What the rules require
Digital and smart tachographs record data in two places: the vehicle unit (VU) fitted in the cab, and each driver's card. Both have limited memory, and both have to be downloaded by the operator within maximum periods. DVSA's guidance, Drivers' hours and tachographs: goods vehicles, section 5, sets out the operator's duties. The page was last updated on 1 July 2026.
| Source of data | Maximum interval | Memory, per DVSA |
|---|---|---|
| Driver card | At least every 28 calendar days | About 28 days of average data |
| Vehicle unit | At least every 90 calendar days | About 365 days of average data |
The intervals are maximums. The guidance also says both must be downloaded "in any case as often as necessary to ensure that no data is lost".
Driver cards: the 28-day rule and the other triggers
DVSA lists these occasions when an operator must download a driver card:
- at least every 28 calendar days
- immediately before the driver ceases to be employed by the undertaking, which DVSA notes also applies to agency drivers
- without delay on becoming aware that the card is damaged or malfunctioning, if it is possible to download data
- without delay where it is reasonably foreseeable that data will be erased imminently
- where the card can only be downloaded through a vehicle unit (for example, if the card is stuck), immediately before ceasing control of the use of the vehicle
- in any case as often as necessary to ensure that no data is lost
Vehicle units: the 90-day rule and the other triggers
DVSA says operators must download data from the vehicle unit:
- at least every 90 calendar days
- immediately before transferring control of the use of the vehicle to another person, for example when the vehicle is sold or un-hired
- without delay upon permanently removing the unit from service in the vehicle
- without delay upon becoming aware that the unit is malfunctioning, if it is possible to download data
- without delay where it is reasonably foreseeable that data will be erased imminently
- in any case as often as necessary to ensure that no data is lost
Hired and sold vehicles need particular attention. If a hire vehicle goes back or a vehicle is sold without a final download, that data leaves your control.
DVSA also notes that operators may use the company card to lock in, in other words protect, their drivers' details.
Keeping data and making it available
DVSA's guidance says operators must "Be able to produce records to enforcement officers for 12 months." The Traffic Commissioners' Statutory Document 3 lists among the transport manager's duties ensuring "that all drivers hours records are kept for a period of no less than 12 months".
In law, Article 33 of Regulation (EU) No 165/2014, as it now applies in GB, requires transport undertakings to keep record sheets and printouts in chronological order and legible form "for at least a year after their use", to give drivers copies of data downloaded from their cards on request, and to produce record sheets, printouts and downloaded data at the request of a control officer.
DVSA's guidance also requires operators to provide copies of charts, manual records and digital data to drivers if asked. Store downloads securely, keep the original files, and make sure you can find a specific driver's or vehicle's data for any given day quickly.
Analysis and infringement follow-up
A download that nobody looks at does not meet the operator's duty. DVSA's guidance says operators must:
- "Make regular checks of charts, manual records and digital data to ensure compliance."
- ensure drivers are properly trained and instructed on the drivers' hours rules and on the correct functioning and use of tachographs
- "Take all reasonable steps to prevent breaches of the rules."
The Traffic Commissioners' operator compliance audit guidance shows what an auditor looks for: how often vehicles and driver cards are downloaded, the process to analyse tachograph data against the drivers' hours and working time rules, "what actions are taken from analysis and by who", and individual driver infringement reports with the action taken. It also lists debriefing driver infringements as evidence of transport manager involvement.
A workable follow-up routine
- Download to a schedule, not on demand.
- Analyse promptly after each download and check for missing mileage or unexplained gaps between card and vehicle data.
- Produce an infringement report for each driver and discuss it with them.
- Record the conversation, any retraining, and any disciplinary step, and have the driver acknowledge it.
- Look for patterns by driver, depot and route, and change scheduling where the work itself causes infringements.
For comparison, the DVSA earned recognition HGV audit standards, which apply only to scheme members, look for driver cards downloaded on at least a 14-day frequency, vehicle units on at least a 42-day frequency, and records submitted for analysis within 7 days of download (DVSA). These are not legal limits for other operators, but they show what DVSA regards as good practice.
Smart tachographs and post-Brexit rules
DVSA's tachograph rules page describes four types: analogue, digital (vehicles registered from 1 May 2006), smart 1 (vehicles registered from 15 June 2019) and smart 2. Smart 2 units "automatically record border crossings and the location of the vehicle and allow for enforcement authorities to remotely interrogate the data". A transitional smart 2 unit lacks the Galileo location verification facility in its software.
Key dates and rules from that page:
- From 24 December 2025, all newly registered goods vehicles must have a full smart 2 tachograph fitted.
- On or after 1 July 2026, a full smart 2 tachograph must be fitted into goods vehicles over 2.5 tonnes used for international journeys for hire and reward.
- If a vehicle operates only within the UK, the originally fitted analogue, digital or smart 1 tachograph can still be used.
- A faulty smart 1 tachograph must be replaced with a full or transitional smart 2 unit.
- Goods vehicles over 2.5 tonnes and under 3.5 tonnes used only in the UK do not have to have a tachograph fitted.
The download intervals are the same whichever type is fitted. What differs after Brexit is the set of rules a journey falls under: DVSA's guidance distinguishes the assimilated GB rules from the AETR rules and journeys between the UK and the EU. For roadside checks, drivers must be able to produce records for the current day and the previous 28 calendar days for domestic journeys under the assimilated rules or AETR journeys, or 56 days for international journeys. That applies to drivers rather than to operator downloads, but it is another reason not to let card data sit unanalysed.
A short checklist
- Schedule driver card downloads well inside 28 days and vehicle units well inside 90 days.
- Download cards when a driver leaves, including agency drivers.
- Download the vehicle unit before a vehicle is sold, off-hired or has its unit replaced.
- Keep data for at least 12 months and be able to produce it promptly.
- Analyse every download, act on infringements, and keep evidence of the action taken.
- Know which of your vehicles run international hire and reward work and check their tachograph type.
Roadworthy Fleet Compliance accepts driver card and vehicle unit file uploads and analyses them for infringements.
This guide is general information, not legal advice. Check DVSA's current guidance for the rules that apply to your journeys.