The legal obligation to train drivers on driving times and the use of the tachograph rests with the company or transport operator. For drivers of 3.5-metric-ton vehicles, a CPC certificate is not required; however, the company must be able to clearly demonstrate that the training was conducted and documented.
In short, proper proof of training includes:
- Reducing the risk of fines, negative audit findings, and being found to lack organization.
- Individual training record, signed by the driver and the instructor.
- Written materials, such as internal procedures, manuals, or presentations.
- Topics related to Regulations 561/2006 and 165/2014.
- Review test, recommended to demonstrate understanding of the rules.
- A complete individual file for each driver.
- Appointing a person responsible for training.
- Filing documents for presentation during an audit.
- Avoid giving verbal explanations without written evidence.
- The option to conduct in-house training without an accredited trainer.
1. Who Has a Legal Obligation to Provide Training
The legal obligation to provide training rests with the company or transport operator, not the driver.
This obligation stems from the principles set forth in:
• Regulation (EC) No. 561/2006;
• Regulation (EU) No. 165/2014.
The operator is required to organize operations so that drivers can comply with the rules regarding driving times, breaks, and the use of the tachograph. This directly includes training drivers.
The CPC is a standardized form of training applicable to drivers with a C/C+E license, but it is not the only accepted form of training and is not mandatory for the 3.5-metric-ton segment.
2. What Regulatory Authorities Require in Practice
During inspections, the authorities do not request the CPC certificate, but instead ask:
“How do you prove that your drivers know the rules and have been trained?”
In the absence of documented proof, there is a real risk that the company will be penalized, even if the violation was committed by the driver.
3. What constitutes admissible evidence in a criminal investigation
3.1. Minutes / Individual Training Record
This is the key document in the event of an inspection. It must include:
• company information;
• the driver’s first and last name;
• the date of the training;
• the training topics;
• the driver’s signature;
• the signature of the person who conducted the training.
3.2. Written training materials
The company must be able to present written materials used for training, such as:
• pocket guide;
• internal procedure regarding the tachograph;
• internal presentations (in print or digital format).
During the inspection, the focus is not on the appearance of the documents, but on their existence, consistency, and whether drivers had actual access to them.
3.3. Training Test
The training test is not legally required, but it is highly valued during inspections. It demonstrates that the training was actually completed.
Example:
• multiple-choice test with 10–15 questions;
• signed by the driver;
• filed in the record.
3.4. Driver's Individual File
Each driver’s individual file may contain:
• employment contract;
• job description;
• tachograph training record;
• proof of materials handover;
• training test, if applicable.
Presenting this file has a major positive impact during inspections.
4. What is NOT enough
The following explanations are NOT considered sufficient in the absence of documentation:
• “I told him what to do”;
• “He already knows”;
• “He has worked at another company before”;
• “He has experience.”
Without written documentation, the training does not exist from a legal standpoint.
5. Who Can Conduct the Training
Training may be conducted by:
• the company administrator;
• the transportation manager;
• an experienced dispatcher;
• an external consultant.
An accredited trainer is not required. Proof of training is required.
6. Example of a Correct Answer on the Test
Inspection: “The driver made a mistake using the tachograph. How was he trained?”
Correct response from the company:
“The driver received in-house training on Regulations 561/2006 and 165/2014. We have an internal procedure, a pocket guide, a training sheet, and a signed test.”
In most cases, this response shifts the responsibility to the specific violation, not to the lack of a compliance system.
7. The Consequences of a Lack of Evidence
A lack of evidence of training can lead to:
• a fine imposed on the company;
• a finding of poor organization;
• negative findings during repeat inspections;
• difficulties with audits and large contracts.
8. Conclusion
The responsibility for training lies with the company. A CPC is not required for drivers of 3.5-metric-ton vehicles, but documented training is mandatory.
In-house training is perfectly legal and sufficient only if it can be clearly demonstrated.
Frequently Asked Questions
Founder and CEO of Paneuropa Logistics
I am György Bokor, Founder and CEO of Paneuropa Logistics. I have been active in the logistics industry for more than 20 years, focusing on international transportation, freight forwarding, last-mile deliveries and customs services. I am passionate about developing efficient solutions that connect businesses across Europe.