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Drivers’ Hours Exemptions: When the Rules Don’t Apply

Exemptions

How to tell which drivers’ hours rules apply - out of scope, GB domestic or assimilated EU - and the exemptions UK operators most often get wrong.

Andy Gilbert
Published
29 July 2026
Last reviewed
29 July 2026

QUICK ANSWER

Drivers' hours exemptions rarely mean no rules at all. Every GB HGV and PSV operation sits in one of three regimes - fully out of scope, GB domestic, or the stricter assimilated (retained EU) rules - and an exemption normally just drops a vehicle from the assimilated rules into GB domestic, not out of regulation entirely. Working time limits and record-keeping duties often still apply.

An exemption rarely means no rules at all

Every HGV and PSV operation in Great Britain sits under one of three drivers’ hours regimes: fully out of scope (no drivers’ hours rules at all), the GB domestic rules, or the assimilated rules (the retained version of the EU rules, Regulation (EC) 561/2006 as it has effect in the UK). An “exemption” almost always means a vehicle drops out of the stricter assimilated rules and into the GB domestic rules, not that it escapes regulation entirely.

And even where the drivers’ hours rules genuinely don’t apply, working time limits and record-keeping duties often still do. Getting this wrong carries its own risk: wrongly assuming an exemption applies is itself treated as a breach, and the burden is on you to show the conditions were met.

Key thresholds to check first

Most exemption questions turn on a handful of numbers. Use this as a quick reference; each one is explained in context below.

  • 3.5 tonnes - the usual goods vehicle (or vehicle-plus-trailer) threshold for the assimilated rules.
  • 4.25 tonnes - from 1 June 2026, certain zero-emission goods vehicles over 3.5t but not exceeding 4.25t are exempt from the assimilated drivers’ hours and tachograph rules in GB. 
  • 7.5 tonnes - used in several goods exemptions, including non-commercial carriage and the materials/equipment/craft-goods exemption.
  • 100 km - a common radius limit (specialised breakdown, agriculture, live animals, alternative-fuel/electric and the materials/equipment exemption).
  • 50 km - the route limit for a regular passenger service to sit outside the assimilated rules, and a record-keeping trigger for some GB domestic goods work.
  • 10 / 9 passenger seats - a passenger vehicle with 9 or more seats (including the driver) is normally in the assimilated rules; up to 8 passenger seats, no drivers’ hours rules apply. 
  • 28 days - an in-scope driver must be able to account for the current day plus the previous 28 calendar days.

The three regimes, and how to tell which applies

The first question is never “which exemption do I use?” It’s “which regime am I in?” Work that out and everything else follows, including whether a tachograph must be fitted and used, and what kind of record you have to keep.

Regime Applies to Key driving limits Working time regime
Out of scope Wholly off-road work; vehicles never carrying goods on a public road; genuinely private driving No drivers’ hours limits Working Time Regulations 1998 and health-and-safety duties still apply
GB domestic (Transport Act 1968) Most goods vehicles exempt from the assimilated rules but still used on the road for work 10 hours’ daily driving; 11 hours’ daily duty Working Time Regulations 1998 (“adequate rest”)
Assimilated (Reg (EC) 561/2006 as it has effect in the UK) Goods vehicles over 3.5t maximum weight, including trailer, used wholly in the UK or 2.5t between the UK and EU (bar exemptions). 9 hours’ daily driving (10 twice a week); 45-min break per 4.5 hours; 56 hours weekly; 90 hours per fortnight Road Transport (Working Time) Regulations 2005

The table shows the goods-vehicle figures. Passenger vehicles follow the same three-regime logic but with different thresholds and limits - see Where passenger vehicles (PSVs) sit, below.

Fully out of scope (no drivers’ hours rules)

A vehicle is outside the drivers’ hours rules altogether in cases such as these:

  • it is operated wholly off the public road, or is never used to carry goods on a public road
  • on that particular job the driver never actually carries goods or passengers. For example, positioning a vehicle, delivering a hire or demonstrator vehicle, moving it between depots, or taking it to be scrapped
  • the driving is genuinely private; not in connection with a job and not to earn a living

One important caveat: a driver who is otherwise in scope of the assimilated rules must still record any off-road driving as “other work.” Being out of scope for the driving limits is not the same as being out of scope for records. This “never carries goods” position also does not cover repositioning a vehicle between two legs of a journey that is itself in scope. 

GB domestic rules

If a goods vehicle is exempt from the assimilated rules but is still used on the road for work, it almost always falls under the GB domestic rules, set out in the Transport Act 1968. The headline limits are simpler: a maximum of 10 hours’ daily driving and 11 hours’ daily duty. There are no prescribed breaks or rest periods, but employers must still ensure “adequate rest” under the Working Time Regulations 1998. 

