She referred to the fact that the new drivers were not required to demonstrate an understanding of how passengers affect braking, stability and handling.
Ms Lee said the standard driving test did not require experience on rural roads with tight bends, undulations or variable grip.
The crash happened on the rural, single-carriageway B4035 near the Portobello crossroads in Shipston-on-Stour.
Addressing the DVSA, Ms Hadfield Lee said driving test requirements did not involve passengers or load-related vehicle dynamics, which she said raised concerns about whether the competencies that were assessed corresponded to those required during the early stages of independent driving.
Concluding, she said the organisations had until 18 February 2026 to respond.
“Your response must contain details of action taken or proposed to be taken, setting out the timetable for action.”
“Otherwise, you must explain why no action is proposed.”