With Smart Tachograph 2 becoming mandatory for in-scope vehicles from August 2025, and ongoing reforms to driver hours and enforcement powers, operators should review their compliance now. Use this checklist to prepare your fleet.
1. Tachograph equipment
- Confirm all newly registered vehicles (from August 2025) are fitted with Smart Tachograph 2 units.
- Plan retrofitting for existing vehicles crossing EU/EEA borders by August 2025 deadlines.
- Ensure calibration is carried out by an approved centre within statutory intervals.
- Check workshop seals and documentation are current and intact.
2. Driver cards & training
- Verify all drivers have up-to-date tachograph cards compatible with Smart Tachograph 2.
- Provide refresher training on: new satellite positioning functions (every 3 hours driving), new border-crossing recording requirements, handling technical errors or malfunctions.
- Document training records for audit purposes.
3. Record-keeping & data
- Download driver card data at least every 28 days.
- Download vehicle unit data at least every 90 days.
- Keep all records for minimum 12 months (recommendation: 24 months).
- Review GDPR/data retention policies for new location and cross-border data.
4. Working time & driver hours
- Check compliance with EU/UK drivers’ hours regulations (driving limits, breaks, weekly rest).
- Cross-check tachograph records against shift rotas to spot inconsistencies.
- Review Working Time Directive compliance (average 48 hours per week).
5. Fleet & maintenance records
- Maintain accurate defect reporting logs.
- Ensure preventative maintenance schedules are documented and up to date.
- Retain MOT/inspection certificates for all vehicles.
6. Border operations & enforcement readiness
- Brief drivers on on-the-spot enforcement checks (including remote interrogation of Smart Tacho 2 data).
- Keep copies of key compliance documents in-cab (licence, insurance, operator’s licence discs).
- Have a process in place to respond quickly to roadside prohibitions or enforcement notices.
7. Operator licence & internal systems
- Audit your operator licence undertakings – are you meeting undertakings on record-keeping, training, and reporting?
- Review your internal transport manager oversight systems.
- Ensure any subcontractors/agency drivers meet the same compliance checks.
8. Contingency & legal support
- Identify a legal/regulatory contact for urgent enforcement issues.
- Have an internal reporting chain if DVSA/CPS investigations arise.
- Schedule an annual compliance audit (internal or external).
Tip: Regulators are expected to increase remote checks and roadside enforcement as Smart Tachograph 2 becomes the standard. Early preparation reduces disruption and liability.
Need advice?
Stephensons’ specialist motoring and road transport solicitors advise on tachograph prosecutions, operator licence undertakings, roadside prohibitions, and DVSA investigations. Contact us on 0161 696 6188 for immediate advice.
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