You may be right, Phil: it seems daft that they want a new photo every ten years and issue a new one with a photo more than five years old but .......
I have no recollection of obtaining/uploading a new photo and I certainly didn't mail one
I just checked dates on my Passport and licence. Passport issued Feb 2009; licence May 2015.
The only differences I can see in the photos is that the one on the licence is:
Black and white instead of colour | slightly smaller | the picture has been slightly cropped, just skimming the hair and bottom of Adam's Apple.
Expression looks the same (slightly distorted by the security markings in/over the photos) and pics show the same amount of hair of which I had less last year than in 2009 (and even less today).
I've also had another look at the DVLA guidance page
"before you start" where it says, "You can
change the licence photo at the same time as renewing your licence." (My italics). I didn't look at the current on-line application form so don't know if any other requirements are included there.
The only explanation I can think of (just seconds ago) is that the photo mustn't be more than 10 years old at expiry of the licence. My Passport expires Feb 2019 and because my over 70's licence expires a few moths earlier the current photo shown on both will still be less than 10 years old. Blimey, old brains work slowly at times.
Ha, Warwick posted while I was cogitating and using my 'seek and poke' typing technique.