At today’s Regulation and Licensing Committee, Linda Holt was prepared to address members on the regulatory and public-safety issues raised by Uber Scot Limited’s application for a booking office licence in Fife. She was not permitted to deliver her statement. We are therefore publishing it in full:
Convener, members of the committee, thank you for allowing me to speak.
My name is Linda Holt. I am one of the named signatories to the shorter objection submitted by members of the East Fife Taxi Association.
I want to concentrate on one question:
What does Uber’s actual regulatory record tell us about the risks of placing public safety in the hands of its systems?
Uber will tell the committee that it is a sophisticated international technology company, that its systems are safe and that it already holds licences elsewhere.
But size, technology and licences granted by other authorities are not substitutes for compliance in Fife.
The most important evidence comes from Transport for London—Britain’s largest and best-resourced taxi and private-hire regulator.
In 2019, TfL refused to renew Uber London’s licence after a change to Uber’s systems allowed unauthorised drivers to upload their photographs to other drivers’ accounts. Those drivers could then collect passengers while appearing in the app to be the driver who had been booked.
This happened on at least 14,000 journeys.
That was not a paperwork technicality. It defeated one of the principal safety protections on which the entire app-based model depends.
There was then an internal Uber audit. The subsequent court judgment records that the audit missed another 13 bogus drivers. Uber’s own witness described what had happened as “a disaster”.
While Uber later made substantial improvements and regained its London licence, this demonstrates that sophisticated automated systems can fail, and Uber’s own internal checks may also fail to discover the full extent of the problem.
This is not ancient history.
TfL’s official decision on Uber’s 2024 licence renewal records approximately 318 breaches during the preceding licence period, affecting 85,340 completed passenger journeys.
TfL attributed the failures to a wrongly applied global systems update, other IT problems and human error.
These failures reveal the danger of global technological changes overriding local regulatory requirements. TfL considered that risk serious enough to require a “hard block”, preventing global changes from being introduced in London until they had passed local compliance testing.
So will Fife have an equivalent safeguard?
Who in Fife will test every significant change to Uber’s systems before it goes live? Who will know whether a global update has weakened vehicle, driver or geographical checks? Will Fife Council even be told before such a change is implemented?
London has specialist compliance officers, extensive data access, independent assurance reports and bespoke licence conditions. It examined approximately 6,000 booking records during Uber’s 2024 pre-licensing inspection.
TfL found hundreds of breaches affecting tens of thousands of journeys. It renewed Uber’s licence for 30 months rather than the maximum five years and retained extensive conditions so that compliance could continue to be closely monitored.
While this application is from Uber Scot Limited, not Uber London Limited, the point is Uber’s businesses rely on the same technology, processes and corporate systems.
Failures resulting from global software changes, central document processing and weaknesses in internal auditing, are plainly relevant to the assurances now being offered in Fife.
Compliance must be demonstrated before this licence is granted—not just promised, assumed or reconstructed after something has gone wrong.
The committee should require independent technical evidence, a complete compliance plan, advance notification of material system changes, prompt reporting of every breach and a clear right for Fife officers to audit the relevant systems and records.
If Fife Council cannot realistically enforce these safeguards, it is failing in its statutory responsibilities.
I therefore ask the committee to uphold my objection and refuse the application. At the very least, it should not grant the licence unless and until Uber has demonstrated—in evidence and through enforceable conditions—that Fife will receive protections comparable to those TfL considered necessary in London.
Thank you