Driver and Vehicle Licensing Agency

3. Mr A complains about DVLA following his application to change the vehicle taxation class of his ex-MOD car from PLG (private/light goods) to diesel He says DVLA subjected him to lies, misleading and contradictory advice and information for several months. He says DVLA gave him options for vehicle taxation reclassification which were not possible to do. Though it provided a financial remedy of £150 and this was increased to £300 by the Independent Complaints Assessor (ICA), he complains that this does not go far enough to remedy the impact to him.

4. Mr A says that he has been caused stress, anxiety, financial concern and logistical difficulties by having to avoid low emission zones when travelling to work got several months due to his vehicle being classed as PLG.

5. As an outcome to his complaint Mr A is seeking service improvements to ensure that consistent and correct advice is provided. He is also seeking an increase to the financial remedy to the upper level 3 of our severity of injustice scale.

6. Mr A purchased the ex-MOD vehicle on 31 August 2024. The car was manufactured in 2018 but was not registered with DVLA until 2024. Cars that are first registered with DVLA on or after 1 April 2020 are taxed on the basis of their CO2 emissions. In order for the car to be registered as diesel it would need to have evidence from the manufacturer to show that the emissions are low enough to qualify for licensing as a diesel car. This is by way of a Certificate of Conformity which shows the car was tested to the relevant standards.

7. When Mr A purchased the car, the dealer he bought it from made the application to DVLA for it to be reclassified and sent a cheque for £190 being the annual rate for car tax for a diesel car.

8. On 24 September 2024, DVLA received the paperwork. Mr A and the dealer made calls to DVLA in November to chase the progress of the application. On 11 November an enforcement letter was automatically sent to Mr A for unpaid tax. This was because though Mr A had paid the tax in August and September, he then cancelled the direct debit due to the dealer having sent payment in full to DVLA for the tax.

9. On 21 November 2024, Mr A made a complaint to DVLA. He raised his concerns about the issues with the tax and that this resulted in him receiving a penalty charge notice, technical issues he had in raising his complaint electronically, the delays in DVLA dealing with the reclassification application and outlined his understanding that once the car was classified correctly this would be backdated to when the car was registered with DVLA.

10. On 18 December 2024 DVLA responded to Mr A’s complaint. It said that it could not locate the paperwork the dealer had sent in September and said it is likely that it has gone astray whilst in transit between Royal Mail and DVLA. It said that when the vehicle was registered on 5 August 2024 no documentation was produced for it to be registered as a diesel car. It advised Mr A that it would need a Certificate of Conformity and provided contact details for the manufacturer in order to obtain this.

11. Mr A escalated his complaint the same day. He again outlined the issues with cancelling his direct debit for the vehicle tax and how this resulted in him receiving a penalty charge notice which DVLA had not addressed in its response. In view of the lost documentation, he requested a new V5 (logbook which records the registered owner of the vehicle) so that a further application for reclassification could be made. He outlined the impact this situation was having on him. He said that he has been inconvenienced, and it was causing him stress and anxiety, and he is having to avoid low emission zones when travelling to work which is causing increasing costs to him. He also said that without a V5, he could not transfer or sell the vehicle to remove the issue. He also said that he continues to pay a disproportionate amount for tax every month and again stated his understanding that once the car was reclassified this would be backdated.

12. On 16 January 2025 DVLA sent a letter to Mr A in response to the re-classification application. It advised that the vehicle was correctly registered and taxed in the PLG class this was because when it was registered with DVLA no CO2 emissions were provided and so it had to be taxed in the PLG class.

13. On 31 January 2025, DVLA provided its second response to Mr A’s complaint. It apologised for the delays and conflicting information he had been given. It explained that when the vehicle was first registered with DVLA it received no evidence of its CO2 emissions and so it was correctly taxed in the PLG tax class. It went on to explain that it did receive the application to change the tax class and that it had been incorrectly passed back and forth between two teams which resulted in a significant delay in it reaching the correct team. In addition it had not been scanned to its system which meant advisers were unable to trace it and this led to him being incorrectly informed that it had been lost in transit. It explained the situation with the payment of the tax and how this resulted in an enforcement letter being sent. It also said the enforcement case had been closed and he no longer had to pay the penalty charge. It went on to explain that it could not change the tax class of his vehicle and a replacement V5 was sent to him on 16 January and the cheque from the dealer for the vehicle tax had been banked and refunded to Mr A as the registered keeper. It again advised what was needed in relation to the CO2 emissions in order for it to consider reclassifying the tax class for the vehicle and provided contact details for the manufacturer. It said that it is evident he had not received the level of service it aims to provide and that there were significant delays in it considering the application being considered, and that as a result he was given conflicting information. It said the enforcement action was correct but apologised that this was not addressed in its previous response. It offered £150 in recognition of the poor service he had received. It also assured him that feedback had been provided of the teams concerned to address any training needs.

14. On 18 April Mr A escalated his complaint to the ICA. In its response issued in August 2025, in addition to the events already outlined, it noted on 5 February 2025 Mr A responded to DVLA’s complaint response. He believed reclassification would now be possible and suggested again that the outstanding tax issues would then be resolved and reclassification would be effective from the date of registration with DVLA. On 19 February DVLA responded and explained that any reclassification that might be made would not be backdated as PLG was correct when vehicle was registered. It sent a further letter on 25 March regarding the offered payment of £150 to which Mr A replied the same day advising that his dealer was in the process of the obtaining the Certificate of Conformity.

