Driving licence checks for employers: how and how often
What the law requires when staff drive for work, how to check a licence with DVLA, how often to check, and what the digital licence, grey fleet, agency drivers and data protection change.
Living guide. We check every figure against its official source and revise this page in place when a fee, rule or dataset changes. The change log at the foot records each revision.

This guide covers Great Britain. Every rule links to the GOV.UK page, legislation or regulator guidance that sets it, and was checked against that page on 12 November 2026. Where something is industry practice or THRIVE's own analysis rather than law, the text says so.
The short answer
- No law tells an employer to check licences at a set interval. The law makes it an offence to cause or permit another person to drive otherwise than in accordance with a licence, and to cause or permit another person to use a vehicle without insurance. Checking licences is how an employer shows it did neither.
- Health and safety law adds a general duty. HSE says employers "must manage health and safety risks" to workers who drive for work, and its guidance lists ensuring licences, insurance, and MOTs are legal and up to date. HSE's guidance does not set a checking interval.
- Two ways to check with DVLA. The driver can create a check code valid for 21 days, which you can use only once. For regular checks across a fleet, DVLA's Access to Driver Data service lets organisations check records once the driver has signed a D906 declaration, which DVLA's form says expires after three years at most.
- How often is a risk decision. Common practice is to check at recruitment, then at least yearly, and more often as penalty points rise. That is practice, not law. A sample schedule is at the foot of this guide.
- The digital driving licence cannot yet be used for employer checks. GOV.UK still says you will be able to save your licence to the app "in future". Certified verification providers can test a driving licence credential in a government sandbox, which is not a live service.
- Penalty points and disqualifications are offence data. The ICO reads criminal offence data broadly, so licence check results need a lawful basis, a condition in Schedule 1 of the Data Protection Act 2018 and, for the employment condition, an appropriate policy document.
Do employers have to check driving licences?
No statute uses the words "check a driving licence", but an employer that lets someone drive for it without a valid licence or insurance commits an offence itself, so in practice a check is the only way to stay on the right side of the law. Section 87(2) of the Road Traffic Act 1988 says: "It is an offence for a person to cause or permit another person to drive on a road a motor vehicle of any class otherwise than in accordance with a licence authorising that other person to drive a motor vehicle of that class" (Road Traffic Act 1988, section 87).
Section 143 does the same for insurance: a person must not "cause or permit any other person to use a motor vehicle on a road or other public place" unless a policy covers that person's use (section 143). The same section gives an employee a defence if the vehicle was not theirs, they were using it in the course of their employment and they had no reason to believe it was uninsured. THRIVE's reading: that defence protects the employee, which leaves the employer that supplied or permitted the vehicle carrying the risk.
On the driver's side, GOV.UK lists the endorsement for driving otherwise than in accordance with a licence (code LC20) at 3 to 6 points, and for using a vehicle uninsured (IN10) at 6 to 8 points. GOV.UK says the police could give a fixed penalty of £300 and 6 penalty points for driving uninsured, and a court case can mean an unlimited fine and disqualification.
What health and safety law adds
The Health and Safety at Work etc. Act 1974 makes it "the duty of every employer to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all his employees" (section 2). The Management of Health and Safety at Work Regulations 1999 require "a suitable and sufficient assessment" of the risks (regulation 3).
HSE applies those duties to the road. Its guidance says: "Health and safety law applies to work activities on the road in the same way as it does on a fixed site", and that the law applies to both company and grey fleet vehicles. It covers employees and people engaged through the gig economy, including limb (b) workers and the self-employed. Commuting is not normally driving for work, unless the journey starts from home and goes to somewhere that is not the person's normal place of work.
The checking point sits in HSE's section on safe drivers. It says you "must assess workers' health and safety capabilities and competence", and lists the things to consider, including "driving record", "any driving or riding offences" and "ensuring licences, insurance, and MOTs are legal and up to date" (HSE: make sure drivers and riders are safe). That is guidance on how to meet the legal duty, and it sets no frequency.
