The growing public debate over the legality of the Driver and Vehicle Licensing Authority’s (DVLA) charging delinquency fees for late renewal of drivers’ licenses seems to be far from over.
Private legal practitioner and consumer protection advocate Appiah Kusi Adomako is taking the debate further with situations and scenarios that render the controversial delinquency unjustified.
The DVLA, in a recent response to the concerns, declared that driver’s licences must remain active at all times and “should never be allowed to expire.”
However, the West Africa Regional Director of CUTS International argues that this blanket stance ignores statutory reality, which holds that an expired licence card, in itself, is not a crime. He explains that under Regulation 46(8) of the Road Traffic Regulations, 2026 (L.I. 2519), an offence is committed only when someone actually drives a vehicle on public roads with an invalid licence.
Furthermore, Regulation 46(1) states that a licence holder “may” renew within one month prior to expiry, making pre-expiry renewal permissive rather than legally compulsory.

To demonstrate why automatically labeling late renewers as “delinquent” is unfair and legally flawed, Appiah Kusi Adomako outlined 10 real-world scenarios where motorists let their licences expire without engaging in any wrongdoing;
1. The Former Member of Parliament (MP)
Consider a politician who serves in Parliament for 12 years and relies entirely on an official chauffeur throughout his tenure. After losing an election, he can no longer afford a driver and decides to drive himself again.
When he visits the DVLA to renew his expired card before touching a steering wheel, the DVLA treats his non-driving years as “misconduct” and levies a delinquency penalty, effectively punishing him for being driven by someone else.
2. The UN Peacekeeper Deployed Abroad
A Ghanaian police officer deployed on a peacekeeping mission in Darfur, or a soldier serving with the UN in Lebanon, serves the nation overseas while his licence expires at home.
Upon returning to Ghana, he visits the DVLA counter to renew his licence before driving, only to be slapped with a delinquency charge for the time he was serving in a war zone.
3. The Foreign Service Diplomat
A Ministry of Foreign Affairs officer is posted to the Ghanaian embassy in Paris for four years. Her Ghanaian licence expires while she is stationed in France. Upon finishing her diplomatic posting and returning home, she faces administrative financial penalties despite having had no opportunity or reason to drive in Ghana during her stay abroad.

4. The Graduate Who Had No Car
A student acquires a licence through the DVLA’s tertiary campus driving program. After graduation, he cannot afford a vehicle and does not drive for six years.
When he finally purchases a car and visits the DVLA to update his card before driving, he is penalized for “delinquency” during the six years when he owned no car and never used public roads.
5. The Overseas Missionary Pastor
A pastor with the Church of Pentecost is assigned to lead a mission in Australia for five years. His Ghanaian driver’s licence naturally expires while ministering abroad.
Upon completing his mission and returning to Ghana, the DVLA labels him “delinquent” when he attempts to lawfully renew his card prior to driving.
6. The Expectant Mother on Medical Rest
A pregnant woman is medically advised by her doctor to stop driving for safety reasons. Her licence expires during her pregnancy.
Six months after giving birth, when she is healthy and ready to drive again, she applies to renew her licence. Under DVLA policy, the months she spent strictly following her doctor’s medical advice are treated as a punishable offence.
7. The Short-Term Vacationer
A citizen travels abroad on a six-month holiday, and their licence expires three months into the trip. Although L.I. 2519 allows renewal within one month prior to expiry, the motorist was physically out of the country during that window.
Upon returning to Ghana, they visit the DVLA office before driving, only to be hit with a delinquency fee.
8. The Stroke Survivor in Recovery
A motorist suffers a stroke and is physically incapable of driving for six years. After a long recovery, he passes the required medical fitness tests and visits the DVLA to renew his licence.
The DVLA penalizes him for the six years he was recovering, expecting a bedridden patient to visit a licensing office solely to keep a piece of plastic current.

9. The Journalist on an Overseas Scholarship
A journalist wins a prestigious one-year Commonwealth scholarship to study abroad. Her licence expires while she is pursuing her studies. Upon completing her course and returning to Ghana, she applies to renew her card before taking to the road, but is forced to pay a penalty for the time spent studying overseas.
10. Non-Resident Ghanaians (The Diaspora)
Ghanaians living in the United Kingdom or United States maintain Ghanaian driver’s licences to use during visits home.
When a card expires while they are abroad, the DVLA’s policy effectively demands that they book expensive international flights back to Ghana solely to renew a card, or face financial penalties when they return for holiday.
Systemic Delays and the Call for Reform
None of these 10 examples involve individuals driving illegally; every single person visited the DVLA office to renew before getting behind the wheel. Compounding the problem, motorists report facing delinquency charges even when delays are caused by the DVLA’s own administrative backlog, such as cases where drivers waited over four years for permanent cards while continually renewing temporary permits.
CUTS International is calling on Parliament to intervene by reviewing how the DVLA applies fees under L.I. 2512 alongside the Road Traffic Regulations (L.I. 2519).
Appiah Kusi Adomako argues that Parliament must hold state institutions accountable by requiring published statutory authority for all fees, creating statutory exemptions for citizens with legitimate reasons for late renewal, and establishing a fair appeal mechanism rather than imposing automated “system-generated” fines.