A small number of operations are exempt even from the GB domestic rules: vehicles used by the armed forces, the police and the fire brigade; drivers who always drive off the public road; and genuinely private driving not connected with earning a living. 

Assimilated (retained EU) rules

These apply to most goods vehicles over 3.5 tonnes maximum permissible weight (including any trailer), used wholly within the UK or over 2.5 tonnes between the UK and the EU. Vehicles in scope must have a tachograph fitted and in use. Journeys beyond the UK and EU fall under AETR rules.

Where vehicles at or below 3.5 tonnes sit

A goods vehicle at or below 3.5 tonnes is outside the assimilated rules, but that does not mean no rules apply.

The assimilated rules bite only above 3.5 tonnes maximum permissible weight, including train weight, in the UK. A van at or below that weight is therefore out of scope of the assimilated rules. In practice, it usually falls under the GB domestic rules instead, so “it’s under 3.5 tonnes” is not the free pass it’s often assumed to be. 

Regulation updates in force from 1st July 2026 now affect vans, light vehicles and combinations of 2.5t-3.5t used for hire or reward on international journeys to and from the EU with further operator licensing and record retention requirements, so the base line weight is now 2.5 tonnes for any international work.

The van-and-trailer trap. The 3.5-tonne line is a combination figure. A car-derived or panel van that is itself under 3.5 tonnes can be pulled into the assimilated rules once a trailer takes the combined maximum authorised mass over 3,500 kg and the vehicle is used commercially. This catches a lot of operators who assume the van’s own plated weight is the only number that matters. 

Zero-emission vans of 3.5 to 4.25 tonnes (from 1 June 2026)

This is a recent and easily missed change. From 1 June 2026, certain zero-emission goods vehicles over 3.5 tonnes but not exceeding 4.25 tonnes are exempt in Great Britain from the assimilated drivers’ hours and tachograph rules. The extra weight comes from the battery, so the law now treats them broadly like an equivalent diesel or petrol van of 3.5 tonnes. They move into the GB domestic rules, and unlike the older alternative-fuel derogation, there is no 100 km distance limit. The change came in through the Goods Vehicles (Testing, Drivers’ Hours and Tachographs etc.) (Amendment) Regulations 2026. 

One important carve-out: a zero-emission vehicle in this 3.5–4.25t band used on journeys between Great Britain and Northern Ireland still needs a tachograph and stays in scope of the drivers’ hours rules unless another exemption applies. Operators with mixed diesel/electric fleets should also watch the boundary, since two similar vans on the same yard can now sit under different regimes. 

Where passenger vehicles (PSVs) sit

Buses, coaches and minibuses follow the same three-regime logic as goods vehicles, but the thresholds turn on passenger seats, route length and commercial status, not vehicle weight.

The starting point is the number of passenger seats, including the driver:

  • Up to 8 passenger seats: no drivers’ hours rules apply (the vehicle is not a PSV for these purposes).
  • 9 or more passenger seats, operating a commercial journey: normally within the assimilated rules, unless an exemption trigger applies; chiefly a regular service not exceeding 50km (GB domestic rules instead) or non-commercial use on a 9-16 seat vehicle (fully exempt from both regimes). 

The 50 km regular-service rule is the one most PSV operators rely on. A regular passenger service whose route does not exceed 50 km falls outside the assimilated rules and into GB domestic rules. The route length is measured by the service route itself. Dead mileage running to and from the depot at the start or end of the day is not counted. 

Under the GB domestic rules for passenger vehicles, the headline limits differ from the goods figures: a maximum of 10 hours’ daily driving and a working day (spreadover) of no more than 16 hours, with at least 10 hours’ rest between working days (reducible to 8.5 hours up to three times a week) and breaks based on the length of the day. Note too that there are no record-keeping requirements under the GB domestic rules for PSVs, though a driver who does any assimilated or AETR driving that day must still produce their card and records for that work. 

Many of the goods exemptions have passenger equivalents (40 km/h vehicles, emergency and rescue, road-test and maintenance, historic and non-commercial vehicles, public-authority operations and the like).

