Rather than licence their businesses, limos and drivers, it would appear that many limousine companies have simply decided to opt for the self-drive hire route. Briefly, this is where the customer agrees to hire the limo on a self-drive basis, but "employs" the services of a professional chauffeur to drive the limo. The hirer must pay the chauffeur direct and in some cases, will also be expected to pay for fuel as well. The arguments as to whether or not this is legal have a momentum of their own, but the bottom line is VOSA have done nothing, that tends to speak volumes, or maybe they just can't be bothered.
So despite the best endeavours of the Government to safeguard the travelling with the amendment to the Road Traffic Act, some (maybe many) limo bosses have simply changed the way they operate their business. So it looks like an own goal for the Department for Transport, ironic given it had taken them so long to improve the legislation in the first place.
Pity the poor individuals and companies that have spent their hard earned money to comply with the revised Act, only to find that they may as well spent it on a good holiday and set up a self-drive hire business instead.