PFD report

Harry Joseph Purcell and Matilda (Tilly) Grace Seccombe · Prevention of Future Deaths report

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Issued 8 Dec 2025•Coventry and Warwickshire

Report record

Published report and response evidence

This page connects the concerns raised in this report with statements found in recipients’ published responses. A link shows a clear evidence connection; it does not assign responsibility.

View original report
Concerns
19

Raised in this report

Recipients
7

Named on the report

Responses found
6

Of 7 recipients

Stated actions
27

Described in responses

Source document

Full report text

This is the full text from the original published report.

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Concerns and recipient responses

Select any concern, action or position to view the source wording.

Report evidence summary

Concerns raised19

  1. Failure to assess new drivers’ understanding of passenger effects on braking, stability and handling
    Part of recurring concern: Failure to reliably assess driver fitness and driving safetyPart of recurring concern: Inadequate driver licensing controls for road safety
  2. Failure of licensing arrangements to address combined inexperience, peer presence and full vehicle loading
    Part of recurring concern: Inadequate driver licensing controls for road safetyPart of recurring concern: Insufficient controls on young and newly qualified drivers carrying young passengers
  3. Lack of a coordinated cross-sector approach to early indications of unsafe behaviour
Responses linked to these concerns

Each statement is shown once, even when linked to more than one concern.

Actions described in response An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.15

  1. Action

    Follow development of the national road-safety strategy’s guidance and supporting road-safety education manual.

    Stated by Brake, the road-safety charityStated plannedThe respondent said that this action was planned when they made their response on 18 December 2025.
  2. Action

    Continue using Brake’s voice and platforms to raise issues identified in the report, including peer influence, vehicle loading and rural road hazards.

    Stated by Brake, the road-safety charityStated in progressThe respondent said that this action was in progress when they made their response on 18 December 2025.
  3. Action

    Release previously undertaken research on stronger licensing measures for young and newly qualified drivers.

    Stated by Brake, the road-safety charityStated plannedThe respondent said that this action was planned when they made their response on 18 December 2025.

Respondent positions A position is what a recipient says about a concern when it does not describe a specific action.9

  1. Position

    A purely self-regulatory agreement to require more young drivers to adopt telematics could be undermined by insurers opting out.

    Stated by Chartered Insurance InstituteUnable to actThe respondent said that a constraint prevented them from taking the relevant action.

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure to assess new drivers’ understanding of passenger effects on braking, stability and handling

Wider context from the report

“2. New drivers are not required to demonstrate an understanding of how passengers affect braking, stability and handling. The standard driving test does not require experience on rural roads with tight bends, undulations or variable grip. Given that collision risk is highest in the early post-test period, there is a concern as to whether current licensing arrangements adequately reflect the conditions young drivers commonly face or include a structured progression stage aligned to this risk. ”

Is this part of a recurring concern?

Yes — Failure to reliably assess driver fitness and driving safety; Inadequate driver licensing controls for road safety.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure of licensing arrangements to address combined inexperience, peer presence and full vehicle loading

Wider context from the report

“1. The inquest noted that newly qualified drivers may carry multiple peer-age passengers immediately after passing their test. This case suggests that inexperience, peer presence and full vehicle loading can combine to elevate risk, and it is unclear how current licensing arrangements address these combined factors. ”

Is this part of a recurring concern?

Yes — Inadequate driver licensing controls for road safety; Insufficient controls on young and newly qualified drivers carrying young passengers.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of a coordinated cross-sector approach to early indications of unsafe behaviour

Wider context from the report

“10. There does not appear to be a coordinated approach linking driver training bodies, insurers, social media platforms and road-safety organisations in identifying or responding to early indications of unsafe behaviour among newly qualified drivers. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Unequal behavioural oversight of named drivers with similar early-stage risk profiles

Wider context from the report

“4. Evidence was heard about the practice of “fronting.” Although it did not apply in this case, it illustrates difficulties insurers may face in identifying the true pattern of vehicle use when young drivers are insured as named drivers. Named drivers may not be subject to telematics monitoring, which can result in differing levels of behavioural oversight for drivers with similar early-stage risk profiles. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure of the standard driving test to require experience on challenging rural roads

