20/05/2026: BNMA provides written evidence to Road Safety Strategy
Illegal number plates undermine ANPR, enabling anonymity and crime. BNMA urges full security, traceability, licensing reform and tougher enforcement. Smart plates with watermarking, holograms and RFID would restore detection and strengthen road safety.
Road Safety Strategy - Written evidence - Committees - UK Parliament
Written evidence submitted by the British Number Plate Manufacturers Association (RSS0097)
INTRODUCTION
1. ABOUT US
1.1 The British Number Plate Manufacturers Association (BNMA) promotes the interests of British number plate manufacturers and raw material suppliers.
1.2 Our members manufacture more than 95% of the number plates on UK vehicles.
1.3 Our members are
a. Bestplate, based in Lytham St Annes, Lancashire
b. Gould Autoplates, based in Bristol, Somerset
c. Hills Numberplates, based in Birmingham, West Midlands
d. Jepson & Co, based in Sheffield, Yorkshire
e. Sandhurst Autoprint, based in Aldershot, Hampshire
f. Tennants UK, based in Nottingham, Nottinghamshire
g. Uniplate Limited, based in Tamworth, Staffordshire
1.4 Collectively, we turnover an estimated £60m a year, directly employ 180 people and produce 20m number plates a year.
1.5 Customers of BNMA members are assured of a gold standard service, using the best quality British products and services. Every member has on-site facilities for manufacturing number plate components and ready-to-fit plates. Every product must pass stringent legislation, including British Standard BS AU 145e, and quality control standards, such as ISO:9001 (2015).
1.6 We work with our members and other stakeholders, such as the Driver and Vehicle Licensing Authority (DVLA), to make sure that number plates are secure, safe and operationally practical.
1.7 Our aims are to
a. Make sure that number plate manufacturing is a sustainable industry
b. Maintain compliance with British standards and key legislation, as well as take a lead on improving norms in the industry
c. Support motor traders, other industry associations and government bodies so that the industry can collaborate on improving standards
2. REASON FOR SUBMISSION
2.1 The BNMA has lobbied successive governments about the need for end-to-end traceability of number plates over many years.
2.2 At present, the absence of effective control measures to ensure the legitimacy of vehicle number plates is resulting in the unlawful manufacture of plates that can defeat Automatic Number Plate Recognition (ANPR) technology.
2.3 As a result of 2.2 and the prevalence of false number plates on the roads,, data collected by ANPR infrastructure across the UK is consistently being undermined.
2.4 As of 2020, ANPR reads between 75 and 80m number plates daily. This was anticipated to reach 100m by the end of 2024. Currently, more than 1m of those reads are inaccurate every single day.
2.5 Criminals can easily fit illegitimate plates to vehicles in the UK, with little chance of detection by relevant authorities. This takes several forms, including
a. Counterfeit number plates – raw materials are easily available, and plates are sold openly on the internet
b. Stolen identity – often known as ‘cloned plates’, these are typically used for short periods of time because the owners report the theft to authorities
c. Expired number plates – often salvaged from vehicles intended to be scrapped after being written off
d. Altering legitimate number plates – legitimate number plates can often be made unreadable to ANPR through a variety of means, including masking products, altering characters or using infrared, invisible ghost characters
2.6 Law enforcement authorities are, therefore, impeded in their attempts to apprehend criminals, who can easily circumvent the very system in place to help catch them.
2.7 We welcome the increased political attention to these issues. We thank MPs Sarah Coombes and, more recently, Al Pinkerton for their campaigns on ghost number plates.
2.8 Through the Road Safety Strategy, the Government has promised to
a. Consult on the growing problem of illegal number plates, including ghost plates
b. Work with the DVLA, Driver and Vehicle Standards Authority (DVSA), police and industry to review the current standard for number plates
c. Empower the DVLA to undertake “more robust” checks on number plate suppliers
d. Use targeted research to better quantify the scale of the problem
e. Explore the potential of artificial intelligence to identify illegal plates
f. Introduce tougher penalties for driving with illegal plates – up to vehicle seizure
2.9 We believe, however, that the Government must take stronger action to make sure that the security, operational and safety problems caused by illegal number plates are properly tackled. Ministers, officials and government agencies must be significantly more ambitious if the manufacture and the dangerous consequences of illegal number plates are to be consigned to history.
