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1            Wheels for Wellbeing position

E-cycles are essential mobility aids for many Disabled people.

Any measures which remove or restrict Disabled people’s option to use safe, legal e-cycles for journeys will have serious negative impacts on Disabled people’s mobility, health and access to employment, education and healthcare.

We are increasingly seeing the illegal and/or dangerous use of and fire risk arising from illegal and/or dangerously modified e-cycles and e-motorcycles being used as justification for banning the use, storage and charging of legal e-cycles and a range of e-powered mobility aids.

Actions that ‘clamp down’ on abuses by gig economy workers are disproportionately likely to cause problems for Disabled workers. since they are more likely to rely on the work as their main income, and are likely to disproportionately impact members of minoritised ethnic groups[1]: All discussions and decisions regarding gig economy workers must ensure they are respected and fairly treated both as individuals and as an important part of the UK workforce.

We consider the banning of e-cycles from public spaces due to concerns about antisocial and/or illegal use of e-cycles and e-motorcycles by delivery riders to be an inappropriate and ineffective response to a problem which has its roots in the exploitation[2] of a vulnerable and minoritised workforce who have not been granted full access to collective bargaining[3].

Approaches to mitigate risk from dangerous use of e-cycles and e-motorcycles could include, in order of priority:

1. Making delivery companies legally responsible for the cycling (and driving) behaviour of their riders: This could help ensure algorithms allow sufficient time for deliveries to be made by people riding legal e-assist pedal cycles on legally-permitted routes, and could encourage significant improvements to rider training provided by companies.
2. Improved provision of accessible cycle routes through town and city centres and along major roads: People cycling, including people riding delivery cycles, will usually choose to use good cycle infrastructure where it exists. Unfortunately, all too often, cycle tracks either don’t exist, meaning cyclists are supposed to be on dangerous carriageways, or are shared pavements with pedestrians. This leads to conflict and risk of collisions between people walking/wheeling and people cycling. Creating good-quality, connected cycle routes is an important safety and accessibility measure.
3. Improved education: There is still a lack of awareness about which e-powered and e-assist devices can be legally used on public highways, as well as lack of awareness of basic highway rules including by many qualified drivers. Public education campaigns to combat illegal and dangerous use of a full range of motor vehicles and cycles could provide useful safety benefits. To avoid creating inaccurate public perception about the risk posed by e-cycles and other e-powered micro mobility devices, resource and visibility of any educational campaign would need to be proportionately distributed such that education is targeted most towards users of devices involved in the most collision deaths and injuries. Nothing related to education, however, will be effective without actions on points (i) and (ii).
4. Improved enforcement of illegal motorcycle use: Seizure of illegal motorcycles and e-motorcycles could reduce use, particularly in recognised problem hot-spots. As above, for this to be a reasonable non-discriminatory measure, enforcement of more dangerous devices such as cars being used illegally would have to be carried out in proportion to the risk each device type poses when involved in a collision, and include action to make delivery companies legally responsible for the travel behaviour of their motorcycle riders.

We consider the explicit banning of e-cycles and e- powered mobility devices from services including health, education and transport, and the de facto banning of such devices from private homes via insurance and tenancy clauses, to be disproportionate and discriminatory responses to the low fire risk posed by legal e-cycles and lithium-ion battery powered devices.

Approaches to mitigate risk from dangerous e-cycle and e-motorcycle electrical systems could include, again, in priority order:

1. Making delivery companies legally responsible for the legality and safety of all e-cycles, (and all motorcycles and other vehicles) that their riders use: Companies could achieve compliance by means such as suppling e-cycles to their riders, and/or by carrying out checks on rider-owned devices. Present exemptions from employment law are being used to transfer responsibility from powerful multinationals to marginalised individuals: This is both unfair to delivery riders and is putting people’s lives at risk. It cannot continue.
2. Initiate schemes such as that used in New York, whereby standardised batteries and chargers are available to riders, who can swap batteries while out-and-about during the day. A publicly organised scheme can ensure battery safety while giving practical advantages to riders that provide an incentive to use the scheme. The availability of standard batteries at public transport stops could also enable eCycles to be transported on public transport without batteries, if the scheme was organised to enable such behaviour.
3. Making sales platforms, including online platforms, effectively and enforceably legally responsible for the safety of the devices and components that they sell. Measures would need to ensure that enforcement can be carried out against overseas organisations which import e-cycles or electrical system components.
4. Make purchase of devices that are illegal to use on the highway, itself illegal, absent a declaration of the particular legal purpose for which it will be used.
5. Introduce a scrappage scheme to replace unsafe devices with safe and legal ones. While worthwhile, we note that the impact of this will be limited by the exploitative nature of gig economy platforms.
6. Educating the public on safe vs unsafe Li-ion battery devices, use and charging practices: Organisations such as London Fire Brigade already have information on how to charge e-cycle and e-scooter batteries safely[4].

