Can a Normal Dash Cam Put Your PCO Licence at Risk?
Timi
Forums make it sound like one wrong dash cam ends your career, but the real risk is less dramatic and still expensive.
Your driver licence vs your vehicle licence
There are two licences in play, and the difference matters.
- Your PCO driver licence is about you: your checks, your conduct, your record.
- The PHV vehicle licence is about the car: its condition, its fittings, its paperwork.
An unapproved camera is mainly a vehicle licence issue. It’s handled through the vehicle inspection, not your driver licence.
How the inspection works
Before a London PHV is licensed, it goes through a TfL licensing inspection. It also needs an MOT carried out within the last 14 days before that inspection.
TfL’s inspection manual treats a camera as a vehicle modification. Owners are expected to apply for approval before fitting one and before spending any money on it. At inspection, you show written confirmation of what was approved, and the examiner records the modification against the vehicle.
For a private hire vehicle there’s also a declaration form for the camera. It has to be completed and signed. A missing or unsigned form is itself a reason for refusal.
Five ways a camera can fail inspection
TfL’s inspection manual lists several camera-related reasons for refusal:
- Unapproved modification fitted. The camera isn’t approved, or wasn’t approved for this vehicle.
- Fitted incorrectly or insecurely. Suction mounts, loose brackets, or a camera that could come free in a crash.
- Poor condition. Damaged units or exposed, unsafe wiring.
- Encroaching on the driver or passenger area. Cables or hardware getting in the way.
- No signed declaration form.
Signage can fail you too. Missing CCTV signs, or a TfL interior sign with blank data controller details, are both reasons for refusal. See TfL CCTV signage rules.
What refusal actually means
Refusal means the vehicle licence isn’t issued that day. It isn’t the same as losing a licence you already hold.
The manual also allows an alternative: if an unapproved device is found, the examiner can let you remove it on site and record an advisory instead of a refusal. That’s useful to know, but don’t plan around it.
What happens mid-licence
If a problem is found during the licence period, the vehicle can be issued a notice stopping it being used until the issue is fixed. For a driver paying weekly rent, this is where it really hurts. The car sits there, the rent doesn’t stop, and you’re not earning.
Can TfL revoke a licence over a dash cam?
TfL has powers to suspend or revoke a PHV licence if it’s no longer satisfied the vehicle is fit for use, or if a licence condition has been breached. In practice, an unapproved dash cam on its own is very unlikely to lead there. Revocation is a separate step, not an automatic result of a bad camera.
If TfL does make a decision against you, you have a right to appeal to a magistrates’ court, usually within 21 days of the decision.
The bigger risk: data protection
When you record passengers in a vehicle you work in, the household exemption doesn’t apply. Whoever decided to fit the camera is a data controller. That brings duties:
- Pay the ICO data protection fee. The ICO says this applies to dash cams used for work, even in your own car. Most small businesses pay the lowest tier, currently £52 a year. TfL can ask to see proof during the licence period.
- Handle footage properly. Keep it secure and encrypted, and delete it automatically within 28 days unless needed for a claim.
- Only release footage on written requests that say why it’s needed.
Not paying the ICO fee can lead to a fixed penalty of up to £4,350. An unapproved camera with audio on and footage on a loose SD card is exactly the setup that causes problems if a passenger complains. More in our guide to cabin cameras and GDPR.
If you rent your car
The vehicle licence belongs to the owner. TfL expects the vehicle owner to get approval for modifications and present the paperwork at inspection. Fitting an unapproved camera to someone else’s licensed car puts their licence at risk, and you’ll be the one left without a car.
Frequently asked questions
Will I lose my PCO licence for having a normal dash cam?
Very unlikely. The usual outcome is a refused inspection, or an advisory if you remove it on site.
What happens if TfL finds an unapproved dash cam at inspection?
The vehicle can be refused a licence that day. The examiner may let you remove it and record an advisory instead.
Do I need to pay the ICO fee for a dash cam?
If you use it in a vehicle you work in, yes in most cases. The lowest tier is currently £52 a year. Use the ICO’s fee checker to confirm.
Can I appeal a TfL decision about my vehicle?
Yes. You can appeal to a magistrates’ court, usually within 21 days of the decision.
Does an unapproved dash cam affect my insurance?
It can raise questions if you rely on its footage after an incident. Check your policy and tell your insurer about any modifications.
The simple fix
Fit an approved camera properly, display the signs, pay the ICO fee and keep the paperwork. Then the camera protects you instead of creating a problem.