Exemptions from the assimilated rules (UK and UK–EU journeys)

These exemptions apply both on journeys wholly within the UK and on journeys between the UK and the EU. A qualifying vehicle normally drops into the GB domestic rules for the GB leg. The exemptions most likely to be relevant to operators include:

  • vehicles not capable of exceeding 40 km/h (about 25 mph), including those held to that speed by a limiter 
  • specialised breakdown (recovery) vehicles operating within a 100 km radius of base 
  • vehicles on road tests for technical development, repair or maintenance, and new or rebuilt vehicles not yet in service (this does not cover driving to or from an annual test)
  • specialised vehicles built or adapted as mobile medical units (for example mobile screening units)
  • vehicles up to 7.5 tonnes used for the non-commercial carriage of goods 
  • historic vehicles used non-commercially. In GB, a vehicle built more than 25 years before the day it is driven 
  • in GB only: RNLI vehicles, vehicles manufactured before 1 January 1947, and steam-propelled vehicles
  • vehicles used in connection with emergencies or rescue operations, for the duration of the emergency

Each comes with precise conditions - meeting the vehicle description alone is not enough.

National derogations (journeys wholly within the UK)

National derogations work like exemptions, but apply only on journeys wholly within the UK. Never on UK-EU journeys.

Those most relevant to the sectors we work with include:

  • door-to-door household refuse collection and disposal 
  • vehicles used in road maintenance and control (such as laying tarmac or removing materials), but not journeys that merely position the vehicle to or from site
  • vehicles used in connection with sewerage, flood protection, water, gas and electricity maintenance services (maintenance of an existing service, not construction of a new one)
  • agriculture, horticulture, forestry, farming and fishery undertakings carrying their own goods within a 100 km radius of base 
  • vehicles carrying animal waste or carcasses not intended for human consumption
  • vehicles up to 7.5 tonnes propelled by natural or liquefied gas or by electricity, carrying goods within a 100 km radius of base 
  • mobile project vehicles used mainly as an educational facility when stationary. For example. mobile libraries
  • vehicles used in connection with telecommunications, radio or television broadcasting, or the detection of radio or television transmitters or receivers
  • vehicles used only on roads inside hub facilities such as ports, airports and railway terminals

These are the ones a haulage, waste, construction or utilities operator is most likely to meet. Several others exist: milk collection, circus and funfair equipment, driving instruction, Royal Mail (as universal service provider), island operations and more.

Waste operators should read the refuse derogation closely, because it is narrower than it looks. To qualify, the work should be carried out by a public authority or by a contractor to one; it should be the primary, door-to-door collection of household-type waste, with the transport remaining subsidiary to the collection; and journeys should not normally exceed a 50 km radius from base. Collecting genuine commercial or trade waste, for example waste from a manufacturing process, falls outside of it. 

The “driving is not my main activity” test

“Driving isn’t my main job” is not, by itself, an exemption. It is one condition inside a specific small-vehicle exemption, and only one.

This is one of the most misunderstood points in the whole area. There is a genuine exemption for vehicles up to 7.5 tonnes used to carry materials, equipment or machinery for the driver’s own use in the course of their work, think an electrician or builder carrying tools and materials to a job. But it applies only if all of these hold:

  • the vehicle, with any trailer, does not exceed 7.5 tonnes
  • it stays within a 100 km radius of base
  • driving does not constitute the driver’s main activity
  • the transport is not carried out for hire or reward

The same structure covers goods produced on a craft basis (baking, furniture-making, pottery and the like) delivered within the same limits. Take any one condition away (over 7.5 tonnes, beyond 100 km, or carried for hire or reward) and the exemption falls away. A scaffolding or removals firm carrying customers’ goods for payment will not qualify on this route, however incidental the driving feels.

A worked example. An electrician driving a 3.5-tonne van with a trailer of their own tools and cable to a job 60 km away, as an incidental part of doing electrical work, is likely within this exemption. The same electrician asked to run a paid delivery of a customer’s materials across the county is not. That carriage is for reward, and may be their main activity for the trip. The facts of each journey decide it.

Non-commercial carriage

Several exemptions turn on the carriage being “non-commercial” -  a narrow, specific definition, not a loose one.

Non-commercial carriage means carriage that is not for hire or reward and not on own account, generates no direct or indirect income for the driver or anyone else, and is not linked to any professional or commercial activity. Moving your own household, or transporting horses not used for competition or a rally car for a hobby in a vehicle up to 7.5 tonnes, can be non-commercial. The moment the trip is connected to a business, including “on own account” carriage of a firm’s own goods,  it is not.

Recovery vehicles and mobile workshops

Recovery and workshop scenarios have their own exemptions, but they hinge on the vehicle being genuinely “specialised.”

A specialised breakdown vehicle operating within a 100 km radius of base is exempt. In case law, “specialised breakdown vehicle” means one whose construction and permanent fittings show it is mainly for removing vehicles that have recently broken down or been in a collision, not just any vehicle pressed into a recovery job. Vehicles undergoing road tests for repair or maintenance, and new or rebuilt vehicles not yet in service, are also exempt, but driving to or from a testing station for the annual test is not covered. 