Wider context from the report

“2. New drivers are not required to demonstrate an understanding of how passengers affect braking, stability and handling. The standard driving test does not require experience on rural roads with tight bends, undulations or variable grip. Given that collision risk is highest in the early post-test period, there is a concern as to whether current licensing arrangements adequately reflect the conditions young drivers commonly face or include a structured progression stage aligned to this risk. ”

Is this part of a recurring concern?

Yes — Failure to reliably assess driver fitness and driving safety; Inadequate driver licensing controls for road safety.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Inconsistent incorporation of safety considerations into young-driver insurance products

Wider context from the report

“5. While telematics devices can monitor driving behaviour, it is unclear how insurers collect, interpret or act upon such data, or how consistently safety considerations are incorporated into insurance products designed for young drivers. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Unclear detection and review of dangerous-driving content uploaded by minors

Wider context from the report

“7. The inquest heard that unsafe driving behaviour was recorded and shared privately on Snapchat prior to the collision. It received no information on whether Snapchat is able to detect or review content depicting dangerous driving, including where uploaded by minors. It also remains unknown whether any such material was shared via public features, such as Spotlight or Public Stories, or whether algorithmic systems could have disseminated it more widely. ”

Is this part of a recurring concern?

Yes — Unreliable monitoring and moderation of harmful social-media content.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of safeguarding processes to identify repeated unsafe conduct among young users

Wider context from the report

“8. The filming and sharing of high-risk driving among peers, apparently treated as entertainment, raised concern that such use may normalise, encourage or reinforce risk-taking behaviour. There is no publicly available information on whether Snapchat has considered these behavioural risks or has safeguarding processes capable of identifying repeated patterns of unsafe conduct among young users. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Uncertainty about wider algorithmic dissemination of dangerous-driving content

Wider context from the report

“7. The inquest heard that unsafe driving behaviour was recorded and shared privately on Snapchat prior to the collision. It received no information on whether Snapchat is able to detect or review content depicting dangerous driving, including where uploaded by minors. It also remains unknown whether any such material was shared via public features, such as Spotlight or Public Stories, or whether algorithmic systems could have disseminated it more widely. ”

Is this part of a recurring concern?

Yes — Social media features failing to control amplification of harmful content.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of a consistent method to identify concealed higher-than-expected use by young named drivers

Wider context from the report

“6. Industry practice does not appear to include a consistent method for identifying when a named driver arrangement may conceal higher-than-expected use by a young driver, with implications for risk assessment and safety. There is also no uniform approach to how telematics is applied or the need for its use communicated to young drivers. The inquest noted uncertainty about how clearly insurers and brokers explain the safety-related aspects of telematics to young drivers or their families, which may influence decisions made when arranging insurance. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Insufficient understanding of peer influence, vehicle loading and rural road hazards

Wider context from the report

“9. The circumstances of this case highlight the continued significance of peer influence, vehicle loading and rural road hazards for young drivers. It is unclear how well these risks are understood by young people, parents (particularly those organising insurance cover), or schools. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Unclear insurer processes for collecting, interpreting and acting on telematics data

Wider context from the report

“5. While telematics devices can monitor driving behaviour, it is unclear how insurers collect, interpret or act upon such data, or how consistently safety considerations are incorporated into insurance products designed for young drivers. ”

Is this part of a recurring concern?

Yes — Inadequate telematics safety controls for young drivers.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Difficulty identifying true vehicle use by young named drivers

Wider context from the report

“4. Evidence was heard about the practice of “fronting.” Although it did not apply in this case, it illustrates difficulties insurers may face in identifying the true pattern of vehicle use when young drivers are insured as named drivers. Named drivers may not be subject to telematics monitoring, which can result in differing levels of behavioural oversight for drivers with similar early-stage risk profiles. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Peer sharing of high-risk driving normalising and reinforcing risk-taking

Wider context from the report

“8. The filming and sharing of high-risk driving among peers, apparently treated as entertainment, raised concern that such use may normalise, encourage or reinforce risk-taking behaviour. There is no publicly available information on whether Snapchat has considered these behavioural risks or has safeguarding processes capable of identifying repeated patterns of unsafe conduct among young users. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure of test requirements to assess passenger and load-related vehicle dynamics

Wider context from the report

“3. The inquest heard that newly qualified drivers may have limited experience of rural roads, vehicles under load or situations that significantly affect handling. Test requirements do not involve passengers or load-related vehicle dynamics, raising concern about whether the competencies assessed at qualification correspond to those required during the early stages of independent driving. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Unclear communication of telematics use and safety implications to young drivers and families

Wider context from the report

“6. Industry practice does not appear to include a consistent method for identifying when a named driver arrangement may conceal higher-than-expected use by a young driver, with implications for risk assessment and safety. There is also no uniform approach to how telematics is applied or the need for its use communicated to young drivers. The inquest noted uncertainty about how clearly insurers and brokers explain the safety-related aspects of telematics to young drivers or their families, which may influence decisions made when arranging insurance. ”

Is this part of a recurring concern?

Yes — Inadequate telematics safety controls for young drivers.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure of qualification competencies to cover early independent-driving conditions

Wider context from the report

“3. The inquest heard that newly qualified drivers may have limited experience of rural roads, vehicles under load or situations that significantly affect handling. Test requirements do not involve passengers or load-related vehicle dynamics, raising concern about whether the competencies assessed at qualification correspond to those required during the early stages of independent driving. ”

Is this part of a recurring concern?

Yes — Failure to reliably assess driver fitness and driving safety.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure of licensing arrangements to provide structured progression aligned to early post-test risk

Wider context from the report

“2. New drivers are not required to demonstrate an understanding of how passengers affect braking, stability and handling. The standard driving test does not require experience on rural roads with tight bends, undulations or variable grip. Given that collision risk is highest in the early post-test period, there is a concern as to whether current licensing arrangements adequately reflect the conditions young drivers commonly face or include a structured progression stage aligned to this risk. ”

Is this part of a recurring concern?

Yes — Inadequate driver licensing controls for road safety.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of a uniform approach to applying telematics

Wider context from the report

“6. Industry practice does not appear to include a consistent method for identifying when a named driver arrangement may conceal higher-than-expected use by a young driver, with implications for risk assessment and safety. There is also no uniform approach to how telematics is applied or the need for its use communicated to young drivers. The inquest noted uncertainty about how clearly insurers and brokers explain the safety-related aspects of telematics to young drivers or their families, which may influence decisions made when arranging insurance. ”

Is this part of a recurring concern?

Yes — Inadequate telematics safety controls for young drivers.

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

Follow development of the national road-safety strategy’s guidance and supporting road-safety education manual.

Verbatim wording from the response

“Education and awareness-raising are also central to our work. Brake has delivered road-safety education for many years, including initiatives in primary schools, and we coordinate Road Safety Week each November. We note the new National Road Safety Strategy’s emphasis on a lifelong learning approach and the government’s commitment to publishing national guidance and a supporting manual for road-safety education. We welcome this focus and will follow its development closely.”

Source location

Response from Brake
Page 1 · response
Published 18 December 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

Continue using Brake’s voice and platforms to raise issues identified in the report, including peer influence, vehicle loading and rural road hazards.

Verbatim wording from the response

“Your report highlights the significance of peer influence, vehicle loading, and rural road hazards for young drivers, and identifies uncertainty around how well these risks are understood by young people, parents (particularly those arranging insurance cover), and schools. These are important issues that require continued consideration at national level.”

Source location

Response from Brake
Page 1 · response
Published 18 December 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

Release previously undertaken research on stronger licensing measures for young and newly qualified drivers.

