Stewart Lochrie, ADINJC Chairman

Tidying up the wrong problem

On the 5th May 2026, DVSA published its latest guidance on swapping driving tests, and the rules will tighten in two stages.

From 12th May 2026, only the two learner drivers involved will be able to arrange a swap, directly, by phone, with both of them on the line.

DVSA continues to claim that it will be against the law for anyone else, including driving instructors, to do it on a learner’s behalf, but the legislation on this is missing and there is no statutory instrument in place to back this up at the time of writing.

“Helping”, in the form of being present while your pupil works through the process is not specifically prohibited.

Until 9th June 2026, learners will still be able to swap with anyone at any test centre in Great Britain. From 9th June 2026 onwards, a geographic restriction kicks in and swaps will only be permitted with a learner whose test is at your test centre, one of your three nearest, or the centre you first booked at.

I’ve had a read through the guidance and it’s all a bit messy. DVSA wants to stop bad actors monetising the booking system in the belief that it will buy time for them to sort out their recruitment.

The trouble is that the implementation looks like a classic case of promising to do something before working out how difficult it would actually be to deliver, and the people most likely to feel the consequences could well be the ones the policy is supposed to help.

The ADINJC supported the limiting of swaps, but not the removal of driving instructors from the booking process.

Instructors could have made this work more efficiently for learners and, dare I say it, the poor call-handling agents at DVSA.

How this might impact swaps

The most likely outcome is that there will be fewer swaps overall.

Swapping requires two learners with mutually compatible bookings, both available at the same time, both within ten working days’ notice, both within the new geographic constraints from 9th June, and both willing to sit on a phone call together while DVSA runs security checks.

Both test bookings must be of the same kind. Every additional friction point potentially removes pairs from the pool.

Fewer swaps means less flexibility for people who are not ready in time, and one possible consequence of that is a lower pass rate.

If a learner has waited months and the only realistic route to a sooner date is closed off, some will likely sit the test under-prepared rather than wait again. “Might as well go for it” becomes the default, with or without an instructor’s blessing – or car.

The market probably won’t disappear, It will adapt

Whenever government regulation creates friction in a process people genuinely need, a market tends to form around relieving that friction. Think visa and immigration support agencies or fast-track passport services.

Removing instructors from the booking process doesn’t change the underlying demand; it just changes who is positioned to meet it.

Any company that can make swaps easier for learners, within the new rules and without breaking the law, will probably do well. The cancellation checker apps that have grown up over the last few years already have the technical infrastructure, the user base, and the commercial model. They may simply pivot into matching learners for swaps and walking them through the phone process.

There’s a real irony here. The Government has been reluctant to raise the test fee, despite repeated lobbying from the ADINJC and others, because it wants to protect taxpayers and voters from cost increases.

But by tightening the rules in this way, it has potentially created a market where private companies will charge those same taxpayers and voters for a service that without state intervention and with instructor support was free.

The Government claims to be protecting hard-hit families during a cost of living crisis, but policy leaves them more exposed than before to private market forces.

Despite this irony, DVSA might quietly welcome the intervention of the market. If a third-party matching service genuinely reduces no shows and gets more tests delivered against the same examiner capacity, that would be a win for DVSA’s metrics whether or not anyone at the agency wants to say so publicly.

Who could lose out

The few bad actors who were quietly running for-profit (often ridiculous profit) test juggling operations out of WhatsApp groups using learner credentials, yes, this should hit them, and that’s clearly the point. Good!

The system shouldn’t depend on instructors holding learner login details and profiting as informal test auctioneers.

But the majority of ADIs managing tests on behalf of their learners were never doing that. And the majority of ADIs don’t get involved in test bookings at all and only care about one thing: test availability improving so their learners can get on with it.

What this policy may do to that majority is inconvenience them in a different way, by routing learners to test centres outside their normal working area as part of the new geographic swap rules.

An instructor based in one part of a city might find themselves agreeing to take pupils to centres they don’t know, on routes they haven’t taught, because that’s the only swap that was available.

The metric that matters

We should be able to monitor the effect of this quite quickly through DVSA’s own data which is shared with the ADINJC and NASP on a regular basis.

Average waiting times, swap volumes, no show rates, tests delivered per examiner; all of it is measurable.

Within a few months, everyone should know whether the policy has worked or not. There won’t be much room for spin either way.

And the metric that matters is waiting times. If they come down, this is a success, full stop.

That’s what DVSA and the Department for Transport cares about, that’s what the majority of ADIs care about, and that’s what learners and their parents care about.

Every other consideration is secondary. If waiting times don’t come down, or go up, then this will likely turn out to have been a piece of administrative meddling dressed as reform.

What this doesn’t fix

Removing instructors from the booking system removes a small number of people who were acting in bad faith and may inconvenience a much larger number who weren’t.

It doesn’t address the actual cause of the test backlog. The crisis is, and always has been, a shortage of driving examiners working under a pay structure that doesn’t make the job attractive enough to recruit and retain at scale. Until that is fixed, every other intervention is arguably rearranging the queue rather than shortening it.

I hope I’m wrong about some of this. I hope the changes help, that the inevitable matching market evolves cleanly with no exploitation, no shows fall, and waiting times come down. But that feels like a lot to hope for. We’ll know soon enough and when we do the ADINJC will continue to hold the DVSA to the data, while continuing to press on examiner recruitment and pay structures.

Fiona’s Thoughts

The 6:00 am alarm on Mondays will still go off, but I no longer have to look for tests.

But my pupils now have to join a massive queue and wait forever to get one, whereas I could have got one booked for them in less than 5 minutes.

Have they got time to wait in that queue before work or college? Or their parents doing so on their behalf.

Will they use my PRN? And will the DVSA just override it anyway when they need to move that test when an examiner is not available, as they do at present. They ignored that question twice on the webinar.

Have the DVSA planned for all the afterschool phone calls they will get and need to make when all the swaps will need to happen?

Have the DVSA budgeted for the cost of the outgoing phone calls, when before it was just one ADI phoning in to make the swap?

I hope the geographic limit on test movements will help reduce test tourism but wasn’t that the idea of Loveday and co. in the first place, back in Covid days, and that’s just been a hangover of that ‘you can take a test anywhere’.

Two changes rather than six is probably about right, three would have been slightly better, especially with the current 24-week window. Logistically it’s hard to persuade anyone to move more than 4/6 weeks, so you must use your swaps carefully.

Our local WhatsApp group will continue to work hard to help pupils to find swaps free of additional charges, to try and make sure tests are taken by the right pupil at the right time.

The key thing is still the lack of examiners.

The DVSA needs to remove the words illegal from their announcements when there is no legislation passed and stop trying to make it look like the majority of instructors are the cause of the problem, when it was a section of them who could have been identified and dealt with.

I personally think there will be an increase in ‘can you take me to test’ calls and no-shows, because people won’t grasp the time frames required and will miss the deadlines.

Let’s hope they review it, in less than 5 years.”

Stewart Lochrie
ADINJC Governing Committee

Fiona Clarke
ADINJC Deputy Secretary

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