Operator Licence Compliance Documents: What to Keep and How Long

stuart47304
Jul 15
5 min read

Legal Responsibilities of Licence Holders – Part 3

Introduction

Running a compliant transport operation isn’t just about vehicles and drivers — it’s about paperwork. And lots of it.

Whether you hold a Restricted, Standard National, or Standard International Operator Licence, the documents you keep (and for how long) can make or break your licence. Failure to produce the correct records during a DVSA inspection, audit, or Public Inquiry could result in:

Licence suspension or revocation
Hefty fines
A finding of unfitness or loss of repute
Damage to your business and reputation

In this comprehensive guide, we’ll walk you through exactly what documentation you need to retain, how long to keep it, and how to organise it to ensure your operation is audit-ready at all times.

Why Keeping the Right Records Matters
Key Operator Licence Documents to Retain
How Long to Keep Each Type of Record
Organising Documents for Maximum Efficiency
Digital vs Paper Records: What’s Accepted?
Common Record-Keeping Pitfalls
Record Auditing – How to Check Your Own Files
Downloadable Retention Schedule PDF
How JS Transport Solutions Can Help
Summary & Next Steps

1. Why Keeping the Right Records Matters

Your Operator Licence comes with undertakings — legally binding promises that you’ll:

✅ Keep your vehicles roadworthy

✅ Comply with driver hours and tachograph rules

✅ Use only authorised operating centres

✅ Notify the Traffic Commissioner of material changes

✅ Keep proper records and produce them on request

The DVSA or Traffic Commissioner won’t just take your word for it — you must prove it through documentation.

Poor record-keeping = non-compliance, even if you’ve done everything else right.

2. Key Operator Licence Documents to Retain

Here’s a breakdown of the core document categories you must retain as an Operator Licence holder:

A. Vehicle Maintenance & Roadworthiness

PMI (Preventative Maintenance Inspection) reports
Defect reports & rectification records
Maintenance planners
Repair invoices
MOT test results
Service records
Calibration certificates (tachographs)

B. Drivers and Operations

Driver licence checks
Driver CPC training records
Tachograph data (driver card and vehicle unit)
Infringement reports and driver debriefs
Working time records (for applicable operations)
Employment contracts and driver handbooks
Daily walkaround check reports
Driver induction and training logs

C. Operator Licence Administration

Operator’s Licence documents (main and copies)
Application and variation paperwork
Communications with the Traffic Commissioner
Financial standing documents (bank statements, accounts)
Insurance certificates
Vehicle hire/lease agreements
Operating centre lease agreements or proof of ownership
Evidence of transport manager CPC (if applicable)

3. How Long to Keep Each Type of Record

Below is a detailed record retention schedule in line with DVSA guidance and best practice.

Record Type	Minimum Retention Period	Notes
PMI Reports	15 months	Keep per vehicle
Defect Reports	15 months	Includes daily walkarounds
Maintenance Planner	15 months	Shows inspection frequency
Repair Invoices	15 months	Linked to inspections
Tachograph Data (Driver Cards)	12 months	Download at least every 28 days
Tachograph Data (Vehicle Units)	12 months	Download at least every 90 days
Infringement Reports	15 months	Include evidence of debrief
Driver Licence Checks	12 months (recommend 3 years)	Retain check logs & dates
Driver CPC Records	Duration of employment + 12 months	Proof of 35 hours every 5 years
Driver Employment Records	6 years	HR best practice
Insurance Documents	6 years	Even if policy ends earlier
Operator Licence Documents	While licence is active	Keep renewals & variations
Financial Standing Proof	At least annually	Required for O Licence compliance
Training & Induction Logs	Duration of employment	Especially safety-critical roles
Vehicle Hire/Lease Agreements	Life of agreement + 1 year	Includes short-term rentals
Operating Centre Agreements	While centre is in use	Lease, licence or ownership proof

✅ Tip: Even where shorter minimums apply, consider keeping digital copies for 6 years for protection against insurance claims and retrospective audits.

4. Organising Documents for Maximum Efficiency

A well-structured system is your strongest defence during a DVSA inspection or Public Inquiry.

Recommended Filing System (per vehicle):

📁 Vehicle Folder – e.g. “AY63TRN”

PMI Reports
Defect Reports
Repairs & Invoices
MOT Certificates
Maintenance Planner
Tachograph Downloads

📁 Driver Folder – e.g. “John Smith”

Licence Checks
CPC Training Logs
Infringement Records
Debrief Forms
Training & Induction

📁 Operator Admin Folder

O Licence & Communications
Financial Standing Docs
Insurance Policies
Operating Centre Evidence
TM CPC & Contract (if applicable)

📁 Archived Folder

Old vehicles
Former employees
Expired documents (clearly marked)

Digital tip: Use cloud-based platforms like Google Drive, Dropbox, or OneDrive with secure backups.

5. Digital vs Paper Records: What’s Accepted?

DVSA and Traffic Commissioner Guidance:

"Electronic documents are acceptable if they are legible, accessible, and capable of being produced on request."

Advantages of Digital Recordkeeping

✅ Easier to search and sort

✅ Access from multiple locations

✅ Built-in backups and date stamps

✅ Easier sharing with TCs or consultants

Risks of Paper Records

❌ Vulnerable to fire, theft, or water damage

❌ More likely to be incomplete or disorganised

❌ Harder to audit or cross-reference

Hybrid tip: Scan and upload all signed paper records to your digital system.

6. Common Record-Keeping Pitfalls

🚫 Missing retention timelinesMany operators dispose of defect reports or PMIs too early — keep them for at least 15 months.

🚫 Scattered document storageRecords kept across different sites, vehicles or people lead to loss or confusion.

🚫 Untraceable repairsRepairs made without linking them to a defect or PMI report = red flag.

🚫 Inadequate audit trailNo notes of driver debriefs, dates of licence checks, or financial reviews.

🚫 No version controlUsing outdated driver handbooks, inspection templates or policies.

Avoid these mistakes by adopting a structured, regularly reviewed compliance system.

7. Record Auditing – How to Check Your Own Files

A monthly or quarterly file audit is one of the best proactive compliance tools you can implement.

Use a simple compliance file checklist such as:

✅ Are all PMIs accounted for this quarter?

✅ Do all vehicles have up-to-date MOTs and inspections?

✅ Have all driver licence checks been logged in the last 6 months?

✅ Are defect reports signed, dated, and followed up?

✅ Are CPC records current for every driver?

✅ Is tachograph data downloaded within time limits?

✅ Are your operating centre documents current and valid?

Create a dashboard to flag missing or overdue items.

8. Downloadable Retention Schedule (PDF)

To make your life easier, we’ve created a free printable/downloadable Compliance Document Retention Schedule.

📥 [Click to Download – Operator Licence Record Retention Chart] (coming soon)

Print and post in your transport office or save to your compliance folder.

9. How JS Transport Solutions Can Help

If you're not sure whether your records meet the required standard, or simply need help building a system that works — we’re here to help.

At JS Transport Solutions, we offer:

✅ Full compliance file audits

✅ Recordkeeping system setup (digital or paper-based)

✅ Custom templates and documentation bundles

✅ Monthly compliance coaching (ideal for Restricted Licence holders)

✅ Pre-audit and Public Inquiry readiness support

✅ Transport Manager cover for Standard Licence holders

Don’t wait for DVSA to find the gaps. Let us help you fix them first.

📞 Contact us now for a free compliance consultation

10. Summary & Next Steps

You can’t afford to get recordkeeping wrong. It’s not just about organisation — it’s about protecting your licence, your reputation, and your livelihood.

Next Steps: