Managing Agency or Casual Drivers: A Guide for Restricted Licence Holders

Many small transport operators and Restricted Licence holders rely on agency or casual drivers to cover peak workloads or special jobs. While this flexibility is invaluable, managing these drivers correctly is critical to maintain compliance and avoid serious legal and operational risks.

This guide covers all you need to know about managing agency or casual drivers under a Restricted Operator Licence — from legal responsibilities and due diligence to record-keeping and training.

1. Understanding the Role of Agency and Casual Drivers

Agency or casual drivers are those who:

• Are not permanently employed by your business

• Are supplied by a third-party agency, subcontractor, or work on a casual basis

• May work irregular or short-term assignments

• Drive vehicles on your Operator Licence and business behalf

Managing these drivers correctly is essential because you remain legally responsible for their compliance while they operate your vehicles.

2. Legal Responsibilities Under a Restricted Licence

As the operator, your duties include:

• Ensuring all drivers are properly licensed and qualified for the vehicle category

• Verifying driver entitlement and restrictions regularly (at least every 6 months)

• Confirming drivers meet tachograph and driver hours rules where applicable

• Providing appropriate induction and training on your company policies

• Keeping records of licence checks, training, and assignments

• Ensuring vehicles are roadworthy and safe for use

• Monitoring driver behaviour and compliance

Failing to properly manage agency or casual drivers can lead to:

• Fines and penalties for non-compliance

• Prohibition notices on vehicles

• Licence suspension or revocation

• Increased scrutiny from DVSA and the Traffic Commissioner

3. Due Diligence Before Engagement

Before allowing an agency or casual driver to operate your vehicles, conduct thorough checks:

Driver Licence Verification

• Use the DVLA online service with driver consent to check licence validity, endorsements, and disqualifications

• Obtain and keep copies of photocard licences

• Check tachograph and Driver CPC (if applicable) status

Agency Credentials

• Verify the agency is reputable and compliant with employment law and transport regulations

• Request references or reviews

• Confirm the agency conducts its own driver checks and training

Insurance and Contractual Agreements

• Ensure the agency provides appropriate insurance cover for their drivers

• Have clear contractual terms covering compliance responsibilities and liabilities

4. Induction and Training

Agency or casual drivers must be inducted before driving for you:

• Explain your company’s health & safety policies

• Cover vehicle-specific instructions and defect reporting procedures

• Provide walkaround check requirements and forms

• Outline route expectations, customer interaction, and conduct standards

• Review any relevant driver hours or tachograph requirements

Induction reduces risk and sets expectations clearly.

5. Assigning and Managing Drivers Day-to-Day

• Maintain a schedule or log of which drivers operate which vehicles and when

• Provide drivers with required paperwork, keys, and contact information

• Ensure vehicles assigned meet compliance standards

• Monitor driver hours and tachograph data (if applicable) regularly

• Establish a point of contact for drivers to report issues promptly

6. Record-Keeping and Documentation

Good records are your best defence if questioned by DVSA:

Record Type	What to Keep
Driver licence checks	Copies or screenshots, date and outcome
Agency agreements	Contracts and insurance details
Induction records	Signed acknowledgment forms
Assignment logs	Dates, vehicles, and driver names
Defect reports	Walkaround checks and repair logs
Tachograph data	Downloads and infringement follow-up

Retain these for at least 15 months or longer if required.

7. Monitoring and Performance Management

• Conduct spot checks and driver audits periodically

• Review DVSA reports and enforcement records on drivers

• Provide feedback and corrective action where necessary

• Consider ongoing training or re-induction for repeat or long-term casual drivers

8. Managing Risks and Avoiding Common Pitfalls

Pitfall: Relying Solely on the Agency

• Don’t assume the agency has fully vetted drivers

• Always perform your own licence and entitlement checks

Pitfall: Poor Communication

• Ensure agency drivers understand your specific compliance needs

• Keep communication lines open and documented

Pitfall: Inadequate Record-Keeping

• Missing or incomplete records can trigger enforcement action

• Use digital systems to streamline documentation

Pitfall: Overlooking Tachograph Rules

• Know when tachograph rules apply, even for casual drivers

• Ensure driver cards are used correctly and data is downloaded

9. Benefits of Effective Management

• Reduced risk of enforcement penalties and prohibitions

• Safer, more reliable fleet operation

• Better working relationships with drivers and agencies

• Clear audit trail to demonstrate due diligence

• Protection of your Operator Licence and business reputation

Final Thoughts

Managing agency and casual drivers under a Restricted Operator Licence requires diligence, good processes, and consistent record-keeping. While these drivers offer operational flexibility, the compliance risks are real and significant.

By following the steps in this guide — thorough checks, clear induction, solid record-keeping, and ongoing monitoring — you’ll build a system that protects your licence and supports safe, legal operations.