I am shocked that it has been almost three years since the Department for Transport (DfT) launched the set of medium-term exemptions from PSVAR for rail replacement (RR) and home-to-school (H2S) services provided by coaches on 13 April 2022. At the time, you could apply for an exemption (called special authorisations) which are valid until 31 July 2026.
Under those exemptions, vehicles covered by a special authorisation were exempt from PSVAR until 31 July 2023 and then had to meet specified levels of compliance depending on the size of the RR and H2S fleet, increasing incrementally over a three-year period, with full compliance in August 2026.
These medium-term exemptions introduced the concept of partial compliance, where vehicles met all requirements for PSVAR, but were exempt from complying with those for wheelchair lifts and destination equipment.
Next year will be 2026, while the final set of those incremental stages of compliance with PSVAR come into force in less than six months’ time, on 1 August 2025. They are as follows:
- Band A (between one and five vehicles): At least one fully compliant vehicle, with the rest of the fleet partially compliant
- Band B (between six and nine vehicles): At least two fully compliant vehicles, with the rest of the fleet partially compliant
- Band C (between 10 and 29 vehicles): At least 25% of the fleet fully compliant, with the rest of the fleet partially compliant
- Band D (30 vehicles or more): At least 35% of the fleet fully compliant, with the rest of the fleet partially compliant.
This is significant because, for the first time, all operators that run any RR or H2S services that are covered by the Regulations are required to have at least one fully compliant PSVAR vehicle. In addition, those in Band C and Band D require significantly more fully compliant vehicles than previously.
Having spoken to several coach operators about these latest compliance levels there are two points I want to make clear:
- They come into force from 1 August 2025, not 2026. 1 August 2026 is currently the date where all coaches on RR and H2S need to be fully compliant
- You need to understand where you are going to source your fully compliant vehicles for the 2025 incremental increase now, not in a few months’ time.
I can predict that sourcing fully compliant PSVAR vehicles of a reasonable quality will become increasingly more challenging and expensive as the year progresses. Don’t leave it too late.
So, what of the future?
The PSVAR call for evidence closed in September 2023 and not much has been said since. I know that many operators were hopeful that there might be a delay to the implementation of the 2025 proposed level of compliance, but I think at this stage that is unlikely, and I would not recommend planning for it.
However, there is much concern about the 1 August 2026 date, when currently all coaches on RR and H2S services covered by the Regulations need to be fully compliant. Those of us in the industry appreciate that this is unachievable, as there will not be enough fully compliant vehicles available.
We also know that some of the early PSVAR retrofit vehicles are now experiencing problems with leaks and equipment malfunctioning.
The UK Coach Operators Association has continued to engage with the relevant officials within DfT on PSVAR. We have made the point that the industry needs some notice as to what will happen next, and that the supply of vehicles (both new and second hand) is limited.
I hope we have some news soon.