HSE's older leaflet Driving at work (INDG382) is often quoted on licence checks. On 12 November 2026 its address on hse.gov.uk returned "page not found", and HSE's current guidance is the web series Employers: driving and riding safely for work, which this guide uses instead.
The stakes go beyond fines. HSE says an organisation could be prosecuted for gross negligence manslaughter or under the Corporate Manslaughter and Corporate Homicide Act 2007 if a worker driving for work is involved in a fatal incident and there is evidence of a grossly negligent act or serious management failures.
How do I check an employee's driving licence?
Ask the driver for a check code, or, for regular checks, get their signed consent and use DVLA's Access to Driver Data (ADD) service, usually through a provider. Looking at the photocard alone does not show penalty points or a recent disqualification, which is why both routes go to DVLA's record.
Route 1: the check code
- The driver creates a code. They sign in to View or share your driving licence information with their licence number, National Insurance number and the postcode on their licence, and create a check code. GOV.UK says: "The check code will be valid for 21 days."
- The driver gives you the code and the last 8 characters of their licence number.
- You enter both at Check someone's driving licence information. GOV.UK says: "You must use the code within 21 days. You can only use the code once - you have to get another code to do another check."
The check shows "vehicles they can drive or any penalty points or disqualifications". You need the driver's permission: GOV.UK warns that "It's a criminal offence to obtain someone else's personal information without their permission." There is a paper route too: you and the driver complete form D888/1 and send it with a £5 fee to DVLA. The online service is for licences issued in England, Wales or Scotland.
The check code suits a small employer, a one-off check at recruitment, or a hire. Its weakness for a fleet is that every check needs the driver to act, so a schedule of checks depends on drivers producing new codes on time.
Route 2: consent-based checks through ADD
DVLA describes ADD as "a real time access service to organisations who have a demonstrable business need to check the driving entitlement and endorsement record of drivers" (DVLA developer portal: ADD FAQ). Organisations may only make enquiries on legitimate drivers where they hold a signed data protection declaration, and DVLA recommends its standard form, the D906/ADD.
The D906 is the driver's declaration. On DVLA's form (version 7/25), the company completes sections 1 and 2, including its reason for asking, and the driver completes and signs sections 3 and 4. The driver declares that they understand DVLA will disclose "personal details, driving entitlements (with any associated restriction codes), valid endorsements and disqualifications (if relevant), photo images (in some circumstances), Certificate of Professional Competence (CPC) and digital tachograph card details (where appropriate)". The form says: "This declaration will expire when I stop driving in connection with the company or in any case, three years from the date of my signature" (DVLA form D906/ADD, copy published by Leeds City Council). DVLA's developer portal names the form but does not link to a copy, so use the current version supplied by DVLA or your provider.
So a fleet using ADD needs a process to renew every driver's D906 before its third anniversary, and to stop checking a driver who leaves.
DVLA's FAQ sets a fee of £0.60 per successful enquiry, "reviewed annually", billed monthly by direct debit, and organisations must build their own front end to show results. Most fleets reach ADD through a provider that has done that work. On these assumptions (200 drivers, checked twice a year on average), DVLA's own fee comes to 200 × 2 × £0.60 = £240 a year. A provider's charges are separate and are not set by DVLA; this guide has not priced them.
What a check shows
| Item | Check code | ADD (with D906) |
|---|---|---|
| Categories you can drive | Yes | Yes, with restriction codes |
| Penalty points and endorsements | Yes | Yes, valid endorsements |
| Disqualifications | Yes | Yes |
| Driver CPC and digital tachograph card details | Not listed | Where requested on the D906 |
Sources: GOV.UK check service and the D906 declaration. Driver CPC periodic training can also be checked at Check your Driver CPC periodic training hours.