Verbatim wording from the response

“We have long campaigned for stronger licensing measures to protect young and newly qualified drivers, and this remains one of our organisational priorities. We partner with the Protect Young Drivers campaign, and we will shortly be releasing research undertaken last year on this issue. I will ensure a copy is shared with you once published.”

Source location

Response from Brake
Page 1 · response
Published 18 December 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

Work with relevant stakeholders to promote consistent good practice in using telematics data to improve road safety.

Verbatim wording from the response

“• Working with insurers, trade associations, road safety groups, driver training bodies, consumer groups and the Financial Conduct Authority to build on existing good practice (such as the BIBA Good practice guide to selling telematics¹⁰) to stimulate: ○ higher prioritisation of young drivers as potentially vulnerable customers ○ greater consistency in the way insurers apply good practice when identifying the misuse of named driver arrangements ○ greater consistency in the way insurers apply good practice in the promotion of telematics to young drivers, ○ greater consistency in the way insurers apply good practice in the use of telematics data to improve road safety.”

Source location

Response from Chartered Insurance Institute
Page 7 · response
Published 18 December 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

Work with relevant stakeholders to promote consistent good practice for identifying misuse of named-driver arrangements.

Verbatim wording from the response

“• Working with insurers, trade associations, road safety groups, driver training bodies, consumer groups and the Financial Conduct Authority to build on existing good practice (such as the BIBA Good practice guide to selling telematics¹⁰) to stimulate: ○ higher prioritisation of young drivers as potentially vulnerable customers ○ greater consistency in the way insurers apply good practice when identifying the misuse of named driver arrangements ○ greater consistency in the way insurers apply good practice in the promotion of telematics to young drivers, ○ greater consistency in the way insurers apply good practice in the use of telematics data to improve road safety.”

Source location

Response from Chartered Insurance Institute
Page 7 · response
Published 18 December 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

Publish guidance by the end of 2026 on behavioural change and proactive risk management, including collection, interpretation and use of data.

Verbatim wording from the response

“• The guidance will identify:”

Source location

Response from Chartered Insurance Institute
Page 3 · response
Published 18 December 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

Work with relevant stakeholders to promote consistent good practice when explaining and promoting telematics to young drivers.

Verbatim wording from the response

“• Working with insurers, trade associations, road safety groups, driver training bodies, consumer groups and the Financial Conduct Authority to build on existing good practice (such as the BIBA Good practice guide to selling telematics¹⁰) to stimulate: ○ higher prioritisation of young drivers as potentially vulnerable customers ○ greater consistency in the way insurers apply good practice when identifying the misuse of named driver arrangements ○ greater consistency in the way insurers apply good practice in the promotion of telematics to young drivers, ○ greater consistency in the way insurers apply good practice in the use of telematics data to improve road safety.”

Source location

Response from Chartered Insurance Institute
Page 7 · response
Published 18 December 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

Consult on a Minimum Learning Period and related pre-test measures, including a possible mandatory modular learner syllabus.

Verbatim wording from the response

“Whilst we are not considering further restrictions on newly qualified drivers such as carrying passengers or driving at night, we are consulting on a Minimum Learning Period in England, Scotland, and Wales before learner drivers can take their practical driving test.”

Source location

Response from Department for Transport and DVSA
Page 2 · response
Published 18 December 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 and update driving-test-centre routes to include relevant high-speed, high-risk rural roads where locations allow.

Verbatim wording from the response

“Reviewing and refreshing all current routes will take time. The expectation is that by 31 March 2026, each Driving Test Centre will have reviewed and updated all routes to be more relevant and to include high speed, high risk rural roads where location allows.”

Source location

Response from Department for Transport and DVSA
Page 3 · response
Published 18 December 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

Implement updates to the car practical driving test, including additional higher-speed-road driving where locations allow.

Verbatim wording from the response

“Following a successful five-month trial, the DVSA introduced updates to the car practical driving test from Monday 24 November 2025. As a result of these changes, learner drivers will spend more time on higher-speed roads during their driving test, where location allows. These changes aim to enhance road safety, address collision rates in rural areas and align the test more closely with real-world driving conditions.”

