What to Do if Your Business Changes – Licence Amendments Explained

Legal Responsibilities of Licence Holders – Part 4

Introduction

Your Operator Licence isn’t a one-time, set-it-and-forget-it application — it’s a living authorisation that must be kept up to date as your business evolves.

Whether you move premises, change company structure, take on more vehicles, or hire a new Transport Manager, you have a legal duty to inform the Traffic Commissioner. Failure to do so is one of the most common triggers for Public Inquiries — and it’s entirely preventable.

In this guide, we break down:

• What counts as a "material change" under your licence

• How and when to notify the Office of the Traffic Commissioner (OTC)

• The difference between a licence variation, an application, and a notification

• What documents you’ll need

• Common mistakes and how to avoid them

• How JS Transport Solutions can handle amendments on your behalf

Table of Contents

1. Why You Must Notify the Traffic Commissioner

2. What Is a Material Change?

3. Changes That Require a Licence Variation

4. Changes That Require Notification Only

5. How to Apply for a Licence Variation

6. Required Supporting Documents

7. How Long Will It Take?

8. Common Mistakes to Avoid

9. What Happens If You Don’t Notify?

10. Help from JS Transport Solutions

11. Summary & Next Steps

1. Why You Must Notify the Traffic Commissioner

When you were granted your Operator Licence, you made a legal undertaking to:

“Inform the Traffic Commissioner of any material change in the circumstances of the business.”

This is not optional — it’s a binding condition. The OTC needs to ensure that your licence still reflects your operation as it currently exists. If it doesn’t, and you haven't informed them, you’re in breach of your undertakings.

The DVSA checks these details during roadside stops, audits, and maintenance inspections. If they notice inconsistencies (e.g., a vehicle operating from an unauthorised centre), they may report you for enforcement.

2. What Is a “Material Change”?

A material change is any change to your business that could affect your licence’s validity or compliance.

Some common examples:

• A new operating centre

• A change in company name or legal entity

• Taking on additional vehicles

• Removing or appointing a Transport Manager

• Becoming insolvent or bankrupt

• Change of directors or partners

• Change of correspondence address

• Changes to your financial standing

Each of these must be dealt with properly — either through a formal variation or a notification.

3. Changes That Require a Licence Variation

A licence variation is a formal application submitted via the Operator Licensing Self Service portal. This includes:

🔄 Adding or Removing an Operating Centre

• New sites must be advertised publicly (as per statutory process)

• You must ensure sufficient parking, environmental suitability, and access

🚚 Increasing (or reducing) Vehicle or Trailer Authorisation

• You must prove financial standing for each additional vehicle

• You cannot operate more vehicles than authorised at any time

👨‍💼 Appointing or Removing a Transport Manager

• For Standard licences only — must submit a TM1 form

• Appointee must hold a valid CPC and accept responsibility

🧾 Changing the Licence Holder's Legal Entity

• E.g., changing from sole trader to limited company

• In most cases, this requires a new licence, not just a variation

🏢 Changing Operating Centre Conditions or Undertakings

• If the conditions imposed (e.g., vehicle limits or operating hours) no longer work

All licence variations may be subject to approval and Public Inquiry depending on circumstances.

4. Changes That Require Notification Only

Some changes don’t need a full variation — but you must still inform the Traffic Commissioner.

You can do this via:

• The online self-service system

• Written notice to the Office of the Traffic Commissioner

Examples of notification-only changes:

• Company name (same legal entity)

• Change of directors or partners

• Change in business address or contact details

• Change of financial support provider (e.g. new bank or guarantor)

• Sale or disposal of vehicles

• Reduction in fleet size (if not below minimum financial standing)

Make sure you keep confirmation emails or letters from the OTC in your records.

5. How to Apply for a Licence Variation

✅ Step-by-Step: Submitting a Licence Variation

1. Log in to the Operator Licensing Self Service portal

2. Click "Apply to make changes to your licence"

3. Select the change(s) you want to make — e.g., operating centre, vehicles

4. Upload supporting documents (site plans, financial proof, TM1 etc.)

5. Pay the variation fee (£275)

6. Submit your application

You will be contacted if further information or a Public Inquiry is required.

6. Required Supporting Documents

The documentation depends on the nature of the change.

Type of Change	Required Documents
Add operating centre	Lease or proof of permission, site plan, advertisement proof
Add vehicles	Updated financial standing evidence (bank statements)
Appoint TM	TM1 form, CPC copy, acceptance form
Change name or address	Company certificate or confirmation letter
Change in partners/directors	Companies House printout or partnership declaration
New legal entity	Entirely new licence application

Always retain copies of submitted documents in your Operator Compliance File.

7. How Long Will It Take?

Change Type	Approx. Processing Time
Minor change (e.g. address)	1–2 weeks
Operating centre variation	3–6 weeks (depending on objections)
New TM appointment	2–4 weeks
New licence application	6–12 weeks (or longer if called to PI)

Delays can happen if:

• You miss supporting documentation

• You fail to advertise a new operating centre correctly

• Financial standing is unclear or insufficient

Tip: Avoid “urgent” last-minute requests by planning ahead for known changes.

8. Common Mistakes to Avoid

🚫 Operating from a new site without authorisationThis is one of the fastest ways to a Public Inquiry — always apply first.

🚫 Assuming changes don’t need reportingEven a minor change in business name needs a notification.

🚫 Not updating contact detailsIf DVSA or the OTC can’t reach you, you could miss a critical compliance warning or inspection notice.

🚫 Failing to evidence financial standing after fleet expansionAdding vehicles requires updated bank statements showing increased funding access.

🚫 Trying to vary a licence to change the legal entityIf your business becomes a limited company, you usually need to apply for a new licence, not vary the old one.

9. What Happens If You Don’t Notify?

If DVSA or OTC discover that you failed to notify a material change, consequences include:

• Formal warning letter

• Public Inquiry call-up

• Licence suspension or curtailment

• Revocation of your licence

• Disqualification as a transport manager or operator

Examples from real cases:

• An operator was banned after failing to notify the loss of financial standing for 6 months

• A Restricted Licence holder had their licence revoked for operating from an unauthorised centre

• A transport manager was disqualified for 5 years for failing to update his role across multiple licences

10. How JS Transport Solutions Can Help

At JS Transport Solutions, we’ve helped dozens of operators:

✅ Submit accurate licence variations

✅ Appoint or remove Transport Managers

✅ Expand vehicle authorisations

✅ Transition from sole trader to limited company

✅ Prepare for operating centre changes

✅ Avoid mistakes that lead to enforcement

Whether you need a one-time licence variation, or ongoing support to manage changes as your fleet grows, we can take care of the entire process.

📞 Book a free consultation: www.jstransport.uk

11. Summary & Next Steps

Your Operator Licence isn’t static — it must always reflect your real-world operation. As your business evolves, your licence must evolve with it.

Key Takeaways:

• Any material change must be notified or approved

• Licence variations must be submitted through the self-service portal

• Supporting documents are crucial to avoid delay or rejection

• Failing to notify changes could trigger a Public Inquiry

• Get professional help to get it right first time

What to Do Now:

• Review your current licence details

• Compare against your real business operation

• Make a list of any updates needed

• Contact JS Transport Solutions for help with submissions

Next in the series: [Compliance Coaching for Restricted Licence Holders – How We Can Help]