2.10 We back the full - rather than partial - implementation of the recommendations made by the ANPR Independent Advisory Group (IAG) in its working group report from 2020. This report was ordered by the Surveillance Camera Commissioner. The recommendations were
a. The inclusion of greater security features within the plate (BNMA comment: this would bring the UK in line with other jurisdictions)
b. Limiting the availability of component materials and introducing a tracking system to identify the origin of manufactured or assembled plates (BNMA: all components should be traceable by police or other enforcement bodies)
c. Formal licensing of manufacturers with third party certification of component materials (BNMA note: self-certification is currently being ignored)
d. The introduction of an increased annual fee (BNMA: this would provide resources for effective document checks and monitoring of standards)
e. Formal licensing of suppliers with new eligibility application criteria (BNMA comment: This would bring the UK in line with other jurisdictions)
f. Digital solutions to enable licensed suppliers to authenticate and authorise individual rights to a number plate (BNMA: verification currently requires original documentation to be shown, which is out of line with developments in online transactions)
g. The development of a structured and tailored communication package for suppliers and customers (BNMA: the market currently does not have a standardised approach, which makes it easier for illegitimate plates to proliferate)
h. Increased penalties and simpler prosecution routes, including the application of existing systems to identify non-compliance (BNMA: penalties are insufficient, though we note that the Road Safety Strategy has outlined tougher punishments)
i. Greater collaboration with partners to align policies (BNMA: proposals should be developed in consultation with Police and Crime Commissioners and operational policing leads to ensure enforceability and consistency)
2.11 In 2020, the BNMA also recommended that number plates should have
a. Unique, overt security markings to visibly authenticate their production
b. Barcoding or covert markings for enforcement officers to validate their origins
c. Official markings, such as Crown copyright or government logos/watermarks
2.12 The BNMA has developed a solution for a fully digitally traceable smart number plate, which will provide the end-to-end security needed to address the concerns mentioned above. The police have agreed to field trials. A document presenting the solution will be ready in the coming weeks and we will share this with the committee. We can confirm, however, that the proposed design would include
a. Laser watermarking
• Retro-reflective sheeting shall be covertly marked by the manufacturer on the reflective side of the plate, with identifying symbols, patterns or words approved by the Government
• Markings should include a manufacturer identifier, batch code and the year of production
• Markings should be applied in predetermined patterns, depending on the physical dimensions of the plate
• The pattern should be applied so that at least one batch mark appears wherever a 100m x 100mm square were drawn on the reflective sheeting
b. Hologram
• A chrome-based holographic foil product applied to the plate’s reflective film
• Size no greater than 15mm x 28mm
• Include a secure QR code, reflecting the unique number in each hologram
• Applied during components manufacturing by a hot-stamping process
c. A radio frequency identification tag
• Concealed from view – placed on the reverse side of the plate or between the reflective film and the substrate, directly behind the hologram
• Encoded with a unique identifier with write protection
• Constructed using tamper-evident materials, so that it is not functional when detached
3. GOVERNMENT POSITION ON ILLEGAL NUMBER PLATES
3.1 The BNMA is concerned that the issue of illegitimate number plates does not appear to be enough of a priority in current government discussions.
3.2 It is positive to see illegal number plates mentioned in the Road Safety Strategy. However, we believe this is an increasingly prominent issue that should have been covered comprehensively.
3.3 As such, number plates should be specifically listed in this consultation's terms of reference and/or granted a separate committee hearing
3.4 Tackling illegal number plates would have a significant impact on crime by removing the anonymity that empowers would-be offenders to believe they can evade the law.
TERMS OF REFERENCE
AMBITIONS AND EVIDENCE
A. The strategy sets targets of a 65% reduction in people killed or seriously injured (KSI), and a 70% reduction in child KSIs, by 2035. Do these targets reflect the right level of ambition?
A.1 Yes, we believe these are ambitious minimum targets that achievable in nine years.