Two things a check shows that employers often miss. First, endorsements "must stay on your driving record for 4 or 11 years, depending on the offence", and a driver can be disqualified for 12 or more penalty points within 3 years (GOV.UK: penalty points). New drivers have a lower line: their licence is cancelled if they get "6 or more points within 2 years of passing your test". Second, restriction codes matter: code 78 limits the holder to automatic vehicles, and code 101 means "not for hire or reward" (GOV.UK: driving licence codes).
A photocard also has to be renewed: GOV.UK says you must renew a photocard licence every 10 years. A car licence normally runs to the holder's 70th birthday and is then renewed for three years at a time (Road Traffic Act 1988, section 99), so drivers over 70 are a group to watch.
Drivers with a non-GB licence
The DVLA checks above only see GB licences. GOV.UK's tool for driving in Great Britain on a non-GB licence sets the limits. A resident with an EU car licence who was younger than 67 when they became resident can drive on it until they are 70. Most other foreign licences are valid for 12 months from residence, then must be exchanged where the country is designated, or replaced by passing a GB test. Record the date the driver became resident, because that date sets the deadline.
How often should employers check driving licences?
No law or official guidance sets an interval; HSE leaves it to the employer's risk assessment. Common practice is a check at recruitment, then at least every 12 months, with shorter intervals for drivers with more penalty points.
Driving for Better Business, a programme run by National Highways, puts it this way: "While statute does not lay down a minimum interval for" checks, "official guidance says you should check during recruitment, and then at regular intervals" (Driving for Better Business, August 2024). The same article describes the risk approach: "the more points on a licence, the higher the risk and the more often they need to be rechecked."
The most specific published recommendation THRIVE found came from the Association for Driving Licence Verification, an industry body, which in 2018 recommended "monthly checks should be carried out on drivers with more than nine points as a matter of best-practice" (reported by Driving for Better Business, July 2018). That is an industry recommendation, not law or government guidance.
THRIVE's analysis of why points-based frequency makes sense: the legal thresholds are fixed. A driver on 9 points is one 3-point offence away from 12, and a driver in their first 2 years is one offence away from the 6-point cancellation. A check interval set so that a new disqualification is spotted within weeks, not a year, follows from those thresholds. Checks also belong at trigger points, not just on a calendar: when someone starts driving for you, changes vehicle category, returns from long absence, has a collision, or tells you of an offence.
A check is a snapshot. Between checks, the employer relies on the driver telling it. A driving policy that requires drivers to report any conviction, fixed penalty with points, disqualification or medical condition straight away fills that gap.
Can employers check a digital driving licence?
Not yet. As of 12 November 2026, the digital driving licence is not generally available and there is no live route for employers to verify one. The physical photocard and the DVLA checks above remain the way to check a driver.
Here is what government has confirmed, in order:
- January 2025: government announced that a mobile driving licence would be "one of the first digital documents in a GOV.UK Wallet" and would be piloted later in 2025.
- December 2025: the Government Digital Service began "testing the digital driving licence through a private trial", with DVLA (GDS blog, 21 January 2026).
- January 2026: GDS said it would let verification businesses "test how they will share data from the digital driving licence with third parties" before "full rollout later in the year". Its roadmap refers to "a wider public rollout in England, Wales and Scotland in 2026" (GDS roadmap: GOV.UK Wallet).
- September 2026: GOV.UK guidance for the digital identity industry says the wallet holds the HM Armed Forces Veteran Card, and "This will be followed by the digital driving licence" (Using GOV.UK Wallet in the digital identity sector). GOV.UK's sandbox guidance, published the same day, lets registered and certified providers "create a test driving licence" and test sharing it with a verifier, but says "The sandbox is not a production environment."
How employers would use it, when it arrives: outside government, users "can choose to share documents with a digital verification service", and those services must first be "certified against the UK digital identity and attributes trust framework" and added to the government register. The user decides whether to share. Use of the wallet is "entirely optional", and government says paper or card copies "should still be made available".
