Consultation outcome

Driver CPC changes: overview of responses and government response

Updated 11 December 2023

Executive Summary

This document: 

• summarises the responses to the consultation on potential changes to the Driver Certificate of Professional Competence (DCPC) qualification 
• details the government’s responses and decisions for future delivery after careful consideration of the contributions received and review of the impacts of implementing reforms

A total of 1,190 consultation questionnaire responses were received, as well 16 position papers from industry stakeholders. The department also received 177 emails which were free text based on the proposals without answering the consultation questions directly. We would like to thank all respondents for their contribution.

Whilst there was a range of views, the principle of reforming DCPC was strongly supported. Furthermore, most respondents agreed with proposals for reforms to periodic training, e-learning, returning drivers, short term exemptions and extensions as well as electronic Driver Qualification Cards (DQCs). Views were also sought on proposals for a test option for periodic renewal.

Having considered these views, the government has decided DCPC will benefit from reforms to increase flexibility when renewing and regaining the qualification. To do this the government will:

• consult further on introducing a new periodic test as an alternative to 35 hours of training, for drivers looking to renew their DCPC – this would also be available for drivers looking to return to the sector and will form an accelerated return pathway for them
• reform training by reducing the minimum course length from 7 hours down to 3.5 hours
• decouple e-learning from trainer-led courses
• develop with the Driver and Vehicle Standards Agency (DVSA) more core course content and encourage informal assessment at the end of modules

Changes for training reforms will be brought into force through secondary legislation using powers within the Retained EU Law (Revocation and Reform) Act. The intention is to bring forward this secondary legislation to commence in summer 2024 but this will not include the introduction of the new periodic test. Proposals for periodic testing will be brought into force at a later point which could be via secondary legislation or further to a slot in an appropriate bill, and will be the subject of further consultation.

Background

The Driver Certificate of Professional Competence (DCPC) was introduced in 2007, from the European Union Directive 2003/59/EC.  This was transposed into domestic legislation by The Vehicle Drivers (Certificates of Professional Competence) Regulations 2007 (as amended), with DCPC coming in force from 2008 for passenger transport and 2009 for goods transport.

The DCPC is a qualification that professional drivers of certain goods or passenger carrying vehicles are required to hold in addition to their driving licence. In the United Kingdom (UK), except in the case where a driver had ‘acquired rights’, it is initially obtained by completing 4 modularised tests consisting of a 2-part theory test, case studies, a practical driving test and a practical demonstration of vehicle operation. DCPC is then renewed by completing 35 hours of periodic training every 5 years. Completing 35 hours of training allows a driver to drive for commercial purposes for 5 years.

The main objectives of DCPC, when introduced, were to improve road safety and the safety of the driver, including during operations carried out by the driver while the vehicle is stopped and to raise the professional recognition of drivers, thereby attracting greater interest in the profession and increasing the number of drivers.

Consultation activity

As a result of the acute driver shortages in 2021, the government announced a policy review into DCPC on 8 November 2021. The review sought to assess how the qualification could be reformed to reduce the burden on drivers and ensure it does not act as a barrier to working in the sector.

The outcome of this review, published on 2 March 2023, proposed ways in which the qualification could be reformed, which were put to public consultation also on 2 March 2023. The consultation was promoted through the department’s website, briefing mainstream media as well as trade press and through direct contact with potential consultees.

Two webinars and further stakeholder events were held during the consultation period with papers submitted by members from these latter events being considered as part of the review process. The events provided an opportunity to explain the proposals and explore aspects of them in depth.

Respondents to the consultation were asked to complete a survey, either online, or by downloadable form and sending to the department via email or post.

Summary of responses

A total of 1,190 consultation questionnaire responses were received. These came from a range of organisations and individuals. The breakdown of survey responses is shown within the following table by stakeholder group.

Stakeholder group	No. Respondents	Percentage
Professional Driver	753	63%
Operator	161	14%
Trainer	184	15%
Other	92	8%
Total	1,190	100%

Among ‘professional drivers’, 607 respondents stated they were currently driving professionally and 146 that they had previously been professional drivers. ‘Operators’ are businesses employing either bus and coach or lorry drivers. Among operators, 40 respondents said they employ coach or bus drivers and 121 respondents that they employed lorry drivers. Amongst the ‘other’ group, 62 respondents stated they were other individuals, 18 that they were other types of organisation, 7 were industry representatives and 5 were road safety organisations.

Whilst the free text-based emails and position papers received have not been counted individually as part of the quantitative responses to the survey, they have been reviewed and considered as part of this response to the consultation.

Analysis of methodology

The consultation document presented the case for change. It proposed approaches for:

• a new periodic test
• reforms to periodic training, including in relation to e-learning
• a new process for returning drivers
• short term exemptions and extensions in exceptional circumstances
• an exchange and recognition scheme for non-UK qualifications as well as electronic Driver Qualification Card (DQCs)

The department invited responses on the suitability of these proposals which, if taken forward, would create 2 parallel systems for periodic renewal within Great Britain (GB). One system would be the existing International DCPC (I-DCPC) regime permitting travel to, from or within the EU and UK, and the other a National DCPC (N-DCPC) permitting travel for GB operators only within GB or Northern Ireland (NI), with ministers’ consent.

DCPC is devolved in Northern Ireland. The NI devolved administration has indicated that the proposed changes related to periodic training and returning drivers planned for implementation in 2024 in Great Britain should extend to Northern Ireland.

We would like to thank all respondents, some of whom supplied detailed comments in addition to their responses to the closed, often multiple-choice, style questions. This document comments on both the quantitative results of and sentiments within those open questions as an indication of overall sentiment towards the proposal, with detailed analysis of the qualitative, or free text, responses conducted to assess the suitability of the proposed approaches. In order to do this, the qualitative/free text responses were grouped into core themes, allowing for the identification of key trends, concerns, or suggestions.

For ease, in most cases, stakeholders are described in the general terms of ‘professional driver’, ‘operator’, ‘trainer’ or ‘other’, rather than to identify individual personnel. However, where the question warrants, in some cases these are broken down further and, in the case of some organisations which have a particular role in representing the interests of a given group, they have been identified.

Proposals

The department proposed the following reforms to the DCPC qualification as part of the consultation:

a. The introduction of a pass/fail test as an alternative, parallel option, to periodic training, so drivers have increased choice.
b. Removal of the current minimum duration for training courses, currently set at 7 hours, or 3 and a half hours when completed over 2 consecutive days.
c. Removal of the requirement to complete split courses, including where part of this contains an element of e-learning, over 2 consecutive days.
d. The introduction of a new specific pathway for previously experienced drivers, or returning drivers, to re-join the sector.
e. Permitting short term extensions to existing DCPCs and short term exemptions from needing a DCPC in exceptional circumstances.
f. The introduction of an exchange and recognition scheme for driving qualifications obtained outside the UK.
g. Removal of the requirement to carry a DQC while driving, with evidence of someone having a DCPC being electronically stored.

Each of these proposals will be dealt with by providing a summary of the responses received followed by the government’s position. Due to the scale of the original consultation survey, it is not deemed appropriate to provide a summary of every single question here.

