Leonardo Machado

Deliveroo 
 1 Cousin Lane 
 London 
 EC4R 3TE 

 Brendan Allen 
 Area Coroner for Dorset 
 Town Hall 
 Avenue Road 
 Bournemouth 
 Dorset 
 BH2 6DY 

 19 November 2025 

 Dear Mr Allen 

 Prevention of Future Deaths Report regarding the death of Leonardo Machado 

 Thank   you   for   your   Report   to   Prevent   Future   Deaths  dated  18  September  2025  regarding 
 the  death  of  Leonardo  Machado  (the  “  Report  ”).  Firstly,  we  wish  to  offer  our  condolences  to 
 Leo’s family and loved ones for their loss. 

 In   the   Report   you   raised   concerns   that   children   under   the   age   of  18  may  be  renting  food 
 delivery  accounts.  You  are  concerned  that  this  might  place  children  in  a  vulnerable  position 
 where  they  are  working  alone  at  night  and  on  motorised  vehicles  at  risk  of  a  traffic  collision 
 and potential death. 

 Riders  must  be  aged  18  or  over  to  carry  out  deliveries  for  Deliveroo.   We  have  strict  controls 
 to   prevent   individuals   aged   under   18   from   onboarding   and   creating   delivery   accounts   - 
 these  are  detailed  further  below.   Riders  may  allow  others  to  use  their  account  (substitution 
 is   a   feature   of  self-employment  in  the  UK)  but  account  holders  are  not  permitted  to  share 
 their   delivery   accounts   with   individuals   who   are   under   18   years   old.   This   is   clear   in   our 
 Rider Supplier Agreement and on our rider website. 

 You  might  be  aware  that  over  the  course  of  this  year,  we  have  been  working  closely  with  the 
 Home   Office   and   other   food   delivery   platforms   to   enhance   compliance   with  right  to  work 
 legislation   by   food   delivery   couriers.   We   have   significantly   strengthened   checks   and 
 processes  that  we  already  had  in  place  to  ensure  that  rider  accounts  are  only  being  used  by 

 Deliveroo 
 Roofoods Limited, 1 Cousin Lane, London, EC4R 3TE 

  authorised   individuals.   Although   your   concerns   do   not   relate   to   right   to   work  specifically, 
 the   work   being   carried   out   in   this   area   strengthens   our   processes   to   prevent   riders 
 operating  on  our  platform  without  our  authority  or  knowledge.  This  includes  individuals  who 
 are  under  18  years  old,  who  are  prohibited  from  accessing  our  platform  under  the  terms  of 
 the app. 

 In  preparing  our  response,  we  have  reflected  on  our  internal  procedures,  including  changes 
 made   to   the   way  we  operate  following  engagement  with  the  Home  Office.  As  summarised 
 below,   we   are   confident   we   have   a   robust   framework   designed   to   reduce   the   risk   of 
 unauthorised riders accessing our platform and we trust you find the response helpful. 

 Measures to prevent unauthorised platform access 

 Deliveroo   takes   this   matter   very   seriously   and   has   a   framework   of   safeguards   in  place  to 
 reduce  the  risks  of  unauthorised  access  to  our  platform,  including  by  those  who  are  under 
 18. In particular: 

 1. 
 2. 

 3. 

 4. 

 5. 

 6. 

 7. 