Source location

Response from Department for Transport and DVSA
Page 3 · response
Published 18 December 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

Work with insurers and road safety charities to promote telematics uptake and communicate its safety benefits to young and novice drivers.

Verbatim wording from the response

“Telematics technology has become a vital tool in promoting safer driving among young motorists, providing real-time feedback and incentivising positive driving behaviours. However, the use of telematics remains optional for motorists, and neither the ABI nor its members have the authority to mandate its adoption. Requiring telematics for all drivers could limit consumer choice and potentially increase the cost of cover for some individuals. Nevertheless, the ABI is committed to working with its members to continue championing the benefits of telematics, encouraging its uptake among new and novice drivers to help improve road safety.”

Source location

Response from The ABI Together Driving Change
Page 4 · response
Published 18 December 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

Advocate to government for young and novice driver safety measures, including progressive licensing, through the Road Safety Strategy.

Verbatim wording from the response

“The primary purpose of motor insurance is to provide financial protection to vehicle owners for damage caused to their own vehicle, or damage or injury they cause to others. A minimum of third-party motor insurance is a legal requirement to drive on UK roads. The ABI is actively engaging with its insurer members through our Motor Insurance Roadmap to support young drivers, and we continue to advocate for progressive policy change at the government level. We strongly welcome the Government’s recent Road Safety Strategy and endorse several key measures designed to protect young drivers, as well as the wider public. The motor insurance industry also invests in and advocates for improved road safety to prevent accidents from occurring. This includes:”

Source location

Response from The ABI Together Driving Change
Page 3 · response
Published 18 December 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

Collaborate with road safety partners and government to raise awareness of young-driver risks and support initiatives reducing road fatalities.

Verbatim wording from the response

“In addition to our work with insurers, the ABI collaborates with leading road safety charities, including BRAKE, RoSPA, and PACTS, to further strengthen our approach to telematics and its role in young driver safety. These partnerships enable us to draw upon expert knowledge and outreach capabilities to ensure that communications about telematics are both accurate and impactful, particularly in highlighting its potential to reduce risky driving behaviours and prevent accidents.”

Source location

Response from The ABI Together Driving Change
Page 4 · response
Published 18 December 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

Campaign with stakeholders, including the Driver and Vehicle Standards Agency, to raise young drivers’ awareness of fronting and ghost broking.

Verbatim wording from the response

“• Continue to campaign to raise awareness amongst young drivers of motor insurance frauds, such as fronting and ghost broking, working alongside stakeholders, including the Driver and Vehicle Standards Agency.”

Source location

Response from The ABI Together Driving Change
Page 5 · response
Published 18 December 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

Encourage effective and appropriate use of telematics data in the insurance sector.

Verbatim wording from the response

“We have carefully considered the matters raised in your report. While we cannot act beyond our statutory remit, we remain committed to ensuring that firms meet the highest standards under our existing rules. We continue to encourage effective and appropriate use of telematics data in the insurance sector.”

Source location

Response from Financial Conduct Authority
Page 3 · response
Published 18 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

A purely self-regulatory agreement to require more young drivers to adopt telematics could be undermined by insurers opting out.

Verbatim wording from the response

“A purely self-regulatory approach to forcing more drivers to adopt telematics is unlikely to work.”

Source location

Response from Chartered Insurance Institute
Page 4 · response
Published 18 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

Prescriptive mandates on telematics technology or communications are unlikely to secure safer driving because telematics benefits require a broader range of measures.

Verbatim wording from the response

“• Second, the greatest benefits of telematics can only be derived from a range of measures. For example, the research agency, Consumer Intelligence, has summarised some of these approaches as:”

Source location

Response from Chartered Insurance Institute
Page 5 · response
Published 18 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

Further restrictions on newly qualified drivers, including passenger or nighttime limits, are not currently being considered.