On the GOV.UK home page for this consultation, you can also find:

• a document containing further analysis of the qualitative responses by consultants ICF
• a document containing a list of all questions asked and responses to questions not analysed within this document or the ICF report

Questions in this document start at number 32, as questions before this were mainly qualifying questions asking respondents about whether they held a DCPC, their intentions for renewal, as well as asking drivers and operators about payment of the DCPC qualification.

Appetite for reform

We asked a range of questions in the consultation asking for respondents’ views on the current effectiveness of DCPC in meeting its stated aims, and on the appetite for reforming it.

Question 32: In your opinion, how effective is DCPC currently in meeting its stated aims of improving:

Road safety?

	Very Effective	Effective	Neither Effective or Ineffective	Ineffective	Very Ineffective	Don’t know
Professional Driver	41	125	228	172	178	5
Operator	18	43	49	22	27	1
Trainer	38	88	32	16	8	0
Other	7	30	25	19	9	1
Total	104	286	334	229	222	7
Total percentage	9%	24%	28%	19%	19%	1%

Professionalism of drivers?

	Very Effective	Effective	Neither Effective or Ineffective	Ineffective	Very Ineffective	Don’t know
Professional Driver	43	113	245	161	183	4
Operator	16	45	44	20	32	1
Trainer	38	78	36	19	10	1
Other	7	25	29	19	9	2
Total	104	261	354	219	234	8
Total percentage	9%	22%	30%	19%	20%	1%

Summary of responses

33% of respondents reported that DCPC was either effective or very effective at improving road safety, compared to 38% of respondents saying it was either ineffective or very ineffective. These numbers are influenced by the number of drivers responding being larger than other groups – 63% of respondents were drivers. 47% of drivers said DCPC was ineffective or very ineffective at improving road safety.

Amongst all other groups, more respondents felt DCPC was effective or very effective (52%) compared to being ineffective or very ineffective (23%). This was most prevalent for trainers with 69% believing it was either effective or very effective at improving road safety. The results for operators were more marginal with 38% responding DCPC was effective or very effective, against 31% who thought it was ineffective or very ineffective and a further 31% thinking it was neither effective nor ineffective in improving road safety.

In terms of professionalism of drivers, results were similar to those for road safety with 31% of respondents thinking DCPC was effective or very effective at improving professionalism of drivers and 39% thinking that it was either ineffective or very ineffective. Again, drivers were more likely to think that DCPC was ineffective or very ineffective at improving professionalism (45%), while for all other groups, more respondents believed it was effective or very effective (38%) compared to ineffective or very ineffective (23%). This was more prevalent amongst trainers with 64% believing DCPC improved professionalism.

For operators, 38% felt that DCPC had been effective or very effective in improving professionalism of drivers, with 33% responding it was either ineffective or very ineffective.

Respondents had the opportunity to provide further information as to why they thought DCPC’s aims of improving road safety and professionalism of drivers were or were not being met. For employers who responded that DCPC was meeting these aims, this was mainly attributed to the fact that training could be tailored to needs. Training providers most commonly stated that DCPC allowed drivers to remain up to date on sector legislation and emerging issues, with this opinion also shared by drivers.

Drivers who said DCPC was not meeting its aims most commonly stated a lack of new content which means repetition of what went before. Some also reported that they do not believe it provides good value in terms of time spent or cost.

Some operators who felt DCPC was not meeting its aims raised concerns that the training content is quite generic and not specific enough for their drivers. However, this was contrasted by some including Wincanton and The Road Transport Industry Training Board (RTITB) who both felt the DCPC was either effective or very effective in improving road safety and the professionalism of drivers. Wincanton explained that since DCPC’s inception “driver training has improved, and this flows through to standards of driving and associated compliance”.

Question 33: In your opinion, does DCPC need reforming?

	should stay the same	should be reformed	should be abolished	Don’t know
Professional driver	72	257	402	15
Operator	21	105	35	0
Trainer	34	141	7	1
Other	11	67	13	1
Total	138	570	457	17
Total percentage	12%	48%	39%	1%

Summary of responses

48% of respondents said that DCPC should be reformed, 39% that it should be abolished and 12% that it should stay the same. Support for abolishing DCPC was mainly among drivers (54%), which was contrasted by only 13% of all other respondents who were not professional drivers. 72% of all other respondents who were not professional drivers were in support of reform.

Respondents had the opportunity to provide further information as to why they felt DCPC should stay the same, be reformed or abolished. Most professional drivers who said DCPC should be abolished stated that the expense and time required outweighs the value it brings. Some also reported that it was a deterrent to join or stay in the industry and a few explicitly expressed it was leading drivers with long-term experience to leave the sector as they did not feel they needed training.

Drivers in favour of reform mostly felt that training was useful, but courses should be shorter and more flexible to fit in with their workloads. These opinions were also shared by employers.

Employers wanting DCPC to remain the same mainly felt that training allowed for content to be tailored to driver and company needs and that a single form of DCPC eliminates confusion for cross-border operations.

Trainers supporting DCPC staying the same most commonly said the current system worked well and were concerned that changes could reduce standards and create added complication and confusion.

Question 36: The changes you think are necessary to reform DCPC

	Driver	Operator	Trainer	Other	Total	% of people responding to this question*
introduce a test option for DCPC periodic renewals?	203	83	73	40	399	50%
offer more flexibility in DCPC training requirements?	206	86	116	50	458	57%
continue developing core content for training modules?	159	59	106	37	361	45%
use more informal assessments after training courses?	106	53	76	21	256	32%
introduce new requirements for drivers looking to re-join the sector?	97	56	62	30	245	31%
allow short-term extensions to DCPC validity periods in exceptional circumstances?	101	51	48	31	231	29%
allow short-term exemptions from needing a DCPC in exceptional circumstances?	66	34	35	20	155	19%
allow the recognition or exchange of qualifications, similar to DCPC, but obtained outside of the UK?	67	29	40	24	160	20%
remove the need for drivers to carry a Driver Qualification Card (DQC) when driving in the UK?	190	56	53	27	326	41%
add another issue or issues?					167	21%

*799 people responded to these questions; the percentages show how many of these 799 people supported each statement.

Summary of responses

The top 4 reforms in order of support were more flexible training requirements, introduction of a test option, continuation of development of core content for training and removal of the need to carry a Driver Qualification Card (DQC) when driving in the UK. All these measures were supported by over 40% of respondents answering this question.

Respondents were provided with the opportunity to provide other issues or reforms as a free text response, with 167 doing this. For other reforms, professional drivers’ most common response was a reduction in the length of training courses and allowing other relevant courses to be counted, for example, one-day refresher courses and First Aid at work. These opinions were shared by operators and other respondents. Respondents from all groups suggested more choice of courses, improvements to quality and removing the ability for drivers to repeat courses. Both drivers and trainers supported more in-cab training.

Training providers suggesting other reforms as a free text response most frequently mentioned a reduction in the 35 hours of training, with some suggesting 25 hours and a focus on quality over quantity. This view was echoed by the RTITB.

Question 43: How important is it that Great Britain and Northern Ireland have the same options for renewing DCPC?

	Important	It makes no difference	Unimportant	Don’t know
Professional driver	209	130	64	33
Operator	73	33	19	9
Trainer	118	23	15	13
Other	47	12	8	10
Total	447	198	106	65
Total percentage	55%	24%	13%	8%

Summary of responses

55% of respondents felt that it was important that Great Britain and Northern Ireland had the same options for renewing DCPC.

Government position

DCPC will be reformed.

We acknowledge the aims and objectives of DCPC to improve road safety and professionalise the sector. From the consultation responses, it is recognised that there are varying views on DCPC’s current effectiveness and that to an extent these differ by the basis on which people responded (for example, professional drivers, operators, training providers etc).

We asked in the consultation for specific evidence that DCPC has improved road safety, but it remains the case that demonstrating a clear causal link is challenging. However, DfT statistics demonstrate that from 2007 (the year before drivers were required to hold the DCPC qualification) to 2020, the number of accidents HGVs have been involved in has declined. During this period, accidents involving cars also fell, however, the percentage decrease in accidents in this period was considerably higher for HGVs than it was for cars (68% decrease compared to 54%).

Road safety organisations, namely the Royal Society for the Prevention of Accidents (RoSPA) and the Parliamentary Advisory Council for Transport Safety (PACTS) both felt DCPC was effective in improving road safety, citing the evidence above, which was supported by stakeholders including Wincanton and RTITB, with Wincanton stating that since DCPC’s inception “driver training has improved”, and this “flows through to standards of driving and associated compliance”.

Whilst a slight majority of drivers supported abolishing DCPC (54%), a sizeable minority (44%) wanted to see DCPC kept as it is or reformed (with the remainder saying ‘don’t know’). Furthermore, overwhelming numbers of other respondents either wanted to keep DCPC as it is or reform it (87%). While we recognise the views of drivers, many of their concerns related to the fact that the time and cost implications outweighs the benefits they bring. Reforms (as outlined in subsequent sections of this document) will directly address these issues, reducing burdens and increasing flexibility, whilst continuing to recognise the important role that DCPC brings in supporting road safety and professionalism in the sector, as reflected by many respondents within the consultation.

In consideration of all these factors, the government intends to keep but reform DCPC, with the nature of this reform being outlined in specific sections of this consultation response. This reform will mean the creation of 2 parallel systems for DCPC, a National DCPC (N-DCPC), and an International DCPC (I-DCPC), the current DCPC regime which complies with the terms agreed in the UK/EU Trade and Cooperation Agreement (TCA).

Both will permit driving within Great Britain and Northern Ireland, should devolved authorities agree. However, only the I-DCPC will also permit driving to, from or within the EU. It is recognised that some concerns were raised over the introduction of parallel systems, for example in terms of creating confusion, but this is a necessary product of introducing reform and it is our view that delivery of these reforms justifies this. The department will work closely with the Driver and Vehicle Standards Agency (DVSA) to ensure these are implemented and communicated in clear and manageable ways.

These changes will, where possible, be made using the Retained EU (Revocation and Reform) Act (REUL) and will apply to the UK.

Proposals for N-DCPC periodic test

It was proposed in the consultation to introduce a pass/fail test as an alternative to periodic training (reformed or otherwise) for drivers seeking to renew their DCPC qualification who only drive domestically. The consultation considered different options for implementation of a periodic test, which included a new periodic test or re-sitting of the initial test, or an initial test re-sit of modules 1 and 2 of the initial DCPC qualification.

Question 40: Overall, do you support the proposed changes under the N-DCPC ‘periodic test’ option?

	Yes	No	Don’t know
Professional driver	229	151	56
Operator	85	38	11
Trainer	70	87	9
Other	49	22	6
Total	433	298	82
Total percentage	53%	37%	10%

Summary of responses

Over 53% of respondents supported the proposal of introducing a periodic test, with 64% of ‘other’ respondents, 63% of operators, 53% of drivers and 42% of training providers being in support. This contrasted to 35% of drivers, 28% of operators, 29% of others and 52% of trainers who opposed the introduction of a test.

Question 41: (for those who answered ‘yes’ to question 40) Do you think N-DCPC periodic test will:

	Driver	Operator	Trainer	Other	Total	Percentage of people responding to this question
Save time	165	65	48	36	314	73%
Provide better work-life balance	122	43	33	17	215	50%
Make renewing DCPC cheaper	173	64	42	33	312	72%
Help attract and retain drivers	162	64	53	39	318	74%
Be beneficial for another reason					97	22%

*432 people responded to this question and could select more than one option. This shows how many of the 432 respondents supported each statement.

Summary of responses

Of the respondents in favour of the test, 74% believed that this would help attract and retain drivers and 72% believed this would reduce costs.

Of the respondents saying the test would be beneficial for another reason, most said that this would demonstrate knowledge, with others noting that this would drive engagement and highlight knowledge gaps.

Question 42: (for those who answered ‘no’ to Q40) Do you think N-DCPC periodic test will:

	Driver	Operator	Trainer	Other	Total	Percentage of people responding to this question*
Add cost	76	11	20	7	114	39%
Add time	59	14	21	5	99	34%
Lead to confusion	92	21	57	16	186	63%
Lead to shortage of international drivers	67	15	31	6	119	40%
Be damaging for another reason					146	49%

*295 people responded to this question and could select more than one option. This shows how many of the 295 respondents supported each statement.

Summary of responses

The main concern among respondents opposed to the test is that it would lead to confusion (63%). 49% responded that this would be damaging for another reason. For those saying this, employers most commonly reported concerns were a reduction in depth and quality of learning that would arise from the test option and that the test should not be a substitute for training. A few employers were also concerned about a potential shortage of test slots.

Amongst training providers responding that it would be damaging for another reason, the most common concern is that it would have a negative impact on road safety. However, they did not explain why this would be the case. Some respondents also felt focus would change from learning to passing a test which would lower standards and result in the loss of peer-to-peer interaction as well as cost and time burdens if drivers were to fail. These opinions were echoed by some drivers.

Question 45: (for drivers and operators) If there was a choice between, I-DCPC training, N-DCPC training or N-DCPC reformed test which would you choose?

	N-DCPC periodic test	N-DCPC reformed training	I-DCPC
Professional driver	152	89	91
Operator	68	30	24
Trainer	31	41	37
Other	23	12	5
Total	274	172	157
Total percentage	45%	29%	26%

Summary of responses

45% of respondents would choose the N-DCPC periodic test if given the choice. Support for the test was especially prevalent amongst operators with 56% saying it was their preferred choice compared to 46% of professional drivers and 28% of trainers.

For professional drivers, there was an even split between N-DCPC and I-DCPC training with 27% supporting both, however, across other groups there was a slight preference for reformed training with 25% of operators in favour of reformed N-DCPC training. This is opposed to 20% favouring I-DCPC. Amongst trainers, there were 38% in favour of N-DCPC training as opposed to 34% in favour of I-DCPC.