 It is a requirement that any rider engaged with Deliveroo is at least 18 years old. 
 As   part   of   our   onboarding   process,   we   take   steps   to   establish   the   identity   of   our 
 riders  to  ensure  we  know  who  we  are  engaging  and  verify  their  right  to  work.  As  part 
 of  that  process,  all  riders  are  required  to  provide  an  official  document  that  evidences 
 their   date   of   birth.   This   might   be   a   passport,   driving   licence   or  birth  certificate  for 
 example.   These   documents   are   checked   before   the   rider   is   granted   a   delivery 
 account.   A   delivery   account   will   not   be   granted   to   an   individual   unless   their 
 documents show they are over 18 years old. 
 Once   a   rider   has   access   to   a   delivery   account,   as  is  the  case  for  all  self-employed 
 individuals   in   the   UK,   they  are  allowed  to  substitute  their  services  to  other  people. 
 However,   we   require   all   substitute   riders   to   be   registered   with   us   before   they  can 
 provide  services  on  behalf  of  the  main  account  holder.   As  part  of  this,  all  registered 
 substitutes   must   complete   the   same   process   to   establish   their   identity   and   their 
 right  to  work,  meaning  that  they  provide  evidence  of  their  date  of  birth  in  the  same 
 manner as the main account holder. Substitution is explained in more detail below. 
 We  run  facial  recognition  checks  to  ensure  that  the  person  using  an  account  is  either 
 the   main   account   holder   or   a   registered   substitute   and   to   detect   and   prevent 
 unauthorised  use  of  the  platform.  These  checks  are  run  at  least  daily  for  all  riders  in 
 the   UK.   This   process   requires   the   rider   to   submit   a   live   video   selfie,  which  is  then 
 checked   by   our   third   party   supplier   to   make   sure   it   matches   the   ID  they  provided 
 during   onboarding.   If   riders   do   not   pass,   their   accounts   are   placed   out   of  service, 
 meaning that they cannot accept orders until they have passed a check. 
 Facial  recognition  checks  are  triggered  in  various  different  scenarios.  The  checks  are 
 designed   to   detect   unauthorised  riders  in  the  areas  of  most  common  abuse  on  our 
 rider app. 
 We   have   recently   increased   the   frequency   and   sophistication   of   these   checks, 
 including   randomising   the   frequency   of   intra-day   checks   to   make   it   harder   for 
 people to predict the checks. 
 Our  facial  recognition  technology  identifies  any  failed  checks  that  indicate  someone 
 other   than   the   main  account  holder,  or  registered  substitute,  may  have  been  trying 

 2 

  8. 

 to   conduct   a   facial   recognition   check   on   their   behalf,   or   where   there   is   other 
 evidence  of  fraud.  These  are  reviewed  by  our  teams  and  where  we  find  evidence  of 
 unauthorised account sharing, we terminate the supplier agreement with the riders. 
 We  also  have  other  measures  in  place  to  enable  us  to  identify  suspicious  activity  or 
 if   an   unregistered   substitute   is   attempting   to   use   our   platform.   Where   we   identify 
 breaches   of   our   processes,   we   take   appropriate   action,   including   terminating 
 supplier agreements with riders where necessary. 

 We  stop  working  with  riders  who  allow  an  unregistered  substitute  to  use  their  rider  account 
 and  will  not  work  with  those  riders  in  the  future.  We  have  processes  in  place  to  enable  us  to 
 identify   whether   a   rider   applicant   has   previously   had   a   supplier   agreement   with   us 
 terminated for allowing an unregistered substitute to provide services on their behalf. 

 Substitution 

 of 

 to 

 the 

 food 

 refer 

 renting 

 delivery 

 licences. 

 You 
 Deliveroo   engages   riders   on   a 
 self-employed   basis;   we   do   not   operate   food   delivery  licences.  We  understand  that  when 
 using  this  term  you  may  be  referring  to  substitution  -  where  one  rider  completes  a  delivery 
 on   another   rider’s   behalf.   Substitution   has   always   been,   and   continues   to   be,   a   common 
 feature  of  self-employment.  It  is  not  specific  to  Deliveroo,  nor  our  sector.   Individuals  with  a 
 Deliveroo  rider  account  are  able  to  arrange  for  a  substitute  to  provide  the  delivery  services 
 on  their  behalf.  As  mentioned  above,  substitutes  must  also  be  registered  and  pass  the  same 
 identity  checks  as  a  main  account  holder  to  provide  services  to  Deliveroo.  Self-employment 
 and  substitution  provides  riders  with  the  flexibility  to  choose  when,  where,  how  and  if  they 
 want   to   provide   their   services   to   us.   This   is   a   valuable   way   of   working   for   self-employed 
 individuals, including riders. 

 We  continue  to  monitor  interaction  with  our  app  to  further  enhance  our  security  checks  and 
 features  to  prevent  abuse,  so  our  platform  remains  safe  and  secure  for  the  riders  who  work 
 with us and our wider communities. 

 We trust that this helps to allay any concerns you may have had. 

 Yours sincerely 

 Deliveroo VP European Operations 
 For and on behalf of Roofoods Ltd (t/a Deliveroo) 

 3

Health and Safety 
Executive 

Deputy Director for Technical 
Support and Engagement  

Health and Safety Executive  
Engagement and Policy Division 

Mr Brendan J Allen 

Area Coroner for the County of Dorset 

30 January 2026 

Dear Mr Allen 

Regulation 28 - Prevention of Future Deaths (

) 

Thank you for your letter and Prevention of Future Deaths report of 5th December 2025, 
, and arising from the inquest into the 
addressed to HSE’s Chief Executive, 
unfortunate death of Mr Machado whilst using a ‘rented’ Uber Eats licence. 
 has 
asked  me  to  respond  to  you  in  my  capacity  as  HSE’s  Deputy  Director  for  Technical 
Support and Engagement 

This was essentially a road traffic accident, and you acknowledge that excessive speed 
was the causative factor in Mr Machado losing control of the motorcycle he was riding.  
However,  you  also  raise  concerns  around  the  rental  or  sharing  of  permits  for  these 
platforms, the employment of minors and lone working.  

