EVM News

Your detailed guide to section 19 & 22 permits

30th July 2026

Section 19 and Section 22 Permits: A complete guide for charities, schools, care groups and new community transport operators.

If your organisation wants to charge anyone — even a small contribution — towards the cost of transporting them, you normally need a full PSV (Public Service Vehicle) operator’s licence. Section 19 and Section 22 permits, created under the Transport Act 1985, are the exemption that lets not-for-profit organisations avoid that full licensing regime.

This guide pulls together the DVSA/Traffic Commissioner guidance, the official DfT PSV 385 handbook, and the Department for Education’s minibus guidance into one practical reference for charities, schools, community groups and care providers.

Do I need a permit or licence to operate my minibus or coach services?

You only need a permit — or a PSV operator’s licence — if you’re accepting “hire or reward”: any payment, in cash or kind, that gives someone the right to be carried, whether or not they end up taking the journey. This includes:

Direct fares
Indirect payments, e.g. a membership subscription, or event tickets that include travel
A school trip “contribution towards petrol” — the DfE guidance is explicit that this counts as hire or reward.

If you make no charge at all, directly or indirectly, you don’t need a permit or licence. If you do charge, and you’re a not-for-profit body, a Section 19 or Section 22 permit is very likely your route — rather than the much heavier full PSV operator’s licence.

Important: you cannot hold both a PSV operator’s licence and a Section 19/22 permit for the same legal entity, and using a permit vehicle “with a view to profit” is a criminal offence that can lead to prosecution and impoundment.

Section 19 or Section 22?

Section 19/22 are narrow exemptions, not commercial trading licences. In exchange for the comparatively low cost (versus an O Licence), you give up the ability to operate commercially or carry the general public at large. A PSV O-licence and a Section 19 or 22 permit cannot be held by the same legal entity — so you can’t mix and match. The same is true for the type of permit. A vehicle can only be used under one permit type at a time, and you must never display a Section 19 and a Section 22 disc together.

But which permit is right for you? See the table below for guidance:

	Section 19	Section 22 (Community Bus)
Who it’s for	Bodies concerned with education, religion, social welfare, recreation, or other community-benefit activities	Bodies concerned with the social/welfare needs of one or more communities, running a local bus service
Who can travel	Only specified classes of passenger (members, people the body helps, pupils, disabled/ill people, defined local communities) — never the general public	Members of the general public
Issued by	Traffic Commissioner (via DVSA) or a “designated body” (many local councils, the Community Transport Association, Scout Association, etc.)	Only the Traffic Commissioner
Typical use case	School minibus, scout group, care home trips, Dial-a-Ride	Registered local bus route run on a not-for-profit basis

Section 19 passenger classes

Every Section 19 permit specifies which classes of passenger it covers:

Class A – members of the permit-holding body
Class B – people the body exists to help, and their helpers
Class C – disabled or seriously ill people, and their helpers
Class D – pupils/students and accompanying staff
Class E – residents of a defined local/rural community whose transport needs aren’t otherwise met
Class F – any other class specified on the permit.

A permit issued to, say, a scout group only allows scout-group members and supervisors to travel — not the wider public, and not another unrelated group, unless that group is also named on the permit.

Vehicle size categories, and which permit covers which vehicle

Vehicle type	Passenger seats (excl. driver)	Section 19	Section 22
Small vehicle (car/MPV)	8 or fewer	Standard permit — separate fares must be charged ✅	Not permitted ❌
Small/standard bus	9–16	Standard permit ✅	(permit may be restricted to this size) ✅
Large bus	17+	Large bus permit only — issued only by the Traffic Commissioner ✅	(only if the Traffic Commissioner is satisfied you can maintain it properly) ✅

A standard permit cannot be used on a large bus, and a large bus permit cannot be used on a smaller vehicle — you need the matching permit type for each vehicle, and a separate permit (and displayed disc) for every vehicle you operate simultaneously.

Roadworthiness certification

Any large bus (17+ seats) used under either permit type must carry a Certificate of Initial Fitness (COIF) or Certificate of Conformity (CoC) (or the newer Road Vehicles Approval Regulations 2009 certificate), whether bought or hired in. Operating a large bus without one is a criminal offence.