Verbatim wording from the response

“Whilst we are not considering further restrictions on newly qualified drivers such as carrying passengers or driving at night, we are consulting on a Minimum Learning Period in England, Scotland, and Wales before learner drivers can take their practical driving test.”

Source location

Response from Department for Transport and DVSA
Page 2 · response
Published 18 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

The driving test cannot replicate every scenario a driver may encounter after qualification.

Verbatim wording from the response

“Turning to the concerns raised regarding the scope of the current driving test: the object of the driving test is to ensure that the candidate is well grounded in the basic principles of safe driving and is sufficiently practised in them to be able to show, at the time of the test, that they are a competent and considerate driver and are not a source of danger to themselves or to other road users. If a candidate reaches the required standard they will pass their test. However, it is not intended to, and could not, replicate every scenario a driver may encounter after qualification.”

Source location

Response from Department for Transport and DVSA
Page 2 · response
Published 18 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

Because vehicle loading and passenger dynamics vary, the test relies on core competencies to support safe adaptation across different conditions.

Verbatim wording from the response

“Vehicle loading and passenger dynamics are important aspects of safe driving, but these situations vary significantly depending on vehicle type and usage. For this reason, the test focuses on core competencies such as hazard perception, vehicle control, and decision-making, which are fundamental to adapting safely to different conditions. Learner drivers have the option to carry passengers during their learning journeys.”

Source location

Response from Department for Transport and DVSA
Page 3 · response
Published 18 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

A single industry-wide method for identifying excessive named-driver use is not feasible because detection is difficult and relies partly on policyholder honesty.

Verbatim wording from the response

“While there is currently no single, industry-wide methodology for identifying higher-than-expected use by named drivers, this is because it can be difficult to identify, and insurers are, to an extent, reliant on the honesty of their policyholders. Nevertheless, insurers do employ a range of tools and data sources to detect potential fronting, including analysing patterns of vehicle usage, monitoring claims histories, reviewing telematics data, and looking for inconsistencies in declared information. For instance, insurers might flag policies where a named driver appears to be using the vehicle far more frequently than the main policyholder, or where telematics data suggests driving habits do not match the profile of the declared main user.”

Source location

Response from The ABI Together Driving Change
Page 4 · response
Published 18 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

The ABI and its members lack authority to mandate telematics adoption for all drivers.

Verbatim wording from the response

“Telematics technology has become a vital tool in promoting safer driving among young motorists, providing real-time feedback and incentivising positive driving behaviours. However, the use of telematics remains optional for motorists, and neither the ABI nor its members have the authority to mandate its adoption. Requiring telematics for all drivers could limit consumer choice and potentially increase the cost of cover for some individuals. Nevertheless, the ABI is committed to working with its members to continue championing the benefits of telematics, encouraging its uptake among new and novice drivers to help improve road safety.”

Source location

Response from The ABI Together Driving Change
Page 4 · response
Published 18 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

Government, through primary legislation, is responsible for decisions about requiring specific insurance product features or telematics.

Verbatim wording from the response

“As we are not the competent authority for matters concerning driver or road safety, we cannot direct insurers in these areas, such as requiring specific product features or mandating the use of telematics. Those decisions sit with the Government through primary legislation.”

Source location

Response from Financial Conduct Authority
Page 1 · response
Published 18 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

Mandatory telematics and driver or road safety matters fall outside the regulator’s remit.

Verbatim wording from the response

“As we are not the competent authority for matters concerning driver or road safety, we cannot direct insurers in these areas, such as requiring specific product features or mandating the use of telematics. Those decisions sit with the Government through primary legislation.”

Source location

Response from Financial Conduct Authority
Page 1 · response
Published 18 December 2025

Open published response

Other statements in published responses

These actions and other statements could not be clearly connected to one concern in this report.

Recipient-stated actions An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.12

  1. 1

    Share the published licensing research with the coroner.

    Stated by Brake, the road-safety charityStated plannedThe respondent said that this action was planned when they made their response on 18 December 2025.
  2. 2

    Develop profession guidance explaining why new drivers may be vulnerable, incorporating existing vulnerability guidance and relevant safety practices.

