REVIEW OF TRAIN DRIVERS LICENCE REGULATIONS TDLCR

Our ref: HSR

Head Office Circular: NP/132/25

1^st August 2025

 

To: The Secretary

All branches and regional councils 

 

Dear Colleague

 

REVIEW OF TRAIN DRIVERS LICENCE REGULATIONS (TDLCR)

 

I write as regards a report I received recently from the Lead Officer about a meeting which took place earlier with year with the DfT (Department of Transport) and ORR (Office of Rail and Road Regulator) to discuss the intended review and reform of the DfT of the Train Driving Licences and Certificates Regulations 2010 (TDLCR) - and the European Law regulations that supplements this (since the UK’s exit from the EU, TDLCR’s goal of achieving consistency across member states by prescribing a set regime used by all is not relevant). 

 

The meeting was organised by DfT to update RMT on feedback from unions and industry bodies to the DfT 2023 PIR (post implantation review) of TDLCR. The current review built on the 2023 work and subsequent engagement by DfT and ORR in 2024 in the pre and post General Election period. 

 

DfT explained that ASLEF and TSSA were consulted at this earlier stage – and these unions wanted change, for example, lowering the minimum age allowed for driving a train from 21 to 18 years came out of the 2023 PIR - to address a shortage of train drivers (RMT National Executive Committee passed policy on this in opposition to lowering the age, on the basis that the drivers grade should recruit from those who have railway experience and that by lowering the age this closed off promotional opportunities for RMT members. The decision read “going forward our policy on the issue of minimum age requirement is that the internal line of promotion into the driver’s grade must be open to all grades, meaning that train drivers are recruited from a wide range of railway experience”. See RMT Head Office Circular NP/186/24 for more information). 

 

The 2023 review identified industry support to maintain the train drivers licensing and certification regime but raised several issues with the licence and associated regime that have prompted DfT into this review. All the main line train operators said they wanted change to the licence - for it to be ‘replaced, redesigned or removed’.

 

DfT outline the aims of their review as follows:

• To have a high-level regulatory framework, replacing current detail in the framework which they now intend will go into standards. They hope that this will make it easier to amend when necessary. The licence will continue to be underpinned by the TDLC Regs 2010
• To use technology, academic, scientific and clinical developments, as having detailed requirements in law makes it difficult to reflect innovation 
• To widen the pool of who can conduct medical examinations. There is currently a log jam with getting drivers through and past their medical. DfT want to widen pool of doctors who can do this work and want to look at the frequency of medicals
• To add new features to TDLCR such as digitisation and the creation of a digital licence or enshrining best-practice into law e.g., the recent project to determine the colour vision requirements for train drivers
• To integrate the licencing process with other HR management systems. TOCs and ORR explain that there is a lot of unnecessary administrative work linked to processing the licence.  For example, ORR receive information on all medicals. They don’t need to know this. They only need to know when someone has failed a medical. 
• To look at who can conduct medical examinations. ORR does not hold in-house medical expertise. The recognition process is limited to the reviewing of any application form against generic requirements in the regulations. 
• To look at who can train new drivers
• To consider clarifying the suspension and withdrawal of arrangements, and any subsequent appeals. The regulations currently say very little on this
• To set out a clear process for challenging medical decision. Currently it is not clear how drivers or their reps can challenge medical decisions or seek secondary opinions. 
• To address concerns about the consistency of the examination requirements

 

The DfT explained that there will be no substantive changes to the licence – i.e. the driver will keep ownership of the licence. There are currently no plans to introduce a licence for other grades. 

 

Further plans to consult on proposals

DfT will have similar meetings with other stakeholders and provide written updates, before the formal consultation starts next year.  

 

At its meeting on 29^th July 2025, your National Executive Committee noted and adopted the following report from its H&S subcommittee from whey they met to consider this matter:

            

We note the report from the Lead Officer. 

 

We instruct the General Secretary to keep this NEC advised of further developments in relation to this matter. 

 

Branches, Regional Councils and relevant members to be advised accordingly. 

 

            I am acting in line with these instructions. Please bring this circular to the attention of all relevant members.

 

Yours sincerely,

 

 

 

Eddie Dempsey

General Secretary