Driver & Vehicle Licensing Agency

3. Mr A complains that in July 2019 DVLA unreasonably refused to register his tractor with its original number plate and provided him with an age-related registration instead.

4. Mr A says he has owned the tractor since 1970 and had driven the tractor as a child, so the tractor along with its original number plate holds a lot of sentimental value for him. He says it was very disappointing to be given an age-related number plate instead.

5. Mr A would like DVLA to reconsider its decision to refuse to register the original number plate.

6. The law says in order to use a vehicle on the road in the United Kingdom, the vehicle must be registered. Registration schemes have changed over the years and, historically, registration was dealt with by local authorities. Responsibility for registration of vehicles transferred to DVLA in 1974.

7. In 1970, Mr A bought a tractor, which had been manufactured in 1961. In July 2019, Mr A sent form V62 to DVLA to apply for a vehicle registration certificate VC5, explaining he had lost the original log book. He enclosed photos of the tractor, including its vehicle identification number (VIN) and engine number, and a letter from an archivist with information about the original registration Mr A was claiming.

8. In August 2019, DVLA told Mr A it could not process the application as it had no record of the original registration. But, it said if he could provide evidence he was entitled to it, then he might be able to keep the number plate. Or, it said he could have an age-related plate.

9. In October 2019, Mr A applied to tax and register the tractor for the first time using form V55/5, separately supplying a letter from the manufacturer confirming it had been built in 1961. In November 2019, DVLA denied this application on the basis Mr A had not proved a link between his tractor and the registration plate, and had not included the fee of £55. It said it needed pre-1983 documentation clearly linking the plate and the VIN, and mentioned the option of an age-related plate again. Mr A provided more paperwork, but later in November 2019, DVLA rejected the application again.

10. Mr A called DVLA for an update in December 2019, saying he had handed over his passport (to prove his identity) and a cheque for £55 at the DVLA office in late November 2019. The next day, DVLA told Mr A the full application would be processed. Mr A asked for a further update in early January 2020 and arranged to meet staff at the DVLA office a few days later with more evidence. After it received this evidence, DVLA was satisfied with the age of the tractor, but not the link between the registration plate and the VIN. Instead, it gave Mr A an age-related plate.

11. Mid-January 2020, Mr A contacted DVLA to ask why he was given the age-related plate, when he did not want this and had not applied for this. DVLA said it had processed his application as if it were an application for an age-related plate because it did not have the necessary evidence to register the plate Mr A had applied for.

12. In February 2020, Mr A complained DVLA had told him it would process his application and then gave him an age-related plate instead. In early March 2020, it gave him a response at stage one of its complaint process, setting out again why it had rejected the application and explaining the evidence which might enable Mr A to register the plate he wanted. Mr A also spoke with DVLA’s complaints team about what evidence was needed.

13. In late March 2020, Mr A phoned DVLA as he had received an insurance advisory letter from the Motor Insurers’ Bureau advising him he appeared to have an uninsured vehicle because there was no insurance registered against the age-related registration he had been given for the tractor. Mr A said he would not make a Statutory Off Road Notification or insure the vehicle under the age-related plate. In April 2020, Mr A asked DVLA to escalate his complaint to the second stage of its process.

14. DVLA completed the second stage response in May 2020, but did not change its decision. After Mr A spoke to DVLA, it said he had not been properly advised at the outset, so he might be due a poor service payment in addition to a refund of the £55 fee he had paid. In July 2020, Mr A rejected the poor service payment and asked for the complaint to be escalated to the Independent Complaints Assessor (ICA).

15. In September 2020, the ICA completed its report but did not uphold the complaint. A few days later, the ICA wrote to Mr A again – to acknowledge some minor errors in his report, which would not alter the outcome – and to say it had spoken to an expert at an owner’s club who had spoken to the council, and unfortunately the council no longer kept historic records relating to his tractor.

Registration decision

18. Before we decide if we should carry out a detailed investigation of a complaint, we look at whether there are signs the organisation has got something wrong. We do this by comparing what should have happened with what did happen. We have done this and have not found any signs DVLA’s decision to issue an age-related registration for Mr A’s tractor was wrong.

19. Mr A collects and repairs old tractors for a hobby and is a member of a club for historic tractor owners. He told us he currently owns 12 such tractors, but the tractor at the heart of his complaint is particularly important to him. He explained that when he was a child, he knew the farmer who originally bought it in 1961. He said the farmer had been kind enough to allow him to ride on it at the time. When he saw the tractor was for sale at a local dealership in 1970, he took the opportunity to buy it and has owned it since then.

20. DVLA does not hold records of the registration numbers used before it took responsibility for these in 1974. Old vehicles, such as Mr A’s tractor, can be registered under the original registration, or under an ‘age-related’ registration. An old vehicle which is registered with an age-related plate can be re-registered under its original registration. In order to get an original registration, an owner can apply to DVLA under its V765 scheme.

21. Our Principles say:

‘Public bodies should aim to ensure that customers are clear about their entitlements; about what they can and cannot expect from the public body; and about their own responsibilities.

Public bodies should do what they say they are going to do.’

22. DVLA guidance for the V765 scheme says:

a. ‘Applications must be submitted on form V765 and signed by the keeper of the vehicle agreeing to the terms and conditions of the V765 scheme. A V55/5 should also be filled in and a recent photograph of the vehicle confirming it as a complete entity must be included. A FEE IS NOT APPLICABLE as the vehicle is being re-registered and is not applying for first registration.

b. The application must have a V765 form signed, stamped and approved by the relevant vehicle owners/enthusiasts club (for their make/type), shown on the ‘List of Vehicle Owners Clubs’ (V765/1). The club may charge a fee to process the application.

c. Evidence MUST be presented with the application to link the registration number to the vehicle. Acceptable forms of evidence include: • the original old style logbook (RF60/VE60) • archive/library records displaying the registration number and the chassis number authorised by the archivist clearly defining where the material was taken from • other pre 1983 documentary evidence linking the chassis and the registration number to the vehicle.’

23. Mr A told us the tractor still has its original plate, but because it is not registered, he has to load it onto a trailer to transport it to shows. Having the tractor registered would mean he could drive it instead. It is understandably important to collectors like Mr A that their classic tractors are complete with original registration where possible. In Mr A’s case, there was also a sentimental motive as his tractor was linked to a cherished childhood memory. Unfortunately, Mr A mislaid the original log book, but was confident the original registration shown on the log book matched the plate on his tractor.

24. He provided DVLA with alternative evidence to the log book between July and October 2019: • photos of the tractor, including the VIN and engine numbers • a letter from the manufacturer confirming it manufactured a tractor with that VIN in August 1961. The model and paintwork described in the letter also match Mr A’s tractor • a letter from the local county archivist with information about the original registration. This listed a dealership and two dates in 1961. The archivist suggested these were the sale and registration dates of the vehicle, but said they could not be certain. No information was recorded about the nature of the vehicle attached to the registration.

25. DVLA was satisfied the evidence Mr A gave showed the age of the tractor, but it said there was no evidence which directly linked the registration and the tractor. We can see the evidence provided by Mr A does show a circumstantial link to the registration, i.e. a vehicle with that registration was apparently sold a month after the tractor was manufactured.

26. DVLA’s view, that this was not direct evidence, seems reasonable given the archivist’s information could be about a different vehicle with coincidental dates. We also note Mr A did not submit a V765 form approved by an owners’ club, which is a requirement of point (b) of the V765 scheme guidance. Unfortunately, although Mr A is confident in his knowledge of his tractor’s historic plate, he was unable to support this with documentary evidence. So, DVLA’s decision not to register the tractor under the registration claimed by Mr A appears to be in line with the scheme guidance.

27. We went on to consider whether DVLA should have issued an age-related registration after it rejected Mr A’s attempt to register the historic plate.

28. DVLA wrote to Mr A in August and November 2019, explaining if he could not get the tractor registered under the V765 scheme, he could get an age-related plate instead. It said to do this he needed to complete form V55/5 ‘Application for first vehicle tax and registration of a used motor vehicle’.

29. In October 2019, Mr A completed form V55/5. Mr A delivered the supporting evidence and fee of £55 in person in November 2019, but the application was rejected again when DVLA failed to match the form with supporting evidence. DVLA reopened the application when Mr A phoned for an update on progress in December 2019. In January 2020, a DVLA caseworker met Mr A in the DVLA reception area to receive more supporting documentation. There is no contemporaneous record of this meeting.

30. Mr A complained he only wanted the historic plate and was not told anything about age-related registrations. When DVLA investigated the complaint, the caseworker recalled explaining the rules of the scheme and telling Mr A he did not have enough evidence to claim a right to the old registration, but he would get an age-related plate instead. The caseworker felt Mr A understood what would happen. The same day, DVLA approved Mr A’s application and assigned an age-related registration number.

31. DVLA twice took steps to explain to Mr A how to apply for an age-related registration (on form V55/5). DVLA received a completed form V55/5 from him, so we think it could have reasonably assumed Mr A wanted an age-related registration. The caseworker also felt they had explained the process and told Mr A, in person, what would happen. Although there is no contemporaneous evidence to back this up, in the context of DVLA’s other explanations, it seems likely this is what the caseworker did. These actions are in line with our Principles, and we saw no sign anything went wrong here.

32. We are sorry to hear of Mr A’s disappointment in the outcome of his application. We saw no reason to doubt his confidence that the tractor is entitled to the historic registration, but unfortunately this does not meet the evidence requirements of the scheme. This means we have decided not to consider Mr A’s complaint any further.

33. We also understand Mr A feels the age-related registration was unwanted, so should have been cancelled because of his complaint. We note DVLA considered this, but is unable to de-register the tractor. If Mr A finds more evidence to support his claim, he can still apply under the V765 scheme to register the tractor under the historic plate.

1. The Parliamentary and Health Service Ombudsman has carefully considered Mr A’s complaint about the Driver and Vehicle Licensing Agency (DVLA). We have seen no sign DVLA’s decision to issue an age-related registration for Mr A’s tractor was wrong.

2. We are sorry to hear Mr A was unable to register his tractor’s historic number plate, to which he has a strong sentimental attachment. While we saw no evidence this was not the historic registration, we also saw no sign he met DVLA’s evidence requirements to claim the plate.