Compliance Health Check: Is Your Operation at Risk?

Running a transport business under a Restricted Operator Licence doesn’t make you exempt from the law — it simply means you’re operating vehicles for your own business, not for hire or reward.

But make no mistake: the DVSA and the Traffic Commissioner expect full compliance from all licence holders — regardless of size.

So how confident are you that your operation is compliant?

In this article, we walk you through a practical Compliance Health Check to assess whether your systems are robust — or whether you could be heading toward trouble.

✅ Why Do a Compliance Health Check?

A self-audit gives you the opportunity to:

• Spot weaknesses before the DVSA does

• Prepare for a potential roadside stop, desk-based assessment or Public Inquiry

• Prove you’re managing your responsibilities seriously

• Keep your vehicles, drivers, and business safe

A compliance health check is like a MOT for your back office — and it could be the difference between smooth running and licence revocation.

🚛 Section 1: Maintenance & Roadworthiness

Let’s start with the backbone of safe operations — keeping your vehicles roadworthy.

Key Questions:

• Do you have a documented maintenance schedule (e.g. every 6–10 weeks)?

• Are Preventive Maintenance Inspection (PMI) reports up to date and filed for at least 15 months?

• Do your reports include brake test results and torque checks (if applicable)?

• Are MOTs up to date — and passing first time?

• Have any defects been logged and rectified with supporting paperwork?

• Do you keep service and repair invoices on file?

Risk Warning Signs:

🚩 PMIs missed or no formal inspection plan

🚩 Repeated MOT failures or prohibitions

🚩 No repair evidence following reported defects

📋 Section 2: Daily Walkaround Checks

These checks are your first line of defence against roadside prohibitions.

Key Questions:

• Are walkaround checks carried out every day, before first use?

• Are defects recorded using a standard sheet or app?

• Are reports signed, dated, and retained for 15 months?

• Are reported defects investigated and signed off as repaired?

• Are drivers trained and briefed on how to report issues?

Risk Warning Signs:

🚩 No defect reports on file

🚩 Same issues reported multiple times without action

🚩 Driver not sure how to report a fault

🕒 Section 3: Tachograph and Driver Hours (If Applicable)

Even Restricted Operators can fall under EU tachograph rules. Are you compliant?

Key Questions:

• Are vehicles fitted with working tachographs if they’re in scope?

• Are driver cards issued and data downloaded every 28 days?

• Is vehicle unit data downloaded every 90 days?

• Are infringements reviewed and signed off with corrective action taken?

• Do you maintain driver hours summaries and tacho printouts?

Risk Warning Signs:

🚩 No downloads for months

🚩 Driver using vehicle without a valid card

🚩 Infringements go unaddressed

🚩 Operating without knowing whether you’re in-scope

👤 Section 4: Driver Management

Your drivers are your legal responsibility — even if that’s just you.

Key Questions:

• Are driver licences checked and logged every 6 months (or more often)?

• Is evidence of CPC training and qualifications available?

• Do you keep copies of licences, penalty points, and categories?

• Have drivers received training on defect checks, load security, and hours rules?

Risk Warning Signs:

🚩 No log of licence checks

🚩 Drivers unaware of legal responsibilities

🚩 Documents scattered or outdated

🗃️ Section 5: Record-Keeping & Filing

If the DVSA or TC asked for documentation today, how quickly could you produce it?

Key Questions:

• Are all records stored securely — digitally or on paper?

• Can you access PMIs, defect reports, and tacho logs quickly?

• Do you have a filing system by vehicle and driver?

• Are key policies (e.g. maintenance, defects, training) written down?

Risk Warning Signs:

🚩 No structure to filing

🚩 Missing or incomplete records

🚩 Can’t demonstrate who did what and when

💷 Section 6: Financial Standing

The TC expects you to maintain a financial buffer to show your business is stable.

Key Questions:

• Can you show proof of available funds (£3,100 for 1st vehicle, £1,700 for each additional)?

• Do you have up-to-date bank statements on file?

• Do you maintain a cash flow forecast or basic accounts?

• Have you submitted the correct financial evidence with any application or variation?

Risk Warning Signs:

🚩 Unable to prove available funds

🚩 Ignoring cash flow problems

🚩 Submitting outdated statements when applying

🏠 Section 7: Operating Centre

Where you keep your vehicle(s) must be approved and suitable.

Key Questions:

• Is your Operating Centre listed correctly on your licence?

• Do you have permission to use the site (e.g. written letter or lease)?

• Does the location have planning consent (or not require it)?

• Have there been any complaints from neighbours?

Risk Warning Signs:

🚩 Parking vehicle at home or on road

🚩 No documentation to prove site approval

🚩 Ignoring complaints or warnings

📄 Section 8: Policies, Procedures & Action Plans

Policies don’t need to be complex — just clear, simple, and relevant to your operation.

Key Documents:

• Maintenance policy

• Defect reporting procedure

• Record-keeping policy

• Training plan (even if informal)

• Responsibility statement (who manages compliance)

Having written processes shows the DVSA and TC that you’re operating with structure and intent.

✅ Compliance Health Check Scorecard

Give yourself a score out of 10 in each area:

Area	Score (0–10)
Vehicle maintenance
Daily walkaround checks
Tachograph compliance
Driver licence management
Record-keeping & filing
Financial standing
Operating centre control
Policies & procedures

TOTAL: /80

• 70–80: You’re in a strong position — maintain momentum

• 50–69: Room for improvement — act now to strengthen weak points

• Below 50: Urgent — you’re at real risk of DVSA enforcement or a Public Inquiry

🧰 What to Do If You’re at Risk

If your self-audit has exposed gaps:

• Prioritise urgent fixes: PMIs, driver checks, tachograph issues

• Organise your records: Set up digital folders or labelled binders

• Create a compliance calendar: Reminders for inspections, checks, downloads

• Seek support: Consider a transport consultant or external audit

• Train yourself or your team: Even one CPD session can improve understanding

⚖️ Final Thoughts

Compliance isn’t about fear — it’s about control, safety, and business survival.

By checking yourself before DVSA checks you, you’ll stay ahead of the game, protect your licence, and avoid the stress and cost of enforcement action.

Restricted Licence or not — the standards still apply. And now you’ve got a health check system to meet them.

Next in the series:👉 Understanding the OCRS Risk Score System