15. In its report the ICA were critical of DVLA’s handling of Mr A’s case and acknowledged it had accepted and apologised for the errors that occurred. Of particular concern was the application being passed between two teams for three months before being dealt with. It acknowledged that DVLA accepted than its first response did not address all the issues raised and there was a delay in providing its response. The ICA also identified that DVLA did not correct Mr A’s incorrect understanding that if the vehicle was reclassified, this would be backdated to when it was first registered, until 19 February. It said it was not incorrect for DVLA to provide information about how to possibly obtain a Certificate of Conformity, though said it was too definitive in its first response that this could be obtained from the manufacturer rather than it being a possibility. The ICA considered the level of consolatory payment offered to Mr A against our own financial remedy guidance. It said that DVLA had correctly assessed that the issues fit within level 2 of our guidance for severity of emotional harm and material inconvenience and it had offered a remedy within the range for level 2. However, it said the offer was too low considering the serious mishandling of the original application, how Mr A was misadvised over a period of several months. It said the substantive advice provided to Mr A about reclassification was not generally wrong but did provide a false optimistic picture of the prospects of reclassification. It said that it accepted that had there not been the confusion and delay in handling his case, Mr A could have made a decision earlier to return to vehicle to the dealer. It therefore recommended DVLA pay Mr A a further £150.

16. On 3 September 2025 DVLA wrote to Mr A again following receipt of the ICA’s report. It acknowledged the handling of his case was below the standard of service he should expect, and it offered its sincere apologies for this. It assured the feedback provided by the ICA had been taken onboard and will be used to improve its services. It also provided options for payment of the further £150.

Financial remedy

19. Before we decide if we should conduct a detailed investigation of a complaint, we look at whether there are signs the event(s) complained about had a negative effect which the organisation has not put right. Having done so we have found DVLA has already done enough to put right the impact of these events.

20. Mr A complains about the level of financial remedy offered to him concerning his complaint to DVLA. He told us in his complaint form that he does not believe that level two of our scale is fitting for his case. He told us that he had read the descriptions for levels two and up and said there were days that levels four and five were appropriate but said it would be disingenuous of him to suggest that these were reflective of the lasting impact to him. However, he believes level three is more appropriate for his experience and the impact to him. In an email to us he also said he endured DVLA for many months and says the ICA has selected a scale without the full understanding of the everyday impact to him and his family. He says he had to deal every day for months with DVLA’s delays, false promises, options to reclassify that did not exist and repeated lies.

21. In considering whether the level of financial remedy offered is appropriate we have looked at the descriptors for levels two and three of our guidance. Level two says:

‘Typically the injustice will arise from a relatively low impact failing, often resulting in a degree of distress, inconvenience or minor pain…We would expect the person affected to recover quickly once the poor service had ceased. Level 2 injustice will not usually have a significant lasting impact, or any effect on the complainant’s ability to live a relatively normal life’.

22. Our guidance goes on to explain the different types of injustice that would be typical of level two. Under emotional it says ‘distress, worry, annoyance and similar injustice of the sort a healthy adult would be expected to deal with on a regular basis, without external support, and which does not impact on the affected person’s day to day functioning, or their ability to live a normal life; for a period of 1-2 weeks to about six months’. Under material, it says ‘instances of poor complaint handling where there is a delay of more than a few weeks, up to around one year’.

23. Level three says:

‘This would include cases where the injustice would have a moderate impact (for example, in terms of distress, worry, inconvenience) but has lasted for a significant period of time…The failings may impact to some extent on the affected person’s ability to live a relatively normal life, for example due to stress impaired sleep, or high levels of inconvenience or uncertainty.’

24. For the different types of injustice, under emotional it says ‘distress, upset or worry lasting 6-12 months. Significant distress (that is distress which results in a degree of functional impairment) lasting from a few weeks to three months’. Under material it says ‘very poor complaint handling, e.g. delays of over a year; or with delays of over six months combined with qualitive failures such as provision of incorrect or incomplete responses…Financial or other hardship lasting three to six months’.

25. We can see from the evidence that although the application was sent to DVLA in September, the issues began in November as this in when Mr A began the communication with DVLA concerning the reclassification. The matter concluded directly with DVLA in April when Mr A escalated his complaint to the ICA, apart from DVLA following up on the ICA’s recommendations in September. This is a period of approximately six months. Mr A told us of the stress, anxiety and financial concern he was caused during this time and he says the ICA does not have a full understanding of the every day impact to him.

26. Having considered all the information available to us we are not persuaded that the impact Mr A has told us about falls into level three of our financial remedy guidance. This is because the impact to Mr A was not to the extent that he was not able to live a relatively normal life or that he required any external support to help him deal with the matter. While DVLA’s complaint handling was poor and its responses delayed, we can see that the matter was concluded with DVLA in around six months. As such it is our view that the impact falls into level two of our guidance and the remedy already provided is appropriate.

27. We are sorry to hear of the difficulties Mr A experienced and how this affected him. We understand that this is not the outcome he is hoping for but we hope we have clearly explained the reasons for our decision.

1. We have carefully considered Mr A’s complaint about DVLA. We have decided DVLA has already done enough to put right the impact of these events on Mr A.

2. We are satisfied that the impact to Mr A has been appropriately considered and a reasonable remedy has been provided. We are sorry to hear about how Mr A has been affected.