Question 54: Would you support giving drivers the choice of completing the N-DCPC ‘Periodic Test’ option along with the existing I-DCPC and N-DCPC ‘Reformed Training’ option?

	yes	no	Don’t know
Professional driver	241	109	82
Operator	74	43	15
Trainer	79	66	24
Other	43	21	12
Total	437	239	133
Total percentage	54%	30%	16%

Summary of responses

54% of people supported the provision of a periodic test option for renewal of the DCPC. Trainers were likely to be less supportive of the test option, with 47% supporting as opposed to 56% of drivers and operators and 57% of ‘others’. In contrast, 30% were against the choice of a periodic test, which was lower for drivers with only 25% opposed compared to 33% of operators, 39% of trainers and 28% of others.

Question 60: of the 2 test options, which do you think is the best option for drivers renewing their DCPC?

	The ‘New periodic test’	The ‘Initial test resit’	I have no preference	Don’t know
Professional driver	186	27	105	51
Operator	62	9	27	11
Trainer	63	12	45	10
Other	38	7	15	3
Total	349	55	192	75
Total percentage	52%	8%	29%	11%

This question asks respondents their preference between the new periodic test and initial test re-sit. Both options would allow drivers to take a pass/fail test as an alternative to 35 hours of training. Under the proposal for the new periodic test, drivers would complete a 60-90 min test consisting of multiple choice and situational judgement questions. Under proposals for an initial test re-sit, drivers would re-sit the theory element of the initial CPC.

The new periodic test was the favoured option with 52% supporting this and only 8% supporting the initial test re-sit. The new periodic test was substantially preferred over the initial test re-sit across all groups, supported by 50% of professional drivers, 57% of operators, 48% of trainers and 60% of others.

Question 46 and 47: In your opinion, how effective could the ‘New periodic test’ be in meeting its stated objective of improving road safety:

	Very Effective	Effective	Neither Effective or Ineffective	Ineffective	Very Ineffective	Don’t know
Professional driver	102	118	75	40	79	22
Operator	39	36	14	11	26	8
Trainer	27	44	20	23	52	3
Other	26	20	4	12	13	2
Total	194	218	113	86	170	35
Total percentage	24%	27%	14%	11%	20%	4%

Question 48 and 49: In your opinion, how effective could the ‘New periodic test’ be in meeting its stated objective of improving professionalism of drivers:

	Very Effective	Effective	Neither Effective or Ineffective	Ineffective	Very Ineffective	Don’t know
Professional driver	97	113	80	39	89	18
Operator	37	33	22	6	27	9
Trainer	25	42	22	23	52	4
Other	21	22	8	9	11	5
Total	180	210	132	77	179	36
Total percentage	22%	26%	16%	9%	22%	4%

Summary of responses

These responses are on new periodic test proposal. Of the 2 proposed test options (initial test re-sit or new periodic test) this was the most favoured option. 51% of respondents believe the new periodic test is likely to be effective or very effective in meeting the stated objectives of DCPC for improving road safety with 31% saying it was likely to be ineffective or very ineffective.

48% of respondents believe the new periodic test is likely to be effective or very effective in meeting the stated objectives of DCPC for improving professionalism of drivers with 31% saying it was likely to be ineffective or very ineffective.

In open text responses, those who felt the new periodic test would improve road safety and professionalism of drivers most commonly said that this would show proof of knowledge and understanding as well as ensure drivers stay up to date on legislative changes. A few drivers mentioned that this could also save time and money.

Some employers also suggested it would create a feeling of achievement amongst drivers. Relevant quotations include “The test would provide a quantifiable result to show that the training has been taken in” and “Though would not be suitable for all drivers, especially those who find a formally test intimidating” (Lorry/bus/coach driver employers) and “Instead of drivers sitting and potentially not taking in the information during training, they will need to be up to speed in order to sit and pass the test.” (Lorry/bus/coach driver employers)

For those who felt the new periodic test would be ineffective or very ineffective at improving road safety, a few raised concerns that this would only confirm abstract knowledge and not at the depth training allows. Some employers had concerns that testing could become a box ticking exercise, which was echoed by the RTITB who added that they felt this would undermine and weaken the necessity to undertake regular training that is professional and structured, which was the most common response amongst the ‘other’ group. Some trainers also felt it could change the focus of learning to passing exams.

Question 50 and 51: In your opinion how effective could the ‘Initial test re-sit’ be in ensuring DCPC meets its stated objective of improving road safety?

	Very Effective	Effective	Neither Effective or Ineffective	Ineffective	Very Ineffective	Don’t know
Professional driver	77	104	93	30	84	47
Operator	33	37	22	9	20	13
Trainer	25	49	28	17	41	8
Other	15	26	11	9	10	6
Total	150	216	154	65	155	74
Total percentage	18%	27%	19%	8%	19%	9%

Question 52 and 53: In your opinion how effective could the ‘Initial test re-sit’ be in ensuring DCPC meets its stated objective of improving professionalism of drivers?

	Very Effective	Effective	Neither Effective or Ineffective	Ineffective	Very Ineffective	Don’t know
Professional driver	68	96	94	38	78	58
Operator	30	33	28	8	19	14
Trainer	23	46	28	18	44	9
Other	15	20	12	6	12	10
Total	136	195	162	70	153	91
Total percentage	17%	24%	20%	9%	19%	11%

Summary of responses

These responses are on the initial test re-sit proposal. Of the 2 proposed test options (initial test re-sit or new periodic test) this was the least favoured option. For road safety, 45% of respondents believe the initial test re-sit is likely to be effective or very effective in meeting the stated objectives of DCPC for improving road safety with 27% saying it was likely to be ineffective or very ineffective.

For professionalism of drivers, 41% of respondents believe the initial test re-sit is likely to be effective or very effective in meeting the stated objectives of DCPC for improving professionalism of drivers with 28% saying it was likely to be ineffective or very ineffective.

In open-text responses, the views of drivers on the initial test resit were similar to those of the new periodic test, with most thinking it was effective in improving road safety saying it would require and demonstrate a good revision of knowledge to keep up-to-date on new developments and provide proof of knowledge. Some drivers saying it would be ineffective reported that it could be detrimental for those not adept at examinations and may dissuade drivers from staying or joining the industry. A few also felt training was better because testing does not necessarily equate to knowledge and learning.

In open-text responses, some respondents stated that the test would not demonstrate the level of knowledge drivers have gained and may be too narrow. Others said that re-sitting the test would not be a means for providing learning, although it could encourage drivers to revisit learning material and encourage knowledge retention and learning.

Question 64: In the case of dual licence holders you think they should:

	have to take both tests, the bus and lorry periodic test, for qualification to drive both sets of vehicles?	only have to pass either the bus or lorry periodic test for qualification to drive either set of vehicles?	Don’t know
Professional driver	122	53	21
Operator	54	16	8
Trainer	73	17	4
Other	26	6	2
Total	275	92	35
Total percentage	68%	23%	9%

Summary of responses

68% of respondents felt that for the test, drivers who hold a dual licence (a licence to drive both a bus and a lorry) should have to take tests for both of these to maintain their qualification for both vehicles. This is supported by the responses to questions 62 and 63 which asked, in the case of the initial test re-sit and the new periodic test, whether there should be different tests for the different licence categories (category D for bus and coach and category C for lorries). Over 59% of respondents were in favour of separate tests for the initial test re-sit and 61% for the new periodic test.

