Call for evidence outcome

Heavy vehicle testing review (HVTR) outcome

Updated 26 January 2024

Potential options

Four potential options for changes to testing for heavy goods vehicles (HGVs) and public service vehicles (PSVs) of operators in the earned recognition (ER) scheme were proposed. The options were:

Option 1- increase the time between tests for ER operators

Removing the requirement for ER operators to have vehicles tested every 12 months.

Option 2 - delegated testing

Allowing ER operators to test their own vehicles and trailers.

Option 3 - streamlined test

Reducing test content, such as removing some items that are covered in routine inspections or, in the longer term, those that can be effectively monitored by in-vehicle systems.

Option 4 - improved service provision. 

The Driver and Vehicle Standards Agency (DVSA) could focus its service improvement on ER operators, for example, by giving complete or greater guarantee of requested authorised test facility slots and greater flexibility around days and hours worked to match maintenance requirements.

Responses and government response

There was moderate support for change to the frequency of vehicle testing (option 1), but this was based on limited responses and evidence to support the possible benefits. It is our view that a change to the frequency of vehicle testing could increase road safety risks if not supervised properly and without adequate safeguards. 

Under option 2 there would be delegated tests every year. Unlike option 1, this would maintain the volume of data fed into ER, but it would mean that it is not under the control of the DVSA and may not be independent from the maintenance.

We also note that for many ER operators, there would only be a benefit of this option if ‘sub-delegation’ of testing by ER operators to third parties was possible. In which case responsibility for the quality of testing would be further complicated.  

For either of option 1 or 2 there are 2 main areas that the call for evidence did not provide significant information on. These 2 areas are to better understand: 

• whether ER ‘as is’ provides the confidence to implement either option and if adjustments can be made to ER to mitigate any risks of these changes 

• how the day-to-day practicalities could be handled, both from a legal and practical perspective  

Both options 1 and 2:

• increase choice for ER operators

• allow more opportunities to reduce unproductive time awaiting tests and fitting tests, including at short notice, around scheduling issues connected with business needs

 Set against these benefits  are the concerns that they would lessen or potentially remove roadworthiness data feeds.

Some comments within the call for evidence pointed out that some of the benefits of these options could be to reduce down time for vehicle preparation for test. This is a concern because the vehicle should meet, at least,  that minimum standard all of the time.

Understanding whether the removal of some or the delegation of all tests will result in this road safety risk is vital to having a clearer view on the way forward for either of option and if ER could now, with some modifications, mitigate this risk.  

Next steps

As a result we are suggesting further work will be done on the option 1 including an assessment of: 

• whether lessening test frequency will result in a reduction in in-use condition between those tests and whether change to ER can mitigate any such risk

• how to ensure ER continues to have sufficient data to be effective in identifying highly compliant operators with safe operating practices - this could include specific records of a periodic inspection of a relevant vehicle at the mid-point between the tests required every two years being included in ER data

• whether ER should be put on a statutory footing in association with any test changes

• whether to require a test to have been completed within the last year for vehicles used in international circulation

• the position of vehicles, both motor vehicles and trailers, which move between ER and non-ER operators

• the position of vehicles of operators who lose the ER status

• the procedures to implement the option for both HGVs and PSVs

Subsequently option 2 will continue to be assessed before a final decision is taken about which of the options to implement or whether to retain the status quo.  

Work on improving service provision, consistent with option 4,  is already being implemented as a ‘business as usual’ activity by DVSA for all operators. It does not require any legislative powers and is being taken forward now.