    Stated by Chartered Insurance InstituteStated plannedThe respondent said that this action was planned when they made their response on 18 December 2025.
  3. 3

    Work with relevant stakeholders to encourage insurers to prioritise young drivers as potentially vulnerable customers.

    Stated by Chartered Insurance InstituteStated plannedThe respondent said that this action was planned when they made their response on 18 December 2025.
  4. 4

    Complete a four-month consultation on guidance addressing behavioural change and proactive risk-management processes.

    Stated by Chartered Insurance InstituteStated plannedThe respondent said that this action was planned when they made their response on 18 December 2025.
  5. 5

    Write to Corporate Chartered general insurance firms highlighting the Regulation 28 report and its safety issues.

    Stated by Chartered Insurance InstituteStated plannedThe respondent said that this action was planned when they made their response on 18 December 2025.
  6. 6

    Publish responses to the road-safety consultations after they conclude.

    Stated by Department for Transport and Driver and Vehicle Standards AgencyStated plannedThe respondent said that this action was planned when they made their response on 18 December 2025.
  7. 7

    Establish and chair a Road Safety Board to support and monitor road safety measures.

    Stated by Department for Transport and Driver and Vehicle Standards AgencyStated plannedThe respondent said that this action was planned when they made their response on 18 December 2025.
  8. 8

    Publish the Road Safety Strategy setting a target to reduce deaths and serious injuries by 65% by 2035.

    Stated by Department for Transport and Driver and Vehicle Standards AgencyStated completedThe respondent said that this action was complete when they made their response on 18 December 2025.
  9. 9

    Consult on lowering the blood alcohol limit for novice drivers in England and Wales.

    Stated by Department for Transport and Driver and Vehicle Standards AgencyStated in progressThe respondent said that this action was in progress when they made their response on 18 December 2025.
  10. 10

    Participate in the Government Motor Insurance Taskforce Stakeholder Panel and advocate integrating telematics data into wider road safety initiatives.

    Stated by The ABIStated completedThe respondent said that this action was complete when they made their response on 18 December 2025.
  11. 11

    Engage insurer members through the Motor Insurance Roadmap to support safer outcomes for young drivers.

    Stated by The ABIStated in progressThe respondent said that this action was in progress when they made their response on 18 December 2025.
  12. 12

    Ensure firms meet the highest standards under existing FCA rules.

    Stated by Financial Conduct AuthorityStated in progressThe respondent said that this action was in progress when they made their response on 18 December 2025.

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

Share the published licensing research with the coroner.

Verbatim wording from the response

“We have long campaigned for stronger licensing measures to protect young and newly qualified drivers, and this remains one of our organisational priorities. We partner with the Protect Young Drivers campaign, and we will shortly be releasing research undertaken last year on this issue. I will ensure a copy is shared with you once published.”

Source location

Response from Brake
Page 1 · response
Published 18 December 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

Develop profession guidance explaining why new drivers may be vulnerable, incorporating existing vulnerability guidance and relevant safety practices.

Verbatim wording from the response

“The CII commits to encouraging the insurance community to consider younger drivers as potentially vulnerable consumers through:”

Source location

Response from Chartered Insurance Institute
Page 7 · response
Published 18 December 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

Work with relevant stakeholders to encourage insurers to prioritise young drivers as potentially vulnerable customers.

Verbatim wording from the response

“The CII commits to encouraging the insurance community to consider younger drivers as potentially vulnerable consumers through:”

Source location

Response from Chartered Insurance Institute
Page 7 · response
Published 18 December 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

Complete a four-month consultation on guidance addressing behavioural change and proactive risk-management processes.

Verbatim wording from the response

“• The guidance will identify:”

Source location

Response from Chartered Insurance Institute
Page 3 · response
Published 18 December 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

Write to Corporate Chartered general insurance firms highlighting the Regulation 28 report and its safety issues.