Government response

As part of the consultation, the department proposed introducing a test that would give drivers the option to take this or reformed training for renewal of N-DCPC. After reviewing all available evidence, including the consultation responses and considerable further stakeholder engagement, and assessing the benefits and disbenefits, we have decided to consult further on testing. This will include asking for views on the possible model through which the test could be delivered and on how effective this would be in delivering on DCPC’s aims (improving road safety and increasing professionalism of the sector).  

A periodic test for N-DCPC renewal was supported by a majority (53%) of consultation respondents, including 53% of drivers. There is clear evidence demonstrating that drivers and operators feel a test would provide a better work-life balance with 50% selecting this as a reason for introducing a test, with 74% saying it would help attract and retain more drivers and 72% that it would make renewing DCPC cheaper.

Considering open text responses to the consultation provides more granular evidence for this, for example in these drivers most frequently reported that the test option will provide proof of knowledge, and, as one stated, this will give drivers “some professional pride”. A few also said that it will highlight knowledge gaps and will enable greater productivity as drivers will have less missed time out from work (73% of respondents said it would save time).  

No concrete evidence was provided that demonstrated the introduction of a test would negatively or positively impact on road safety. Instead, a mixture of concerns were expressed, most notably that a test would not afford the same assurance as 35 hours of training, or that specific safety training may be more rigorous.  

Other concerns on the introduction of a test were that it could lead to confusion, that testing is not something some drivers would be familiar or comfortable with and that it could lead to a reduction in the availability of training (if most drivers opted to take the test). On this latter point, consultation evidence demonstrated that roughly 50% of respondents said they would take the test, with the remaining 50% split between taking reformed N-DCPC training and I-DCPC. On the points raised around confusion and appropriateness, the option to complete reformed training would remain open to drivers and the department will work closely with DVSA to ensure communication is clear regarding this.  

The development of the test would be informed by the new consultation and rigorously conducted to ensure that it examines critical safety knowledge in order to provide a high level of assurance that those passing it are considered to have the appropriate knowledge to drive safely and professionally. This new consultation would help inform the best way to do this and the development of the test would draw upon expertise, including at DVSA, gained through experience of developing and administering existing driving tests, and exhaustive work to ensure the test is sufficiently robust.  

Training would continue to be a part of the initial stage of gaining a DCPC and remain in place as an option for drivers who want to do this instead of taking a test. The option of taking a test could provide flexibility to drivers, helping them achieve time and cost savings, and may help to retain drivers and avoid future HGV and PSV driver shortages without impacting road safety or the professionalism of the sector.

Proposals for N-DCPC reformed training

The objectives of these proposals were to make the renewal of the qualification by training as flexible as possible and reduce barriers to remaining, joining and re-joining the sector, whilst retaining the rigour of DCPC that is valued by so many, particularly in regard to road safety and professional standing.

Question 37: Overall, do you support the proposed changes under the N-DCPC reformed training option?

	Yes	No	Don’t know
Professional driver	206	182	49
Operator	77	44	13
Trainer	87	73	8
Other	45	24	7
Total	415	323	77
Total percentage	51%	40%	9%

Summary of responses

The table shows support both in terms of total responses and by each stakeholder category for proposed changes under the N-DCPC reformed training option, for example among professional drivers 47% were in favour of the reforms compared to 42% who were not and among operators, 57% were in favour, while 33% were not. Reasons behind these views where then requested in the following questions shown below – respondents could select as many entries as they felt necessary.

Question 38: (Those supporting the reform) Do you think N-DCPC reformed training will:

	Professional Driver	Operator	Trainer	Other	Total	Percentage of people responding to this question*
Save time	138	53	52	31	274	65%
Provide better work-life balance	97	25	51	15	188	45%
Make renewing DCPC cheaper	137	51	32	24	244	58%
Help attract and retain drivers	146	57	68	37	308	74%
Be beneficial for another reason					102	24%

*419 people answered this question. The percentages represent the percentage of those 419 who supported the statements.

Summary of responses

Of all responses to this question, the most selected benefits of the proposals for N-DCPC reformed training were that it would save time and help attract and retain drivers, 2 key rationales behind reform to DCPC.

Other reasons given for why the change would be beneficial were greater flexibility, with drivers citing this would help concentration and interest. RTITB echoed this view stating that “reformed DCPC training will improve driver engagement”. They explained “these changes will lead to better training outcomes and thus to improved road safety and professionalism among drivers”. Some operators noted the change would assist small businesses to plan, as it allowed for greater flexibility.

Question 39: (Those not supporting the reform) Do you think N-DCPC reformed training will:

	Driver	Operator	Trainer	Other	Total	Percentage of people responding to this question*
Add cost	93	15	25	13	146	45%
Add time	65	13	24	9	111	34%
Lead to confusion	108	31	61	17	217	66%
Lead to shortage of international drivers	80	15	33	10	138	42%
Be damaging for another reason					155	47%

*327 people answered this question, percentages represent the percentage of those 327 who supported the above statements.

Summary of responses

66% of respondents to this question thought that the changes would lead to confusion, with lower proportions saying it would add cost (45%) and lead to a shortage of international drivers (42%).

Respondents were given the opportunity to provide open text responses outlining how this may be damaging for another reason. A few drivers noted it would reduce drivers’ employment prospects. Some training providers felt the training would become rushed and be detrimental to their business. Wincanton explained that creating a 2-tier system will provide opportunities for smaller operators to use a cheaper training option. This would place “all other operations who continue to operate to the higher standard at a disadvantage.”

Question 71: In your view, would removing the requirement to complete split course over 2 consecutive days mean:

You are more likely to renew your DCPC?

	Yes	No	Don’t know
Professional driver	183	112	44
Operator	38	29	10
Trainer	47	21	9
Other	12	2	2
Total	280	164	65
Total percentage	55%	32%	13%

Provide better work/life balance?

	Yes	No	Don’t know
Professional driver	186	100	45
Operator	36	28	8
Trainer	47	21	8
Other	11	3	1
Total	280	152	62
Total percentage	57%	31%	13%

Summary of responses

The majority of respondents said the reforms to training would mean professional drivers would be more likely to remain in the sector and provide for a better work/life balance. 55% of drivers said the reformed training would mean they are more likely to renew their DCPC, whilst 32% said it would not. Likewise, 57% of drivers said it would provide for a better work/life balance while 31% said it would not, with the remainder in both cases unsure.

Question 72: How likely are the N-DCPC ‘reformed training’ changes to make it easier to:

Attract drivers?

	Very Effective	Effective	Neither Effective or Ineffective	Ineffective	Very Ineffective	Don’t know
Professional driver	72	128	94	21	92	26
Operator	33	48	27	8	14	1
Trainer	37	56	32	8	28	4
Other	12	30	16	4	8	3
Total	154	262	169	41	142	34
Total percentage	19%	33%	21%	5%	18%	4%

Retain drivers?

