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How often to download driver cards and vehicle units, how long to keep tachograph records, and how to analyse data and act on infringements.
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If you run vehicles fitted with a tachograph, you have a continuous legal duty to download the data, keep it, analyse it and act on what it shows. In practice, that means downloading driver cards at least every 28 days and vehicle units at least every 90 days, keeping the records available for inspection, identifying drivers' hours and working time infringements, debriefing drivers and holding a documented audit trail.
The download is the easy part. The duty the rules really care about, and the one operators most often miss, is analysing the data and managing the infringements it reveals. A box of downloaded files nobody has looked at is not compliance; it is evidence waiting to be used against you.
It is easy to assume that once the data is off the card and the unit and safely on a drive somewhere, the job is done. It isn't. Downloading simply preserves the record. The obligation that actually protects your licence is what you do next.
That duty to check, not just download, is written into the rules. Regulation (EU) No 165/2014 requires transport undertakings to make regular checks and ensure tachographs are used correctly, and Article 10 of Regulation (EC) No 561/2006 makes you responsible for organising drivers' work and checking compliance. GOV.UK puts it plainly: make regular checks of charts, manual records and digital data.
A compliant operator does all of the following, as a routine, every cycle:
Miss the last four and you have a filing system, not a compliance system.
Two intervals, and they are not the same. Driver cards must be downloaded at least every 28 days; vehicle units at least every 90 days. Both are maximum intervals - the latest you can leave it - not recommended frequencies.
You must download each driver's card at least once every 28 calendar days. The reason is practical as well as legal: a Generation 1 digital driver card holds only about 28 days of activity before the oldest data is overwritten and lost. An “average” day is treated as 93 activity changes, so on busy multi-drop work a generation 1 card can fill in fewer than 28 days.
Part-time and agency drivers are where operators get caught. The 28-day clock runs on the calendar, not on shifts worked, so a driver who only works two days a week still needs their card downloaded every 28 days. If a driver is going on leave, download before they go.
You must also download a card outside the 28-day cycle in these situations:
You must download the vehicle unit at least once every 90 calendar days. A vehicle unit holds roughly a year of average data before the oldest is overwritten, but don't let that lull you. The 90-day maximum (raised from 56 days in 2015) is the legal limit, and a vehicle off the road or away from base can still drift past it. The 90-day window is designed to let many operators fold the download into a scheduled safety inspection.
This is the single most common mix-up: 28 days for cards, 90 days for vehicles. If you remember nothing else, remember that the card interval is the shorter and more frequent of the two, because the card is where data is lost first.
The legal maximums are a backstop, not a schedule. Bring downloads forward where the risk of a gap is higher - for example where vehicles are hired in and out, where drivers are casual or agency, where the work is lots of short urban movements, or where you have a history of missing mileage or repeat infringements. The cost of an early download is nothing; the cost of a lost day of data can be a recordable offence.
Regardless of where you are in the 90-day cycle, you must download vehicle unit data:
When a digital or smart vehicle joins your fleet, lock it to your company card (“lock in”); when it leaves (sold or un-hired) lock out. Locking in protects your data so that the full record can only be downloaded with your company card. GOV.UK recommends it because, if a previous operator had locked in and you didn't, you can find you are unable to download your own data. Locking out signals the end of your interest in the vehicle. It is a small habit that prevents a nasty surprise at download time.
Different records, different retention periods. Underestimating these is the second classic mistake, because the headline “keep it for a year” figure only covers part of the picture.
You must be able to produce records to enforcement officers for 12 months. That is DVSA’s stated minimum for digital VU downloads, driver card downloads and any analogue charts used for drivers’ hours compliance. Keeping them longer is sensible. It costs almost nothing and it covers you if an issue surfaces later.
Records used to show compliance with the Road Transport (Working Time) Regulations 2005 must be kept for at least two years. Specifically, regulation 11 requires an employer to retain them for two years after the end of the period covered by the records. The 48-hour weekly average is calculated over a reference period that is normally 17 weeks (one fixed period each year runs to 18), and can be extended to 26 weeks by a collective or workforce agreement.
If tachograph data is the only place a driver's working time is recorded, treat the longer two-year working-time period as the figure that governs how long you keep it. In practice many operators simply retain all tachograph data for two years so they never have to decide which rule applies to which file.
If a unit fails and its data cannot be recovered, the repairing centre should issue a certificate of undownloadability. Keep it for at least 12 months. It is your evidence for why a gap exists.
“Tachograph records” is broader than the downloaded files. A complete record set includes:
Separately, drivers must carry records in the cab: the current day plus the previous 28 calendar days for domestic and AETR journeys under the assimilated rules, or 56 days for international journeys to and from an EU member country.
