Sebastian Theuerkauf
In short
From 1 July 2026, light commercial vehicles (LCVs) engaged in cross-border transport will also be required to use a digital tachograph. This means that vehicles with a gross vehicle weight (GVW) of 2.5 tonnes or more used for commercial transport across European borders must be equipped with a second-generation version 2 intelligent tachograph (Gen2V2). This “tachograph requirement” includes not only the operation of tachographs in the fleet, but also the regular read out, analysis and archiving of driver card data, plus the driving, rest, working and break times.
For those of you who know “next to nothing” about these changes, DAKO can help. With the following article and other, more specific posts on tachograph requirements, we want to help your company quickly gain an understanding of the topic. Whether you operate trucks, LCVs, or a mixed fleet, we provide practical tips, experience-based insights, and checklists to help your company prepare for the change.
Firstly, the question arises as to why tachograph requirements are now being introduced for light commercial vehicles in particular. Until now, these requirements only applied to heavy commercial vehicles with a GVW of over 3.5 tonnes.
In the area of “classic commercial transport”, the introduction and continuous development of tachograph regulations and labour laws were directly linked to the creation of safer conditions on European roads. Even today, we still see the devastating accidents that can occur when drivers of heavy commercial vehicles are overtired. The clarification and expansion of the rules for the transport industry therefore needed to take current technical capabilities into account and, beyond that, ensure fair and socially acceptable competition in the European Single Market.
As a result, the extension of tachograph requirements to include vehicles with a GVW of 2.5 tonnes or more can be seen as a response to changed conditions in the transport industry. Previous exemption of this vehicle class from these requirements often led to drivers in commercial transport vehicles under 3.5 tonnes being forced to work dangerously long shifts. Companies accepted these risks in order to secure competitive advantages over the more restricted truck industry. From the perspective of the EU bodies, such a threat to driver safety and that of the general public represented a “blind spot” in legislation for a long time. Accordingly, the amendments to the legal norms mentioned in the next paragraph aim to achieve the following key objectives:
Tachograph requirement for light commercial vehicles: act now!
As millions of tachographs need to be retrofitted in Europe, there are long wait times at service centres. We therefore emphasise the importance of planning these retrofits early on. We recommend combining retrofitting with routine maintenance or inspection work to minimise time out of action.
In a nutshell: Am I affected?
The EU regulations detailed in the next paragraph apply to all commercially used vehicles and vehicle combinations with a GWV over 2.5 tonnes travelling on European roads in cross-border traffic. These transporters or vans are commonly referred to by their manufacturers’ brand names such as “Sprinter” or “Transit” class.
Beyond this idea of everyday practice, it’s important to note that a commercially used car (van, SUV or station wagon) with a trailer attached could exceed the aforementioned weight limit and would therefore be subject to these tachograph requirements. This is often the case, for example with vehicles used in trade work or at weekly markets.
Other industries that are particularly affected include: CEP service providers, freight forwarders, trade fair constructors, food transporters, the construction industry, special transport providers and removal companies.
With Regulation (EU) 2020/1054, the European Union has extended the validity of the ‘Driving and Rest Time Regulation’ (EU) 561/2006 to vehicles and vehicle combinations with a maximum authorised weight of more than 2.5 tonnes in cross-border traffic from 1 July 2026.
In accordance with the Tachograph Regulation (EU) 165/2014 and the Driving and Rest Time Regulation (EU) 2020/1054, the installation of a second-generation version 2 intelligent tachograph, also known as Smart Tacho V2, will also become mandatory in these vehicles in cross-border freight transport from 1 July 2026.
In short: The deadline for the tachograph requirement for LCVs in cross-border traffic is fast approaching and should be addressed proactively and systematically! From the effective date, companies must be able to present driving and activity data for the previous 56 days. This brings the deadline for installing your tachographs or the manual documentation requirement (activity records) forward to the beginning of May 2026. Otherwise, you may face substantial fines or even vehicle immobilisation during official inspections.
It is also important to note that the measures described below must be implemented in parallel with ongoing day-to-day operations. Any vehicle breakdowns, time in the workshop, unforeseen technical issues, staff rotation and delays must be taken into account as a matter of urgency. Conclusion: Planning ahead is one of the most important steps on the way to a legally compliant and sustainable fleet.
Taking a critical look at your own day-to-day operations is the necessary first step in determining which changes relating to your fleet and staff need to be addressed, when and in what order. This initial audit will give you a significant competitive advantage. Don’t have a master plan yet? Don’t worry, DAKO is here to help with its blog series on the LCV tachograph requirements:
IMPORTANT: It is important to remember that all affected transport companies are facing the same challenges at the same time. Your planning can therefore make all the difference!
From senior management to fleet managers and drivers, everyone must be familiar with the regulations governing driving, rest and working times at European and national level.
