In short, the answer is yes.
In the middle of 2006, the Road Safety Act 2006 was introduced which closed the ‘loophole’ by which companies could operate a limousine hire business without an operators or private hire licence. Because this was an amendment to an existing act and as a consequence of the material affect it would have on many existing businesses, a softly, softly approach has been adopted to the introduction meaning that the law will only be enforced from January 2008.
Therefore, from 1st January 2008, no unlicensed limousine operator will be able to avoid the risk of prosecution; given there has been ample warning in relation to the amendment to existing legislation. The most common form of licensing is a local authority approved ‘private hire licence’ or in the case of London, a PCO licence which is issued by the Public Carriage Office, part of Transport for London. It is also possible to operate a limousine business with an ‘Restricted Licence’ issued by the Traffic Commissioners, however, in this case, any vehicles which carry more than 8 passengers must have what is known as a ‘Certificate of Initial Fitness’ (most limousines cannot meet the requirements of this test) and the chauffeurs must have an appropriate Public Carrying Vehicle (PCV) licence. Furthermore, operators with a Restricted Licence can only operate one or two such vehicles and the operation of these vehicles must be not be the primary business, it must be incidental.