A.2 However, this can only be achieved if we tackle the root causes of the decline in safety on our roads. The increase in reckless motoring can, at least in part, be attributed to the opportunities we give criminals to drive undetected through rogue, ghost or illegally cloned number plates.
B. Are governance, delivery and resourcing arrangements across government departments and key partners strong enough to achieve these targets?
B.1 Until the work of Sarah Coombes MP and the publication of the Road Safety Strategy, the Government and DVLA failed to address the risks of illegal ghost number plates.
B.2 As far back as 2018, the Surveillance Camera Commissioner warned that problems with ANPR technology meant that 1.2m number plates were being misread every single day. In May 2020, the BNMA produced a report setting out the extent of the problem, even offering a credible solution that would be cost free to the Government and not require additional legislation.
B.3 Despite being aware of the risks for so long, little or no action has been taken by successive ministers and the DVLA.
B.4 The illegal use and production of number plates have received more media and political attention over the past year. We are, however, deeply concerned that the associated problems warranted only a handful of mentions in the Road Safety Strategy. There is a sense that ministers feel the issue has been mentioned and therefore ‘ticked off’, when, in reality, the scourge of fake number plates will continue to undermine road safety. We need to have the confidence that drivers who break the law can be detected and tracked through their number plates.
B.5 We believe this committee, worried MPs and organisations like the BNMA will have to consistently remind the DVLA, Department for Transport and Home Office that this issue is very far from resolved.
C. Are the measures set out in the Strategy collectively sufficient to deliver its targets? What further measures, if any, would strengthen its impact?
C.1 The Road Safety Strategy does not set out strong, specific measures for tackling illegal number plates. Instead, it notes a series of ambitions, such as empowering the DVLA to “carry out more robust checks on number plate suppliers”. We are pleased illegal number plates have been mentioned in the consultation, but disappointed that the detail is incredibly vague at this stage.
C.2 We will only know if the measures are sufficiently strong when they are properly set out and the consultation into tougher penalties for drivers using illegal plates is completed. At present, we have little detail about these processes, which we urge ministers to explain in detail as soon as possible.
C.3 We strongly recommend that the DVLA ends its current, ineffective Register of Number Plate Suppliers and starts again. There must be stricter application criteria and annual licence fees, which would fund greater enforcement.
C.4 As mentioned above, covert and overt security features must be introduced on number plates, allowing police to easily detect and penalise illegality. These features will also allow plates to be tracked back to their manufacturers.
D. Are the measures set out in the Strategy based on robust evidence?
D.1 The BNMA, Surveillance Camera Commissioner and All-Party Parliamentary Group for Transport Safety are among the groups that have gathered detailed, robust evidence about the issues related to illegal number plates. Rochdale Trading Standards, which has been at the forefront of collecting information, is continuing with ‘Operation Ghost’ to gather more data about illegally modified plates that are rendered invisible to ANPR cameras.
D.2 We believe the lack of detection and end-to-end-traceability means that the problems could be considerably more acute than the current evidence – which is already damning – suggests.
D.3 No significant measures have yet been announced, but they must be soon based on the evidence already provided and the likelihood that the situation is far worse than even those findings show.
E. The Government has said its Strategy is informed by Sweden’s Safe System Approach. What other international or UK examples offer the most relevant lessons for reducing deaths and serious injuries?
E.1 As noted above, illegal number plates promote reckless driving, which inevitably leads to increased death rates and serious injuries.
E.2 The UK and Ireland are the only countries in Europe that do not have security features in number plates and traceability throughout the supply chains.
E.3 The Netherlands is often cited as the gold standard for number plate security. Every licence plate issuance is registered and includes unique features.
E.4 Holographic validation stickers are found on number plates around the world, from Ecuador to Iraq. Most EU jurisdictions require these visual cues for the police officer.
THEME ONE: SUPPORTING ROAD USERS
The BNMA believes it is more appropriate for other stakeholders to answer questions F-J.
THEME TWO: TAKING ADVANTAGE OF TECHNOLOGY, DATA, AND INNOVATION FOR SAFER VEHICLES AND POST-COLLISION CARE
K. How can the Government maximise the safety benefits of Advance Driver Assistance Systems (ADAS) and ensure they are used safety and appropriately?