One limit matters for fleets. The technical specification of the mobile driving licence lists "Vehicles you can drive" and restriction codes among its attributes, and does not list endorsements or penalty points (GOV.UK Wallet technical documentation, beta). THRIVE's reading: on the published specification, a wallet licence proves identity and entitlement but does not replace a DVLA record check for points and disqualifications.
Grey fleet, agency drivers and 4.25-tonne electric vans
Grey fleet
Staff driving their own cars for work are inside the employer's duty. HSE says: "Make sure that privately owned vehicles used for work purposes are safe. Workers must do checks on their vehicles, have them serviced and have insurance and a valid MOT" (HSE: make sure vehicles are safe). Vehicles under cash allowance schemes count as grey fleet too.
For a grey fleet driver, check four things: the licence, as for any driver; that the insurance covers the driver for business use, which is what section 143 turns on; a current MOT where the car needs one; and that the car is taxed. THRIVE's practice note: ask to see the certificate of insurance, not just the schedule, because the certificate states the permitted uses. Reimbursement is a separate question, covered on THRIVE's mileage rates page and in its explainer on approved mileage allowance payments.
Agency drivers
An employment business supplying a driver has its own legal duty. It "may not introduce or supply a work-seeker to a hirer unless it has obtained confirmation" that the work-seeker has the experience, training, qualifications and "any authorisation which the hirer considers are necessary, or which are required by law" (Conduct of Employment Agencies and Employment Businesses Regulations 2003, regulation 19). A driving licence for the right category is an authorisation required by law.
That duty sits on the agency, but the section 87 and 143 offences are about whoever causes or permits the driving, which includes the hirer. THRIVE's analysis: the hirer cannot rely on the agency's word alone. State the categories and any Driver CPC requirement in the booking, ask for evidence of the agency's check, and run your own check code before a supplied driver first takes a vehicle.
Electric vans up to 4.25 tonnes on a car licence
Since 10 June 2025 a category B holder needs no extra training to drive one. GOV.UK's licence page says category B (test passed on or after 1 January 1997) covers vehicles with up to 8 passenger seats with a maximum authorised mass of "4,250kg for electric or hydrogen vehicles - zero emission vehicles only" (GOV.UK: driving licence categories).
The training point changed recently. Before June 2025, a category B holder "must undertake 5 hours of additional training" before driving such a van (DfT consultation outcome, 2023). DfT confirms regulations "came into force on 10 June 2025, which remove a requirement for category B licence holders to undertake additional training" and align towing allowances (DfT consultation response, 24 November 2025). The law is the Motor Vehicles (Driving Licences) (Amendment) (No. 2) Regulations 2025, which extend to England, Wales and Scotland.
What an employer must check:
- The licence: a full category B licence. The extra allowance does not appear on it: GOV.UK says "There will be no change to your photocard driving licence to reflect this additional entitlement" (GOV.UK: driving an electric or hydrogen-powered vehicle).
- The van: that it is a zero emission vehicle (the regulations define it as having no internal combustion engine, or one with zero CO2 emissions) and that its plated maximum authorised mass is no more than 4,250kg. A diesel or plug-in hybrid van over 3,500kg still needs C1.
- Towing: the van and trailer together must not exceed 7,000kg, and the trailer never more than 3,500kg. With a 4,250kg van, the trailer is limited to 2,750kg.
- Familiarisation: not a legal requirement, but GOV.UK says that before driving a zero emission vehicle on a public road "you should" get familiar with the controls and "practise driving it in a safe, controlled environment". HSE's competence duty applies as it does to any vehicle, so THRIVE's view is that a recorded familiarisation drive is the simplest evidence of competence.
Other rules for these vans, such as drivers' hours and the MOT class, are in THRIVE's guide to tachographs for vans and its explainer on van payload and driving licence rules. Models in this weight band appear in the electric vans over 1,000kg payload list.