Manual entries fill the gaps the tachograph can't capture by itself. Drivers should make a manual entry or printout where, for example:
Missing or sloppy manual entries are a common source of apparent infringements and of missing mileage. A driver who forgets to insert their card, or who doesn't record a start location, can turn a perfectly legal day into a data gap that looks like unrecorded driving. Train drivers to make manual entries at the start of duty, not at the end of the month when the infringement report lands.
A manual entry is not a workaround for a forgotten card. If a driver has simply left their card at home, they should not drive an in-scope vehicle fitted with a digital or smart tachograph and then rely on manual records to cover the day. The manual-record allowance is for a card that is lost, stolen or malfunctioning, not one left on the kitchen table.
Missing mileage is the distance a vehicle has travelled that isn't accounted for by any driver's card record. In the data it shows up as a difference between the odometer reading at the end of one card record and the start of the next. The vehicle moved, but no card was in the slot to record who was driving or how.
It matters because, to an examiner, missing mileage looks like driving that someone is trying to hide. It can indicate a card not being used, a second driver, yard movements, a workshop test drive or a download gap. None of those is necessarily an offence. However, an unexplained gap is a red flag, and a documented explanation is the difference between a non-issue and an investigation.
To investigate, cross-match the vehicle unit data against the driver-card records, and against any other source you hold: telematics or fuel data, job sheets, workshop and hire records, gate or weighbridge logs. Where a vehicle was driven without a card, identify the driver, get a written explanation, debrief them, and decide whether it needs training, a system change or something more formal.
Whatever you find, record it against the analysis report. “Yard move” on its own proves nothing; “yard move, vehicle [reg], [driver], [date], shunting to the wash bay, confirmed by [manager]” is a closed item that will stand up under scrutiny.
This is the heart of the duty, and where outsourced analysis earns its keep. Analysis turns raw downloads into a clear list of what went wrong, why, and what you did about it.
Analysis software checks each driver's activity against the drivers' hours rules and the Working Time Regulations (driving time, breaks, daily and weekly rest, the 48-hour average, night work) and flags anything outside the limits. Good analysis distinguishes genuine infringements from data artefacts (a missed manual entry, a ferry, a card pulled at the wrong moment) so you spend your time on the breaches that count.
An identified infringement is the start of a short, repeatable process:
A debrief is not automatically a punishment. Sometimes the right answer is refresher training or better route and shift planning; what matters is that repeat issues show clear management escalation.
A Traffic Commissioner doesn't expect a perfect fleet, infringements happen. What they expect is a system: that you find infringements promptly, deal with them consistently, and can prove it. “We have a process and we follow it” is the single most powerful thing an operator can demonstrate. Ad-hoc checks and a spreadsheet someone updates when they remember do not pass that test.
Tachograph data is personal data about identifiable drivers, so the UK GDPR and the Data Protection Act 2018 apply. That doesn't make compliance complicated, but it does mean a few things are not optional:
The audit trail is the evidence that your process is real. “Good” looks like a dated, retrievable record showing, for each cycle:
If you can pull all of that for any driver and any week without a scramble, your audit trail is doing its job.
You don't have to guess what “good” looks like. DVSA’s Operator Compliance Audits guidance sets out, in black and white, the records an operator is expected to produce and it doubles as a checklist to test your own system against. On the tachograph side it asks for:
If you can produce all of that for a sample of drivers and vehicles covering the last few months, you are in good shape for a desk-based assessment, a site audit or a public inquiry. If you can't, that list is your gap list.
Your drivers’ hours and tachograph record feeds directly into the traffic-enforcement side of your Operator Compliance Risk Score (OCRS). DVSA uses OCRS to decide whose vehicles to stop and whose records to examine. A higher score means more attention. The score runs on a rolling three-year window, so today’s analysis discipline shapes the inspection pressure you’ll face for years.
DVSA can also ask for your drivers' hours records remotely (a desk-based assessment) or at the depot (a fleet assessment). Records they judge unsatisfactory push your score up. And if matters reach a public inquiry, the question is rarely whether one driver made one mistake. It is whether you had a system capable of preventing, finding and correcting mistakes. A demonstrable analysis process is the answer to that question.
Pulling it together, a well-run operation can answer yes to all of these:
The failures that come up again and again are predictable - and avoidable:
Monitoring download schedules, analysing every cycle and identifying the infringements in the data is what a tachograph analysis bureau does. For most operators the value isn't only the analysis itself; it's having that part done consistently, by people who do nothing else, so the evidence trail is ready and the driver debriefs and corrective action can be built on it. That removes both the routine burden and the risk that a quiet month becomes a problem nobody noticed. This is the service Tacho Agent provides.
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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