MOT testing classes

Seats (excl. driver)	Test class	Where tested
8 or fewer	Class IV	Standard authorised MOT station
9–12	Class IV	Standard authorised MOT station
13–16	Class V	Approved HGV/LGV or specially designated MOT station
17+	Class VI	Approved HGV/LGV testing station, tested by DVSA examiners

Small vehicles (≤8 seats) are tested at the 3rd anniversary of registration then annually; everything else is tested annually from registration.

What it costs

The following permit costs are accurate as of Summer 2026:

Permit	Fee
Standard bus permit (Section 19)	£11
Large bus permit (Section 19)	£20
Community bus permit (Section 22)	£55
Local bus service registration/variation	£60
Community bus service registration/variation	£13

Fees are non-refundable, and you need one permit (and disc) per vehicle you’ll use at the same time — three vehicles running simultaneously means three permits and three fees.

Designated body fees vary

If you obtain a Section 19 standard permit from a local authority or the Community Transport Associatio n rather than the Traffic Commissioner directly, the fee is set by that body and can differ — recent examples range from around £10–£19 per permit. Always check the current fee with whichever body is issuing it.

Useful note on permit validity: Permits and discs issued on or after 6 April 2009 are valid for a maximum of 5 years before renewal is needed.

Driver licensing — the part that trips people up most

This is where organisations most often get caught out, because the rules differ by vehicle weight/size and by when the driver passed their car test. The universal baseline is as follows:

All drivers of a permit vehicle must be 21 or over.
Anyone holding a full PCV (D or D1) licence, PCV Community licence, or equivalent Northern Ireland licence can drive — and be paid to drive — a permit vehicle of any size.

Small vehicles (8 or fewer passenger seats) or minibuses — Section 19 only

A driver needs to have held a full category B (car) licence for at least 2 years. There’s no restriction on being paid to drive these under a Section 19 permit.

EVM’s LuxuryCab (8-seater minibus) would sit within this category for weight and seating capacity. It can be driven on an M1 (UK car licence).

Small/standard buses (9–16 seats)

(a) Passed the car test before 1 January 1997. These drivers were automatically granted D1 entitlement. As long as they retain it, they can drive a small bus of any weight under the permit, and can be paid. At age 70 they need a medical to renew the D1 entitlement (normally renewed every 3 years thereafter).

(b) Passed the car test on or after 1 January 1997. No automatic D1 entitlement — category B only lets them drive a small bus if all of the following apply:

Held a full category B licence for at least 2 years
Receives no payment beyond out-of-pocket expenses (fuel, parking, tolls — i.e. must be a genuine volunteer)
Vehicle’s maximum gross weight does not exceed 3.5 tonnes (or 4.25 tonnes where the extra weight is specifically due to equipment for carrying disabled passengers, e.g. a ramp)
No trailer is towed
If the licence is automatic-only, only an automatic vehicle is driven
If aged 70+, they meet the medical standard that would qualify them for D1.

This weight/payment combination is the single biggest practical restriction for schools, charities and small community groups using post-1997-qualified staff or volunteers.

Available models that sit within this qualifying category at EVM include: Tribus (8-seater/4 wheelchair accessible minibus), and Trend Sprinter minibuses. Both the diesel and electric variants of the Tribus and Trend, would qualify for the weight threshold of the D1 licence.

Large buses (17+ seats)

Driver must hold a full PCV (D) licence, PCV Community licence, or NI equivalent — and can be paid.

Summary table

Driver’s licence situation	Small vehicle (≤8)	Small bus (9–16)	Large bus (17+)
Full PCV/D or D1 licence	Paid OK ✅	Paid OK, any weight ✅	Paid OK ✅
Category B, test before 1 Jan 1997 (has D1)	Paid OK ✅	Paid OK, any weight ✅	❌ (unless also PCV)
Category B, test on/after 1 Jan 1997	Paid OK ✅	⚠️ Volunteer only, ≤3.5t (4.25t w/ disabled equipment), no trailer	❌

Click here to browse our range of 17+ minibuses and coaches.

