When Must You Notify the Traffic Commissioner?

stuart47304
Jul 15
5 min read

Legal Responsibilities of Licence Holders – Part 12

Introduction

As an Operator Licence holder — whether Restricted, Standard National, or Standard International — you made a series of legal undertakings when your licence was granted.

One of the most critical is:

“I will inform the Traffic Commissioner of any material change in the circumstances of the business.”

Failing to notify the Traffic Commissioner (TC) of changes to your business operations can lead to:

Enforcement action
Public Inquiry
Licence suspension, curtailment, or revocation
Disqualification as an operator

In this guide, we’ll explain:

What counts as a material change
When and how to notify the TC
What information you must provide
What happens if you fail to notify
How JS Transport Solutions can help you manage updates smoothly

Why Notifications Matter
What Is a “Material Change”?
Changes You Must Notify the Traffic Commissioner About
Notification vs. Licence Variation – What’s the Difference?
How to Notify the TC
Information and Evidence You May Be Asked For
What Happens If You Don’t Notify
Common Mistakes and How to Avoid Them
Case Examples
How JS Transport Solutions Can Help

1. Why Notifications Matter

When you apply for and operate under an O Licence, the Traffic Commissioner must have an accurate picture of:

Who is running the business
What vehicles are in use
Where they are being operated from
Who is responsible for compliance
Whether financial and safety undertakings are being met

If your business changes and you don’t notify the TC, your licence details are out of date.

This is not just administrative — it’s a licence breach.

2. What Is a “Material Change”?

A material change is anything that affects the conditions of your licence, the nature of your operation, or your ability to remain compliant.

This includes:

Changes in ownership or control of the business
Changes to your operating centre(s)
Changes to the number or type of vehicles used
Adding or removing a Transport Manager
Change of trading name or registered company details
Change of business or correspondence address
Loss of financial standing
Business insolvency or liquidation
Criminal convictions or significant legal issues involving you or key staff
Changes in company directors, partners, or company structure

You are expected to notify the TC promptly — typically within 28 days or sooner if possible.

3. Changes You Must Notify the Traffic Commissioner About

Here’s a breakdown of common material changes you must report:

Change	Requires Notification?	Requires Licence Variation?
Change in trading name	✅ Yes	❌ No
Change of legal entity (e.g. sole trader to Ltd)	✅ Yes	⚠️ Usually requires new licence
Change of directors/partners	✅ Yes	❌ No
Change in business or correspondence address	✅ Yes	❌ No
Appointment/removal of a Transport Manager	✅ Yes	✅ Yes
Loss of Transport Manager (Standard Licence)	✅ Yes – immediately	✅ Yes – submit TM1 or seek interim arrangement
Loss of financial standing	✅ Yes	✅ May affect licence validity
Change to operating centre(s)	✅ Yes	✅ Yes – variation required
Increase in authorised vehicles/trailers	✅ Yes	✅ Yes – variation required
Convictions of relevant persons	✅ Yes	❌ No – but may trigger PI
Bankruptcy or insolvency	✅ Yes	❌ No – but may lead to suspension

4. Notification vs. Licence Variation – What’s the Difference?

Not all changes require a full licence variation. Some just need a notification.

Notification Only	Licence Variation
Change of correspondence address	Adding a new operating centre
New director or partner	Increasing authorised vehicles
New trading name	Appointing or removing a Transport Manager
Company structure change	Changing licence type
Loss of financial standing	Changing undertakings or conditions

Tip: When in doubt, notify. The TC prefers over-disclosure to under-reporting.

5. How to Notify the TC

You can notify the Traffic Commissioner in one of two ways:

📌 Online via the Operator Licensing Self Service Portal

Log in at www.gov.uk/manage-operator-licence
Select the option to “Notify a change to my licence”

✉️ In writing (email or post)

Send to:Office of the Traffic CommissionerHillcrest House386 Harehills LaneLeedsLS9 6NF📧 You can also contact them via email at enquiries@otc.gov.uk

Include:

Your licence number
Clear description of the change
Supporting documents
Your contact details
Date of the change

6. Information and Evidence You May Be Asked For

Depending on the change, the TC may request:

Change	Supporting Documents
New director	Companies House printout or partner declaration
TM appointment	TM1 form, CPC certificate, signed agreement
Business address change	Proof of occupancy or lease
Financial standing issue	Bank statements, accounts, loan agreements
Trading name change	Updated business registration or VAT certificate
Change in company structure	Accountant’s letter, new company registration

Always retain copies of what you submit — and note the submission date in your compliance file.

7. What Happens If You Don’t Notify

Failing to inform the TC of material changes can result in:

A formal warning
Your licence being marked for review
A Public Inquiry
Suspension, curtailment, or revocation of your licence
A finding of loss of repute
Personal disqualification as an operator or TM

Even seemingly minor changes (e.g., new business name or extra vehicle) can raise serious concerns if not reported.

8. Common Mistakes and How to Avoid Them

🚫 Failing to notify a change in legal entityChanging from sole trader to limited company usually means applying for a new licence — not just notifying.

🚫 Not reporting the loss of a Transport ManagerIf you operate under a Standard Licence, you must notify immediately and propose a replacement within 28 days.

🚫 Operating from a new site before approvalYou must apply for a variation before using the site — not after.

🚫 Delaying submission until the next licence renewalNotifications must be made when the change happens, not just when you reapply or renew.

🚫 Ignoring convictions of partners or directorsThese must be reported — the TC will consider whether they impact your good repute.

9. Case Examples

🧰 Case 1: Change of Business Address

What happened:An operator moved depot but forgot to inform the TC.

Outcome:DVSA visited the previous address and found no vehicles. A formal warning was issued and the operator was required to attend a compliance audit.

🚛 Case 2: Loss of Financial Standing

What happened:Operator’s bank balance dropped below the required threshold. They didn’t inform the TC.

Outcome:At Public Inquiry, licence was curtailed. Operator was nearly disqualified.

📝 Case 3: Director Change Not Reported

What happened:New director joined the business but the TC wasn’t notified.

Outcome:Flagged during DVSA inspection. TC issued a warning and demanded full director history disclosure.

10. How JS Transport Solutions Can Help

At JS Transport Solutions, we help operators — especially Restricted Licence holders — stay on top of their obligations.

✅ What We Do:

Advise on what changes must be reported
Prepare and submit notifications and supporting documents
Manage licence variations and TM appointments
Liaise with the Office of the Traffic Commissioner
Update your compliance file to reflect changes
Help you avoid errors that lead to enforcement

Need help now?📞 Visit www.jstransport.uk for fast, reliable Operator Licence support.

Conclusion

As a licence holder, it’s your legal duty to keep the Traffic Commissioner informed of any material changes. Don’t assume a small change won’t matter — if it affects your licence conditions, operations, or repute, you must notify.

Stay compliant. Stay informed. Protect your licence.