Applicant: Uber Scot Limited
Premises: Rosyth Business Centre, Unit 18, 16 Cromarty Campus, KY11 2WX
Application Date: 23 January 2026
Objection by: James Glen on behalf of East Fife Taxi Association (EFTA)
1. Statutory Framework
This objection is made in terms of:
- Schedule 1, paragraph 3 of the Civic Government (Scotland) Act 1982 (the “1982 Act”)
- Paragraph 5(3) of Schedule 1 (grounds for refusal)
- The Civic Government (Scotland) Act 1982 (Licensing of Booking Offices) Order 2009
By virtue of Article 3 and the Schedule to the 2009 Order, Part I of the 1982 Act applies to booking offices, including the refusal grounds in paragraph 5(3) of Schedule 1.
The Licensing Authority must refuse the application if satisfied that any of the statutory grounds are met.
2. Grounds of Objection
EFTA submits that this application should be refused under Schedule 1 paragraph 5(3) on the following grounds:
(a) Fit and Proper Person – Paragraph 5(3)(a)(ii)
The Licensing Authority must refuse an application if, in its opinion, the applicant is not a fit and proper person to be the holder of the licence.
Uber Scot Limited is part of a corporate structure with a documented history across the UK of:
- Regulatory non-compliance findings
- Enforcement action by licensing authorities
- Findings by courts regarding operational failings
- Issues concerning driver verification and account misuse
The question for this Committee is not whether Uber holds licences elsewhere, but whether this applicant satisfies the fit and proper test in this licensing area, under this Authority’s standards and enforcement regime.
Given the scale, remote management structure, and reliance on app-based dispatch without direct local supervisory infrastructure, there are legitimate concerns regarding effective oversight and accountability within Fife.
(b) Management for the Benefit of Another – Paragraph 5(3)(b)
The Committee must refuse where the activity would be managed by or carried on for the benefit of a person who would be refused the licence if they made the application themselves.
The application names a day-to-day manager residing in York. The corporate control and operational systems are centralised outside Fife.
There is a real question as to whether the booking office would in practice be operated locally, or whether it is effectively a remote dispatch hub controlled elsewhere, with nominal premises within Fife.
If operational control is exercised by persons or corporate entities not subject to direct scrutiny by this Authority, paragraph 5(3)(b) is engaged.
(c) Premises Not Suitable or Convenient – Paragraph 5(3)(c)
Under paragraph 5(3)(c), refusal is mandatory where premises are not suitable or convenient for the conduct of the activity, having regard to:
- The location, character or condition of the premises
- The nature and extent of the proposed activity
- The kind of persons likely to be involved
- Public order or public safety
The proposed premises are a unit within a business centre. The application proposes operation 24 hours per day, 7 days per week.
Key concerns:
- Whether the premises are genuinely operational dispatch premises or merely an administrative address.
- Whether any staff will be physically present.
- Whether the premises are equipped for regulatory inspection and supervision.
- Whether complaint handling, record keeping and booking traceability will be locally accessible.
If the booking operation is effectively digital and controlled outside Fife, the premises may not meet the statutory test of suitability and convenience.
(d) Public Safety and Public Order – Paragraph 5(3)(c)(iv) and (v)
The Authority is expressly entitled to consider public safety. A booking office is not a passive administrative function. It is the gateway to licensed vehicle deployment.
Concerns include:
- Adequacy of driver identity verification
- Control of account sharing
- Prevention of unlicensed vehicle dispatch
- Effective compliance with local licensing conditions
Given the scale and automated nature of the applicant’s dispatch model, the Committee must be satisfied that:
- Only Fife-licensed vehicles will be dispatched within Fife
- Drivers cannot circumvent local licensing controls
- There is effective real-time oversight
Absent clear evidence of enforceable local controls, the public safety limb of paragraph 5(3)(c) is engaged.
3. Immigration Compliance
The 1982 Act, as amended, and the 2009 Order (as further amended) embed immigration compliance requirements into booking office licensing
The Committee must be satisfied that:
- Proper right-to-work checks are embedded in the applicant’s processes
- Ongoing monitoring mechanisms exist
- Systems prevent unlawful working
Given the scale and remote onboarding model used by the applicant nationally, robust local scrutiny is essential.
4. Compliance with Fife Council Booking Office Conditions (BO5)
Without rehearsing the full text, Conditions 1–4 of the Fife Council Booking Office Conditions require, in summary:
- Proper maintenance of booking records
- Accurate retention of dispatch details
- Production of records on request
- Effective management and supervision
EFTA submits that the Committee must examine whether:
- Records will be stored locally or offshore
- The Council will have immediate access
- A named, accountable manager is physically present within Fife
- There is a meaningful local complaints process
If compliance depends entirely on remote systems outside the jurisdiction, enforcement becomes materially more difficult, undermining the licensing regime.
5. Conclusion
Under Schedule 1 paragraph 5(3) of the 1982 Act, the Licensing Authority shall refuse the application if any of the statutory grounds are made out.
EFTA submits that serious and legitimate concerns arise under:
- Paragraph 5(3)(a) – Fit and proper person
- Paragraph 5(3)(b) – Management for the benefit of others
- Paragraph 5(3)(c) – Unsuitable premises and public safety
- Paragraph 5(3)(d) – Other good reason
This is not a routine application. It is a large-scale, algorithmically controlled dispatch platform seeking entry into a tightly regulated local licensing regime.
The Committee must be satisfied — not hopeful — that:
- The booking office will be genuinely based and accountable within Fife
- Public safety safeguards are demonstrably robust
- Local enforcement will not be rendered impractical
Unless and until those matters are fully evidenced, EFTA respectfully requests that the application be refused.
EFTA also respectively seeks the opportunity to address the Regulation & Licensing Committee should the application proceed to determination.
Yours sincerely
James Glen (on behalf of East Fife Taxi Association)