Part of our Operator Questions series. We explain exactly what a digital tachograph records, where the data lives, and the download deadlines you need to meet.
This is one of the questions we're regularly asked by transport managers and operators - so here's the straight answer from our analysts.
Driver digital tachograph cards record all vehicle activity and tachograph mode selections. Periods of other work, break, drive, POA, train/ferry flags, Out of Scope and any manual entries inputted are recorded along with the date stamp and timeframe for each mode. The information is stored on the internal memory chip located on the card and extracted through the raw data download process.
Vehicle units record and store all information pertaining to the vehicle and information from the driver card, allocating duty, manual entry flags and any events and faults to the card inserted at the time. Overspeeds are also recorded against the driver and card at the point of infringement, recording average speed, maximum overspeed and duration of the infringement. Regulation (EU) No 165/2014 Article 4, specifies the data elements that must be stored on the vehicle unit and driver card.
Digital driver card chips are capable of storing up to 28 days of data, which coincide with the driver card download requirement (The Passenger and Goods Vehicles (Recording Equipment) (Downloading and Retention of Data) Regulations 2008, which requires the transport undertaking to ensure driver card data is downloaded within 28 days; vehicle unit data must be downloaded within 90 days (increased from 56 days and updated via The Passenger and Goods Vehicles (Recording Equipment) (Downloading of Data) Regulations 2015) under regulation 97D of the same instrument.
Data is overwritten if cards are not downloaded within the parameters. Vehicle unit data is overwritten if vehicle units are not downloaded within the equivalent of 365 calendar days of average driver activity (Commission Implementing Regulation (EU) 2016/799 defines ‘365 days’ as 365 calendar days of average drivers’ activity in a vehicle, where average activity per day is defined as at least 6 drivers or co-drivers, 6 card insertion/withdrawal cycles, and 256 activity changes; in standard mixed-fleet operations this equates to approximately one year of recording before oldest data is overwritten).
Generation 2 smart tachograph units (mandatory fitment for new vehicle types from 21 August 2023 and for all new vehicles from 21 August 2025, under Commission Implementing Regulation (EU) 2021/1228 amending Regulation (EU) No 165/2014) contain the ITS Intelligent Transportation System function allowing for enhanced vehicle communication and crucially automated remote enforcement.
GNSS global vehicle positioning serves a similar purpose as the ITS system via location-based enforcement. Vehicles register locations at the start, end and every three hours of a duty period. Paired with the ITS system, operators, analysts and enforcement officers are presented with clear data displaying infringements via the driver, the vehicle, and location data confirming if vehicles park up at the operating centre. The requirement to park authorised vehicles at the operating centre is an undertaking of the operator licence under s.13C(4) of the Goods Vehicles (Licensing of Operators) Act 1995, as reflected in the Guide to Maintaining Roadworthiness, which confirms that Traffic Commissioners rely on the operator licence undertakings as the standard for whether maintenance and operational arrangements are satisfactory or if operator undertakings are being abused.
The Passenger and Goods Vehicles (Recording Equipment) (Downloading of Data) Regulations 2015
Commission Implementing Regulation (EU) 2016/799
Implementing regulation - 2021/1228 - EN - EUR-Lex
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