In leading the response, the Health and Safety Executive (HSE) has sought the views 
of several other governmental organisations, and these are included in our response 
below  which  viewed  together  describe  a  comprehensive  framework  of  guidance  and 
legislation. However, that does not mean that we are complacent, and you will also note 
proposals to improve on the current situation. 

Riding and driving for work: 

In respect of the road traffic accident itself, HSE views that road traffic accidents are 
generally a matter for the Police to investigate and enforce, rather than HSE, using the 
most applicable legislation. This is set out in Health and Safety at Work etc Act 1974 - 
Section 3. 

The  Department  for  Transport  (DfT)  commented  that  the  safety  of  anyone  driving  or 
riding  on  our  roads  is  a  priority,  and  that  includes  those  who  drive  for  work.  The 
government expects that employers or engagers of anyone driving or riding for work to 
ensure that they are as safe as possible on our roads. DfT worked closely with the HSE 
to  update  the  joint  DfT/HSE  guidance  on  work  related  road  safety.  The  revised 
guidance, published in September 2021 and called Driving and riding safely for work, 
clearly sets out what commercial organisations and their workers, whether employees 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 or  self-employed,  must  do  to  manage  work-related  road  safety  by  reference  to  their 
obligations under law. 

DfT has also announced as part of the Road Safety Strategy that it will pilot a National 
Work-Related Road Safety Charter for businesses that require people to drive or ride 
for them. The aim of the Charter is to help employers to reduce work-related road risk 
and  improve  safety  for  all  road  users  by  promoting  good  practice,  and  to  improve 
compliance with current legislation and guidance. It will include the use of Heavy Goods 
Vehicles (HGV)s, Light Goods Vehicles (LGVs), cars, motorcycles, e-cycles and cycles. 
The pilot will run for two years and will be monitored and fully evaluated.  

The tragic death of Leonardo Cardoso Machado has raised several important concerns. 
DfT is committed to making our roads safer and we are ready to work with others to 
achieve this. Road safety is a shared responsibility, and DfT’s strategy reflects that. It 
considers action needed by government, local authorities, industry, emergency services 
and  communities  to  tackle  the  causes  of  collisions  and  save  lives.  By  investing  in 
infrastructure, education, and enforcement, DfT are taking decisive steps to make our 
roads safer for everyone. 

Sharing of permits 

The sharing of permits between licence owners and “substitutes” is a contractual issue 
and not an area HSE has any control over.  

The Department for Business and Trade (DBT) are the more appropriate governmental 
body, and they have addressed the practice of “renting” food delivery licences to under 
18’s and the concerns that this raises. 

Food delivery companies do often allow account holders to use other people to carry 
out  work  for  them  under  their  account.  This  practice  is  sometimes  referred  to  as 
substitution or sending  a  substitute.  The ability  for someone  who  is  self-employed  to 
subcontract  work  is  a  key  feature  of  self-employment  and  is  a  lawful  commercial 
arrangement.  It  is not something  that  is regulated  or licensed by government  in  food 
delivery, or many other sectors where this practice can be found.  

As the report notes, most food delivery firms require that all riders and their substitutes 
are at least 18 years old. The government has been working closely with food delivery 
firms  so  that  they  increase  the  use  of  facial  verification  checks  and  fraud  detection 
technology to ensure only registered account holders and their registered substitutes 
can work off their platforms. 

Employment of Minors: 

HSE has some high-level guidance on the employment of young people under the age 
of 18: Young people at work: Overview - HSE. The Department for Education state that 
the restrictions on child employment in the Children and Young Person’s Act 1933 apply 
to children who are of compulsory school age. Therefore, these restrictions would not 
apply  in  the  case  of  Leonardo  Cardoso  Machado  who,  as  a  17-year-old,  would  be 
classed as a ‘young worker’.  

 
 
 
 However, we note from the response from Uber Eats UK Limited to the coroner on 18 
November  2025,  that  their  terms  and  conditions  include  requirements  that  persons 
under the age of 18 are prohibited from having a delivery licence or to act as a substitute.  

