The Driving Instructors Association (DIA) has written to Government ministers raising serious concerns about controversial changes to driving test booking rules.

It is a warning that a lack of engagement with the driver training industry risks undermining efforts to tackle record waiting times.

Test waiting times remain at an average of over 22 weeks.

Waiting game

The DIA intervention comes weeks after the Motor Vehicles (Driving Licences) (Amendment) Regulations 2026, which came into force on 12 May, made it illegal for third parties, including Approved Driving Instructors (ADIs), to book or amend practical driving tests on behalf of learners.

While it is still very early days for the changes to bed in and for true results to be understood, the association believes the changes are based on false premises and are likely to create more problems rather than address the significant issues at hand.

The DVSA says the changes are designed to tackle test reselling and abuse of the booking system.

However, the DIA argues the reforms have created significant unintended consequences and has criticised what it describes as a failure by ministers and officials to address concerns raised by the industry.

In the letter submitted to ministers, the DVSA and parliamentarians, the association said it was “critical that stakeholders are appraised of these concerns, as the consequences are deep and far-reaching for the industry, the profession, driver training, testing and licensing, and road safety.”

1+1=3

The DIA warned that the issues identified also have wider implications for future consultations and Government decision-making, adding that they “have ramifications for future consultations DVSA (or related Government functions) may be entrusted to undertake, and any policy and strategy or decision-making which is based on such.”

Among the association’s principal concerns is the evidence used to justify the changes.

The report questions “where is the actual evidence that ADIs were significant bad actors in the booking process”, noting that the DVSA had cited instructor involvement as part of its rationale for making it illegal for professional trainers to book tests on behalf of pupils.

The DIA is also seeking answers on why the original consultation did not include an option to restrict access to the booking system solely for ADIs, rather than introducing a blanket prohibition on all third-party bookings.

“Third-party apps continue to operate and market test slot availability to pupils today. ADIs are now locked out of the system entirely, yet the exploitation continues. The booking changes have in fact spawned a secondary market of test-swapping services”.

Good to talk

Further concerns centre on whether the consultation process itself was robust enough.

The report asks whether decision-making was “based on flawed and questionable consultation data” and whether the impact assessment was “wholly inadequate for the actual cost impact”, claiming a de minimis assessment (a simplified, proportionate regulatory document used by government departments to certify that a proposed policy, rule, or change has a financial impact that falls safely below the threshold for a full Impact Assessment) was used despite costs potentially exceeding £40 million.

The association also raises legal questions over whether the consultation satisfied the established ‘Gunning Principles’, which require public consultations to be conducted fairly and transparently.

While the regulations were introduced to tackle the exploitation of learners by test resellers, the DIA argues that the measures have not solved the underlying problem.

The report highlights “the fact that the measures taken have not halted third-party abuse of the booking process or the exploitation of learners.”

Care and consideration

There are also concerns about the impact on vulnerable candidates.

The report asks whether “the needs of SEND pupils have been adequately provided for” and whether the reforms have created additional barriers for learners who rely on instructor support throughout the testing process.

The DIA further argues that the changes risk diminishing the role of instructors within the driver training system.

The report questions whether decision-makers have “created further risk, and opportunity cost, in terms of further minimising the role of the Approved Driving Instructor as a professional gatekeeper” and asks whether the DVSA has “unnecessarily damaged the standing of professional ADIs, and the trust between the licensee and the regulator.”

The dispute comes as driving test waiting times remain stubbornly high.

Wait here

Latest figures show average waits reached 22.4 weeks in April 2026, while 69 test centres recorded the maximum 24-week waiting time throughout 2025.

DVSA’s stated commitment is to reduce average waiting times to seven weeks by the end of 2027 through a combination of recruitment, capacity increases and booking system reforms.

However, the DIA believes that examiner recruitment and retention, rather than restrictions on instructors, will be the key to delivering long-term improvements.

The report has now been sent to ministers, the DVSA, the Transport Committee and MPs across all major political parties, ensuring the debate over the effectiveness and fairness of the new regulations is likely to continue as pressure grows to bring down waiting times for learners.

There is yet to be a response to the letter, and it is also very early to assess the results of the reforms.

However, the DIA believes the changes to the booking system and other measures implemented to reduce test waiting times are fundamentally flawed from the outset and are likely to cause more problems rather than alleviate the problems in the British driving test booking system.

Read the full DIA letter here.