The UK’s APS permitting scheme marks a pivotal moment for autonomous passenger services. It offers operators a clear route to market, bypassing legacy licensing and enabling advanced trials from 2026. With full rollout expected by 2027, the scheme could unlock £42bn in economic value and 38,000 new jobs. Shoosmiths explores what this means for ambitious operators, and why now is the time to shape the rules.

Published  12 September 2025

The UK Government has launched a consultation on a proposed Automated Passenger Services (“APS”) permitting scheme which is designed to establish a legal framework for the deployment of self-driving passenger services.

The APS permitting scheme – which will be implemented at law by regulations that will be informed by this consultation - marks a significant step towards enabling commercial autonomous transport across the UK.

It is anticipated that the creation of the APS permitting scheme will facilitate advanced trial services from spring 2026 with full implementation anticipated by late 2027. This is projected to create 38,000 jobs and contribute £42 billion to the UK economy by 2035.

This is the third of a series of consultations related to the regulations underpinning the Automated Vehicles Act 2024 (“Act”). In particular the consultation gives operators of automated vehicles the chance to help inform what the future regulatory environment for APS will look like.

What is the APS permitting scheme?

The APS permitting scheme will apply to passenger services which operate without a human driver (such as autonomous buses and taxis).

It offers an early route to market for operators by providing regulatory certainty and disapplying traditional licensing regimes for taxis, private hire vehicles, and public service vehicles (like buses) where an APS permit is granted.

In the short term it is expected that the scheme will facilitate advanced trials of automated vehicles in the UK without a safety driver and inform what a more detailed APS framework might look like ahead of full implementation in 2027.

The APS application process

Permit application process

The  Secretary of State for Transport  is the primary authority responsible for granting APS permits. However, where required, they must ensure that there is consent from the relevant local licensing authority.

Operators should therefore obtain consent from the local licensing authority before applying for an APS permit. The appropriate authority depends on the location and type of service being deployed - whether taxi/PHV-style or bus-style/PSV services.

• taxi-style services: Permits may only be issued by the licensing authority for each area of operation. These are typically unitary or lower-tier local authorities (e.g. borough or district councils), or Transport for London in the capital.
• bus-style services: The Secretary of State will determine licensing. Where services operate in franchised areas, consent must be obtained from the relevant franchising authority (e.g. Transport for London or Transport for Greater Manchester).

Pre-application & application information requirements

Applicants are expected to engage with the relevant licensing authorities before submitting their application to ensure alignment and completeness. They are also encouraged to consult with relevant traffic authorities and emergency services to ensure their APS can respond appropriately to incidents and emergencies.

Licensing authorities will use the following information to assess whether to grant or refuse consent:

• scope of service: Deployment area, vehicle details, and operating hours
• service assessment:
  • design and operational plans
  • passenger safety and safeguarding policies and procedures
  • data management protocols
  • insurance and financial stability
  • evidence of stakeholder engagement
  • accessibility considerations

Accessibility considerations:

Under the Act the Secretary of State must consider whether granting an APS permit will improve understanding of how automated services can best serve older and disabled persons. Applicants must therefore demonstrate how their services will be accessible to all users, including those with protected characteristics.

Applicants should also note that future obligations may include reporting on accessibility outcomes.

Safeguarding and Customer Service

Applicants must also outline safeguarding procedures to protect passengers - particularly vulnerable individuals - and provide clear customer service protocols for handling complaints and service disruptions.

Fees

Details of fees payable for permit applications are expected to be decided later.

Permit management: Renewals, variation, suspensions, & withdrawal

The Secretary of State is responsible for varying, suspending, or withdrawing APS permits in response to infringements. These powers and procedures include:

• renewal: Permits may be renewed within a defined window - six months before expiry and closing two months prior. Permits are valid for up to five years, though shorter durations are expected during pilot phases or for new entrants. If a renewal is pending, the permit remains valid until a decision is made (subject to the five-year limit).
• variation: Permit holders may apply to amend the scope or conditions of their permit. The Secretary of State may also vary permits without the holder’s consent.
• suspension/withdrawal: Permits may be suspended or withdrawn for breaches of permit conditions, serious or repeated traffic infractions, false statements during the application process, safety concerns, or disruption to traffic and/or the emergency services.
• appeals: Operators may appeal decisions regarding permit refusal, variation, or suspension.

Disclosure of information

Permit conditions will require certain information to be published and may mandate confidential sharing with public authorities or private entities. To provide some comfort to operators, the Act makes it an offence for the recipient authority or entity to disclose such information unless authorised by legislation or another enactment.

Operators may also be required to share data on routes, timetables, fares, live updates, accidents and complaints. This data may be used by authorities such as the Driver and Vehicle Standards Agency or police, particularly in relation to safety or accessibility. Operators should implement robust systems for logging and reporting, as this may affect permit renewals or enforcement.

Your chance to influence the future regime now

The APS permitting scheme should pave the way for operators of automated vehicles to move towards advanced trials (without a safety driver) in the UK as early as Spring 2026. The proposed rules and processes for obtaining and maintaining a permit to offer APS are set out in the consultation.

The UK Government is requesting feedback on those rules and processes from interested stakeholders, so this provides the perfect opportunity to help inform what the future regulatory environment for APS looks like.

The consultation is open until  11:59pm on 29 September 2025  and, if anything currently in the consultation and draft statutory instrument could negatively impact on your business operations, now is the time to raise any concerns.

Respond to the consultation: here.

If you would like advice on how this scheme may affect your organisation, please contact us.