During recent months, CPT reported that the Bus Registrations Team at the Office of the Traffic Commissioner (OTC) has faced backlogs in the processing of local bus service registration applications. CPT has now reported that the OTC has informed them that the backlog continues with a large number of applications not being dealt with in time for their intended commencement date. 

The OTC is taking steps to address the issues, including: 

• Additional permanent staff are being allocated to the PSV team, including a dedicated middle manager to oversee the PSV and bus registration function. 
• Four temporary staff have been recruited to assist in the clearance of the backlog. 
• Traffic Commissioners have agreed a measure with DVSA/OTC managers that applications are processed or referred to a Traffic Commissioner within 10 working days of a complete application to ensure that DVSA are held to account for the service provided. 

 The OTC has also emphasised that incomplete applications do not assist efficient processing and has therefore worked with CPT to provide the following information for operators to note when submitting applications. 

1. Ensure applications are submitted in sufficient time, taking account of statutory notice periods to local authorities and the OTC.  
2. Ensure applications are completed correctly - take time to read forms, and provide all required information and documents. Be clear in what is being requested. 
3. Ensure the correct application form and local authority pro forma is submitted. The latest forms include questions about aspects such as Enhanced Partnerships. 
4. Ensure timing points meet the requirements detailing in the Senior Traffic Commissioner’s Statutory Document. Where timing points are in excess of 15 minutes apart provide a clear explanation for this in the application. 
5. Where applications are sent by email, include the registration number (not the service number) in the subject line. For new registrations, include your Operator’s Licence number and write ‘NEW’. 
6. Ensure that the local authority pro forma is completed correctly and clarify with the local authority before sending to the Traffic Commissioner. 
7. Where multiple local authority pro formas are required, ensure all are attached to the application. Do not send incomplete documents whilst awaiting missing ones. 
8. Where there is no response from a local authority, supply evidence to the OTC with the application on the 29th day that the local authority has had the required time to consider the application. 
9. When submitting payment details by email, send these as a separate attachment, as opposed to in the main body of the email. This allows that information to be destroyed more easily. If payment is not sent initially, ensure payment is made at the earliest opportunity when requested. 
10. If submitting a short notice application, ensure that it meets the legislative requirements relating to short notice applications and include evidence to substantiate this. 

 The failure of the OTC to deal with applications to register, vary or cancel services by the intended effective date means that the affected service cannot be introduced, varied or cancelled without the operator breaching the relevant legislation. 

It is recognised that this presents challenges for operators, local authorities and passengers.  

CPT have been advised that the Traffic Commissioners will not make an adverse finding against an operator who operates a service contrary to an existing registration provided the following criteria have been met regarding registrations submitted to a Traffic Commissioner: 

• The correct local authority pre-notification has been given
• Applications have been properly received within the OTC with all registered particular information
• The full 42-day notice period (or 56 days in Wales or 112 days for franchise transition areas) has passed
• That the registration (or change) is due to commence on or before 31 October 2025.  

Short notice applications are not included in the above measure - operators seeking short notice dispensation must therefore still wait for confirmation of acceptance by the Traffic Commissioner. 

It is also recognised that other aspects of local service operation are impacted by the registration delays, for example the need for Bus Open Data (BODS) in England to marry up with current timetables. 

 CPT have had discussions with DVSA and have been assured that, where operators have made timely efforts to submit applications, and can demonstrate difficulties in being able to comply with aspects like BODS, a pragmatic approach to enforcement will be applied. DVSA’s Bus Operator Account Managers have also been briefed regarding the issue. 

Further details are set out in this letter from the OTC.