Lone Working: 

It is well known and established that lone working can present a risk to workers, and 
this should form part of an employer’s risk assessment. This includes the requirement 
to  assess  risks  and  should  consider  ways  in  which  the  work  can  be  organised  to 
minimise the potential for harm.  Relevant training, supervision, monitoring and support 
should  be  provided  for  lone  workers.  HSE  specifically  considers  lone  workers  in 
providing  guidance  and  this covers both  the  employers of  lone  workers and  the  lone 
workers themselves; Lone working - HSE. 

However, HSE acknowledges that there are practical limits to what can be done in the 
driver  delivery  sector  because work  like  this  inevitably involves working  alone, to 
deadlines, often at night and with the attendant road risks.  

Lastly,  a  great  deal  of  work  is  going  on between  government  and  the  food  delivery 
industry to tighten control and reduce abuse of legitimate systems such as substitution, 
for example  this initiative Delivery firms to bolster rider security  checks  to  stop  illegal 
working - GOV.UK.   

The new Employment  Rights  Act 2025 is  also  aimed  to  address  weakness  of current 
system - Employment Rights Act 2025: overview factsheet  

I  trust  that  this  response  from  HSE,  along  with  the  contributions  from  the  other 
governmental  departments,  gives  you  confidence  and  reassurance  that  the  issues 
raised in his report are actively being addressed.  

Yours sincerely,

RE Report to Prevent Future Deaths 
25 November 2025 

Dear Mr Allen, 

Thank you for sending us a copy of your report. I was saddened to read about the death of Mr 
Machado in your report and I extend my deepest sympathy to his family and loved ones. 

I am writing in response to your request for further information on the actions we take around 
courier safety. For some background context, Just Eat is predominantly a marketplace, which 
means that the majority of the partners on our platform are independent businesses who directly 
employ or engage their own couriers. To complement this, we offer delivery for restaurants that do 
not have this service, engaging with self-employed independent contractors.  

We have high standards for those that deliver on behalf of the business and our expectations are 
clearly communicated to couriers as part of onboarding and guidance processes, with a clear 
courier agreement which couriers sign up to in order to deliver on our network. When couriers sign 
up to the Just Eat network, we conduct background checks to determine eligibility, including 
checks that the courier is over the age of 18, has the right to work in the UK, does not have criminal 
convictions, and, if applicable, holds a suitable driving licence.  

Under the UKʼs employment law, self-employed independent couriers have the legal, unfettered 
right to use a substitute and Just Eat provides guidance to couriers on how they can do this safely 
and responsibly. Whilst couriers have the legal right to substitute their work, this can only be to 
others who are over the age of 18 and have the legal right to work in the UK. We have recently 
introduced further enhanced checks to ensure that substitutes meet the requirements that we set 
for all couriers on our network. Couriers must now pre-register any substitutes and are given a 
short grace period to complete biometric checks and to submit documents proving their age and 
that they have the right to work. If these documents are not provided, both the main account 
holder and their substitutes will be removed from the network. Couriers also undergo random 
biometric screening checks throughout their runs to ensure the people using the accounts are only 
those who have been verified to do so.   

More broadly, courier safety is a major focus at Just Eat and we have escalation processes in 
place for any serious issues raised. We are in regular contact with our couriers with a chat function 
within the app which couriers can use to raise any concerns and we have a safety and support 
section within our courier help centre which provides couriers with information on reporting 
incidents. We closely monitor any incidents regarding courier safety so that we can support our 

1 

 
 
 
 
 
 
 
 
 courier network effectively. We also provide extensive safety guidance materials available on our 
courier website.  

I hope this letter has provided you with assurances on our processes and we would be happy to 
discuss this further if you require.  

Kind regards, 

Senior Delivery Director UK&I 

2

Uber Eats UK Limited 

Floors 13-15 

Aldgate Tower 

2 Leman Street 

London 

18 November 2025 

Dear Area Coroner, 

Thank you for your letter dated 6 October 2025 and the enclosed Prevention of Future Deaths report dated 
23 September 2025 touching upon the death of Mr. Machado.  

Everyone at Uber Eats was deeply saddened to hear of this incident. We would like to express our sincere 
condolences to Mr Machado’s family and friends.  

