What Changed On 1 July 2026
Regulation (EU) 2020/1054, which amended the existing tachograph regulation (EU) 165/2014, extended the scope of the rules from vehicles over 3.5 tonnes down to light commercial vehicles with a maximum authorised mass (MAM) between 2.5 and 3.5 tonnes. As of 1 July 2026, any such vehicle used in the international carriage of goods for hire or reward, or in cabotage operations, must carry a second-generation smart tachograph (known as G2V2), the same generation of device already mandatory for heavy duty vehicles under the smart tachograph retrofit programme completed in 2025.
Alongside the hardware requirement, the driving and rest time rules that apply to HGV drivers now apply in full: a 9-hour daily driving limit (extendable to 10 hours twice a week), a 56-hour weekly limit, a 90-hour limit across any two consecutive weeks, a mandatory 45-minute break after 4.5 hours of driving, and daily rest periods of at least 11 hours. For a driver used to working to their own schedule in a van, that's a significant operational shift.
What Counts As International Transport
The trigger for this rule isn't vehicle size on its own, and it isn't distance travelled. It's two things happening together: the transport is for hire or reward (carrying goods for a paying customer, rather than the operator's own stock), and the journey is international, meaning it crosses at least one EU or EEA border, or counts as cabotage (domestic haulage carried out by a foreign-registered operator).
That rule covers a lot of vehicles. A single cross-border delivery run makes the vehicle and driver subject to the full regime for that operation, not just a proportion of it. There's no minimum distance exemption for a short hop across a border, even if the journey ends in the country it started in, and there is no allowance for an operator who only crosses occasionally. If the job is paid carriage and it crosses a frontier, the tachograph and driving-time rules apply.
What Fleets in Benelux, Switzerland and Austria Need To Check
The rule may hit hardest for operators who have never thought of themselves as international hauliers at all.
In Belgium, the Netherlands and Luxembourg a genuinely local delivery route often crosses a border as a matter of course. A van running between Maastricht and Liège, or Antwerp and Breda, is crossing a national frontier on what feels like a routine local job. The same is true of Luxembourg, tucked between three larger countries, where cross-border van work to serve nearby German or French towns is standard practice for small operators who've never considered themselves part of an "international" supply chain. A more extreme example comes from the town of Baarle-Hertog in Belgium. A trip from one part of the town to another can very easily start in Belgium, pass through the Netherlands, and end back in Belgium, having crossed the border several times en route.
Austria sits at the centre of eight neighbouring countries, and van operators running deliveries between Vorarlberg and Germany or Switzerland, or between Salzburg and southern Germany, cross a border as a matter of geography rather than any deliberate international expansion of the business.
Switzerland adds a further complication. It sits outside the EU, but the tachograph and driving-time rules apply there too, through Switzerland's bilateral transport agreement with the EU, which extends the same framework to Swiss-registered vehicles and to EU vehicles operating into Switzerland. A Swiss operator running a light van between Basel and Freiburg, or Geneva and Lyon, is firmly inside the scope of the law.
For fleets in this position, cross-border van work often also triggers posting-of-drivers obligations, requiring a declaration through the EU's IMI system and proof that the driver receives at least the host country's minimum pay for the time spent there. Tachograph data becomes part of the evidence a driver needs, and part of what a roadside inspector will check, on top of the driving-time rules themselves. A small operator who's never filed an IMI declaration, and never fitted a tachograph, can find themselves subject to both requirements at once.
The Exemptions Are Narrower Than They Look
Two exemptions carry over from the existing regulation, and it's important to be precise about where they end.
The craft or trade exemption covers vans carrying materials, equipment or tools that the driver will use to carry out their own work, such as a tradesperson travelling to a job with their own supplies, provided the journey stays within 100 km of the operator's base and driving isn't the person's main occupation. It does not cover a driver whose job is to deliver goods on behalf of paying customers.
The own-account exemption covers vehicles carrying goods that belong to the operator's own business, where the transport isn't carried out for hire or reward. A van moving a company's own stock between its own sites can fall outside the scope. A van carrying goods for a customer, on a paid job, cannot.
The practical effect is that most small operators running paid delivery, courier or distribution work across a border are inside scope, even if the exemption wording sounds like it might apply to them at first read. It's worth checking each regular route against both tests specifically, rather than assuming the business is covered because it's small.
What Small Fleet Owners Need to Do Now
- Audit the fleet by weight and route immediately. Identify every vehicle with a MAM between 2.5 and 3.5 tonnes, then check which of those run international or cabotage work for hire or reward, even occasionally. Any vehicle that qualifies has been operating outside the rules since 1 July 2026.
- Fit a G2V2 smart tachograph to every vehicle that falls inside scope without delay. Fitting demand across Europe has been high since the deadline, so installers in some regions may still be working through a backlog, which makes it worth booking sooner rather than later.
- Get a company card in place. Vehicles inside scope need the operator's company card registered before download and audit obligations can be met.
- Set up a 28-day and 90-day download routine. Driver card data must be downloaded at least every 28 days, and vehicle unit data at least every 90 days, with records kept for a minimum of 12 months. If a vehicle has been in scope since 1 July, the first of those deadlines has already passed, so this routine needs setting up alongside the tachograph fit, not afterwards.
- Train all drivers on the driving and rest time limits, not just on how to use the tachograph itself. A driver used to organising their own day around deliveries needs to understand the 9-hour, 45-minute break and 11-hour rest rules now, given that roadside checks can happen on any cross-border run from here on.
For an operator running two or three vans who has never handled tachograph data before, a straightforward manual downloader is usually the right starting point rather than a full depot infrastructure. It's worth comparing the options in more detail to make sure you make the most suitable choice for your circumstances. For example, the Lisle Digidown and DigidownPlus units are built for exactly this scale of fleet, downloading both driver card and vehicle unit data via USB or SD card with no software licence to manage. For fleets running regular cross-border routes where a van might not return to base for days, DigidownRDL downloads remotely over the mobile network, so a missed 28-day deadline because the vehicle was on the road in another country stops being a risk at all. Check how remote tachograph downloads work to understand the mechanism in full.
The Cost of Getting It Wrong
Enforcement of the law is national, and the penalties vary sharply by country. With the rule now in force, authorities are including light commercial vehicles in the same roadside checks already used for HGVs, so a van without the required equipment is as exposed to inspection as a lorry. France can impose fines of up to €30,000 alongside vehicle seizure. Poland's administrative penalty runs to €12,000, with the vehicle's registration certificate retained until it's resolved. The Netherlands fines €4,400 for operating without approved equipment, and Germany €1,500. For a small operator, the practical impact goes beyond the fine itself:
- A van stopped without a compliant tachograph can be immobilised at the roadside, in a country where the operator has no local depot or support.
- The driver may be stranded until the vehicle is released, with knock-on costs for the delivery and the next job in the schedule.
- Larger customers increasingly require proof of tachograph compliance from every subcontractor before awarding cross-border work, regardless of vehicle size.
Closing the Compliance Gap
The 2.5-tonne threshold caught a segment of the fleet that had previously never had to think about tachograph compliance, and the routes most likely to have tripped the international-transport trigger without anyone noticing are the short, familiar, cross-border runs that Benelux, Swiss and Austrian operators undertake every week. The rule has been in force since 1 July 2026, so checking each regular route against the new rule, rather than against what feels like a local job, is now the single most urgent thing an operator that isn't yet compliant can do.
If you're still working out which download hardware fits a fleet that's just moved into scope, please get in touch and our experts will be happy to talk through what best suits your routes.
