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Update on substantial change, VHI declarations and MOT exemption

MOT exemption for Vehicles of Historic Interest
See our concise two page article. Note the clarification in the second paragraph that "the new MOT exemption arrangement is one of three entirely separate matters concerning historic vehicles, which thankfully will stay separate as none of them affect each other at all". More

MOT exemption flowchart
Illustrates the substantial change, VHI declaration and MOT exemption procedure. Flowchart 2

Timing issues flowchart
Illustrates how a VHI self declaration has to be made with an application for a VED application for an Historic car.
Flowchart 3

VED exemption flowchart
This flowchart illustrates the procedure for claiming VED exemption. It is a separate process from VHI/MOT exemption but is included here for reference. Flowchart 1

DfT Guidance on "substantial change"
See the DfT Guidance and FBHVC's useful notes on the DfT Guidance. A key thing a keeper assessing their vehicle for a VHI declaration needs to note is that understanding the Substantial Change guidance is not simply about technical aspects of substantial change but also about the interpretation of a guidance document with its very subtle drafting.
DfT Guidance

Support with DfT Guidance and a VHI self declaration
Should V8 Register members wish to discuss any matter relating to the DfT Guidance or VHI eligibility and any issues and concerns with self declaring a 40 year old MGBV8 as a VHI, do contact the V8 Registrar for assistance. Email

Other important MOT rule changes from 20th May 2018
See our NEWS item. More

Posted: 180403 & Updated: 180410

The UK Government has clarified its approach to the implementation of its obligations under the EU Roadworthiness Testing Directive and how it will affect the UK MOT test as it applies to historic vehicles, and specifically Vehicles of Historic Interest (VHI). The new regime for exemptions from the requirement to take the MOT test comes into force on 20th May 2018. The Federation of British Historic Vehicle Clubs (FBHVC) is seeking the cooperation of member clubs in assisting keepers of historic vehicles registered in Great Britain (England, Wales and Scotland) in self declaring VHI (Vehicle of Historic Interest) status and obtaining an exemption from the requirement that vehicles should undertake an annual MOT test. This exemption is available to any vehicle which qualifies as a VHI: essentially it was manufactured or registered for the first time at least 40 years previously, is of a type no longer in production, has been historically preserved or maintained in its original state and has not undergone substantial changes in the technical characteristics of its main components in the last 30 years.

The Department for Transport (DfT) has issued guidance - VHI: Substantial Change Guidance (DfT Guidance) - which sets out the basis upon which the keeper of a historic vehicle registered in Great Britain may declare to the DVLA (Driver and Vehicle Licensing Agency), through a question on the annual relicensing form or online application, that a vehicle qualifies as a VHI. DfT Guidance . Making a VHI declaration to the DVLA in respect of a vehicle is not compulsory. Not doing so in any year, because the keeper is content to have the vehicle undertake an MOT test, does not mean the vehicle cannot be validly declared a VHI in any subsequent year.

To discuss any matter relating to the DfT Substantial Change Guidance or VHI eligibility or MOT exemption do contact the V8 Registrar for assistance.

DfT Guidance and self declaration as a VHI
The DfT Guidance sets out a comprehensive set of criteria to be used in deciding whether a 'substantial change' to a vehicle has occurred. It also states that no change carried out more than thirty years ago requires to be considered. Any changes to the vehicle in the last 30 years have to be considered whether they are substantial or not with reference to the criteria set out in the DfT Guidance on "substantial change". Currently no procedure is proposed by DfT or DVLA to audit or check the validity of declarations made by keepers of such vehicles. The responsibility of declaring a vehicle is a VHI will rest entirely with the keeper of the vehicle.

Marque or historic vehicle expert
The DfT Guidance, in its fifth paragraph, states that keepers should, if they are in doubt as to the status of their vehicle for a VHI declaration, consult a marque or historic vehicle expert prior to making a declaration to DVLA. The purpose of requiring the availability of experts is purely to assist keepers in making their declaration, should they wish to do so. The DfT Guidance also states that a list of such experts will be kept by the FBHVC. The FBHVC refer to this list as the "List of Experts". There is no compulsion on keepers to consult an expert from the list, or indeed any expert, before making their VHI self declaration. We understand the MG Car Club has been requested to become an expert on the List of Experts being assembled by the FBHVC. Information of the scope of the role, procedures and the identity of the Club's "expert" or "experts" is awaited. So as the start of the new MOT exemption concession is rapidly approaching we have set up the consultation service mentioned above to help fellow MGV8 members with any queries they may have with the guidance or procedure. See alongside for details.

We understand the function of an expert is to advise keepers of their opinion, in their best judgement, on questions asked by the keeper both as to:
a) whether the vehicle is eligible in accordance with the DfT Guidance criteria to be declared as a VHI and,
b) to the extent they have any relevant knowledge, the time any change to the vehicle was made.

For these purposes:
a) An expert does not make the final decision on whether or not a vehicle is declared as a VHI.
b) An expert may require to inspect the vehicle to enable them to reach their opinion but will not be obliged to do so.
c) No expert will be obliged to provide an opinion, unless they are satisfied the information they have been provided with is accurate and sufficient.
d) An expert will have no responsibility to the DfT, DVLA, FBHVC or any third party whether directly or indirectly in respect of their opinion.
e) An expert is free to decline to provide an opinion, whether to members of their own organisation or to others, if in their view they are not in possession of sufficient, or sufficiently precise and accurate, facts.
f) An expert or an organisation nominating an expert is entitled to reimbursement of any costs incurred in reaching or providing the opinion and may make a reasonable charge for the service provided, which may be different depending upon whether the keeper making the request is or is not a current member of the MG Car Club and the V8 Register.

In providing consultation services of expert services to vehicle keepers, the V8 Registrar, the V8 Register, the MG Car Club and the FBHVC will have no responsibility for any views, opinions or decisions the V8 Registrar may express to a member seeking assistance or to any third party for the views expressed. The responsibility for declaring a vehicle is a VHI will rest entirely with the keeper of the vehicle.