2            Gig economy riders, unsafe e-cycles and motorcycles and unsafe cycling/driving practices:

Gig economy riders are already marginalised. They frequently earn well under minimum wage[5]. We believe the online systems through which work is allocated effectively make riders compete against each other in a race-to-the-bottom, and are alarmed to hear reports of modern day slavery associated with gangmasters “allocating” use of accounts and providing accommodation, cycles, etc.

To earn enough to live, gig economy riders are effectively incentivised to ride in unsafe ways, including through spaces reserved for pedestrians, at excessive speeds, using illegal e-motorcycles and while working very long hours.

Using even legal e-cycles in unsafe ways is reported: Hot-swapping multiple batteries of varying quality onto a cycle, fast-charging batteries outside design parameters, hacking legal e-cycles to increase maximum speeds and sharing a single cycle between more than one rider are all reportedly commonplace to maximise use of expensive cycles, minimising expenditure and sharing costs.

Gig economy riders reportedly have high turnover, with individuals rarely working for delivery companies for very long.

The above factors mean that measures targeting individual riders will inevitably be ineffective – new people will simply replace them and unsafe practices will continue. We suspect measures targeting the supply of e-cycles and components will be similarly ineffective, since the financial imperatives to go faster and remain in motion for longer are so great. We note the OPSS’s acceptance in oral evidence that “enforcement is a problem”.

Approaches to improve e-cycle safety and use must target the organisations which have the power and reach to make the real differences needed.

3            Reports of increasing inaccessibility due to inappropriate restriction of e-cycle and e-powered mobility devices

1. The restriction of e-cycle access onto TfL services is particularly notable.
   Since the introduction of the ban on non-folding e-cycles, TfL has clarified in a response to City Hall Greens that any e-cycle can be taken onto permitted services as long as the battery is disconnected (see appendix 6.7).
   Most e-cycles have removeable batteries and most non-disabled people will be able to remove their e-cycle battery and push the unpowered cycle through a station without difficulty.
   This means that the current ban is, in effect, only a ban on people who need to have the e-assistance on their cycle working to move through a station and onto and off a train: i.e. the present situation is essentially a highly discriminatory ban on Disabled cyclists.
   We do not accept TfL’s claim in oral evidence that it is “not feasible” to have an exemption for Disabled people: the above measures permitting both folding e-cycles and e-cycles with batteries disconnected effectively mean there are already exemptions in place for most if not all non-disabled people.
   While there is some worry that any evidence/certification could be forged, it seems much easier just to disconnect a battery than to bother forging an exemption certificate. In addition, we note that blue badges for cars can be, and often are, forged: the existence of forgery is not seen as a reason to deny the parking concessions associated with blue badges. We also note that TfL stations and revenue protection staff all have sophisticated devices for checking tickets etc.

In addition, recent reports and requests for support from individuals to Wheels for Wellbeing during 2025 regarding restriction of use of e-cycles and other Li-ion battery devices as mobility aids by Disabled people have included:

1. Housing providers banning all e-cycles from their buildings, including from designated cycle stores;
2. Large employers banning a range of lithium-ion battery powered e-mobility devices from being used, stored or charged on their premises;
3. Transport providers who had previously allowed specific individuals’ e-cycles onto vehicles removing permission, preventing individuals from travelling;
4. Users of class 2 and 3 “invalid carriage” powerchairs being refused access to public transport due to the Li-ion batteries in their mobility aids, despite these having class 1 medical device certification (checking after the oral evidence session reveals that constraints of confidentiality prevent disclosure of which operators).
5. Even if it doesn’t amount to a complete restriction, resistance to EAPCs in general (such as supplying fewer EAPCs as part of hire schemes, or not providing adequate charging locations for privately owned EAPCs) are having a disproportionate impact on Disabled people, since Disabled people disproportionately use e-assist, whether using an “adapted” cycle or a standard e-cycle.

4            Other Consequent Restrictions

We believe that failure to deal appropriately with the problems caused by gig economy platforms is causing other restrictions that are have the effect of particular detriment to Disabled people.

Among these restrictions are “Public Space Protection Orders” that restrict cycling by Disabled people who are not being antisocial.

We also have particular fears that behaviour of gig economy riders is creating greater concern about and opposition to cycling on pavements and in pedestrianised areas.

We fully understand the opposition, especially when the gig economy riders are riding motorcycles and motor scooters – whether illegal unregistered ones that look like EPACs or more conventional ones. For Disabled people to access shops and facilities in pedestrianised areas and to safely navigate built up areas, it is essential that we are permitted to cycle on pavements and pedestrianised areas at times. We campaign for cycle use in pedestrian spaces to be limited to Disabled people going at walking speed only, provided there are also safe and interconnected cycle routes.

We are aware that a proportion of the opposition to cycling in pedestrian spaces comes from legitimate concerns of Disabled people. We share these concerns. Appropriate regulation of gig economy platforms and their relationship to their riders/drivers is essential for the protection of Disabled users of pavements as well as Disabled cyclists and prospective cyclists.

5            Conclusions

Disabled people need access to e-cycles as essential mobility aids. We need legal changes so Disabled people can access the devices that provide access to local transport options for us.

Failure to appropriately deal with safety problems associated with e-cycles is causing Disabled people significant problems. These problems can be expected to increase over time, with adverse impacts on Disabled people’s mobility and health. Impacts will be both direct, via active restriction of our mobility options, and through indirect mechanisms such as by reducing Disabled people’s access to healthcare and participation in employment and education.

Key problems being caused include direct risks to Disabled people via injury or death due to dangerous e-cycle and motorcycle use and through fire risk from dangerous electronic systems, and inappropriate bans of e-cycles from public space.

There are a variety of measures that can be taken to substantially and effectively mitigate risk. For us, the highest priority when it comes to usage of devices is to make delivery companies legally responsible for the cycling (and driving) behaviour of their riders. Similarly, for mitigating electrical risks, our highest priority is to make delivery companies legally responsible.

There are a variety of other measures that can, and should, be taken, but they should be used in the context of tacking the question of legal responsibility of the delivery companies.

6            Appendices: Wheels for Wellbeing resources, evidence and submissions relevant to e-cycle safety and the gig economy

In the past year, Wheels for Wellbeing have released a number of position statements and submissions directly relevant to e-cycle safety and the gig economy:

6.1            May 2025: Wheels for Wellbeing evidence submission to the Public Bill Committee on the Crime and Policing Bill regarding Public Space Protection Orders (PSPOs)

PSPOs are frequently enacted with the intention of reducing frequency of actual or perceived antisocial and dangerous cycling by gig economy riders in city centres.

Our submission states that:

1. PSPOs related to cycling and their enforcement often have detrimental equalities impacts that are not recognised by the local authority in question, resulting in these impacts not being mitigated.
2. The lack of consideration of the requirements of the Equality Act (2010) is resulting in disproportionate and unreasonable harm to Disabled people’s mobility through PSPOs that restrict cycling.
3. The ability to challenge an FPN through the courts is so costly as to make it beyond the reach of the vast majority of Disabled people.
4. This means that exemptions that can only be accessed through challenging an FPN once issued are worthless and do not, in practice, meet any equalities aims.
5. PSPOs are being used to restrict cycling when other, more appropriate mechanisms for restricting cycling that is truly antisocial already existed.
6. PSPOs are being used to restrict cycling that is not antisocial.
7. The mechanisms to challenge the introduction of a PSPO that is unlawful are so restricted as to mean unlawful PSPOs are probably being made.

6.2            March 2025: Wheels for Wellbeing position statement on TfL non-folding e-bike ban on public transport

https://wheelsforwellbeing.org.uk/tfl-non-folding-e-bike-ban-on-public-transport-wfw-position-statement/

Outlines the need Disabled people have to use suitable mobility aids, including e-cycles, including the need to make multi-modal journeys with our mobility aids.

States that:

1. We recognise the fire risk posed by illegal e-motorcycles and unsafely modified e-cycles;
2. The ban in its original form will disproportionately and unreasonably exclude Disabled people from making journeys;
3. Reasonable adjustments must be made to the TfL non-folding e-bike ban to enable Disabled people to continue to travel with their safe e-cycle mobility aids on public transport, in order to avoid the ban being discriminatory under the Equality Act (2010).

