Why operators check driving licences
An operator licence is granted on the basis that the holder will run its vehicles safely and lawfully. Part of that is making sure every driver holds the right entitlement for the vehicle, that the entitlement has not expired, and that the driver has not been disqualified. A driver's paper or photocard licence only tells you what was true when it was printed. The DVLA record tells you what is true today.
The Senior Traffic Commissioner's Statutory Document 3 on transport managers lists, among the transport manager's duties, ensuring "that drivers hold the appropriate licence for the vehicle they are driving" and ensuring "that regular checks are carried out on the drivers' licences (usually every 3 months)". In practice this is one of the first things an examiner or a Traffic Commissioner will ask about when looking at an operator's systems.
The DVLA routes for checking
There are two main ways to see a driver's record: the free online check using a check code, and DVLA's Access to Driver Data (ADD) service for organisations that need to check many licences. Operators can also use a commercial licence-checking service; ask any provider how it obtains DVLA data and how consent is handled.
View or share your driving licence information: check codes
Through the GOV.UK service View or share your driving licence information, a driver can see the vehicles they can drive and any penalty points or disqualifications, and can create a check code to share their record. To create a code the driver needs their driving licence number, National Insurance number and the postcode on their licence.
The operator then uses the Check someone's driving licence information service with the last 8 characters of the driver's licence number and the check code. Two rules matter for planning:
- A check code must be used within 21 days.
- It can only be used once. A fresh code is needed for every check.
Checking online in this way is free. GOV.UK also explains that licences can be checked by phone or post, with call charges applying and a £5 fee for a postal check (Employing people to drive).
Check codes work well for small fleets and for one-off checks such as a new starter's first day. The weakness is that the process depends on each driver generating a code on time, every time, so it needs a reminder system behind it.
Access to Driver Data (ADD) and commercial checking services
DVLA describes ADD as a real-time service for organisations "who have a demonstrable business need to check the driving entitlement and endorsement record of drivers" (DVLA ADD FAQ). To use it directly, a company must pass accreditation checks and enter into a contract with DVLA, and pays an enquiry fee of 60 pence for each driver record. DVLA states that data supplied through ADD must not be used for identity checking of any kind.
Some operators use a licence-checking provider rather than contracting with DVLA directly. Either way, the driver's agreement is still required.
Consent: the D906 declaration
For checks made through ADD, DVLA offers, and recommends, a standard declaration, form D906 (the "driving licence information fair processing declaration"). The company fills in its details and its reason for processing the information before the driver completes and signs the declaration. DVLA's guidance notes on the form say it will not accept forms that have not been signed and dated by the driver, and that the information may only be used for the stated reason.
The declaration text on the form states that it "will expire when I stop driving in connection with the company or in any case, three years from the date of my signature". Operators should therefore track signature dates and collect a new declaration before the three years run out, or when a driver leaves and later returns.
What to look for on the record
Entitlement categories
Check that the categories match the vehicles the driver will actually use. GOV.UK's driving licence categories page defines them:
| Category | What it covers (summary of GOV.UK definition) |
|---|---|
| C1 | Vehicles between 3,500kg and 7,500kg maximum authorised mass (MAM), with a trailer up to 750kg |
| C1E | C1 vehicles with a trailer over 750kg; combined MAM not over 12,000kg |
| C | Vehicles over 3,500kg, with a trailer up to 750kg MAM |
| CE | Category C vehicles with a trailer over 750kg |
| D1 | Vehicles with no more than 16 passenger seats, maximum length 8 metres, trailer up to 750kg |
| D | Any bus with more than 8 passenger seats, with a trailer up to 750kg MAM |
A common gap is a driver who holds C but is rostered on an articulated vehicle or drawbar combination that needs CE.
Validity dates and provisional entitlement
Lorry and bus entitlement has its own validity date, separate from the car entitlement. Drivers aged 45 or over renewing a lorry or bus licence need a medical examination report (form D4), and DVLA sends renewal reminders 56 days before the licence runs out (GOV.UK). Make sure the record shows full, not provisional, entitlement for the categories concerned.
Endorsements, points and disqualifications
Look at the number of penalty points, the offence codes behind them and any disqualification. Points do not automatically bar someone from driving for you, but they are information you should act on. The Traffic Commissioners' operator compliance audit guidance asks whether there is "a system in place for staff with higher penalty points" and "what consequent action is taken".
How often to check
No statute sets a single checking interval for operators. What the published guidance says is:
- Statutory Document 3 (Senior Traffic Commissioner): regular checks, "usually every 3 months".
- DVSA earned recognition HGV audit standards: a "process to monitor and check driving licences every three months with a risk-based approach to additional checks" (DVSA). This is a standard for scheme members, but it is a useful benchmark for any operator.
- Operator compliance audits (Traffic Commissioners): auditors ask how frequent the checks are, whether they cover only HGV and PCV drivers or all staff who may drive any company vehicle, and whether the operator uses an online service.
A sensible reading of this is a quarterly baseline for every driver, with more frequent checks where the risk is higher. Higher-risk groups might include drivers with points on their record, new starters and agency drivers, and drivers whose lorry entitlement is close to its renewal date. Whatever policy you choose, write it down, apply it consistently and be able to show the evidence.
Keeping evidence of checks
Keep a record of each check: the driver, the date, the categories and validity dates seen, points and offence codes, who carried out the check and what action followed. Keep consent declarations alongside, with their signature dates so renewals are not missed. Handle this data carefully: it is personal data, and DVLA is clear that it may only be used for the purpose stated on the declaration.
A short checklist
- Check every driver before they first drive for you, including agency drivers.
- Set a written checking frequency, at least quarterly, with a risk-based uplift.
- Choose a route: check codes for occasional checks, or ADD directly or through a provider for regular checks.
- Hold a valid D906 for every driver checked through ADD and diary its three-year expiry.
- Compare categories against the vehicles and trailers each driver actually uses.
- Record the outcome of every check and the action taken on points or expiring entitlement.
Roadworthy Fleet Compliance can hold DVLA licence check results and send reminders when checks fall due, alongside an operator's other compliance records.
This guide is general information, not legal advice. Check the current GOV.UK guidance or take professional advice for your own circumstances.