Driver Record-Keeping for Restricted Licence Holders: Avoiding Common Mistakes

If you operate under a Restricted Operator Licence, you’re responsible for your drivers’ compliance — even if you don’t have a Transport Manager on board. That includes keeping proper driver records.

But many small fleet operators fall into the trap of:

• Not knowing what records to keep

• Keeping incomplete or outdated information

• Not storing records securely or for long enough

• Being unprepared when DVSA requests evidence

In this post, we’ll break down exactly what driver records you need to keep, how long to keep them, and how to avoid the most common mistakes made by Restricted Licence holders.

Why Driver Record-Keeping Matters

Even if you only run 1 or 2 vehicles, you still have to prove that:

• Drivers are licensed and legal

• Any working time rules are being followed

• Driver hours are managed properly (where tachographs apply)

• Walkaround checks are completed daily

• Defects are reported and addressed

• Your operation is controlled and monitored

Failing to do so can result in:

• Fixed penalties for drivers

• Prohibitions or points on your licence

• A DVSA warning or audit

• A call to Public Inquiry

• In extreme cases, revocation of your licence

Core Driver Records You Must Keep

Here’s what every Restricted Licence holder should maintain for each driver, whether employed, casual, agency or family:

✅ 1. Copy of Driving Licence

• Clear photocopy or scan (front and back)

• Check the licence is valid for the vehicle class (e.g. C1, C)

• Check for endorsements or disqualifications

Retention: Keep while the driver is active + 6 years after leaving

✅ 2. Driver Licence Checks (DVLA)

• Use DVLA’s online check service or a checking agency

• Should be done at least every 6 months (every 3 months is best)

• Record:

  • Date checked

  • Who checked it

  • Result (points, categories, status)

Tip: Keep a Licence Check Log with dates and findings for each driver.

✅ 3. Driver Declaration Form

A signed form confirming:

• They will report any licence changes

• They’ll complete daily walkaround checks

• They’ll follow your company’s transport procedures

Retention: While driver is active

✅ 4. Daily Walkaround Check Records

• One report per day per vehicle

• Can be paper or digital

• Should show:

  • Vehicle reg, date, time

  • Driver’s name/signature

  • Any defects found (and action taken)

Retention: Minimum of 15 months

✅ 5. Defect Report Forms

• Any reports made outside of daily checks (e.g. mid-shift faults)

• Should be signed off when resolved

• Essential to prove vehicles are safe and monitored

Retention: 15 months minimum

✅ 6. Tachograph Data (if applicable)

If you use vehicles in-scope of EU drivers’ hours:

• Download driver card data every 28 days (minimum)

• Store infringements and rectification reports

• If using GB domestic rules — keep duty records (see below)

✅ 7. GB Domestic Hours / Working Time Records

If tachographs don’t apply, you must still keep:

• Daily log of hours on duty

• Breaks taken

• Driving time

• Rest periods

Retention: 2 years recommended

✅ 8. Training Records (if applicable)

• Any in-house or external training (e.g. CPC, walkaround checks)

• Driver induction forms

• Toolbox talks or safety briefings

Retention: Keep for 6 years if possible

✅ 9. Disciplinary Records or Infringement Warnings

• Records of any driver breaches or enforcement

• Notes of verbal warnings or improvement plans

• Signed records of action taken

Retention: 6 years

✅ 10. Employment / Contractor Information

• Start and end dates

• Right to work checks

• Contract or agreement (if self-employed or agency)

Retention: 6 years for HMRC and legal compliance

Top 7 Mistakes Restricted Operators Make

Mistake	Why It’s a Problem
❌ Not checking licences regularly	Driver may be banned or unqualified
❌ No walkaround check evidence	Can’t prove daily safety checks are happening
❌ Incomplete tachograph data	Risk of DVSA fixed penalties and licence action
❌ Missing or outdated driver files	Fails basic audit checks
❌ Over-reliance on verbal agreements	No paper trail in disputes
❌ No record of defect rectification	Breach of safety obligations
❌ No GB domestic hours records	Leaves a major gap in compliance proof

Simple Filing System for Driver Records

Whether paper or digital, use a consistent structure:

Per Driver Folder (or section):

pgsql

Copy

📁 John Smith ├── Driving Licence Copy ├── DVLA Check Log ├── Signed Declarations ├── Walkaround Checks (link to vehicle folder) ├── Tachograph / Hours Records ├── Training Certificates ├── Disciplinary Records ├── Contract / Terms

Tip: Link daily defect reports and tacho data to the vehicle as well as the driver for traceability.

Digital Tools to Help You

Task	Free/Low-Cost Tool
Licence checks	DVLA View Driving Licence
Form signing	DocuSign, Adobe Fill & Sign
Hours recording	Spreadsheet or driver logbook
Walkaround checks	SmartCheck, Truckfile, R2C (paid apps)
File storage	Google Drive, OneDrive, Dropbox

Start with a spreadsheet tracker and scanned documents — and grow from there.

What DVSA Wants to See

During a DVSA audit, you’ll be asked to produce:

• Driver licence status and checks

• Evidence of walkaround checks

• Defect resolution trail

• Hours/duty records (domestic or EU)

• Driver training or declarations

All within a reasonable timeframe — typically 10–15 minutes per request.

Conclusion

Driver record-keeping might seem overwhelming — but with a bit of structure and discipline, it becomes a manageable part of your weekly routine.

The key is to be proactive, consistent, and transparent. Whether you employ drivers or do all the driving yourself, the records you keep show whether you’re serious about road safety and legal compliance.

Next in the series:👉 Understanding Tachograph Responsibilities Under a Restricted Licence