Somewhere between the school minibus and the commercial coach operator sits a whole layer of British transport: scout groups, village community buses, charity day centres, sports clubs. Most of it runs on permits under sections 19 and 22 of the Transport Act 1985 - an exemption regime that lets not-for-profit organisations carry passengers for payment without holding a full PSV operator licence. It is also a regime where the edges matter, because operating for hire or reward with neither licence nor valid permit risks prosecution and having the vehicle impounded.
The starting point is strict: an organisation in Great Britain that accepts any sort of payment for providing passenger transport must normally hold either a PSV operator licence - issued by a traffic commissioner - or a private hire vehicle licence from the local authority. Drivers of PSVs usually also need PCV entitlement on their driving licence. “Payment” is read broadly, which is exactly why the permit regime exists.
Sections 19 and 22 let organisations operating without a view to profit hold a permit exempting them from the PSV O-licence when providing transport for a charge - and, under specified conditions, their drivers can be exempt from needing PCV entitlement. The obligations do not evaporate: the permit holder is responsible for operating within the law, with properly maintained vehicles and appropriately qualified drivers. And eligibility now has a gateway: the operator must first satisfy one of the exemptions to EU Regulation 1071/2009 - the exclusively non-commercial purposes exemption, the main-occupation exemption, or the short-distance exemption - before meeting the 1985 Act’s own not-for-profit criteria.
Section 19 permits come in two sizes. Standard permits cover vehicles adapted to carry no more than 16 passengers excluding the driver. Large bus permits cover 17 or more. They are granted to bodies - educational and other organisations - transporting their own members or the people the organisation exists to help. The hard line: a section 19 vehicle CANNOT carry members of the general public. The scout hut run, yes; a paying seat for a passer-by, no.
Section 22 permits go to bodies concerned for the social and welfare needs of one or more communities, running a community bus service without a view to profit. The key difference: community bus services are local bus services and CAN carry the general public - local meaning passengers travel at separate fares for less than 15 miles. Vehicles must be adapted for 9 or more passengers, and large buses (17+) are only authorised where the traffic commissioner is satisfied there are adequate maintenance facilities or arrangements - roadworthiness is gated at the door. A permit issued before 6 April 2009 does not authorise a large bus at all.
A permit is not tied to one vehicle - it transfers between vehicles, but covers only one at a time, and an organisation can hold several permits and both types. The discipline is in the windscreen: the correct disc must be displayed showing how the vehicle is being used at that moment, and a section 19 and a section 22 disc must never be displayed together. Running a local bus service? The section 22 disc. Taking the same minibus out with the youth group? The section 19 disc - and no public fares.
The not-for-profit boundary has teeth. Commercial organisations - including privately owned schools, nursing homes and activity centres - are not eligible for a permit at all. And the anti-avoidance rule reaches through structures: where a permit holder provides transport on behalf of another organisation - say a separate legal entity set up to run the transport - that other organisation must also operate without a view to profit. Incorporating the transport arm does not launder a commercial parent into eligibility.
The permit regime exists so community transport does not have to become a bus company. It survives on the boundary being respected: not-for-profit, correctly permitted, correctly disced, and never quietly commercial.