	Very Effective	Effective	Neither Effective or Ineffective	Ineffective	Very Ineffective	Don’t know
Professional driver	94	121	84	25	93	18
Operator	40	44	20	9	14	1
Trainer	43	49	37	8	24	3
Other	20	30	11	4	6	2
Total	197	244	152	46	137	24
Total percentage	25%	31%	19%	6%	17%	3%

Summary of responses

Responses supported the view that reformed DCPC would be very effective or effective in attracting drivers (52%). This view was shared when broken down into stakeholder groups. Specifically, among professional drivers very effective or effective was selected by 47% of respondents compared to ineffective or very ineffective being selected by 26% of this cohort.

The tables show greater support, when viewing total responses, to the assertion that N-DCPC reformed training measures would be very effective or effective in retaining drivers (56%), compared to those viewing changes as being ineffective and very ineffective (23%). This overall view was shared by professional drivers, where very effective or effective was selected by 50% of respondents compared to ineffective or very ineffective being selected by 27%.

Qualitative analysis of the free text responses for question 72, across all respondent groups, shows that those saying the changes would make it easier to attract and retain drivers primarily cited the increased flexibility. They stated, for example, that courses being under 7 hours would encourage attendance and participation, that the shorter courses will enable better work-life balance, and that the disruption to working schedules would be reduced.

The respondents who said the changes would not make it easier to attract and retain drivers gave varied reasons for this. These included that the changes do not go far enough, it would still take 35 hours to complete, that 7 hours, for example, every year would be better, concern that they wouldn’t be relevant/receive value for the training and that the cost and time barriers still remain.

Government response

Having considered all the evidence received during the consultation, including wider stakeholder engagement, and making an assessment of impacts and benefits we have decided to proceed with the proposed reforms to DCPC training.

We will introduce reform to remove the current minimum time limit for N-DCPC training courses set at 7 hours and replace this with a new minimum limit of 3.5 hours. This will also include removal of the requirement to complete split courses over 2 consecutive days.

As demonstrated, these reforms were supported by a vast majority of respondents, including drivers, operators and training providers. Greater flexibility in training requirements was the most favoured reform (question 36) and supported by 57% of people responding to this question. Industry has been calling for increased flexibility, and these reforms will give drivers more choice, and make the training less burdensome, enabling an enhanced ability to better manage work/life balance and reduce disruption from the training on working time.

Many stakeholders put forward these points at consultation, with Logistics UK commenting that ‘drivers would find it less burdensome having 3.5 hours of training in one sitting’, while the Road Haulage Association (RHA) stated that the majority of their members ‘support the proposed creation of the N-DCPC and the allowance of more flexible training, including shorter courses’.

The Confederation of Passenger Transport (CPT) stated the change would mean ‘less restrictive options to comply [with]’ and ‘the flexibility of split modules means that drivers are likely to be better focussed on course materials…[training] could be arranged for days when drivers are not fully occupied meaning that operators would not need to release drivers for a full day’.

However, Unite the Union expressed concern that shorter courses may be used by some employers to compel their employees to take courses between shifts. The department and DVSA recognise these concerns and will work with industry to ensure such instances are avoided.

However, in light of both support for the proposal and our consideration that shorter courses will enhance driver experience, we will mandate that any training course (excluding ‘e-learning’) should not be less than 3.5 hours. In addition, this reform was supported by evidence from the previous DCPC review where the majority of drivers (41%) and operators (44%) said 3.5 hours would be optimal when compared to 7 hours (drivers 22%, operators 10%) and 5 hours (drivers 26% and operators 19%).

This will provide an appropriate balance between ensuring training is long enough to be meaningful, whilst also providing flexibility, something which adhering to rigid 7-hour courses, made up on consecutive days or set days each year, has been shown to prevent.

The new minimum limit of 3.5 hours will not prevent training organisations from developing courses longer than this, as is currently permitted, but prevents the possibility of 1 or 2-hour courses which could, in addition to issues around knowledge gained, be difficult to administer and keep track of by drivers and employers alike.

The issue of the potential to create additional confusion is noted and is partly the reason for setting the minimum at 3.5 hours, therefore aligning with current practices of split courses (which will be uncoupled). Furthermore, the alignment with current requirements for I-DCPC split courses may make it easier to transfer completed training between the 2 schemes in the future, thereby mitigating the risk of dry-up of I-DCPC training courses as one large stakeholder noted. Robust guidance will be developed and supplied to stakeholders in due course.

When longer courses are split, provided the split does not produce 2 halves of a course that are less than 3.5 hours, there will be no requirement to complete this training over 2 consecutive days as currently is the case. The flexibility is supported by the majority of respondents based on the qualitative and quantitative data available, particularly among professional drivers who deem the change as being positive for driver attraction and retention, a key driver behind these reforms. However, whilst no minimum limit will be stipulated within the legislation, employers or course providers may require split courses to be completed within a certain number of days should they wish.

The department recognises the importance of quality training and the role of developing high-quality core content and use of informal assessments in delivering quality outputs. The continued development of core content was the third most supported reform (Q36).

The Review Report found ‘relevance of training’ was reported in the driver survey as the most important consideration when determining whether drivers would renew their DCPC with 60% of respondents citing this, above the cost of training (56%) and time needed to complete training (45%). DVSA will continue to work with industry to develop core content to ensure quality of training.

There was recognition in the consultation from some employers regarding the benefits of end of course assessments for ensuring driver engagement and confirmation of knowledge. The Association of Local Bus Managers (ALBUM) noted that although they would not support a “move to an examination” they would support assessment following modules to confirm knowledge retention.

Unite also support including as an assessment at the end of each module to assess understanding. End of course assessments were the fourth most supported reform amongst consultation respondents. The department recognises the benefits of end of course assessments in ensuring engagement. Although we would not move to mandate end of course assessments, the DVSA will encourage the continued re-focus of training form prescriptive course completion to outcome-based learning.

DVSA will therefore continue to work with industry on the development of suggested core content, as well as the continued re-focus of training from prescriptive course completion to outcome-based learning through promoting more informal assessment through their course approvals processes. These measures will support continual improvement in the quality of training and do not require any further regulation.

Proposals for e-learning under the N-DCPC

Question 73: What time limit do you think should be imposed between completion of a trainer-led course and corresponding e-learning?

	Don’t know	No time limit should be imposed	Up to 24 hours after the trainer-led course	Up to 7 days after the trainer-led course	Up to 30 days after the trainer-led course	Within another time period, in days above 30 days	Another Answer
Professional driver	110	126	28	93	62	4	10
Operator	29	35	8	37	22	1	2
Trainer	21	31	22	46	33	1	13
Other	17	16	3	19	15	1	4
Total	177	208	61	195	132	7	29
Total percentage	22%	26%	8%	24%	16%	1%	4%

Summary of responses

The question was designed to understand whether any time limits should be set for when e-learning can be taken in relation to a corresponding trainer led course. Currently, requirements stipulate that training modules including where part of these contain e-learning aspects should be completed over 2 consecutive days. In practice, this has been implemented to require e-learning aspects to be completed within 24 hours of a corresponding trainer led course.

