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Notes -
You're shifting the licensing requirement from the government to the insurers. Now, either insurance companies insure everybody regardless of competence (which means they get landed with responsibility for 'this legally blind drunk driver ploughed into a line of toddlers and you insured him') or they use their own set of tests before insuring drivers.
If they set their own set of tests, it's likely that some people will fail them. So they still end up with no licence. And if people are lying on forms or avoiding going to the doctor because of conditions they think will disqualify them from getting a licence, they'll either lie the same way to the insurance companies, or just not bother with getting insurance. And allegedly 13% of drivers in the USA are already driving uninsured, so driving without a licence isn't that big a step either.
Sure, but at least they'll only have to lie about things that actually affect their driving ability enough for insurance companies to care about them, and the insurance companies will be incentivized to find ways around these problems, such as by making certain medical tests mandatory.
Then if the insurance companies make tests mandatory or no insurance, how is that different from the government making regulations?
I do think there is room in between "ah feck it, if you can turn the key in the ignition you get a licence" and "if you so much as sneeze you're off the road", but I don't think this is a problem that is solvable purely by market forces. The first person injured or killed in an accident by someone 'licensed' by the insurance company, and there will be calls for more stringent standards. More stringent standards = incentive to lie or not report conditions. And that brings us back to where we started, except that now they're lying to the insurance company, not the driving licence department.
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