6.3            January 2025: Wheels for Wellbeing position statement on Statutory Guidelines on Lithium-ion battery safety for e-bikes

https://wheelsforwellbeing.org.uk/wheels-for-wellbeing-position-statement-on-statutory-guidelines-on-lithium-ion-battery-safety-for-e-bikes/

States that:

1. We broadly support introduction of statutory guidance to improve safety of lithium-ion battery powered devices.
2. Disabled people are at greater risk of injury or death in building fires due to being less able to escape. Reduction of fire risk is clearly important for Disabled people’s safety and equality.
3. Disabled people also need safe, affordable mobility options which provide sufficient mobility range to make essential journeys. This must include e-powered and e-assist devices including wheelchairs, mobility scooters, micro-mobility and e-cycles: E-cycles are essential mobility aids for many Disabled people.
4. The statutory guidelines cover only batteries intended for use on “e-bikes”, not comparable capacity batteries intended for use in other devices. As such, these statutory guidelines are not comprehensive enough to reduce Li-ion battery fire risk from either batteries used in illegal or modified e-cycles and motorcycles, or from Li-ion batteries used in other devices, including mobility devices, and charged in homes and workplaces.
5. The specific targeting of “e-bikes” in the statutory guidelines perpetuates the harmful myth that legal EAPCs pose a high fire risk. This myth is being used to justify restrictions on EAPC use by housing providers, service providers, workplaces and transport providers, fueling public fear of e-cycles, including amongst Disabled people. One consequence will be reduction in e-cycle availability and e-cycle maintenance options, harming the mobility options of Disabled people, many of whom can or could use EAPCs as mobility aids to make essential journeys. Reduced active mobility decreases Disabled people’s ability to take part in daily life, including employment, education, healthcare, self-care and care of others, community activities and leisure, also harming the government’s growth, health and green missions.

Asks that:

1. The statutory guidelines are updated to cover lithium ion batteries intended for any use which are likely to be stored or charged in homes and which are of a capacity sufficient to present a significant risk in case of thermal runaway.
2. The statutory guidelines are altered to clarify the very low fire risk posed by legal, unmodified EAPCs.

6.4            August 2024: Wheels for Wellbeing briefing on e-cycles, fire safety and Disabled people’s mobility

https://wheelsforwellbeing.org.uk/e-cycles-fire-safety-and-disabled-peoples-mobility/

Provides links and details of evidence on the importance of e-cycles for Disabled people’s mobility and the relative risk of e-cycle and e-scooter fires.

States that:

1. We consider the banning e-cycles from public spaces and services and the de facto banning of e-cycles from private homes via insurance and tenancy clauses to be inappropriate, disproportionate and discriminatory responses to the low fire risk that the government and fire services agree is posed by legal e-cycles.
2. Banning e-cycles from homes, from public transport and from important destinations in response to a low risk of fire in legal, appropriately-used devices fails to account for the huge importance of e-cycles used as mobility aids and for essential transport by many Disabled people, who often have no other viable mobility options.

6.5            April 2024: Wheels for Wellbeing Quick Guide to Public Spaces Protection Orders

https://wheelsforwellbeing.org.uk/wheels-for-wellbeing-quick-guide-to-public-spaces-protection-orders-pspos/

States that:

1. Public Spaces Protection Orders (PSPOs) are being used by some local authorities (councils) to ban cycling in areas of towns and cities – usually in town or city centres.
2. Some local authorities are including exemptions which allow Disabled people to continue riding their cycles through the PSPO area.
3. Unfortunately, we do not believe that the exemptions can be sufficiently broad or administered sufficiently well to provide good access for Disabled people cycling. Disabled people riding bicycles and who may not appear stereotypically Disabled to all observers are probably most likely to be disbelieved by any person enforcing a PSPO.
4. Other local authorities are not even including exemptions for Disabled people cycling.
5. In either case, council officials, police officers and members of the public may challenge Disabled people who are using their cycle as a mobility aid to replace walking.
6. Any local authority considering using a PSPO to reduce antisocial behaviour including by people cycling (or using e-motorcycles) needs to consider alternatives to PSPOs, equality impacts and exemptions very carefully

6.6            April 2024: Wheels for Wellbeing e-assist pedal cycles proposal discussion sheet: Safe, inclusive and accessible mobility

https://wheelsforwellbeing.org.uk/e-assist-pedal-cycles-proposals-2024-discussion-sheet-safe-accessible-and-inclusive-mobility/

States that:

