Recurring concern

Failure to protect underage food-delivery riders from road traffic collisions

Get email alerts

Request correction

First reported 23 Sep 2025•Latest report 5 Dec 2025

Definition

What this concern includes

Includes failures in arrangements specifically affecting the road safety of underage people carrying out food-delivery work, including oversight of licence rental or age restrictions where it permits underage riding, controls on powered two-wheeled delivery work, night-time or lone-working safeguards, and measures intended to prevent or reduce collision risk.

Not included

Excludes general road-safety hazards, driver licensing or youth road-use concerns without an underage food-delivery work context.
Excludes adult food-delivery rider risks unless the assertion explicitly concerns the same underage food-delivery safety arrangement.
Excludes generic lone-working, exploitation, employment or licensing failures where road-collision risk to underage food-delivery riders is not materially identified.
Excludes clinical assessment or treatment failures after a road traffic collision unless the assertion concerns the prevention and control of the underage food-delivery road-safety risk.

Reports: 2
Individual concerns: 2
Date range: 2025–2025
Stated actions: 13

Reports over time

Reports about this concern issued each year.

* 2026 is projected from reports observed to 7 Sep 2026.

Most frequent recipients

Reports about this concern sent to each recipient.

Deliveroo1

Department for Business, Innovation, Science and Trade1

Department for Education1

Department for Transport1

Department for Work and Pensions1

Health and Safety Executive1

Home Office1

Just Eat1

Uber Eats1

Concerns and responses across reports

Only concerns grouped under this recurring concern are included. Select any concern, action or position to view the source wording.

5 Dec2025
Dorset
Concerns raised1
1. Risk of road traffic collisions involving children working at night on powered two-wheeled vehicles
This report raised 2 other concerns. They are not shown here because they do not form part of this recurring concern.
Responses linked to these concerns
Each statement is shown once, even when linked to more than one concern.
Actions described in response 1
1. Action
  Update and publish joint guidance on driving and riding safely for work.
  Stated by Health and Safety ExecutiveStated completed
Respondent positions 2
1. Position
  Road traffic accidents are generally for the police to investigate and enforce rather than HSE.
  Stated by Health and Safety ExecutiveOutside remit
1. Position
  Practical limits constrain measures addressing lone working in delivery driving because the work inherently involves solo, deadline-driven and often nighttime activity with road risks.
  Stated by Health and Safety ExecutiveUnable to act
AI-generated summary

Leonardo Cardoso Machado · Prevention of Future Deaths report

This summary was generated using AI from the published report. Please read the original report for the complete account.

Report summary

Leonardo Cardoso Machado, aged 17, died on 16 April 2023 after losing control of a motorcycle while travelling at speed and colliding with metal railings. The report raised concerns about limited oversight of rented food delivery licences being provided to children under 18, and the resulting risks of lone night work and road traffic collisions.

Read the report on judiciary.uk
Source evidence
How this individual concern was interpreted
PFD Monitor created a concise, searchable interpretation from the report wording shown below.
PFD Monitor interpretation
Risk of road traffic collisions involving children working at night on powered two-wheeled vehicles
Wider context from the report
“1. During the inquest evidence was heard that: i. There is significant national concern about the “rental” of food delivery licences to under 18s. In general terms, food delivery platforms place age restrictions on those who can obtain a licence to deliver food. However, there appears to be no oversight of the rental of these licences to those under the age limit. This places children in a vulnerable position: lone working, often at night, riding electric or motorised scooters, mopeds or motorcycles and delivering to individuals that are not known to the drivers. 2. I have concerns with regard to the following: i. There appears to be no or limited oversight of the practice of “renting” a food delivery licence to children under 18 years of age, which I hear is a national issue; ii. As a consequence, children are working in the food delivery economy, which involves lone working at night, with deliveries being made to the home addresses of private individuals, placing the children in a vulnerable position; iii. That placing a child in a lone working environment at night and on the roads on electric or motorised scooters, mopeds or motorcycles also increases the risks of them coming to harm through a road traffic collision, leading to a risk of death. ”
Source location
Leonardo Cardoso Machado · Prevention of Future Deaths report
Page 3 · concerns
Open source report
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Update and publish joint guidance on driving and riding safely for work.

