UT/2024/000008 - [2025] UKUT 00100 (TCC)

Bolt is part of the Bolt group of companies, the parent company of which is based in Estonia. The group provides a global mobility platform offering a range of services, including transport by private hire vehicle (“PHV”), in over 400 cities worldwide.

In the United Kingdom, Bolt is a licensed PHV operator.

The platform became fully operational in London in June 2019. Since then, Bolt has expanded to other areas across the UK. London is Bolt’s biggest market from a UK and global perspective.

The platform enables Bolt’s customers to request a PHV to take them from point A to point B by using an app on their smart phones. Customers can select from a wide range of PHV options before completing their request.

Bolt accepts requests for rides from customers via the platform and provides each customer with an estimated fare and arrival time. Once a request for a ride has been received, Bolt allocates the journey to a PHV driver who is willing to transport the customer. All bookings and acceptances of PHV journeys are carried out via the platform and in accordance with Bolt’s terms and conditions for drivers and passengers.

With effect from 1 August 2022, Bolt has acted as principal in the re-supply of passenger transport by PHV, which it buys from self-employed PHV drivers and re-supplies to its customers. Bolt contracts separately with both drivers and passengers and is responsible for all invoicing and remittance of payments. There is no contractual relationship between the drivers and the customers.

The PHV drivers are independent contractors. They are free to provide PHV transport independently of the platform, including to Bolt’s competitors. In order to provide transport services to Bolt, a PHV driver must first register with Bolt and be granted access to the Bolt platform. The drivers provide their own vehicles and all equipment needed to provide transport. They are also responsible for maintaining their vehicles, ensuring that there is a valid MOT and appropriate insurance cover, acquiring licences, paying road tax, tolls, fuel and any electricity charge costs (to the extent relevant).

Bolt allocates a customer's request for transport by PHV to a driver based on the driver’s proximity to the customer at the time of the request. Bolt provides the driver with the destination, and the estimated duration and fee for the journey. The drivers are free to accept or reject any offers to fulfil PHV journeys.

The sole exceptions to the allocation by proximity rule are PHV journeys that depart from London, Manchester, Birmingham and Edinburgh airports. In such cases, other allocation arrangements are in place to avoid congestion around the airports.

Bolt provides transport to a diverse group of customers who choose to travel via Bolt for a variety of different reasons. The customers include overseas tourists travelling in the UK and UK residents travelling for personal and business reasons. Bolt supplies journeys of different lengths both within and between cities or towns.

Between August 2022 and May 2023, Bolt provided 35.9 million PHV journeys. Just over 1.8 million of those journeys were provided to customers with a Bolt account that had been registered overseas between August 2022 and May 2023. During the same period, out of the 35.9 million PHV journeys, Bolt supplied 24,300 PHV journeys that were 100km or longer; 274,750 journeys of 50km or longer; and 1,258,490 journeys of 25km or more. A number of PHV journeys provided by Bolt were to and from key transport hubs, such as train stations, bus stations, tube stops, airports. Between August 2022 and May 2023, Bolt supplied 831,282 (2.3% of the total) PHV journeys to or from airports and 3,162,289 (8.9% of the total) PHV journeys to or from train stations.

Bolt offers its customers help and assistance via the Bolt app, its website as well as by email and 24-hour phone lines. Bolt currently has 24 employees dedicated to customer service in-house and has outsourced the rest of the operations to a team consisting of 169 individuals who deal with over 115,000 enquiries a month. Customers can receive assistance at any point in the process (e.g. when making a booking, manoeuvring around the app and/or once the PHV journey has taken place) via in-app messaging. In addition, Bolt maintains an up-to-date blog on its website offering travel advice to customers.