Verbatim wording from the response

“• In response to these findings, the CII (Chartered Insurance Institute) commits to:”

Source location

Response from Chartered Insurance Institute
Page 2 · response
Published 18 December 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

Publish responses to the road-safety consultations after they conclude.

Verbatim wording from the response

“The consultation on introducing a Minimum Learning Period for learner drivers closes on 11 May and can be found at the following link: https://www.gov.uk/government/consultations/introducing-a-minimum-learning-period-for-learner-drivers/introducing-a-minimum-learning-period-for-learner-drivers-category-b-driving-licence”

Source location

Response from Department for Transport and DVSA
Page 4 · response
Published 18 December 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

Establish and chair a Road Safety Board to support and monitor road safety measures.

Verbatim wording from the response

“That is one reason why, on 7 January 2026 my Department published a new Road Safety Strategy, setting out the Government’s vision for a safer future on our roads for all. The Strategy sets an ambitious target to reduce the number of people killed or seriously injured on British roads by 65% by 2035. This target will focus the efforts of road safety partners across Britain, with measures to improve road design, protect vulnerable road users, and review motoring offences. All of this will be supported and monitored by a new Road Safety Board which I will chair.”

Source location

Response from Department for Transport and DVSA
Page 2 · response
Published 18 December 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

Publish the Road Safety Strategy setting a target to reduce deaths and serious injuries by 65% by 2035.

Verbatim wording from the response

“That is one reason why, on 7 January 2026 my Department published a new Road Safety Strategy, setting out the Government’s vision for a safer future on our roads for all. The Strategy sets an ambitious target to reduce the number of people killed or seriously injured on British roads by 65% by 2035. This target will focus the efforts of road safety partners across Britain, with measures to improve road design, protect vulnerable road users, and review motoring offences. All of this will be supported and monitored by a new Road Safety Board which I will chair.”

Source location

Response from Department for Transport and DVSA
Page 2 · response
Published 18 December 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

Consult on lowering the blood alcohol limit for novice drivers in England and Wales.

Verbatim wording from the response

“Additionally, as part of the motoring offences consultation, we are consulting on a lower blood alcohol limit for novice drivers in England and Wales.”

Source location

Response from Department for Transport and DVSA
Page 2 · response
Published 18 December 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

Participate in the Government Motor Insurance Taskforce Stakeholder Panel and advocate integrating telematics data into wider road safety initiatives.

Verbatim wording from the response

“Furthermore, our engagement with the Department for Transport is central to these efforts. The ABI participated in the Stakeholder Panel of the Government’s recent Motor Insurance Taskforce, where we advocated for the integration of telematics data into broader road safety initiatives.”

Source location

Response from The ABI Together Driving Change
Page 4 · response
Published 18 December 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

Engage insurer members through the Motor Insurance Roadmap to support safer outcomes for young drivers.

Verbatim wording from the response

“The primary purpose of motor insurance is to provide financial protection to vehicle owners for damage caused to their own vehicle, or damage or injury they cause to others. A minimum of third-party motor insurance is a legal requirement to drive on UK roads. The ABI is actively engaging with its insurer members through our Motor Insurance Roadmap to support young drivers, and we continue to advocate for progressive policy change at the government level. We strongly welcome the Government’s recent Road Safety Strategy and endorse several key measures designed to protect young drivers, as well as the wider public. The motor insurance industry also invests in and advocates for improved road safety to prevent accidents from occurring. This includes:”

Source location

Response from The ABI Together Driving Change
Page 3 · response
Published 18 December 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

Ensure firms meet the highest standards under existing FCA rules.

Verbatim wording from the response

“We have carefully considered the matters raised in your report. While we cannot act beyond our statutory remit, we remain committed to ensuring that firms meet the highest standards under our existing rules. We continue to encourage effective and appropriate use of telematics data in the insurance sector.”

Source location

Response from Financial Conduct Authority
Page 3 · response
Published 18 December 2025

Open published response
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Information checked against the published report and official responses · Data reviewed 7 Sep 2026 · About data quality and limitations

Official responses located
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Data last updated 7 September 2026