Schools specifically: the “hire or reward” test

The Department for Education’s 2013 guidance (still the standard reference for school transport) adds some school-specific clarity:

Charitable/maintained/academy/free schools are treated as non-commercial bodies. If pupils travel without being obliged to pay, it’s not hire or reward — a teacher with a plain category B licence can drive under the standard car-licence rules described above, without needing a permit at all.
Asking pupils for even a small “contribution towards petrol” turns the trip into hire or reward – at which point you either rely on the category-B driving rules (with the weight and volunteer conditions above) or apply for a Section 19 permit for extra legal certainty.
Fee-paying independent schools without charitable status are more likely to be treated as commercial — the school fees themselves can be viewed as payment that includes an element for transport. Such schools are advised to seek independent legal advice and strongly consider a Section 19 permit or full PSV operator’s licence.
A teacher only counts as driving “voluntarily” if driving isn’t part of their contracted duties and they’re not separately paid for it (reimbursed expenses are fine). If driving is contractual or specifically remunerated, the driver needs a full D1/D licence regardless of vehicle weight.

Other vehicle and safety requirements you’ll need to plan for

Seat belts: minibuses/coaches/buses first used on or after 1 October 2001 need seat belts in all forward and rear-facing seats, including the driver’s. Where fitted, belts must be worn by passengers aged 14+ (with limited exemptions), and drivers must always wear theirs.
Equipment: permit vehicles (other than small vehicles/Land Rovers) must carry a compliant fire extinguisher and a stocked first aid box, and must display a maximum-passenger-capacity notice in letters at least 2.5cm high.
Maintenance: you’re responsible for keeping the vehicle roadworthy — daily walkaround checks plus safety inspections, recommended every 6–10 weeks, in addition to servicing and MOT.
Insurance: you must tell your insurer the vehicle is used for hire or reward under a permit (exempt from PSV/PHV licensing) — this applies even to small vehicles.
Drivers’ hours/tachographs: small vehicles and minibuses under Section 19 are exempt from tachographs; volunteer drivers aren’t subject to drivers’ hours rules, but employed drivers are subject to domestic hours rules. Large buses generally need a tachograph and EU drivers’ hours rules apply, subject to some short-route exemptions for Section 22 services.
Accessibility: vehicles carrying more than 22 passengers, first used from 31 December 2000 onward and running a local/scheduled service, may need to meet the Public Service Vehicles Accessibility Regulations 2000 (wheelchair space, boarding device, priority seating, handrails, etc.).

Quick decision checklist for a new operator

Are you charging anyone, directly or indirectly, for the journey? If no — no permit needed. If yes, continue.
Are you a not-for-profit body (charity, school, scout group, care organisation, community group)? If no, you likely need a full PSV operator’s licence instead.
Will the general public travel, or only specific people/groups you exist to serve?
- General public → Section 22
- Defined members/clients only → Section 19
How many passenger seats does the vehicle have?
- ≤8 → small minibus or MPV, separate fares required, Section 19 only
- 9–16 → standard/small bus permit
- 17+ → large bus permit (Traffic Commissioner only, needs COIF/CoC)
Who will drive it, and what’s their licence history? Check against the driver table in Section 5 — this decides whether they can be paid and what maximum vehicle weight they’re limited to.
Apply to the Traffic Commissioner (via DVSA), your local authority, or a designated body such as the Community Transport Association, and budget for the relevant fee.

Where to go for more information

The main basis of the information is the VOSA website. If you want detailed information or advice, we advise you to contact the following authoritative bodies:

DVSA / Central Licensing Office, Leeds — 0300 123 9000, permits@otc.gov.uk
Community Transport Association (CTA) — Advice Line 0845 130 6195, advice@ctauk.org, www.ctauk.org
Official guidance: gov.uk – Section 19 and 22 permits and obligations
DfE minibus guidance: Driving School Minibuses (DfE/DfT/ACPO, August 2013)

We have created this guide using information we were able to find on the internet. This guide summarises official DVSA/DfT/DfE guidance for general orientation only. It is not a legal document and doesn’t replace individual legal advice — only the courts can give a definitive interpretation of the legislation. If you’re unsure of your organisation’s position, contact DVSA or the CTA advice line before operating.