Guide 8. How to Appoint and Manage a Transport Manager

When it comes to running a commercial vehicle operation, one of the most vital appointments you’ll make is that of a Transport Manager. Whether your operation is large or small, having a qualified and competent individual overseeing your transport operations is not just good practice—it’s a legal requirement under the Operator Licensing system in the UK and across the EU.

In this blog, we’ll explore the process of appointing a Transport Manager, managing their role effectively, understanding the key legal obligations and responsibilities, and knowing what to do when a Transport Manager leaves your operation. We’ll also delve into the differences between internal and external Transport Managers and when each type is appropriate.

1. What is a Transport Manager?

A Transport Manager (TM) is the professionally competent individual responsible for ensuring that a company’s transport operations are conducted in accordance with the law. Their core duty is to maintain compliance with the conditions of the Operator’s Licence issued by the Traffic Commissioner.

Under the Goods Vehicles (Licensing of Operators) Act 1995 and Regulation (EC) No 1071/2009, a business that operates heavy goods vehicles (HGVs) or public service vehicles (PSVs) must have access to a professionally competent Transport Manager.

2. Types of Transport Managers: Internal vs External

Internal Transport Manager

An internal Transport Manager is typically a full-time or part-time employee who works directly within the organisation. They are embedded in the day-to-day operations and are often involved in strategic planning, vehicle procurement, compliance, and staff training.

Advantages:

• Greater control over daily operations

• Consistent oversight

• Can integrate better with company culture and policies

External Transport Manager

An external Transport Manager, often called a “CPC Holder for Hire,” is a consultant who provides their services under contract. This is typically suitable for smaller operations with limited transport activities.

Advantages:

• Cost-effective for smaller businesses

• Brings wide industry experience

• Can be more flexible

Note: External TMs can only act for up to four operations with a combined total of no more than 50 vehicles, unless otherwise authorised.

3. Legal Obligations When Appointing a Transport Manager

When you apply for or vary an Operator’s Licence, you must declare your nominated Transport Manager(s) and demonstrate their:

• Professional competence – evidenced by a Certificate of Professional Competence (CPC)

• Good repute – no serious convictions or past failings

• Effective and continuous management – must be genuinely involved in the operation

Key Legal Requirements:

• Must be formally nominated on the Operator’s Licence

• Must have a clear agreement (especially for external TMs)

• Must meet hours-per-week engagement expectations:

  
  

  • 2–5 vehicles: ~8 hours/week

  • 6–10 vehicles: ~12 hours/week

  • 11–14 vehicles: ~20 hours/week

  • 15+ vehicles: ~full-time

  
  

If you’re appointing an external TM, you’ll need to provide a copy of the contract and get approval from the Traffic Commissioner.

4. Responsibilities of a Transport Manager

Transport Managers play a central role in ensuring that transport operations are safe, efficient, and compliant. Their main responsibilities include:

Compliance Monitoring

• Ensuring that the operator adheres to all licence conditions

• Monitoring vehicle maintenance schedules

• Checking driving hours, working time rules, and tachograph records

Safety and Maintenance

• Overseeing regular vehicle inspections

• Ensuring defects are reported and rectified promptly

• Keeping detailed maintenance records

Driver Management

• Ensuring drivers are properly licensed and trained

• Monitoring conduct and performance

• Providing induction and refresher training

Record Keeping

• Keeping records for a minimum of 15 months as required

• Ensuring documentation is accurate and up to date

  
  

Reporting and Communication

• Communicating with the Traffic Commissioner when required

• Reporting significant issues (e.g., collisions, compliance failures)

• Advising on improvements or corrective action

Neglecting these responsibilities can result in regulatory action, including public inquiries, fines, and the loss of the Operator’s Licence.

5. Appointing a Transport Manager: Step-by-Step

Step 1: Identify Operational Needs

Evaluate how many vehicles and depots you operate to determine the necessary level of oversight. This will influence whether you need an internal or external TM.

Step 2: Verify Competence

Ensure the candidate holds a valid CPC and has a clean record. For external TMs, check they are not over-committed with other businesses.

Step 3: Draft an Agreement

Create a written agreement detailing the TM’s duties, working hours, authority, and reporting lines. For external TMs, this is essential for Traffic Commissioner approval.

Step 4: Apply to the Traffic Commissioner

Submit a variation or new licence application with TM details. Include:

• The TM’s CPC certificate

• Evidence of repute (e.g., DBS check if required)

• Contract (if external)

Step 5: Onboarding

Once approved, introduce the TM to key staff, provide access to operational systems, and clarify their compliance monitoring duties.

6. Managing the Transport Manager Effectively

Provide Resources and Authority

Ensure your TM has the tools and authority to carry out their role. This includes access to:

• Fleet data

• Tachograph systems

• Driver records

• Maintenance logs

Regular Reviews and Audits

Meet with your TM regularly to review compliance KPIs. Conduct internal audits and follow up on any non-conformance.

Training and Development

Encourage continuous professional development. Legislation and best practices change, and a well-informed TM will help your operation stay ahead.

Collaboration and Integration

The TM should be involved in senior management discussions related to fleet strategy, budgeting, and recruitment. They are not just an admin function—they’re your compliance backbone.

7. When the Transport Manager Leaves

The departure of a TM is a serious matter with legal implications. Here’s what you must do:

Immediate Notification

You must inform the Traffic Commissioner within 28 days of a Transport Manager leaving their post.

Temporary Arrangements

If possible, appoint an interim TM—this may require urgent recruitment or temporarily hiring an external TM.

Variation of Licence

Apply to vary your licence with the new TM’s details and supporting documentation. If no replacement is available, you may request a grace period.

Grace Periods

The Traffic Commissioner may allow up to 6 months, extendable to 9 months, for you to appoint a replacement. You must apply formally and justify why the extension is necessary.

Warning: Operating without a qualified TM and no grace period can lead to suspension or revocation of your licence.

8. Common Pitfalls to Avoid

• Token Appointments: Appointing a TM who is not genuinely involved is illegal and may result in licence revocation.

• Overloading External TMs: Ensure external managers are not managing more vehicles than allowed.

• Poor Record Keeping: Missing or inaccurate records can lead to enforcement action.

• Lack of Communication: TMs must be kept informed of all transport activities and changes.

• Failure to Notify Changes: Not informing the Traffic Commissioner of staff changes is a breach of your obligations.

9. Best Practices for Long-Term Success

• Invest in Compliance Tools: Use fleet management software to simplify monitoring.

• Foster a Compliance Culture: Empower drivers and supervisors to support TM goals.

• Schedule Regular TM Reviews: Use KPIs and performance targets to assess effectiveness.

• Plan for Succession: Have contingency plans in place in case your TM leaves.

Conclusion

Appointing and managing a Transport Manager is a cornerstone of a compliant and efficient transport operation. Whether you opt for an internal or external TM, it’s vital to understand their responsibilities, support their work, and stay on the right side of the law.

Transport Managers are more than a regulatory requirement—they are strategic assets who help your business stay safe, legal, and profitable.

Proper recruitment, onboarding, and ongoing collaboration will ensure you meet your legal obligations and build a robust, well-managed transport operation.