1. Proposals to increase maximum e-assist pedal cycle motor power and throttle speeds will not address the key barriers to Disabled people’s cycling;
2. Better access to EAPCs with lower (4-12mph) maximum throttle speeds and exemptions for handcycles and wheelchair carrying cycles to have higher powered motors, would improve access to cycling for some Disabled people;
3. A blanket increase on permitted motor power and throttle speeds would carry high risk of causing significant overall harm to Disabled people’s mobility through increased risk to Disabled people from EAPC riders and increased negative perceptions of cycling. Increased negative perceptions would be likely to lead to increased access restrictions such as physical barriers and PSPOs, both of which routinely prevent many Disabled people from using cycles as mobility aids.
4. We would welcome investigation of measures to improve access to cycling for Disabled people without increasing risk to others walking/wheeling & cycling.
5. Development of a new motorcycle category could facilitate use of higher power and heavier e-cycles on carriageways only, with safety regulations & licencing of use.
6. We would welcome development of national guidance on safe use of all cargo-carrying cycles, including loading, rider sight lines and brake function.
7. Making delivery companies responsible for the safety and legality of their riders’ cycles and cycling could reduce risk, improve public opinion and increase business viability for cycle delivery firms.

6.7           Response shared with us by London Assembly members re TfL e-bike ban

““Thank you for writing to us on behalf of Caroline’s constituent regarding the ban on e-bikes on the London Underground.

“As you will be aware, we recently announced that all non-folded e-bikes will be banned on parts of London’s transport network from 31 March to ensure the safety of customers and staff.

“We have been working closely with the London Fire Brigade and other partners to carry out a comprehensive review of the safety of e-bikes and their suitability for carriage on the TfL transport network. While the majority of e-bikes are safe, there have been a small number of incidents where non-foldable e-bikes have caught fire on the transport system in London. To ensure the safety of the network for customers and staff, customers in possession of non-foldable e-bikes will not be permitted to travel on most TfL services, including on the Tube, Overground, Elizabeth line and DLR. The ban includes all non-folding e-bikes, including standard cycles that have been converted to e-bikes using conversion kits.

“TfL’s analysis suggests that cycles that have been adapted using electronic conversion kits pose a greater fire risk than purpose-built e-bikes, however, it can be hard to differentiate between modified and un-modified e-bikes. Until improved product safety measures are in place for converted cycles, batteries and chargers, a ban is necessary for all non-folded e-bikes. TfL and LFB continue to work with Government to seek improved product safety for electronic cycles. We are not aware of any reports of foldable e-bike fires in London, and there are fewer opportunities for foldable cycles to be converted into e-bikes using conversion kits, due to their specific shape, size and mechanical constraints.

“Regarding the constituent’s query specifically, if an e-bike does not have its battery connected then it is not classed as an e-bike for the purposes of TfL’s ban on non-foldable e-bikes. Therefore, in these circumstances, the standard cycle restrictions would apply to such a device. [our bold] We are working alongside the Government regarding e-bike safety standards and our polices will be kept under review pending any future improvements in product safety legislation.

“On the second point about illegal e-bikes, we are working closely with the Government to seek improved product regulations for e-bikes. In particular, we would welcome effective regulation on the e-bike, and e-scooter, market to ensure there are sufficient product quality checks on devices sold within the UK marketplace. This would need to include second-hand platforms as well to ensure devices sold are suitable and sufficient.

“The Metropolitan Police Service (MPS) Cycle Safety Team engages and educates all road users and conducts roads policing enforcement against unsafe and irresponsible behaviour that can impact the most vulnerable road user. Police officers and TfL’s operational enforcement officers engage with riders to comply with the highway code. MPS officers will use their discretion to respond fairly and proportionately, focusing effort on where this causes risk to pedestrians and cyclists themselves.

“The public can report dangerous, illegal, or antisocial road user behaviour directly to the police via their online reporting tool, RoadSafe London.  Every report helps the police and TfL to understand where and when poor road user behaviour takes place. The information and intelligence gathered via this tool is used to inform the activity of the police and partners. The tool is available online at Report a road traffic incident | Metropolitan Police.”

[1] CIPD UK gig economy thoughts and insights October 2023, James Cockett https://www.cipd.org/uk/views-and-insights/thought-leadership/cipd-voice/uk-gig-economy/

[2] The Bureau Investigates, March 2021, Emiliano Mellino et al https://www.thebureauinvestigates.com/stories/2021-03-25/deliveroo-riders-earning-as-little-as-2-pounds

[3] “Deliveroo not forced by law to engage with unions, Supreme Court rules – BBC, Michael Race https://www.bbc.co.uk/news/business-67484101

[4] London Fire Brigade “charging electric bike and electric scooter lithium batteries” https://www.london-fire.gov.uk/safety/lithium-batteries/charging-electric-bike-and-electric-scooter-lithium-batteries/

[5] The Bureau Investigates, March 2021, Emiliano Mellino et al https://www.thebureauinvestigates.com/stories/2021-03-25/deliveroo-riders-earning-as-little-as-2-pounds