How to Manage Driver Compliance Without a Transport Manager

stuart47304
Jul 15
5 min read

Legal Responsibilities of Licence Holders – Part 10

Introduction

If you’re operating under a Restricted Operator Licence, you are not legally required to employ a Transport Manager. But here’s the catch — the responsibilities that a Transport Manager would normally oversee still exist. And as the licence holder, you are personally responsible for ensuring that your drivers stay compliant with UK transport law.

That includes:

Daily walkaround checks
Licence and Driver CPC validity
Driver conduct and fitness
Tachograph compliance (where applicable)
Recordkeeping and monitoring
Driver training and inductions
Responding to infringements and incidents

Many small operators assume that because they only run a few vehicles, they’re not at risk. But this is a dangerous myth. Most Public Inquiries involving Restricted Licence holders come down to poor driver management.

This post shows you exactly how to manage driver compliance without a Transport Manager, using practical systems, templates, and routines that anyone can implement — even if you're a sole trader juggling multiple jobs.

The Legal Responsibilities You Still Carry
Why Driver Compliance Is the Most Common Pitfall
Daily Walkaround Checks: What You Must Do
Checking Driver Licence and CPC Status
Setting Rules for Driver Conduct
Managing Tachograph & Hours Compliance (if applicable)
Keeping the Right Records
Creating a Driver Induction and Training Plan
Monthly Driver Compliance Checklist
How JS Transport Solutions Can Help

1. The Legal Responsibilities You Still Carry

If you hold a Restricted Operator Licence, the law expects that you, as the licence holder, will still:

✅ Monitor and record vehicle condition

✅ Ensure drivers perform walkaround checks

✅ Check that all drivers are properly licensed and qualified

✅ Enforce safe driving behaviour

✅ Comply with driver hours and tachograph rules (if required)

✅ Maintain a complete audit trail of driver activity and checks

There is no excuse for ignorance — you signed undertakings agreeing to these conditions, and the Traffic Commissioner will hold you to them.

2. Why Driver Compliance Is the Most Common Pitfall

DVSA roadside stops and Traffic Commissioner reports show that driver issues account for more compliance failings than anything else.

The most common failures are:

No evidence of daily vehicle checks
Driving with expired CPC
No proof of licence checks
Repeated hours infringements
Failure to analyse tachograph data
No induction or training documentation
Poor driver behaviour (rude to inspectors, safety risks)

These aren’t just procedural failings — they are risk factors that endanger the public and erode your licence’s credibility.

3. Daily Walkaround Checks: What You Must Do

Every driver must complete a pre-use walkaround inspection of their vehicle before starting their journey.

What needs checking?

Lights, indicators and horn
Brakes and air leaks
Tyres, wheels and mirrors
Windscreen, wipers and washer fluid
Fuel and oil levels
Load security and bodywork
Number plates and reflectors

What should you have?

A daily defect report form (paper or digital)
A process for reporting defects
Evidence of repairs
At least 15 months of retained defect reports

Pro Tip: Check 2–3 completed defect reports every week to ensure compliance.

4. Checking Driver Licence and CPC Status

You must ensure that each driver:

Holds the correct category of licence
Has a valid and current Driver CPC (if required)
Is medically fit to drive

Best Practice:

Conduct a licence check every 6 months (or quarterly for higher risk)
Use the DVLA online portal with driver consent
Record check date, result, expiry, and any endorsements
Keep copies or screenshots in the driver’s file

For CPC, keep:

Certificate of completion (DQC card)
Record of 35 hours completed in the current 5-year cycle

5. Setting Rules for Driver Conduct

Even if you’re a small operator, you need a basic driver policy outlining:

✅ Speeding and driving laws

✅ Mobile phone use

✅ Fatigue and rest

✅ Drug/alcohol testing

✅ Personal presentation

✅ Behaviour with customers and enforcement officers

Why this matters:

The Traffic Commissioner can revoke your licence if you knowingly employ or fail to manage a high-risk or poorly behaved driver.

Include this code of conduct in your driver induction pack and have drivers sign to confirm understanding.

6. Managing Tachograph & Hours Compliance (if applicable)

Not all Restricted Licence holders fall under EU or GB tachograph rules — but if you do, you must manage:

Driver card downloads (at least every 28 days)
Vehicle unit downloads (at least every 90 days)
Weekly analysis of driving time, breaks and rest
Infringement reports with documented driver debriefs
Policies for re-training and sanctions

Even if you have just one vehicle with a digital tacho, you must store and analyse the data — failing to do so could result in:

Fines
Prosecution
PI summons
Licence revocation

7. Keeping the Right Records

Here’s what you must retain for driver compliance:

Record	Retention Period
Daily defect reports	15 months
Licence check logs	3 years (best practice)
CPC evidence	Duration of employment + 1 year
Tacho downloads	12 months
Infringement reports	15 months
Debrief forms	15 months
Driver conduct/disciplinary records	6 years
Induction and training logs	Duration of employment

All records should be legible, signed, and accessible on request.

8. Creating a Driver Induction and Training Plan

Whether you have 1 driver or 10, an induction programme is essential.

What to include:

✅ Company policies and expectations

✅ Driver conduct rules

✅ Vehicle walkaround check training

✅ Use of defect sheets

✅ Driving laws refresher

✅ Tachograph rules (if applicable)

✅ Procedure for reporting incidents

Get each new driver to sign off that they’ve received and understood the induction.

Ongoing Training

Annual refresher sessions
CPC course attendance tracking
Coaching after infringements or complaints

9. Monthly Driver Compliance Checklist

Use this checklist to stay on top of your driver compliance:

✅ All drivers completed daily checks

✅ All defect sheets submitted and followed up

✅ All defects repaired with proof

✅ Driver licence check dates are current

✅ No CPC certificates expiring soon

✅ No overdue tacho downloads

✅ Infringement reports reviewed and signed

✅ Training logs updated

✅ Driver policy signed and stored

✅ No conduct issues unaddressed

Tip: Keep a monthly scorecard to track changes and highlight issues before DVSA does.

10. How JS Transport Solutions Can Help

We specialise in supporting Restricted Licence holders who don’t have a dedicated Transport Manager but still want to get compliance right.

Our Driver Compliance Services:

✅ Full driver file setup (digital or paper)

✅ Editable daily defect sheets

✅ Licence check log templates

✅ Induction checklist and conduct policy

✅ CPC tracking spreadsheet

✅ Tachograph analysis and debrief support

✅ Monthly compliance coaching

Whether you're running a couple of vans or growing your own fleet, we give you the tools and support to stay legal — and protect your Operator Licence.

📞 Book a free consultation now at👉 www.jstransport.uk

Conclusion

Being a Restricted Licence holder doesn’t free you from responsibility — it increases it. Without a Transport Manager, you are the compliance system.

But with the right routines, checklists, and support, you can: