DVLA ‘ghost records’ highlight EU driving licence loophole


Highlighting a strange loophole in the law, loss adjuster Claims Management & Adjusting (CMA) is calling for all UK residents to keep the Driver and Vehicle Licensing Agency (DVLA) informed of their current address.

DVLA building. Pic: Matthew Horwood/Getty Images

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A GB licence holder must immediately notify the DVLA of any change of address, this is stipulated at section 99(4) of the The Road Traffic Act 1988. Yet, under Section 99A(3), EU driving licence holders can drive in the UK for as long as their licence remains valid. As a result, their registered address can easily be years out of date. The extent of the anomaly is illustrated by the fact that non-EU licence holders have a maximum of 12 months to exchange their licence for a GB one.

CMA says the issue has long been problematic, but the frequency of such cases is increasing. To confirm this, CMA Managing Director, Philip Swift, a former police detective, submitted a Freedom of Information (FOI) request asking for the number of “ghost records” in the DVLA driver database. Why? Because when a UK resident with a non-GB licence is convicted of a motoring offence, the DVLA will create a ghost record to register the penalty against. In March 2022, the DVLA provided the following on the number of new ghost records created:

Year 2018 2019 2020 2021
DVLA Non-GB Licence records 19,524 26,523 20,144 27,413


Mr Swift commented: “We had noticed a steady rise in cases involving the presentation of non-GB driving licences, and the DVLA ghost record data backs this up. This problem is, even for minor collisions, these claims can be extremely time-consuming.

“It can’t be right that GB licence holders can be fined up to £1,000 for failing to inform the DVLA of a change of address, while resident non-GB licence holders face no such sanction – even if they’ve been living in the UK for years and their registered address is patently not current but an overseas residence.

“From a purely practical standpoint, the current law causes unnecessary delays for insurers and claimants. Making basic enquiries about a GB licence holder is a quick and easy process via the DVLA, but the same cannot be said for a non-GB licence. The last thing you want after a collision or theft is to have your claim held up by a simple licence query.

“That’s why we’re calling for all UK residents to keep the DVLA updated with their current address. Why not do it voluntarily? Life would be so much easier all-round if everyone did.”

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