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Suspend Licence Delinquency Charges Until Legal Basis Is Shown — CUTS Tells DVLA

Felicia Opoku by Felicia Opoku
August 8, 2026
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CUTS International has called on the Driver and Vehicle Licensing Authority (DVLA) to suspend its escalating “delinquency” charges on expired driver’s licences until the Authority publicly explains the legal basis, approval process and formula used to determine the fees.

The public policy think tank argues that the charges are not clearly supported by the Road Traffic Regulations, 2012 (L.I. 2180) and could unfairly penalise motorists whose licences have expired even if they did not drive during the period.

In a statement issued on August 9, 2026, Director of the West Africa Regional Centre of CUTS International, Accra, Appiah Kusi Adomako, urged the DVLA to identify the specific statutory instrument and approved fee schedule authorising each charge.

Under the DVLA’s 2026 Summary of Licensing and Other Activity Rates, renewing a driver’s licence before expiry costs GH¢127.

However, the amount rises to GH¢204.25 where the licence has expired by one day to six months, GH¢279.25 for seven to 12 months, GH¢315.25 for up to two years, GH¢352.25 for up to four years and GH¢404.25 for more than four years.

CUTS said similar escalating charges apply to the replacement of expired licences.

“The DVLA must show Ghanaians the law, the approved fee schedule and the formula behind every cedi it collects as a delinquency charge,” Mr Adomako said.

“Public power must rest on law. If the Authority cannot point to a clear legal basis for each charge, it must stop collecting the money and refund affected licence holders.”

CUTS questions legal basis

CUTS’ concerns centre on Regulation 33 of L.I. 2180, which provides for the renewal of a driver’s licence both before and after its expiry.

According to the organisation, the regulations recognise the possibility of renewal after expiry and separately provide for an offence where a person fails to renew a licence as prescribed.

Under the regulations, a person who fails to renew a driver’s licence as prescribed may, upon summary conviction, face a fine of between 10 and 25 penalty units, imprisonment for up to 30 days, or both.

CUTS argues that the distinction is significant because the law provides for enforcement and prosecution where an offence is committed, rather than automatically treating every expired licence as evidence that its holder unlawfully drove during the period.

The think tank is therefore asking the DVLA to clarify whether the escalating amounts are renewal fees, administrative penalties or another form of charge.

“If the amounts are penalties, the DVLA must explain the legal process that permits an administrative system to impose them without proof of driving during the period of expiry, without a hearing and without a finding by a court,” its statement said.

Mr Adomako stressed that CUTS was not advocating the use of expired licences.

“CUTS is not encouraging anyone to drive with an expired licence. Driving without a valid licence must attract lawful enforcement,” he said.

“Our concern is different: the DVLA should not presume that every person with an expired licence continued to drive, then impose an automatic escalating charge without first establishing the legal and factual basis.”

‘Expiry does not prove unlawful driving’

CUTS said the mere expiry of a driver’s licence should not automatically be equated with unlawful driving.

It pointed out that a licence holder could be living abroad, studying, ill or otherwise not driving for an extended period before returning to Ghana and seeking to renew the licence.

Mr Adomako said such motorists should be encouraged to regularise their licences before returning to the road rather than being treated as though they had committed an offence.

“That citizen should be encouraged to regularise his licence before returning to the road. He should not be branded delinquent and punished as though expiry itself proves unlawful driving,” he said.

“The system must distinguish an expired document from the separate act of driving without a valid licence.”

CUTS also questioned the use of the term “delinquency”, arguing that it could imply wrongdoing before the circumstances of an individual licence holder have been established.

The organisation proposed neutral descriptions such as “renewal after expiry”, alongside clear criteria for waivers, exemptions or evidence that a vehicle was not being used during the period.

Concern over GH¢181 data amendment fee

CUTS has also raised concerns over a GH¢181 charge for amending information in a licence holder’s electronic records.

The think tank said charging motorists to update basic details such as telephone numbers or residential addresses could discourage them from keeping their records current.

It noted that accurate contact and residential information is important for road safety, identity verification, criminal investigations and emergency communication.

“The DVLA should design fees to support compliance, not discourage it. When a citizen wants to correct an address or telephone number, the Authority gains better data,” Mr Adomako said.

“Charging GH¢181 for a basic update risks leaving the database outdated and weakens the public interest the database is meant to serve.”

Parliament urged to investigate

CUTS has called on Parliament to conduct an urgent inquiry into the legality, approval and administration of the DVLA’s escalating “delinquency” charges.

It is also urging the DVLA and the Ghana Police Service to clarify their respective enforcement responsibilities.

According to the think tank, the public should be given clear information on the procedures for investigating, prosecuting and sanctioning motorists who operate vehicles without valid driver’s licences.

CUTS maintains that greater transparency over the charges would help ensure that the DVLA’s fee regime complies with the law while protecting motorists from potentially arbitrary administrative penalties.

Tags: CUTS InternationalDVLA
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