Operator Licence Compliance and the Maintenance Records That Keep You Legal

Every goods vehicle operator licence comes with an undertaking to keep driver defect reports, safety inspection records and routine maintenance records for 15 months. Under section 26 of the Goods Vehicles (Licensing of Operators) Act 1995, a traffic commissioner can revoke, suspend or curtail a licence when an undertaking hasn't been kept.

The records are your evidence that the vehicles were kept roadworthy, and the responsibility stays with the operator even when a garage or contractor does the inspections. DVSA's Guide to maintaining roadworthiness sets out how it expects that system to run, and most of the detail below comes from it. The rules described here are for operators in Great Britain; Northern Ireland licenses goods vehicle operators under its own 2010 Act, through the Department for Infrastructure.

Know what your licence undertakings commit you to

Operators give a set of undertakings when they apply for a licence, and traffic commissioners expect them to be kept for the life of the licence. A Deputy Traffic Commissioner's decision from June 2026 sets out the maintenance undertakings in their standard wording:

• vehicles and trailers will be kept fit and serviceable

• drivers will report promptly any defects or symptoms of defects that could stop a vehicle or trailer being operated safely, and those defects will be promptly recorded in writing

• records of driver defect reports, safety inspections and routine maintenance will be kept for 15 months and made available on request

Your licence carries its own full list, which also covers areas such as drivers' hours, tachographs and vehicle numbers, and it may include extra undertakings or conditions. Check the version you hold.

Reporting changes is a separate duty. GOV.UK's goods vehicle operator licensing guide says relevant changes, such as a new transport manager or a different operating centre address, must be reported to the traffic commissioner within 28 days, along with anything your licence conditions require you to report. If you change maintenance contractor, check whether your conditions cover it.

Section 26 of the 1995 Act gives the commissioner power to act where "any undertaking recorded in the licence has not been fulfilled". Prohibitions count as well. A prohibition under section 69 or 70 of the Road Traffic Act 1988 on a vehicle you own, issued in the previous five years, is a separate ground for revocation, suspension or curtailment.

Build a complete record set for every vehicle and trailer

DVSA's guide expects each vehicle and trailer file to hold several linked records, with the safety inspection sheet as only one of them. These are the ones it names.

Electronic systems are fine. If an inspection report is held electronically you don't need to keep the paper copy, but the guide expects the system to be tamper-proof, to keep a clear audit trail and to produce a hard copy when asked.

On older fleets, check tyre ages carefully. Tyres more than 10 years old must not be used on the front steered axle of an HGV, and a tyre that reaches 9 years should be flagged at the safety inspection.

Set safety inspection intervals

There's no single legal interval. DVSA's guide gives bands based on how hard the vehicle works, and you choose where your fleet sits by time, mileage or both.

Source: DVSA Guide to Maintaining Roadworthiness, section 4.2 (page updated 28th April 2025)

Two rules sit on top of the bands. Any vehicle or trailer 12 years or older needs a safety inspection at least every 6 weeks, whatever work it does. And a trailer you run that's outside your own inspection schedule, such as one belonging to another company, shouldn't go more than 13 weeks between inspections.

Plan the dates at least 6 months ahead on a forward planner. The guide expects each inspection to happen in the ISO week it's booked for, so a PMI that slips into the next week shows up as late on your own records. If your fleet's work changes (new contracts, heavier loads, more off-road), review the interval straight away.

Prove brake performance at every inspection

DVSA expects every safety inspection to include a brake performance assessment, and the result belongs on the file with the inspection sheet. The guide accepts three ways of doing it.

A laden test on a calibrated roller brake tester is the method DVSA calls most effective. The vehicle can go on the rollers up to 14 days before the inspection date. 

Some vehicles are hard to load for a test, for example those that normally run well below their permitted axle weights, or that carry livestock or certain dangerous goods. For those, the guide accepts an unladen roller brake test unless the vehicle's construction or weight rules it out, with the reasons written up in a risk assessment.

On trailers, an electronic braking performance monitoring system (EBPMS) can do the job. Its report has to be evaluated before every safety inspection, then signed and attached to the inspection paperwork. EBPMS is only available for trailers at present, and it doesn't replace the brake test at the annual test.

Without EBPMS, DVSA expects at least four laden brake tests a year, spread evenly, and the annual test can count as one of them. At the inspections in between, an approved and calibrated decelerometer can measure overall brake performance, with brake temperatures taken before and after: the final readings should be clearly higher than the first. Decelerometers can't be used to test trailer brakes.

Whichever method you use, file the printout, report or readings with the inspection record it belongs to.

Use parts records to make the file stand up

The guide doesn't list parts as a record of their own, but several of its requirements only work if you know what was fitted. Emissions systems are to be repaired to the manufacturer's standards. Recalls need evidence of rectification, and ADAS repairs and calibrations should be fully documented. 

A line on a job card that says "replaced brake pads" records the work; a part number and an invoice let someone check it.