The largest response to this question (26%) from all respondents was that there should be no time limit imposed in the future, with the second most selected option (24%) being up to 7 days and 22% being unsure. When split by stakeholder category the order of these varied. The majority of professional drivers (29%) still favoured no limit followed by 7 days (21%), however, the majority of operators and training providers favoured 7 days (both at 28%), followed by no limit (26% and 19% respectively).

Of the other time limits and answers provided, a few respondents suggested the time limit should be within 90 days or within 12 months. The most frequent response when not selecting a predefined option was to register disagreement with e-learning.

Question 75. What is the likelihood of you choosing to take courses which have an e-learning element if the changes proposed were implemented?

	Very likely	Likely	It makes no difference	Unlikely	Very unlikely	Don’t know
Professional driver	108	71	74	18	44	21
Operator	22	25	18	6	6	1
Trainer	17	19	11	10	17	1
Other	8	5	3	0	1	0
Total	155	120	106	34	68	23
Total percentage	31%	24%	21%	7%	13%	5%

Summary of responses

The popularity of the reform can be seen by the greater numbers of people opting for very likely or likely (31% and 24%) compared with unlikely or very unlikely (7% and 13%) when asked about the likelihood of taking e-learning following changes. There was, however, not an insignificant amount of people who felt changes would make no difference in their take-up of e-learning with 21% selecting this.

Indeed, among professional drivers specifically, 22% felt the change would make no difference, while 21% felt the change would make them likely to take e-learning. Despite this, among professional drivers very likely received 32% of all selections, higher than unlikely and very unlikely combined which registered 5% and 13%. When the professional driver data (drawn out specifically to understand professional drivers’ experience of e-learning) was cross referenced with the travel time they gave to and from training locations, the majority of respondents within the 0 and 1 to 2-hour travel time groups (the most selected), said the change would be very likely to encourage them to take courses with an e-learning elements. This suggests that the desire to take e-learning is not simply one of convenience.

Operators or trainers most selected ‘likely’ that reforms would lead to more e-learning, 32% and 25% respectively. However, among trainers 23% selected ‘very unlikely’ when responding to the use of e-learning as a result of changes.

Question 76: Do you think the proposed changes to e-learning will make it easier to:

Attract drivers

	Yes	No	It makes no difference	I don’t know
Professional driver	171	96	124	42
Operator	55	19	47	8
Trainer	50	40	66	6
Other	33	8	19	12
Total	309	163	256	68
Total percentage	39%	20%	32%	9%

Retain drivers

	Yes	No	It makes no difference	I don’t know
Professional driver	187	101	104	40
Operator	61	23	36	5
Trainer	52	46	57	6
Other	39	8	13	11
Total	339	178	210	62
Total percentage	43%	23%	27%	8%

Summary of responses

Data in both tables show greater support for e-learning changes attracting and retaining drivers with 39% of respondents believing that this will attract drivers and a further 43% believing changes will help retain existing drivers. There is a significant minority however who think that the changes will make no difference in attracting (32%) or retaining drivers (27%).

Government response

Following consideration of the evidence received during this consultation, including survey and open-ended responses, as well as wider stakeholder engagement, we will proceed with the proposals for greater flexibility on e-learning. Specifically, reform will remove the requirement that split courses containing e-learning elements must be completed across 2 consecutive days and the requirement that only 2 hours of e-learning is permitted per trainer-led course.

Data above demonstrates support for these reforms and that overall, and specifically among professional drivers, there is strong support for the view that the reforms will help to retain and attract drivers to the sector, a key aim of the proposals. Furthermore, submissions by, for example, Royal Mail, Logistics UK and the Road Haulage Association support the quantitative data, with all supporting increased flexibility regarding e-learning, another key aim of the reform to DCPC. Critically, this reform introduces choice for drivers on e-learning, but does not mandate that any amount of training must be conducted online for those who do not wish to do so. Allowing drivers to conduct some courses online can help to provide a better work-life balance for drivers which in turn could help to retain drivers within the workforce and help to avoid future driver shortages.

Given we will be permitting split trainer led courses to be completed over periods in excess of 2 consecutive days, it is consistent for the same to apply to split courses containing e-learning elements. There is a slim majority in favour of this among total responses but also specifically among professional drivers. Despite this not being a view shared by training providers it is an equally slim majority favouring a 7-day minimum duration over no time limit.

In the interests of providing a clear approach for those undertaking DCPC, and to promote greater flexibility, we will therefore remove the requirement for split courses containing e-learning elements to be completed over 2 consecutive days. We are also removing the requirement that only 2 hours of e-learning is allowed per trainer led course.

The overall maximum allowance for e-learning per 35 hours of training will remain 12 hours. It is our assessment that this strikes the right balance between the increased flexibility of encouraging more e-learning and the specific benefits of trainer led courses. Course creators will be free to develop e-learning training courses either as standalone or linked to a course as they see fit. Any e-learning material produced would still be subject to DVSA approval, at which point an assessment will be made as to its suitability in delivering the necessary standard of course content.

These reforms do not prevent training providers or operators setting their own requirements for e-learning completion.

Proposals for returning drivers

Questions 77 and 78: Do you support the principle of ‘specific return pathways’ to allow drivers to return to the sector?

	Yes	No	Don’t know
Professional driver	315	69	51
Operator	104	18	11
Trainer	125	36	8
Other	58	15	4
Total	602	138	74
Total percentage	74%	17%	9%

Summary of responses

Overall, 74% of all respondents to this question agreed with the principle of specific return pathways (or a different regime to the one currently in place) for drivers to return to the sector. By stakeholder group all recorded above 72% in support of the principle, with trainers recording 74% support.

Question 78 asked respondents who were not in favour of the proposals why this was the case. Respondents were able to provide free text responses. 118 respondents provided a reason. Drivers and trainers felt the proposals would result in added complication and questioned the disparity between the system for current and returning drivers.

The Royal Society for the Prevention of Accidents (RoSPA) echoed this view of disparity noting that they:

would be opposed to allowing someone who had not driven in a professional capacity for a period of time to take less training initially to allow them to return to the sector.

Question 80: In your view what is the minimum time, in months, a driver’s DCPC qualification should have lapsed before they can utilise any of the ‘specific return pathways’?

	Below 2 months	From 2 months	From 2 and up to 3 months	From 3 and up to 4 months	From 4 and up to 5 months	From 5 and up to 6 months	From 6 and up to 7 months	6 months and over	12 months	15 months	24 months +	None	Didn’t directly answer the question
Professional driver	91	2	36	10	6	71	73	3	23	1	17	6	10
Operator	26	0	14	1	3	23	19	2	20	0	3	4	4
Trainer	31	0	12	10	0	33	27	0	16	0	5	5	4
Other	15	0	10	5	0	14	5	1	3	0	3	1	2
Total	163	2	72	26	9	141	124	6	62	1	28	16	20
Total percentage	24%	0%	11%	4%	1%	21%	19%	1%	9%	0%	4%	2%	3%

Summary of responses

The most supported category was for the minimum lapse period to be below 2 months at 24% followed closely by 5 to 6 months at 21%. 19% of people were in favour of 6-7 months and 11% of people in favour of 2 to 3months. Very few respondents did not give a timeframe but stated in open ended questions that it should depend on the driver’s length of service.

