Are You Audit-Ready? A Practical Guide for Operator Licence Holders

Legal Responsibilities of Licence Holders – Part 6

Introduction

One of the most overlooked threats to any commercial vehicle operator — especially those with a Restricted Operator Licence — is the dreaded DVSA or Traffic Commissioner audit.

Audits can happen at any time, with or without warning. You might be flagged due to:

• A roadside prohibition

• A customer complaint

• A licence variation application

• A random check by the DVSA

• A follow-up to a previous warning

Regardless of how it starts, the big question is:Would you pass a full audit of your transport compliance system today?

In this detailed guide, we’ll show you exactly what it means to be audit-ready — and how to get there, stay there, and sleep easy at night knowing your Operator Licence is protected.

Table of Contents

1. What Is an Operator Licence Audit?

2. Why Audits Happen (Even to Good Operators)

3. Key Audit Areas

4. Common Reasons Operators Fail Audits

5. Self-Audit Checklist

6. Audit Readiness – Documents You Must Have

7. Creating an Audit Trail

8. What to Expect During a DVSA or OTC Audit

9. Tools and Templates to Help

10. How JS Transport Solutions Prepares You to Pass

1. What Is an Operator Licence Audit?

An audit is a formal inspection of your systems, processes, and records to assess how well you're meeting your legal undertakings as a licence holder.

It may be conducted by:

• A DVSA examiner

• A Traffic Commissioner’s enforcement officer

• An independent auditor (e.g. following a PI or request)

You’ll be judged on whether your systems:

• Comply with the Operator Licence conditions

• Keep road users safe

• Show a culture of compliance

Audits may be on-site, remote, or part of a Public Inquiry. The findings can lead to:✅ A clean bill of health⚠️ Warnings or improvement recommendations❌ Suspension, curtailment, or revocation of your licence

2. Why Audits Happen (Even to Good Operators)

Many Restricted Licence holders believe they’ll never face scrutiny. But audits are common and can arise for reasons like:

• DVSA encounter reports (e.g. roadside stop showing defect)

• Failure to submit documents after a warning

• Missing safety inspection records

• Licence variation applications (e.g. new vehicles or centres)

• Referrals from local authorities or neighbours

• Random spot checks

You don’t have to be a bad operator — just disorganised — to land in hot water.

3. Key Audit Areas

Auditors will typically assess the following:

🧰 Vehicle Maintenance

• Inspection intervals and planner

• Condition of safety inspection reports

• Defect reporting and repairs

• MOT history and preparation

• Roadworthiness file completeness

🚛 Driver Management

• Daily walkaround checks

• Licence checks and validity

• CPC qualification tracking

• Driver conduct records

• Tachograph use and data downloads (if applicable)

🗂️ Records and Admin

• Document retention (15+ months)

• Operating centre evidence

• O-Licence details and correspondence

• Financial standing documentation

• Proof of compliance with undertakings

4. Common Reasons Operators Fail Audits

🚫 Missing inspection records

🚫 Incorrect or backdated safety intervals

🚫 No proof of repairs after defects

🚫 No evidence of licence checks

🚫 Tachograph data not downloaded

🚫 Operator unaware of basic responsibilities

🚫 No system to monitor compliance

Even one of these can trigger a formal warning, or worse, a Public Inquiry.

5. Self-Audit Checklist

Use this as your internal monthly audit tool.

✅ Maintenance planner covers 6–13 week intervals

✅ All PMI reports are complete, signed and dated

✅ Defect reports and repair evidence are in place

✅ Daily walkaround checks are logged

✅ Driver licences checked and recorded

✅ CPC records for all drivers on file

✅ Tachograph data downloaded on schedule

✅ Infringement reports debriefed and signed

✅ Financial standing proof available (bank statements)

✅ Operator Licence documents current and accurate

✅ Operating centre usage complies with licence

✅ All records stored for at least 15 months

✅ Material changes (e.g. business address, directors) notified

Score yourself out of 12. If you're below 10 — you're not audit-ready.

6. Audit Readiness – Documents You Must Have

You must be able to produce these during an audit or within 7 days of request:

Document	Retention Period
Safety inspection reports	15 months
Defect reports and repairs	15 months
Maintenance planner	15 months
Driver licence check records	12 months (best practice: 3 years)
CPC training certificates	Duration of employment + 1 year
Tachograph data	12 months
Infringement debriefs	15 months
Financial proof (bank statements)	Most recent 3 months minimum
Insurance documents	Current + previous 6 years
Operating centre leases or ownership	Duration of use

7. Creating an Audit Trail

An audit trail is a clear sequence of documents showing:

1. A task was carried out

2. It was checked or reviewed

3. Action was taken if issues were found

4. Everything is signed and dated

For example:

• A defect is found during a daily check

• Driver logs it on a defect sheet

• Vehicle is taken off-road and repaired

• Workshop signs off the repair

• Operator signs off the defect log

• Record stored for 15 months

This shows you're not just ticking boxes — you're actively managing compliance.

8. What to Expect During a DVSA or OTC Audit

Audits vary depending on who performs them, but they typically include:

• Introductory interview

• Review of your systems and files

• Random checks of vehicle records

• Evidence of driver management

• Questions about your knowledge and responsibilities

• Action plan if failings are found

You may receive:

• A report with pass/fail

• Recommendations for improvement

• A referral to the Traffic Commissioner

• An invitation to attend a Public Inquiry

9. Tools and Templates to Help You Pass

We recommend the following tools for audit preparation:

📝 Monthly Audit ChecklistTrack your key documents and compliance tasks

📄 Document Retention ScheduleKnow exactly how long to keep each file

📆 Maintenance Planner TemplatePlan and log PMIs for each vehicle

🧾 Defect Report SheetsDaily checks + driver signatures

🗃️ Compliance File IndexOrganise records into easy-access folders

📊 Tacho Analysis SummaryKeep on top of driver hours infringements

All of these are included in our Audit-Ready Toolkit — available free to JS Transport Solutions clients.

10. How JS Transport Solutions Prepares You to Pass

We’ve helped dozens of operators prepare for audits, avoid enforcement, and stay compliant.

Here’s what we offer:

✅ Compliance File Setup

We create or tidy up your entire operator records system.

✅ Document Templates

Customised documents tailored to your operation.

✅ Monthly Audit Reviews

We check your key records and highlight issues before DVSA finds them.

✅ Pre-Audit Mock Inspections

We walk you through a dry run of an audit.

✅ On-Call Advice

Got an urgent DVSA notice or request? We respond and help you act fast.

✅ Public Inquiry Preparation

If it comes to it, we’ll help you build your defence and prepare documentation.

Our motto: Fix it before it’s found.

Conclusion

An audit shouldn’t be a crisis — it should be something you’re ready for at all times.

Being audit-ready is not about perfection — it’s about having the right systems, processes, and evidence in place to prove that you're operating safely, legally, and responsibly.

If you’re a Restricted Operator Licence holder without a Transport Manager, you carry the full legal burden of compliance. Don’t leave your licence to chance.

Ready to Get Audit-Ready?

📞 Book a free compliance health check with JS Transport Solutions today.We’ll review your current status, highlight any gaps, and create a plan to keep you compliant.

👉 Visit www.jstransport.uk

Next in the series: [What Happens at a Public Inquiry – and How to Avoid One]