Two practical points operators get wrong. First, a relay recovery can keep each vehicle within its own 100 km radius.  However, a single long tow, or a tow-dolly job that runs beyond 100 km from base, may need a tachograph if the combination exceeds 3.5 tonnes and no other exemption applies. Second, there is no general “mobile workshop” exemption. A workshop van may fit the materials/equipment exemption or a listed maintenance derogation, but only if those exact conditions are met. A label on the side of the vehicle is not enough.

An exemption from drivers’ hours is not an exemption from working time

This is the single most important point on the page. Falling outside the drivers’ hours rules does not switch off the working time rules, and it rarely switches off record-keeping either.

Two separate regimes are at work:

  • Drivers under the assimilated or AETR rules are also subject to the Road Transport (Working Time) Regulations 2005: an average 48-hour week (with no individual opt-out), up to 60 hours in any single week provided the average holds, a 10-hour limit on night work unless extended by agreement, and breaks once work exceeds 6 hours. 
  • Drivers under the GB domestic rules are instead covered by the Working Time Regulations 1998, including the duty to provide “adequate rest.”

So a vehicle can be exempt from the 561/2006 driving limits and still sit squarely within a working time regime. Record obligations can also still apply: under the GB domestic rules, written records are generally required where the vehicle needs an operator’s licence and the driver drives more than 4 hours that day. 

Records can still be required

An exemption from the driving limits does not always switch off record-keeping. Work out what you still have to record before you assume there’s nothing to keep.

In broad terms:

  • In scope of the assimilated rules: the driver keeps full tachograph records and must be able to account for the current day plus the previous 28 calendar days; driving, other work, availability, breaks and rest. Any off-road driving on an otherwise in-scope day is recorded as “other work.” 
  • Under the GB domestic rules (goods): a written weekly record sheet is generally required where the vehicle needs an operator’s licence and the driver drives for more than 4 hours that day. A tachograph can be used to make these records instead of paper. 
  • Postal vehicles over 3.5 tonnes: must fit and use a tachograph and keep records even where they’re exempt from the assimilated driving limits.

The mistakes that get operators caught

  1. Assuming “under 3.5 tonnes” means no rules. It usually means GB domestic rules, not none.
  2. Assuming “driving isn’t my main job” is an exemption. It is only ever one condition within a specific small-vehicle exemption.
  3. Treating a 561/2006 exemption as a working time exemption. They are separate regimes; one does not carry the other.
  4. Relying on an exemption without checking every condition. Distance radius, weight, purpose and “for hire or reward” all have to line up.
  5. Mixing PSV route types without rechecking the regime. A driver who does a sub-50 km regular service and then a longer or private-hire run can move between GB domestic and assimilated rules in the same day.
  6. Assuming a 3.5–4.25t electric van is exempt everywhere. The GB exemption does not extend to Great Britain–Northern Ireland journeys, which still need a tachograph.
  7. Forgetting records. Off-road driving and GB-domestic work can still have to be recorded.

How to be sure an exemption applies

Before relying on any exemption, confirm three things: the regime, the exact conditions, and the records you still owe.

  • Identify the regime first (out of scope, GB domestic or assimilated) rather than reaching straight for an exemption;
  • Check the precise conditions against current GOV.UK guidance weight, radius, purpose and whether it’s for hire or reward, all of which can change; 
  • Confirm what still applies before you stand the obligation down. Where there’s genuine doubt, operate to the rules until the exemption is confirmed.

This is exactly the kind of judgement that proper tachograph analysis is designed to support. Tacho Agent's role is to check the data and identify the infringements in it, so the question 'do the rules actually apply here?' is answered from the records, not from assumption.

External references

This article is provided for general guidance only and reflects our understanding of the rules as they apply in Great Britain as at the date shown on this page. It is not legal advice and should not be relied on as a substitute for advice tailored to your specific operation.
Drivers' hours, tachograph, working time and operator licensing rules are detailed and change over time, and some requirements differ in Northern Ireland and for international journeys. Always check the current guidance on GOV.UK and the underlying legislation on legislation.gov.uk, and consult your transport manager or a qualified compliance professional before acting.
To the fullest extent permitted by law, Tacho Agent Ltd accepts no liability for any loss arising from action taken, or not taken, in reliance on this article. Nothing here excludes or limits any liability that cannot lawfully be excluded, including for death or personal injury caused by negligence or for fraud. Use of this article is also governed by our Terms of Use.

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