N/A.
L. What is the right approach to strengthening vehicle safety standards? What measures should the Government prioritise in response to issues such as headlamp glare, increasing vehicle size and broader issues not currently being considered by the Government’s consultation?
L.1 The BNMA has recommended that number plates should have
a. Unique, overt security markings to visibly authenticate their production
b. Barcoding or covert markings for enforcement officers to validate their origins
c. Official markings, such as Crown copyright or government logos/watermarks
L.2 BNMA has developed a solution for a fully digitally traceable smart number plate, which will provide the end-to-end security needed to address the concerns mentioned above. The police have agreed to field trials. A document presenting the solution will be ready in the coming weeks, when we will be pleased to share this with the committee. We can confirm, however, that the proposed design would include
a. Laser watermarking
• Retro-reflective sheeting shall be marked by the manufacturer on the reflective side of the plate, with identifying symbols, patterns or words approved by the Government
• Markings should include a manufacturer identifier, batch code and the year of production
• Markings should be applied in predetermined patterns, depending on the physical dimensions of the plate
• The pattern should be applied so that at least one batch mark appears wherever a 100m x 100mm square were drawn on the reflective sheeting
d. Hologram
• A chrome-based holographic foil product applied to the plate’s reflective film
• Size no greater than 15mm x 28mm
• Include a secure QR code, reflecting the unique number in each hologram
• Applied during components manufacturing by a hot-stamping process
e. A radio frequency identification tag
• Concealed from view – placed on the reverse side of the plate or between the reflective film and the substrate, directly behind the hologram
• Encoded with a unique identifier with write protection
• Constructed using tamper-evident materials, so that it is not functional when detached
THEME THREE: ENSURING INFRASTRUCTURE IS SAFE
M. How should evidence on the relationship between speed limits and safety influence new guidance? Does the Strategy strike the right balance between a nationally set direction and local decision-making regarding speed?
N/A.
N. What measures would be most effective in improving safety on rural roads and is the Strategy’s proposed approach sufficient?
N/A.
O. What scope is there for road design and maintenance to further improve safety?
O.1. While infrastructure design and maintenance are critical components of overall road safety, the BNMA’s expertise lies specifically in vehicle identification integrity and enforcement systems.
O.2. We would simply observe that effective road design must work alongside credible enforcement mechanisms. Where drivers believe they can avoid detection through illegal number plates, the safety benefits of infrastructure improvements may be undermined.
THEME FOUR: ROBUST ENFORCEMENT TO PROTECT ALL ROAD USERS
P. What measures would most improve compliance and deterrence in relation to motoring offences? Which such offences have the biggest impacts on collision and casualty rates?
P.1. Compliance improves when detection is perceived as inevitable and sanctions are certain.
P.2. Illegal and ghost number plates undermine this principle by enabling anonymity. Where drivers believe they can evade identification, the deterrent effect of speed enforcement, uninsured driving checks and ANPR systems is weakened.
P.3. The most effective compliance measures would include
a. End-to-end traceability of plate manufacture and supply
b. Real-time authentication capability for enforcement officers
c. Stronger roadside seizure powers for deliberate concealment
d. Formal licensing and audit of plate suppliers
P.4. Without supply-side reform, driver penalties alone will have a limited impact.
Q. What role do the type and severity of sanctions play in deterring dangerous driving and which sanctioning approaches are most effective at changing driver behaviour?
Q.1. Evidence from policing consistently shows that certainty of detection is a stronger deterrent than the absolute size of a fine.
Q.2. However, current penalties for illegal number plates inadequately reflect the deliberate circumvention of law enforcement systems.
Q.3. Effective sanctions would include
a. Increased fines reflecting the enabling nature of the offence
b. Mandatory penalty points
c. Vehicle seizure powers for repeat or deliberate offenders
d.
e. Escalating sanctions for commercial suppliers knowingly producing illegal plates
Q.4. Sanctions should clearly distinguish between minor formatting errors and deliberate concealment. The latter should attract significantly stronger penalties.
Q.5. The objective is not punitive excess, but restoring the credibility of enforcement systems.
March 2026