Logistics and transport · DVSA · WTD · Traffic Commissioner
Fatigue management for HGV and transport operators
Tachograph compliance is the legal floor. Traffic Commissioners and DVSA now expect a documented fatigue management system as part of your operator licence undertakings. Here is what that means in practice.
The hours rules at a glance
EC Regulation 561/2006 (retained UK law), updated April 2025.
Domestic-only operations follow slightly different rules. PSV (bus/coach) operators are subject to the same framework with separate sector guidance from the Traffic Commissioner.
What the regulations actually require
Drivers' hours rules
The core HGV hours rules are retained from EU law and enforced in Great Britain. They cap daily driving, mandate rest periods, and require tachograph recording. The April 2025 Drivers' Hours and Tachograph (Amendment) Regulations extended record-keeping to 56 days for international routes under AETR alignment. Roadside DVSA enforcement checks these records directly.
Working time, not just driving time
The Road Transport (Working Time) Regulations 2005 cover total working time, not just driving. Mobile workers (drivers who do not have a fixed place of work) are limited to an average 48-hour working week over a 17-week reference period, with a hard cap of 60 hours in any single week. This includes driving, loading, paperwork, and waiting time. Many operators track tachograph hours but not total working time - these are different figures. From 6 April 2026, Section 35 of the Employment Rights Act 2025 formally mandates working time record-keeping for all employers under the Working Time Regulations 1998. Records must be kept in "such manner and format as the employer reasonably thinks fit." RotaPulse produces those records automatically.
New tachograph hardware deadline
From 1 July 2026, all LGVs over 2.5 tonnes used on international journeys must be fitted with a second-generation Smart Tachograph. DVSA has confirmed enforcement will be immediate - prohibition notices, financial penalties, and OCRS (operator compliance risk score) impacts from day one. Average fitting lead times are 4-6 weeks, so operators who have not yet booked an approved fitter may already be cutting it close. This requirement applies to the recording device, not the hours rules themselves: your existing compliance profile covers the correct rest and duty cycle thresholds.
The DVSA and Traffic Commissioner expectation
When you hold an operator licence, you undertake to comply with drivers' hours rules. DVSA Earned Recognition and Traffic Commissioner public inquiries both look for a documented fatigue management policy - not just tachograph compliance. DVSA expects to see: a written policy setting limits on working hours and overtime, a system that records and monitors those limits, and a process for responding to breaches. An operator that cannot produce this evidence at a public inquiry is at risk of licence curtailment or revocation.
Questions Traffic Commissioners ask at public inquiries
These require documented evidence. Verbal answers do not satisfy a public inquiry.
- ›Do you have a documented driver fatigue policy?
- ›How do you monitor working time, not just driving time?
- ›What happens when a driver approaches or exceeds limits?
- ›Can you show records for the past 56 days (or 17-week working time reference)?
- ›How do you manage fatigue risk for early-start or multi-leg schedules?
The difference between tachograph compliance and fatigue management
Tachographs record driving time. They do not record total working time, loading time, or waiting time. They do not score cumulative fatigue across a sequence of shifts. A driver who does the maximum legal hours on five consecutive days, starting at 04:00 each morning, will have clean tachograph records. The HSE Fatigue Risk Index would flag several of those shifts as high risk.
DVSA and Traffic Commissioners understand this distinction. In public inquiry decisions, commissioners have noted the difference between compliant records and managed risk. An operator with clean tachographs but no fatigue scoring system is compliant, not safe. Those are not the same thing for licensing purposes.
How RotaPulse helps
WTD working-time tracking alongside FRI scoring
RotaPulse scores every shift with the HSE Fatigue Risk Index and enforces the UK Road Transport WTD rules through a dedicated compliance profile: 60h weekly hard cap, 90h fortnightly limit, and a 17-week rolling average check against the 48h reference. Both FRI risk and WTD breaches appear on the same Compliance Dashboard.
PDF compliance report for public inquiries
Export a dated PDF covering any period. It shows each driver's risk scores, plain-English flags, and the engine version used. Accepted as evidence that you have an active, documented monitoring system.
Plain-English flags for transport managers
Instead of raw numbers: Early start after short rest, Sixth consecutive day, Working week over 55 hours. Your transport manager can act on these without reading the regulations themselves.
Rota fixer for minimum-change corrections
When a pattern triggers a flag, RotaPulse proposes the smallest adjustment that resolves it: move the start time, reduce the shift length, or add a break. No AI - deterministic and re-validated by the engine.
What RotaPulse does not do
RotaPulse scores shift patterns against the HSE FRI algorithm and tracks working time. It does not read tachograph data directly, substitute for your tachograph analysis software, or guarantee operator licence compliance. It produces the documented fatigue monitoring evidence that sits alongside your tachograph records.
Build your fatigue evidence file before the inquiry
Free plan covers one week for up to 10 drivers. No credit card. Export a PDF the same day.