Of course, the scope and specific content of this prior knowledge, as well as how it is communicated, must be adapted to the respective tasks in everyday business. This requires not only a high degree of sensitivity to the respective work processes, but also, in some cases, external assistance or advice. Drivers must also receive practical instruction in the use of tachographs and driver cards, and processes within the company must be adapted and re-created.
In concrete terms, this means that a so-called transport manager must be appointed from among those responsible for the vehicle fleet. The appointment of this position is legally binding but can also be outsourced to an external service provider. In principle, the transport manager is responsible for compliance with all regulations regarding driving, rest and working times for drivers, as well as for the roadworthiness of all vehicles, and is also personally liable.Konkret bedeutet dies, dass unter den Fuhrparkverantwortlichen ein so genannter Verkehrsleiter benannt werden muss. Die Benennung dieser Position ist rechtlich verbindlich, kann aber auch an einen externen Dienstleister ausgelagert werden. Grundsätzlich ist der Verkehrsleiter für die Einhaltung aller Vorschriften bezüglich Lenk-, Ruhe- und Arbeitszeiten bei den Fahrern sowie für die Verkehrstauglichkeit aller Fahrzeuge verantwortlich und auch persönlich haftbar.
A more detailed description of the specific range of tasks and the associated liability risk can be found in our separate article on this topic.
Furthermore, it must be determined which drivers are involved in international transport as these should receive special training. However, even drivers who only operate in national transport must know what to do and what documentation they must hand over to their colleagues if they occasionally drive vehicles with a built-in tachograph.
This requires not only a one-off training course on the subject, but it is also recommended that there be a specific contact person for the drivers, who can be available to answer questions and deal with problems on an ongoing basis. It makes sense for this to be the transport manager, but it is also possible to appoint another trusted person within the company. The latter is particularly recommended if the transport manager’s responsibilities are outsourced.
As there has been no Europe-wide tachograph requirement for vehicles under 3.5 t to date, most of these vehicles will have to be retrofitted. Both the procurement of the tachographs and the retrofitting dates should be planned well in advance.
Shortly before 1 July 2026, the large number of vehicles affected may lead to bottlenecks in both delivery by tachograph manufacturers and workshop appointments. Another factor to consider is that the cost of retrofitting a tachograph and the necessary sensors will depend heavily on the vehicle manufacturer and the exact vehicle type.
If you are considering purchasing new vehicles, you should also make specific arrangements with your authorised dealer regarding the installation of tachographs in the vehicles. It is not yet clear whether and to what extent manufacturers (OEMs) will equip their transporter models with tachographs in the future.
a) Applying for driver cards: A driver card is a personal document belonging to the driver. It must be applied for in good time by the driver himself at the driver licensing authority. The processing time can be 14 days or more.
b) Obtaining a company card: A company card is required to read the data from the tachograph. It must be applied for in good time by the transport company at the relevant authorities in the respective federal state.
c) Readout hardware and software: Appropriate technology is required to read and evaluate data from tachographs and driver cards. You should clarify in advance which solutions are suitable for your company – if necessary, through a consultation.
Once tachographs have been installed in vehicles, they must be read out, and the data obtained must be evaluated and stored securely. This requires not only technical support, but also clear routines and responsibilities. Information on changes in the law must also be communicated to drivers on a regular basis. If necessary, drivers must be instructed and trained in a well-documented manner about any offenses committed. When new employees start, they must also be introduced to the topic and receive ongoing support.
Regular technical maintenance and calibration of the tachograph devices must also be organised to ensure proper operation.
Appropriate technical support is available to help meet the associated deadlines.
It can be assumed that, from the effective date, authorities across Europe will be ready to check compliance with the new regulations near borders or on long-distance routes. Failure to install a tachograph will then be expensive and may even result in the vehicle being prohibited from continuing its journey.
Using a DSRC (Dedicated Short-Range Communication) interface installed in the latest tachograph versions (Gen2V2), the inspection authorities of the responsible Federal Office for Logistics and Mobility (BALM for short) will in future also be able to check for tampering, violations or other anomalies while you’re on the road. This increases the risk of being pulled over and thoroughly checked during roadside inspections, should there be any violations. At the same time, this risk and thus the likelihood of delays due to more thorough checks at these stops is reduced if devices and data are compliant. Companies that comply with the law will therefore save valuable time and administrative effort in the future.
At the same time, driving personnel should be trained in dealing with the authorities. Drivers should always be aware of what data they may be required to present and in what form. It is also important that drivers do not feel insecure in these situations and are able to respond calmly and objectively to the requests of the authorities. Any language barriers should also be taken into account here. Drivers should also be aware that penalties for violations are set individually by each EU country and can be imposed during inspections. This means that the sanction mechanisms of the country in which the inspection is carried out apply. In some cases, these can be much harsher than measures imposed in Germany.