None of the following is a named legal requirement. It's practice that makes the records you are required to keep harder to question:

• the part number and brand against each repair line on the job card

• the approval standard where one applies, such as UN Regulation 90 (ECE R90) for replacement brake linings, discs and drums, which exists so aftermarket parts match the braking performance of the originals

• the supplier invoice filed with the job card, or referenced from it in your maintenance system

• tyre age recorded when a tyre is fitted, so the fleet-wide tyre record stays current

Start with braking parts, since brakes are assessed at every safety inspection and every annual test. Our braking range covers brake discs, brake drums, calipers, slack adjusters, pad and disc fitting kits and brake chambers and actuators, with the rest of the brake system range in one place.

Monitor your system before DVSA does

DVSA scores operators on their compliance record, and you can see your own score. The Operator Compliance Risk Score (OCRS) draws on three years of data from annual tests, roadside inspections, site visits and desk-based assessments. 

It gives you a red, amber or green band for roadworthiness and another for traffic offences such as drivers' hours, and DVSA uses it to decide which vehicles to stop at the roadside. You can check it, along with test histories and roadside reports, through DVSA's online service.

The guide also suggests reading your own inspection reports for patterns. A lot of repeat faults can mean inspections are too far apart, walkaround checks aren't thorough, or defects aren't being fixed quickly. Very few defects can mean the opposite problem: intervals that are too long, or inspections that aren't finding things. Annual test results deserve the same attention, including vehicles that needed work on the day to pass, and any prohibitions or inspection notices.

If a contractor does your inspections, their first-time pass rate at the annual test is the obvious figure to watch, and the guide expects you to talk to them regularly and deal with problems quickly. The legal responsibility for the vehicle's condition doesn't move to them.

Operators that have held a licence for at least two years, with no regulatory action from a traffic commissioner beyond a formal warning in that time, can apply for DVSA earned recognition. Members need a DVSA-validated IT system that tracks maintenance and drivers' hours KPIs over 4-week periods and tells DVSA when they're missed, plus an audit by an authorised provider on joining and every two years after. In return, the DVSA guide says enforcement staff are "less likely to visit your premises" and vehicles are "less likely to be stopped at the roadside for inspections".

Understand what happens when records fall short

DVSA findings, such as prohibitions or an assessment of the operator's systems at a site visit or from the desk, can lead a traffic commissioner to call the operator to a public inquiry. Under section 26 of the 1995 Act, the possible outcomes include revoking, suspending or curtailing the licence, and transport managers can lose their good repute.

In November 2025 a Deputy Traffic Commissioner revoked the licence of RMK Haulage Ltd after a public inquiry in Cambridge. A DVSA assessment had been marked unsatisfactory in many areas. Among the findings, vehicles weren't receiving safety inspections at the required eight-week intervals, and the former transport manager said the director had asked him to remove records that might show vehicles in use on days they were supposed to be in for inspection. 

The Deputy Commissioner said "the creation of false maintenance records which he passed to his transport manager does not reflect well on him."

The company and its director were disqualified from holding an operator licence for 12 months, and the transport manager lost his good repute and was disqualified from acting as a transport manager for 12 months. Read the full decision summary on GOV.UK.

Run a file check on one vehicle this week

Pick one vehicle and one trailer and check their files against the guide. You'll find any gaps while there's still time to fix them:

• Safety inspection records go back at least 15 months, at the planned interval, each one signed off as roadworthy

• Every inspection has a brake performance result attached

• Driver defect reports for the same period show how and when each defect was put right

• The forward planner is booked at least 6 months ahead, and any vehicle or trailer aged 12 years or more is on a 6-week interval or shorter

• Tyre ages are recorded, with nothing over 10 years old on a steered axle

• Wheel re-torque checks are recorded wherever a wheel has been off

• For the last brake job, you can show the part numbers fitted and the invoice

• If a contractor does your inspections, the written contract is on file

If the parts trail is where the file falls down, start putting it right on the next job. For brake work, see our brake system range and air brake parts. If you're unsure which part fits, call 01527 68279 with the chassis number.

Frequently asked questions

How long do you have to keep HGV maintenance records?

At least 15 months for safety inspection records, repair records and driver defect reports. Keeping those records for 15 months, and producing them on request, is also one of the standard undertakings on an operator licence. DVSA recommends keeping nil defect reports for at least 3 months.

How often does an HGV need a safety inspection?

It depends on the work. DVSA's guide gives bands from every 10 to 13 weeks for light, easy work down to every 4 weeks off road, and any vehicle or trailer 12 years or older needs one at least every 6 weeks.

Do you need a brake test at every safety inspection?

DVSA expects a brake performance assessment at every safety inspection. That can be a roller brake test, an EBPMS report on trailers, or a decelerometer test, with at least four laden brake tests a year where EBPMS isn't used.

If a contractor maintains our vehicles, who's responsible?

You are. The guide says operators remain responsible for the condition of vehicles and trailers inspected or maintained for them by contractors, and you need a written contract with them on file.

Resources

DVSA: Guide to maintaining roadworthiness | Goods Vehicles (Licensing of Operators) Act 1995, section 26 | Traffic commissioner decision: Walls Truck Services Ltd (30th June 2026) | GOV.UK: Goods vehicle operator licensing guide | GOV.UK: Operator Compliance Risk Score, how you're scored | GOV.UK: DVSA earned recognition, join the scheme | GOV.UK: Haulage operator loses licence following extensive failures | Goods Vehicles (Licensing of Operators) Act (Northern Ireland) 2010