The two intervals, and the third one people forget #
28 days
Download from the driver card
GOV.UK, tachograph rules
90 days
Download from the vehicle unit
GOV.UK, tachograph rules
42 days
Used analogue charts returned by the driver to the operator
GOV.UK, tachograph rules
The third one is what catches mixed fleets. An operator running a couple of older vehicles alongside digital ones is tracking two different cycles with two different artefacts, one of which arrives as paper in a driver's bag.
None of these intervals is a single deadline. They are rolling deadlines, one per driver and one per vehicle, and they all move independently. Twenty drivers and fifteen vehicles is thirty five separate clocks, each with its own due date, each resetting when the last download happened rather than on a date the office chose.
That is what makes the job feel disproportionate to its difficulty. There is nothing hard in it. There is simply no natural moment at which it becomes due for everybody at once.
What the driver has to produce, and what the office has to hold #
Two different obligations, often conflated.
What the driver produces at the roadside
- Charts and any legally required manual records for the current day and the previous 28 calendar days, for AETR or domestic journeys under the assimilated rules
- Or 56 days for international journeys to and from an EU member country
- The driver card, where one has been issued
GOV.UK, tachograph rules
What the operator holds
- Regular checks of charts, manual records and digital data to ensure compliance
- The ability to produce records to enforcement officers for 12 months
- All reasonable steps to prevent breaches of the rules
GOV.UK, responsibilities of vehicle operators
The retention periods and the limits that sit behind them are set out on drivers' hours record keeping.
The exceptions that generate the most paperwork #
A lost or broken card is where the admin multiplies. GOV.UK states that where it is impossible to use a driver card, because it has been lost, stolen or damaged or is malfunctioning, a driver may drive without it for a maximum of 15 calendar days, or longer if necessary for the vehicle to be returned to its premises.
That is allowed provided they produce two printouts, one at the start of the day and another at the end. The driver must report the issue to DVLA and request a replacement card within seven days.
Read that as an administrative process rather than a rule and you get three nested clocks on one driver.
-
Seven days to request the replacement
-
Fifteen days of permitted driving
-
A daily pair of printouts
That have to be collected, identified and filed.
Multiply by the number of cards that go missing in a year and the exception is not an exception at all. It is a recurring workflow that nobody designed.
The equipment deadlines are dated and public #
DVSA's approved tachograph centre special notice 01-23, published 11 January 2024, sets out when a full or transitional smart tachograph 2 must be fitted:
| From | Applies to |
|---|---|
| 21 August 2023 | Newly registered in scope vehicles undertaking international journeys |
| 21 February 2024 | All newly registered in scope vehicles, regardless of journey type |
| 31 December 2024 | Retrofit into in scope vehicles with an analogue or digital tachograph on international journeys |
| 19 August 2025 | Retrofit into in scope vehicles fitted with a smart tachograph 1 on international journeys |
| 1 July 2026 | Newly registered goods vehicles over 2.5 tonnes on international journeys for hire and reward |
Which parts of the download cycle run on rules #
Runs on rules
- Knowing which driver cards are due or overdue for download today, which is date arithmetic against a 28 day interval
- Knowing which vehicle units are due against the 90 day interval, the same arithmetic on a different clock
- Spotting a driver with no data at all for a period, which is a gap in a set
- Tracking the seven day and fifteen day clocks on a broken card, which is three dates and a count
- Knowing which vehicles are inside which equipment deadline, which is published dates against a fleet list
Needs a transport manager
- Deciding what an infringement means for that driver, which is a management responsibility
- Deciding whether a pattern is a training issue or a planning issue, which is the substance of the duty
Operators in DVSA's earned recognition scheme already live with a version of this rhythm: all key performance indicators are measured over four week periods, reported at the end of the period and sent to DVSA four weeks later. Whether or not a business is in the scheme, the shape of the problem is the same. The detection is arithmetic, the response is management, and the two keep getting done by the same person in the same hour.
The wider set of licence undertakings that this sits inside is covered on operator licence paperwork, and to put hours against your own compliance cycle, start with the cost of admin time calculator or sort the tasks with the which tasks run on rules checklist.