Understanding Your Responsibilities as a Restricted Operator Licence Holder

If you hold a Restricted Operator Licence, you might assume your responsibilities are less demanding than those of a Standard Licence holder. After all, you’re only moving your own goods, right?

But that assumption can lead to serious consequences — including DVSA enforcement action, Public Inquiries, and even revocation of your licence.

In this guide, we’ll set the record straight and explain exactly what your responsibilities are as a Restricted Licence holder, covering:

• What a Restricted Licence allows (and doesn’t)

• The undertakings you agreed to

• Your key responsibilities under DVSA and Traffic Commissioner expectations

• Common myths — and costly mistakes

• Tips for staying compliant without a transport manager

Whether you run one lorry or a small fleet, this is your plain-English guide to running legally and confidently under a Restricted Licence.

What Is a Restricted Operator Licence?

A Restricted Operator Licence allows you to operate vehicles over 3.5 tonnes gross plated weight (MAM) for the purpose of carrying your own goods in connection with your own business.

You cannot:

• Carry goods for other people (i.e., operate as a haulier)

• Be paid for transporting goods on behalf of anyone else

• Subcontract haulage work from another business

Typical restricted licence holders include:

• Builders and construction companies

• Retailers and wholesalers

• Landscaping or plant hire businesses

• Catering and events companies

• Utility contractors

You Still Gave Undertakings – Legally Binding Ones

When you applied for your licence, you made formal operator licence undertakings — and these apply equally to Standard and Restricted licences.

Here’s a summary of what you agreed to:

Undertaking	What it means
Vehicles will be kept in a fit and serviceable condition	You must operate a proper maintenance regime
Drivers will carry out daily checks	You must have a defect reporting process
Maintenance records will be kept for 15 months	You need an organised filing system
Vehicles will be not overloaded	You must manage weights and loading
Vehicles will be operated within speed limits	You’re responsible for driving behaviour
No false statements or documents will be provided	Integrity matters
Any relevant changes will be reported to the Traffic Commissioner	e.g. change of address, new vehicle, company changes

Failing to meet any of these is a potential breach of your licence — and could lead to a Public Inquiry.

Key Responsibilities You Must Manage

Let’s break this down into practical areas you’re legally responsible for:

🔧 1. Vehicle Maintenance

You must:

• Set and follow a preventive maintenance schedule

• Carry out daily walkaround checks

• Keep detailed maintenance records (PMIs, repairs, MOTs, services)

• Ensure brake tests are conducted at appropriate intervals

• Use competent and reliable maintenance providers

👷 2. Driver Management

Even if you’re the only driver, or using family or occasional staff, you must:

• Ensure daily checks are completed and recorded

• Monitor driver hours and tachograph compliance (if in-scope)

• Carry out driver licence checks at regular intervals

• Provide basic training on defect reporting and walkarounds

• Manage driver conduct (e.g. speeding, offences)

🗂️ 3. Record-Keeping

You must maintain:

• Maintenance records (min 15 months)

• Defect reports

• PMI reports and repair evidence

• Driver hours/tacho data (if applicable)

• Operating centre permissions (if challenged)

• Financial records (to prove financial standing if required)

Records can be paper or digital, but must be:

• Clear

• Organised

• Accessible to DVSA or Traffic Commissioner upon request

🏠 4. Operating Centre Management

You must:

• Park vehicles at your authorised centre(s)

• Keep the site tidy and safe

• Avoid nuisance to neighbours (noise, fumes, obstruction)

• Update your licence if you want to change the centre

Complaints from neighbours or councils can trigger investigations or a Public Inquiry.

⚠️ 5. Communication with the Traffic Commissioner

You are legally obliged to inform the TC of:

• Change of address

• Change of entity (e.g. sole trader to limited company)

• Adding or removing operating centres

• Adding or replacing vehicles

• Changes to business type or capacity

Failure to do so can be treated as lack of repute — a serious matter.

Common Misconceptions That Lead to Trouble

❌ Belief	✅ Reality
“I’m a restricted operator — the rules don’t apply to me.”	The undertakings apply to all licence types.
“I only drive occasionally — I don’t need a maintenance plan.”	Even one vehicle needs a formal inspection schedule.
“I can use any garage — doesn’t matter who.”	You must use competent providers with proper documentation.
“I can park anywhere I want.”	Vehicles must be based at your approved Operating Centre.
“I don’t need to keep records as long.”	DVSA expects 15 months minimum, and often longer.

Restricted Licence Holders Are Being Targeted More Often

In recent years, the Traffic Commissioners have noted that many restricted licence holders:

• Don’t fully understand their obligations

• Fail to keep proper records

• Don’t have any formal systems

• View the licence as a “tick box” formality

As a result, DVSA is inspecting restricted licence holders more frequently, and Public Inquiries for non-compliant restricted operators are on the rise.

But I Don’t Have a Transport Manager…

That’s true — Restricted Licences don’t require one, but that doesn’t mean you’re off the hook.

Instead, you must:

• Take personal responsibility

• Implement your own systems

• Seek advice where needed

• Consider hiring a transport consultant or External Transport Manager (ETM) on a part-time basis

This can be very cost-effective for small fleets — and could help you avoid much bigger issues down the line.

How to Stay Compliant Without a TM

✅ Create a Compliance Calendar

Include:

• Maintenance inspections

• MOT dates

• Insurance renewals

• Tachograph downloads

• Licence checks

✅ Use Templates and Checklists

Don’t reinvent the wheel — use pre-made:

• Walkaround check sheets

• Maintenance logs

• Record-keeping policies

• Driver debrief forms

✅ Set Reminders

Use Google Calendar, Microsoft Outlook, or even wall planners to track key dates.

✅ Get a Mid-Year Health Check

Hire a consultant to review your systems annually and catch any red flags early.

Conclusion

Holding a Restricted Operator Licence doesn’t make you “semi-compliant” — it simply means you’re transporting your own goods, not someone else’s. The legal responsibilities remain just as serious, and the consequences for non-compliance just as real.

The good news? With the right systems and a little bit of discipline, staying compliant is absolutely achievable — even for one-vehicle operations.

Next in the series:👉 Keeping Digital Maintenance Records: Benefits & Best Practices