Verbatim wording from the response
“The Department for Transport (DfT) commented that the safety of anyone driving or riding on our roads is a priority, and that includes those who drive for work. The government expects that employers or engagers of anyone driving or riding for work to ensure that they are as safe as possible on our roads. DfT worked closely with the HSE to update the joint DfT/HSE guidance on work related road safety. The revised guidance, published in September 2021 and called Driving and riding safely for work, clearly sets out what commercial organisations and their workers, whether employees”

Source location
Response from HSE & Gov Dept
Page 1 · response
Published 8 December 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Road traffic accidents are generally for the police to investigate and enforce rather than HSE.

Verbatim wording from the response
“In respect of the road traffic accident itself, HSE views that road traffic accidents are generally a matter for the Police to investigate and enforce, rather than HSE, using the most applicable legislation. This is set out in Health and Safety at Work etc Act 1974 - Section 3.”

Source location
Response from HSE & Gov Dept
Page 1 · response
Published 8 December 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Practical limits constrain measures addressing lone working in delivery driving because the work inherently involves solo, deadline-driven and often nighttime activity with road risks.

Verbatim wording from the response
“However, HSE acknowledges that there are practical limits to what can be done in the driver delivery sector because work like this inevitably involves working alone, to deadlines, often at night and with the attendant road risks.”

Source location
Response from HSE & Gov Dept
Page 3 · response
Published 8 December 2025
Open published response
23 Sep2025
Dorset
Concerns raised1
1. Failure to protect child food-delivery workers from road traffic collision risks
This report raised 2 other concerns. They are not shown here because they do not form part of this recurring concern.
Responses linked to these concerns
Each statement is shown once, even when linked to more than one concern.
Actions described in response 12
1. Action
  Verify couriers’ and substitutes’ identities and dates of birth through internal document checks and third-party fraud screening before approving accounts.
  Stated by Uber Eats UK LimitedStated completed
2. Action
  Use random and risk-triggered real-time facial verification to detect unauthorised account sharing and confirm the account user matches the registered identity.
  Stated by Uber Eats UK LimitedStated completed
3. Action
  Refine and add account-sharing detection signals to identify attempts to circumvent platform security controls.
  Stated by Uber Eats UK LimitedStated completed
1. Action
  Update and publish joint work-related road-safety guidance for commercial drivers and riders.
  Stated by Health and Safety ExecutiveStated completed
2. Action
  Introduce enhanced substitute checks, including preregistration, biometric verification and document checks, with removal of non-compliant accounts.
  Stated by Just EatStated completed
3. Action
  Verify riders’ and registered substitutes’ identity, age and right to work before granting or authorising platform access.
  Stated by Roofoods Ltd (t/a DeliverooStated completed
4. Action
  Run daily facial-recognition checks against onboarding identification and suspend accounts that fail until the checks are passed.
  Stated by Roofoods Ltd (t/a DeliverooStated completed
5. Action
  Increase facial-recognition check frequency and sophistication, including randomised intraday checks.
  Stated by Roofoods Ltd (t/a DeliverooStated completed
6. Action
  Review failed facial-recognition checks and terminate supplier agreements where they evidence unauthorised account sharing or fraud.
  Stated by Roofoods Ltd (t/a DeliverooStated completed
7. Action
  Identify suspicious activity and unregistered substitute use, taking enforcement action including termination of supplier agreements where necessary.
  Stated by Roofoods Ltd (t/a DeliverooStated completed
8. Action
  Identify applicants previously terminated for allowing unregistered substitutes and prevent renewed engagement where applicable.
  Stated by Roofoods Ltd (t/a DeliverooStated completed
9. Action
  Strengthen rider-account compliance checks and processes through collaboration with the Home Office and other delivery platforms.
  Stated by Roofoods Ltd (t/a DeliverooStated in progress
Respondent positions 2
1. Position
  Police, rather than HSE, are responsible for investigating and enforcing road traffic accidents.
  Stated by Health and Safety ExecutiveRedirects responsibility
1. Position
  Practical limits constrain measures to reduce risks in delivery driving because the work inevitably involves lone working, deadlines and night-time road risks.
  Stated by Health and Safety ExecutiveUnable to act
AI-generated summary

Leonardo Cardoso Machado · Prevention of Future Deaths report

This summary was generated using AI from the published report. Please read the original report for the complete account.

Report summary

Leonardo Cardoso Machado, aged 17, died on 16 April 2023 after losing control of a motorcycle and colliding with metal railings while fleeing a police traffic stop. Concerns included limited oversight of rented food-delivery licences for children under 18, and the vulnerability and road-traffic risks associated with children working alone at night on motorised vehicles.

Read the report on judiciary.uk
Source evidence
How this individual concern was interpreted
PFD Monitor created a concise, searchable interpretation from the report wording shown below.
PFD Monitor interpretation
Failure to protect child food-delivery workers from road traffic collision risks
Wider context from the report
“2. I have concerns with regard to the following: i. There appears to be no or limited oversight of the practice of “renting” a food delivery licence to children under 18 years of age, which I regard is a national issue; ii. As a consequence, children are working in the food delivery economy, which involves lone working at night, with deliveries being made to the home addresses of private individuals, placing the children in a vulnerable position; iii. That placing children in a lone working environment at night and on the roads on electric or motorised scooters, mopeds or motorcycles also increases the risks of them coming to harm through a road traffic collision, leading to a risk of death. ”
Source location
Leonardo Cardoso Machado · Prevention of Future Deaths report
Page 3 · concerns
Open source report
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Verify couriers’ and substitutes’ identities and dates of birth through internal document checks and third-party fraud screening before approving accounts.

Verbatim wording from the response
“We would like to begin by stating unequivocally that everyone delivering on the Uber Eats platform must be at least 18 years of age. This requirement is set out clearly in our Courier Terms and Conditions that all couriers sign in order to use the app and we have a number of robust checks in place (outlined below) to ensure this requirement is met. If we become aware of someone delivering on the platform who may be under 18 we take immediate action, including reporting to law enforcement or relevant authorities where necessary.”

Source location
Response from Uber Eats
Page 2 · response
Published 29 September 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Use random and risk-triggered real-time facial verification to detect unauthorised account sharing and confirm the account user matches the registered identity.

Verbatim wording from the response
“To help ensure that only the account holder or registered substitutes (i.e. those confirmed to be over 18) are using the account, Uber Eats uses industry leading account-sharing detection technology. This includes real-time identity verification software (launched in 2019), which requires couriers to take a selfie that is compared in real time with the profile photo that has been matched with their registered identity documentation. These real-time facial verification checks occur randomly, at least once a day and also in circumstances where we suspect that an individual performing the delivery may not be the same person as the accountholder. In addition to these checks, we monitor for suspicious behaviours that may indicate attempts to circumvent our security controls, which can trigger additional identity verification checks.”

Source location
Response from Uber Eats
Page 2 · response
Published 29 September 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Refine and add account-sharing detection signals to identify attempts to circumvent platform security controls.

Verbatim wording from the response
“We are continually enhancing our processes to ensure our platform is safe. Although action taken was not in direct response to this incident, we have refined and added to our suite of account-sharing detection signals in recent years.”

Source location
Response from Uber Eats
Page 2 · response
Published 29 September 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Update and publish joint work-related road-safety guidance for commercial drivers and riders.

Verbatim wording from the response
“The Department for Transport (DfT) commented that the safety of anyone driving or riding on our roads is a priority, and that includes those who drive for work. The government expects that employers or engagers of anyone driving or riding for work to ensure that they are as safe as possible on our roads. DfT worked closely with the HSE to update the joint DfT/HSE guidance on work related road safety. The revised guidance, published in September 2021 and called Driving and riding safely for work, clearly sets out what commercial organisations and their workers, whether employees”

Source location
Response from Health and Safety Executive
Page 1 · response
Published 29 September 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Introduce enhanced substitute checks, including preregistration, biometric verification and document checks, with removal of non-compliant accounts.

Verbatim wording from the response
“Under the UK’s employment law, self-employed independent couriers have the legal, unfettered right to use a substitute and Just Eat provides guidance to couriers on how they can do this safely and responsibly. Whilst couriers have the legal right to substitute their work, this can only be to others who are over the age of 18 and have the legal right to work in the UK. We have recently introduced further enhanced checks to ensure that substitutes meet the requirements that we set for all couriers on our network. Couriers must now pre-register any substitutes and are given a short grace period to complete biometric checks and to submit documents proving their age and that they have the right to work. If these documents are not provided, both the main account holder and their substitutes will be removed from the network.”

Source location
Response from Just Eats
Page 1 · response
Published 29 September 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Verify riders’ and registered substitutes’ identity, age and right to work before granting or authorising platform access.

Verbatim wording from the response
“1. It is a requirement that any rider engaged with Deliveroo is at least 18 years old.”

Source location
Response from Deliveroo
Page 2 · response
Published 29 September 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Run daily facial-recognition checks against onboarding identification and suspend accounts that fail until the checks are passed.

Verbatim wording from the response
“4. We run facial recognition checks to ensure that the person using an account is either the main account holder or a registered substitute and to detect and prevent unauthorised use of the platform. These checks are run at least daily for all riders in the UK. This process requires the rider to submit a live video selfie, which is then checked by our third party supplier to make sure it matches the ID they provided during onboarding. If riders do not pass, their accounts are placed out of service, meaning that they cannot accept orders until they have passed a check.”

Source location
Response from Deliveroo
Page 2 · response
Published 29 September 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Increase facial-recognition check frequency and sophistication, including randomised intraday checks.

Verbatim wording from the response
“6. We have recently increased the frequency and sophistication of these checks, including randomising the frequency of intra-day checks to make it harder for people to predict the checks.”

Source location
Response from Deliveroo
Page 2 · response
Published 29 September 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Review failed facial-recognition checks and terminate supplier agreements where they evidence unauthorised account sharing or fraud.

Verbatim wording from the response
“7. Our facial recognition technology identifies any failed checks that indicate someone other than the main account holder, or registered substitute, may have been trying”

Source location
Response from Deliveroo
Page 2 · response
Published 29 September 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Identify suspicious activity and unregistered substitute use, taking enforcement action including termination of supplier agreements where necessary.

Verbatim wording from the response
“8. We also have other measures in place to enable us to identify suspicious activity or if an unregistered substitute is attempting to use our platform. Where we identify breaches of our processes, we take appropriate action, including terminating supplier agreements with riders where necessary.”

Source location
Response from Deliveroo
Page 3 · response
Published 29 September 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Identify applicants previously terminated for allowing unregistered substitutes and prevent renewed engagement where applicable.

Verbatim wording from the response
“We stop working with riders who allow an unregistered substitute to use their rider account and will not work with those riders in the future. We have processes in place to enable us to identify whether a rider applicant has previously had a supplier agreement with us terminated for allowing an unregistered substitute to provide services on their behalf.”

Source location
Response from Deliveroo
Page 3 · response
Published 29 September 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Strengthen rider-account compliance checks and processes through collaboration with the Home Office and other delivery platforms.

Verbatim wording from the response
“You might be aware that over the course of this year, we have been working closely with the Home Office and other food delivery platforms to enhance compliance with right to work legislation by food delivery couriers. We have significantly strengthened checks and processes that we already had in place to ensure that rider accounts are only being used by”

Source location
Response from Deliveroo
Page 1 · response
Published 29 September 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Police, rather than HSE, are responsible for investigating and enforcing road traffic accidents.

Verbatim wording from the response
“In respect of the road traffic accident itself, HSE views that road traffic accidents are generally a matter for the Police to investigate and enforce, rather than HSE, using the most applicable legislation. This is set out in Health and Safety at Work etc Act 1974 - Section 3.”

Source location
Response from Health and Safety Executive
Page 1 · response
Published 29 September 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Practical limits constrain measures to reduce risks in delivery driving because the work inevitably involves lone working, deadlines and night-time road risks.

Verbatim wording from the response
“However, HSE acknowledges that there are practical limits to what can be done in the driver delivery sector because work like this inevitably involves working alone, to deadlines, often at night and with the attendant road risks.”

Source location
Response from Health and Safety Executive
Page 3 · response
Published 29 September 2025
Open published response

Data last updated 7 September 2026

What this concern includes

Not included

Reports over time

Concerns raised1

Risk of road traffic collisions involving children working at night on powered two-wheeled vehicles

Actions described in response An action is something a respondent says it has done, is doing, or plans to do in response to the concern raised.1

Respondent positions A position is what a respondent says about the concern when they do not describe a specific action.2

Concerns raised1

Failure to protect child food-delivery workers from road traffic collision risks

Actions described in response An action is something a respondent says it has done, is doing, or plans to do in response to the concern raised.12

Respondent positions A position is what a respondent says about the concern when they do not describe a specific action.2

Actions described in response 1

Respondent positions 2

Actions described in response 12

Respondent positions 2