged and when a contractual hire begins.

A Question That Remains Unanswered

At the centre of the debate is Section 39 of the London Cab Order 1934, which requires taxi meters to be activated when a cab is legally hired.

While the legislation has existed for decades, the growing use of smartphone booking platforms has complicated what was once a relatively straightforward process.

Bokhari argued that uncertainty around the definition creates ambiguity for both drivers and passengers, particularly where journeys are arranged through third-party apps before passengers enter a vehicle.

In response, the Mayor referred to a position first outlined several years ago, stating that TfL continues to actively consider the matter.

Rise of Taxi Apps Creates New Challenges

The issue has become increasingly relevant as digital booking platforms have changed the way many passengers access licensed taxis.

Unlike traditional street hails or taxi rank pickups, app-based bookings introduce questions about when the legal hire actually begins — whether at the point of booking, vehicle dispatch, passenger collection or meter activation.

The distinction could have implications for fare liability, cancellation charges and regulatory compliance.

However, the Mayor noted that taxi booking platforms themselves currently sit outside TfL's direct regulatory powers.

According to City Hall, the only aspects of an app-booked taxi journey that TfL directly regulates are the licensed driver, the licensed vehicle and the fares prescribed under existing legislation.

Calls for Greater Regulatory Clarity

Critics argue that the lack of a clear legal interpretation leaves both drivers and passengers operating in uncertain territory.

Bokhari questioned whether TfL should seek a formal legal ruling to establish exactly when a hire begins and remove any ambiguity from the system.

Rather than committing to such action, the Mayor highlighted ongoing discussions with central government regarding broader reforms to taxi and private hire legislation.

Those discussions form part of TfL's wider Taxi and Private Hire Action Plan, which includes efforts to secure greater powers to regulate taxi booking companies operating within London.

A Long-Running Debate

The matter is not new.

Similar concerns were raised in 2021 when Assembly Member Keith Prince questioned how app-based taxi services interact with existing fare regulations.

At the time, the Mayor reiterated that drivers must not charge passengers more than the maximum fare shown on the taximeter, while also acknowledging that taxi booking apps remain outside the current licensing framework.

TfL has previously stated that it continues to engage with companies offering app-based taxi services to encourage compliance with existing regulatory requirements where applicable.

Future Reform May Be Needed

As technology continues to reshape the taxi industry, pressure is likely to grow for greater legal clarity.

Many industry observers believe that legislation written long before the emergence of digital booking platforms may struggle to address modern operating models without formal reform.

Until either the courts provide a definitive interpretation or Parliament introduces updated legislation, the question of exactly when a London taxi is legally "hired" appears set to remain unresolved.

For drivers, passengers and operators alike, that uncertainty continues to sit at the intersection of traditional taxi regulation and the increasingly digital future of urban transport.