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Expired Photocard Driving Licences – What is the Risk?

“As at 18 November 2017, there were 3,391,737 drivers with a full or provisional driving licence where the photograph has expired.” This quote is taken from a Freedom of Information Request (FOIR6454) on behalf of Licence Link. What is the best approach to take in order to establish the number of employed vocational and company car drivers that fall into this category?

The photocard driving licence, by law has to be renewed every 10 years. The expiry date is shown on the front of the card in section 4b. Once expired the holder can be fined up to £1000. The ten-year expiry is due to the fact the appearance of the holder will change over that period of time and the requirement is that the photo must be a true likeness.

Why is it so important to manage expired licences effectively? The Government website states that it is essential for the police and other enforcement agencies to have the clearest and identifiable image so that fraudulent usage is not being undertaken. The ten-year expiry also ensures that the holder has all of the latest security features that will protect against fraudulent use.

Indeed, failure to renew an expired photocard, can lead to a licence being revoked. This can possibly occur where the police need to issue a fixed penalty notice, but the driver’s address has also changed during the ten year period and DVLA has not been informed. Any impending renewal reminders from the DVLA, in this case, will go unnoticed.

Another aspect worth considering is the Terms and Conditions that come with a Group Vehicle Insurance Policy. Insurance cover providers will often refer to the Insurance Act 2015 Part 2 The duty of fair presentation. It states that the insured must make a fair presentation of the risk that the insurer will be exposed to. Any disclosure must be reasonably clear and accessible, that material representation is substantially correct providing an expectation of belief in its correctness and presented in good faith.

The provision of the act is to ensure that a fair representation of risk is presented at the time of insurance cover commitment. As with all risk assessment any change that increases exposure to it, can lead to a removal of cover and a loss of premium if not disclosed to the insurance provider. If increased risk is identified and disclosure has been made then this could result in increased premiums if amendments have to be made or at renewal of the insurance policy.

Best practice, when managing employee driving licences, is to check drivers’ entitlements, endorsements and points, convictions and disqualifications and just as importantly checking for expired photocards. Having a set process and procedure in place to ensure frequent checking of licences that are about to expire or already expired will reduce risk and remove any possibility of increased insurance premiums or potentially, having an insurance policy revoked.

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