The cross‑party House of Lords Secondary Legislation Scrutiny Committee has issued a detailed critique of the Draft Train Driving Licences and Certificates (Amendment) Regulations 2026, raising substantial concerns about whether the proposed changes can realistically deliver the Government’s aim of increasing the number of qualified train drivers in Great Britain.
The Committee’s 52nd Report of Session 24–26 highlights that although the Department for Transport (DfT) intends to reduce the minimum age for obtaining a train driving licence from 20 to 18—potentially opening the career pathway to school leavers aged 16—major gaps remain in how the policy would be implemented in practice.
Key Practical Issues Identified
The Committee notes several operational and legislative challenges that could undermine the policy’s success, including:
- Age restrictions for apprenticeships: Current rules stipulate that Level 3 train driving apprenticeships require a minimum age of 18. As a result, even with the revised licensing age, 16‑year‑olds would still be unable to enter the apprenticeship route without further reform.
- Training pipeline ambiguity: Train driving apprenticeships typically take between 12–18 months to complete and often involve waiting periods before training can begin. The Committee highlights uncertainty over what a 16‑year‑old would do during this gap, especially given legal requirements for under‑18s to remain in education or training. The report warns that the absence of a clear, end‑to‑end training pathway could deter younger entrants.
- Existing training shortages and backlogs: The UK rail industry is already facing capacity constraints in driver training, with limited places and a backlog of trainees. According to the Committee, this means lowering the licence age alone will not resolve the driver shortage—especially as existing bottlenecks relate to wider licensing legislation.
- Gaps and inaccuracies in the DfT’s Explanatory Memorandum: The report criticises the Department for failing to address key implementation issues in its official documentation and notes that the Memorandum initially included incorrect information about the length of the public consultation.
The DfT has informed the Committee that it is working with industry partners to reform the minimum apprenticeship age and is considering wider changes to the train driver licensing regime.
Committee Chair Calls for Further Ministerial Clarification
Lord Watson of Invergowrie, Chair of the Secondary Legislation Scrutiny Committee, expressed concerns about the lack of clarity surrounding the proposed reforms:
“We have been told that there are considerable challenges facing the train driver workforce with a potential shortfall of about 2,500 drivers by 2030. While these draft Regulations are intended to address this issue, it remains unclear as to how the instrument will achieve its aims in practice.
“The Department for Transport should have addressed the issues raised in our report in the Explanatory Memorandum (EM) to the draft Regulations but failed to do so. The department has provided some responses and corrected some wrong information in the EM, but there remains a lack of clarity about implementation. It also appears that, for the draft Regulations to achieve their aims, further changes will be needed to the minimum age requirement for the train driving apprenticeship and the train driver licensing regime.
“Further questions on these issues should be addressed by the Minister and we have suggested that the House raise these with the Government so it can provide the necessary clarity.”
With the UK rail sector already facing increasing passenger demand, workforce pressures, and an urgent need for modernisation, the Committee warns that regulatory reform must be coherent, comprehensive, and clearly communicated if it is to successfully address the projected driver shortfall by 2030.
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