Licence categories employers check most
| Category | What it allows (GOV.UK) | What to check |
|---|---|---|
| B (test passed on or after 1 January 1997) | Vehicles up to 3,500kg MAM with up to 8 passenger seats; 4,250kg if zero emission. Trailer up to 3,500kg, combination up to 7,000kg | Fuel type and plated weight of vans over 3.5 tonnes |
| B (test passed before 1 January 1997) | "usually allowed" to drive a vehicle and trailer up to 8,250kg MAM | The record itself, as GOV.UK says to check |
| BE | A vehicle up to 3,500kg MAM with a trailer; trailer limit depends on the BE "valid from" date | Before 19 January 2013: any trailer within the vehicle's limits. On or after: trailer up to 3,500kg |
| C1 | Vehicles between 3,500kg and 7,500kg MAM, with a trailer up to 750kg | Driver CPC card if driving professionally; renewal by post at 70 |
Source: GOV.UK: driving licence categories.
Grandfather rights for pre-1997 drivers
A driver who passed a car test before 1 January 1997 usually holds more than category B. DfT explains that until that date "drivers who passed their car test also gained entitlement to drive a light lorry or van (C1 entitlement) without the need for a separate test", and that "Those drivers retained the 'grandfather right' to continue to drive vehicles up to 8.25 tonnes" (DfT driving licensing call for evidence, 2022). Drivers who passed a car test before 1 January 1997 also kept D1 with code 101. GOV.UK's comparison of old and new categories shows how these appear today: C1, C1E with restriction code 107 ("not more than 8,250 kilograms"), and D1 with code 101 ("not for hire or reward"). That is why a long-serving driver can take a 7.5-tonne lorry on what they think of as a car licence.
Three cautions for employers. The entitlement is on the record, so check it, never assume it. A professional C1 driver also needs a Driver CPC: GOV.UK says you must do 35 hours of periodic training every 5 years to keep it, and lists C1 among the lorry categories. And the C1 and D1 entitlements must be renewed by post at 70, because DVLA's online service cannot renew a C1 or D1 entitlement. A C1 vehicle also brings operator licensing into play; see THRIVE's operator licence and HGV compliance guide.
Data protection: lawful basis, offence data and retention
A licence check collects personal data, and penalty points and disqualifications relate to offences. The ICO says criminal offence data covers personal data "relating to" criminal convictions and offences, and "'Relating to' should be interpreted broadly"; even "The fact that a person has no criminal convictions is personal data 'relating to' criminal convictions" (ICO: what is criminal offence data). The ICO does not mention driving licences specifically. THRIVE's reading is that a record of endorsements falls within this broad definition, and the cautious course is to treat it so.
What that means in practice:
- A lawful basis under Article 6 of the UK GDPR. THRIVE's view is that most employers will look at legal obligation, given the duties described above, or legitimate interests. Record which you rely on.
- A Schedule 1 condition. The ICO says that if you keep records of criminal offences without official authority, you "must meet one of the 28 conditions in Schedule 1 of the DPA 2018" (ICO: collecting and keeping employment records). The ICO's table shows the "Employment, social security and social protection" condition needs an appropriate policy document, which the ICO describes as "a short document outlining your compliance measures and retention policies".
- Do not rely on consent. The ICO warns about consent where "you are in a position of power over the individual, eg you are a public authority or the individual's employer" (ICO: conditions for processing). The D906 is a declaration DVLA requires before it releases data; it does not have to be your data protection basis.
- Tell drivers. The ICO says you must give privacy information "at the time you collect their information". The D906 itself requires that the driver "is informed and understands how their driving licence information will be processed". Name the checks, their frequency and who sees the results in the driving policy and privacy notice.
- Keep only what you need. The ICO says data protection law "does not set specific time limits", and that you should "only keep the records you still need" and erase or anonymise the rest. Set a period in the appropriate policy document, for example keeping the latest check result and the date of each check while the person drives for you, plus whatever period your insurer or legal claims require.