It has been reported that Mr. Machado may have been travelling with an Uber Eats branded bag on the 
back of the motorcycle on the night of the incident. We have carried out a thorough investigation and can 
confirm that Mr Machado was not carrying out deliveries arranged through the  Uber Eats platform, as a 
substitute courier or otherwise, on the night of the incident on 16 April 2023.  

Coroner’s concerns 

This note sets  out Uber Eats’ response to section 5 of the PFD Report and, in particular, the Coroner’s 
matters of concern which are as follows:  

1.  During the inquest evidence was heard that: 

i.     There is significant national concern about the “rental” of food delivery licences to under 18s. In general 
terms, food delivery platforms place age restrictions on those who can obtain a licence  to  deliver  food.  
However,  there  appears  to  be  no oversight of the rental of these licences to those under the age limit. 
This  places  children  in  a  vulnerable  position:  lone  working,  often  at  night,  riding  electric  or  motorised 
scooters, mopeds or motorcycles and delivering to individuals that are not known to the drivers.   

2.  I have concerns with regard to the following: 

i.     There appears to be no or limited oversight of the practice of “renting” a food delivery licence to children 
under 18 years of age, which I heard is a national issue;  

ii.     As  a  consequence,  children   are  working  in  the  food  delivery economy, which involves lone 
working  at  night,  with  deliveries  being  made  to  the  home  addresses  of  private  individuals,  placing  the 
children in a vulnerable position;   

iii.     That placing children in a lone working environment at night and on the roads on electric or motorised 
scooters, mopeds or motorcycles also increases the risks of them coming to harm through a road traffic 
collision, leading to a risk of death. 

 
 
 
 
 
 
 
 
 
 
 
 
 Uber Eats’ response  

We would like to begin by stating unequivocally that everyone delivering on the Uber Eats platform must 
be at least 18 years of age. This requirement is set out clearly in our Courier Terms and Conditions that all 
couriers sign in order to use the app and we have a number of robust checks in place (outlined below) to 
ensure this requirement is met. If we become aware of someone delivering on the platform who may be 
under 18 we take immediate action, including reporting to law enforcement or relevant authorities where 
necessary. 

The safety of couriers, customers and community is of the utmost importance to Uber Eats. To register for 
an  Uber  Eats  account,  all  couriers  must  pass  a)  identity  document  verification  conducted  by  our  own 
specially trained teams and b) comprehensive fraud checks conducted by an expert third party (including 
Ubble, First Advantage). An account will only be approved if a courier’s identity document and date of birth 
is verified at each stage. 

As  independent  contractors,  couriers  have  the  right  to  subcontract  (or  ‘substitute’)  to  a  person  of  their 
choosing so long as their substitute meets certain safety criteria, including being at least 18 years of age. 
This requirement is made explicit in the Courier Terms and Conditions.  

The age of registered substitutes is verified  using  the  same process as above: multiple, comprehensive 
verification checks conducted by our internal team and independent expert providers to confirm their date 
of birth. 

To help ensure that only the account holder or registered substitutes (i.e. those confirmed to be over 18) 
are using the account, Uber Eats uses industry leading account-sharing detection technology. This includes  
real-time  identity verification software (launched  in 2019), which requires  couriers to take a selfie that  is 
compared  in  real  time  with  the  profile  photo  that  has  been  matched  with  their  registered  identity 
documentation. These real-time facial verification checks occur randomly, at least once a day and also in 
circumstances where we suspect that an individual performing the delivery may not be the same person as 
the  accountholder.  In  addition  to  these  checks,  we  monitor  for  suspicious  behaviours  that  may  indicate 
attempts to circumvent our security controls, which can trigger additional identity verification checks. 

If we were to become aware that a courier was attempting to share their account with a minor - whether as 
a substitute or by providing unauthorised access to their own account - we would take immediate action, 
including  suspending  the  account  to  investigate  and  taking  any  appropriate  steps,  which  may  include 
contacting  relevant  authorities.  We  have  a  dedicated  24/7  Public  Safety  Team,  who    respond  to  law 
enforcement  data  requests  and  regularly  engage  with  law  enforcement  to  support  a  swift  and  effective 
response to incidents.  

We are continually enhancing our processes to ensure our platform is safe. Although action taken was not 
in direct  response  to  this incident, we have  refined and  added  to  our suite of  account-sharing detection 
signals in recent years.  

We hope this response assists the coroner’s consideration of the matter, and we would like to once again 
express our deepest sympathies to Mr. Machado’s family and friends for their loss. 

Yours faithfully 

Uber Eats UK Limited  
Uber Eats UK Limited