Loveday Ryder
Driver and Vehicle Standards Agency
1 Unity Square
Nottingham
NG2 1AW

RE: Formal Objection to Proposed Driving Test Booking Reforms

Dear Loveday,

We are writing to you on behalf of The Driving Instructor and Trainers Collective (DITC) to formally express our strong objections to the proposed changes outlined in the recent DVSA consultation regarding the booking and management of driving tests.

While we welcome the opportunity to contribute to the discussion, we are deeply concerned that the survey options fail to address the root cause of the issue—namely, the DVSA’s ongoing struggle to manage demand, provide sufficient test availability, and maintain a booking system fit for purpose.

We must first ask: What problem are these changes trying to solve? If the core issue is test availability and waiting lists, then we believe the current proposals are misdirected and may lead to further inefficiencies and inequality of access.

We are alarmed by the narrative being formed around so-called ‘bots’—a term that, in practice, is often used to unfairly group together test-resellers, opportunistic brokers, and professional ADIs using legitimate means to support their pupils. Where is the evidence that bots are the cause of test wastage? We have seen far more instances of failed test attendance arising from last-minute learner bookings made without the support or knowledge of an instructor.

Let us be clear: driving instructors do not have to book tests for their pupils. But many choose to do so—especially in regions with severe test shortages—because it is often the only way to ensure alignment between test readiness, business logistics, and the learner’s success. It is a professional tool that helps us mitigate a broken system, not abuse it.

We are being presented with what appears to be a constrained and pre-determined list of options:
– Removing ADIs from the booking process
– Removing our ability to manage or amend tests
– Eliminating the ability to swap test locations or dates
– Imposing limits on location changes by distance
– Or: maintaining the status quo

We are concerned that this is not meaningful consultation, but rather the appearance of engagement to validate decisions that may already be made. We urge the DVSA to pause and reflect:

– Removing ADIs from the process will disproportionately impact rural learners, those who work or study away from home, and areas already suffering from limited availability (notably London and the South East).
– Capping location swaps penalises those trying to find a solution within a broken system.
– Placing all booking responsibility on the learner ignores the proven fact that ADIs are far better placed to judge test readiness, reduce no-shows, and maximise the use of limited test slots.

We reiterate our strongest concern: if we lose the ability to book or manage tests on behalf of our pupils, it will not return. That flexibility has been vital in maintaining some semblance of function in a system overwhelmed since the pandemic backlog began.

What this proposal does is:
– Create a scapegoat in “bots”
– Shift blame toward instructors
– Remove vital tools that help us keep the system working
– And worst of all, hand full control to those with the least professional insight into test readiness

Panic-booking, no-shows, and test slot wastage will increase—not decrease—if these reforms go ahead.

We therefore call for:
1. Clear, published evidence that test-reselling bots are the primary source of test wastage
2. Withdrawal of any proposals that reduce the role of ADIs in the booking and test-readiness process
3. Greater collaboration with professional organisations and instructors to co-design a fit-for-purpose, fair, and future-proofed booking system

For now, we urge all ADIs to vote No Change in the consultation—not because we believe the current system is perfect, but because the options presented offer no genuine solution to the real problems.

We ask the DVSA to listen to the professionals who work every day to make this broken system functional—for the benefit of their pupils, road safety, and the integrity of the profession.

We remain committed to constructive engagement, but we will not stand by as vital tools are removed under the illusion of reform. We have responded to the survey and are encouraging all colleagues to do so. While we trust this will be taken into account, along with so many instructors feeling resigned to a predetermined outcome, we feel obliged to express our severe concerns directly.

Yours sincerely,

Chris Bensted & Ian Brett
On behalf of The Driving Instructor and Trainers Collective, its members and many other concerned ADIs