The ICO notes that its employment and criminal offence data guidance is "under review and may be subject to change" because of the Data (Use and Access) Act. This guide will be updated when the ICO publishes revised guidance.
A policy checklist
- Scope: list every role that drives for work, including grey fleet, pool car users, agency drivers and occasional drivers, using HSE's definition of driving for work.
- Before first drive: check the licence with DVLA (check code or ADD), confirm the category matches the vehicle, and, for grey fleet, see insurance with business use, MOT and tax.
- Consent paperwork: hold a signed D906 for each ADD driver and diary its renewal before three years.
- Frequency: set intervals by risk in your risk assessment, and add trigger checks for a new vehicle category, a collision or a reported offence.
- Reporting duty: require drivers to report offences, points, disqualifications and relevant medical conditions immediately.
- Thresholds and actions: say what happens at set points levels, such as a conversation, training, or removal from driving duties, and who decides.
- Special cases: non-GB licences with their residence date, new drivers in their first 2 years, drivers approaching 70, pre-1997 C1 drivers and 4.25-tonne electric van drivers.
- Data: lawful basis, Schedule 1 condition, appropriate policy document, privacy notice and retention period, all written down.
- Review: review the policy every year and when the rules change, such as when the digital licence opens to employer checks.
Sample risk-based check schedule
This is an example written by THRIVE, not law and not official guidance. It shows one way to turn the risk approach into intervals. Set your own in your risk assessment and agree it with your insurer.
| Driver record | Example interval | Example action |
|---|---|---|
| 0 to 3 points | Every 12 months | None beyond the check |
| 4 to 6 points | Every 6 months | Conversation with line manager |
| 7 to 8 points | Every 3 months | Driver risk review or training |
| 9 points or more | Monthly | Formal review of driving duties |
| New driver (first 2 years) with any points | Every 3 months | Review, given the 6-point cancellation rule |
The 2018 ADLV industry recommendation cited above set monthly checks for drivers with more than nine points; this example starts the monthly band one point earlier, at 9. All the bands are THRIVE's illustration, built on the legal 12-point and 6-point thresholds.
About this guide
THRIVE researched this guide from GOV.UK, DVLA's developer portal and form D906, legislation.gov.uk, HSE's current driving for work guidance, the ICO's guidance, and Government Digital Service publications on GOV.UK Wallet.
It does not cover Northern Ireland, where licensing is devolved; medical fitness to drive and DVLA notifiable conditions; drivers' hours and tachographs, which are in the tachograph guide; or dismissal and employment law questions about drivers who lose their licence. It names no commercial licence-check providers.
The next scheduled review is 12 February 2027, or sooner if the digital driving licence opens to employer verification, DVLA changes the ADD fee or the D906, or the ICO publishes its revised guidance.
Free to quote and cite with a link to this page. Suggested citation:
THRIVE, "Driving licence checks for employers: how and how often", reviewed 12 Nov 2026. https://www.thrivefleet.co.uk/guides/driving-licence-checks-for-employers
Sources
legislation.gov.uk: Road Traffic Act 1988, section 87 - Offence of causing or permitting driving otherwise than in accordance with a licence. Checked 12 November 2026.legislation.gov.uk: Road Traffic Act 1988, section 143 - Offence of causing or permitting use without insurance; employee defence. Checked 12 November 2026.legislation.gov.uk: Road Traffic Act 1988, section 99 - Licence duration to age 70, then three years. Checked 12 November 2026.legislation.gov.uk: Health and Safety at Work etc. Act 1974, section 2 - Employer's general duty. Checked 12 November 2026.legislation.gov.uk: Management of Health and Safety at Work Regulations 1999, regulation 3 - Duty to make a suitable and sufficient risk assessment. Checked 12 November 2026.legislation.gov.uk: Conduct of Employment Agencies and Employment Businesses Regulations 2003, regulation 19 - Employment business must confirm qualifications and authorisations required by law. 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