By stakeholder group, only trainers preferred 5 to 6 months at 23% compared to below 2 months which received 22%.

Question 81: In your view what is the maximum time, in months, a driver’s DCPC qualification should have lapsed before they can utilise any of the ‘specific return pathways’?

Respondent group	Below 12 months	12 months	From 12 and up to 18 months	From 18 and up to 24 months	From 24 and up to 30 months	From 30 and up to 36 months	From 36 and up to 42 months	42 months	48 months	59 months	60 months	Over 60 months	No limit	Didn’t directly answer the question
Professional driver	73	0	58	56	24	25	66	1	0	1	10	8	15	10
Operator	23	1	26	18	5	13	17	0	0	0	6	0	3	4
Trainer	35	1	34	31	5	13	12	0	2	0	5	0	4	1
Other	7	0	10	18	1	4	7	0	2	0	4	0	3	2
Total	138	2	128	123	35	55	102	1	4	1	25	8	25	17
Total percentage	21%	0%	19%	19%	5%	8%	15%	0%	1%	0%	4%	1%	4%	3%

Summary of responses

The majority of support was for the maximum lapse period to be below 12 months at 21% followed closely by 12 to 18 months and 18 to 24 months, both at 19%. One respondent stated that it should be on a case-by-case basis.

Questions 82 and 83: Which of the ‘specific return pathways’ would you support?

	The N-DCPC ‘Periodic Test’	The return to driver training	Either the N-DCPC ‘Periodic Test’ or the return to driver training	None of these	Don’t know
Professional driver	93	82	122	34	17
Operator	33	23	44	10	7
Trainer	21	66	45	11	0
Other	15	18	24	3	2
Total	162	189	235	58	26
Total percentage	24%	28%	35%	9%	4%

Summary of responses

The majority of support was for either of the options provided, recording 35% of all selections. The preference for only the return to driver training or only the N-DCPC periodic test garnered less support at 28% and 24% respectively. When viewed by stakeholder group, the preferred option after either of the options (still the majority), among professional drivers and operators was for the N-DCPC periodic test, whereas among trainers it was the return to driver training. 27% of professional drivers and 24% of operators preferred the test, compared to 15% of trainers. Whereas 48% of trainers preferred the training, compared to 24% of professional drivers and 20% of operators.

Drivers and operators that selected the N-DCPC periodic test most commonly stated that it was because it was the most time and cost effective, with some operators saying it would help attract drivers. Those who chose either of the options preferred this because of the flexibility it brings. Of the respondents who selected none of the options, alternatives they gave included a practical driving module, and keeping the current annual training time but focusing on driver hours and regulations.

Translink NI, operating scheduled bus, coach, educational and special services across Northern Ireland, stated the test could be preferable provided a minimum DCPC lapse period was implemented. Logistics UK noted that some of their members were supportive of re-taking the initial qualification tests again, but most would support the training option.

Question 87: You think the best option:

	is that the remainder of training be completed every year, for a maximum of 7 hours, giving an annual DCPC entitlement?	is that the 28 hours of remaining training is completed at any point within the five-year DCPC entitlement?	for the return to driving training is completing neither of these options?	don’t know which is the better option?
Professional driver	77	44	40	41
Operator	21	14	18	7
Trainer	60	29	7	9
Other	17	9	2	5
Total	175	96	67	62
Total percentage	44%	24%	17%	16%

Summary of responses

The most popular selection (44%) was for an annual, or rolling, DCPC entitlement requiring 7 hours of training per year. This position was supported by numerous stakeholders who submitted formal position papers, such as Logistics UK, RHA, Unite and Royal Mail. 24% choose the option where 28 hours of training would be completed at any point within a 5-year DCPC entitlement.

Of the 17% of respondents who chose neither of these options, the responses were varied. They included suggestions of a 1-day refresher course covering drivers’ hours, health and safety and first aid followed by a test, a test and driving assessment, an initial course covering the minimum requirements (drivers’ hours, road safety) and for the rest to be completed the following year.

Question 89: In your opinion the hours of training that should be completed before a driver is allowed to return to driving commercially?

	Don’t know	Up to 1 hour	Above 1 and up to 7 hours	Above 7 and up to 14 hours	above 14 and up to 21 hours	above 21 and up to 28 hours	above 28 and up to 35 hours
Professional driver	15	19	69	52	15	8	24
Operator	5	3	24	16	2	0	9
Trainer	3	0	40	37	11	2	13
Other	1	1	17	10	0	1	3
Total	24	23	150	115	28	11	49
Total percentage	6%	6%	38%	29%	7%	3%	12%

Summary of responses

38% of respondents felt that drivers should complete between 1 to 7 hours before returning to driving, with 29% believing drivers should complete 7 to 14 hours.

Question 90: In your view within what time period should a driver complete the remainder of their training after a ‘return to driving’ module in order to gain a 5-year entitlement to drive commercially?

	Within 1 year	Between 1 and up to 2 years	Between 2 and up to 3 years	Between 3 and up to 4 years	Between 4 and up to 5 years	Another time period, in years:	Don’t know
Professional driver	78	26	12	8	50		17
Operator	17	11	5	2	14		6
Trainer	39	21	6	3	26		3
Other	8	3	3	4	9		2
Total	142	61	26	17	99	26	28
Total percentage	36%	15%	7%	4%	25%	7%	7%

Summary of responses

36% of respondents thought drivers should complete the remainder of the training within the first year. The next most supported option was between 4-5 years, which was selected by 25% of respondents.

For respondents entering ‘another time period’, in the free-text response the most frequent view was within 5 years or that a driver should undergo training every year. Nottingham City Transport explained “we train existing PCV holders for several weeks (classroom-based compliance and supervised driving in-service). We will continue to do this”.

Question 92: Do you think the proposed changes for returning drivers are likely to make it easier to attract drivers to the sector?

	Yes	Makes no difference	No	I don’t know
Professional driver	184	74	44	26
Operator	73	25	12	4
Trainer	69	35	22	13
Other	48	4	4	5
Total	374	138	82	48
Total percentage	58%	21%	13%	7%

Summary of responses

Over half (58%) of respondents believed the changes would attract drivers to the sector, with 34% suggesting changes would have no impact or make no difference on numbers. When broken into stakeholder groups, 56% of professional drivers, 64% of operators and 50% of training providers thought the changes would help. Splitting professional drivers further and focussing solely on those defining themselves as previously being professional drivers but were no longer, 57% of this group felt the changes would make it easier to attract drivers to the sector.

Question 93: In your view how many times should a driver be able to utilise the ‘specific return pathways’?

Respondent group	None	Only once	Twice	Three times	Four times	I don’t know	As many times as required	Didn’t directly answer the question
Professional driver	2	61	11	8	1	37	203	4
Operator	2	28	3	1	0	15	64	2
Trainer	1	51	6	6	0	12	61	2
Other	0	15	1	3	0	4	36	1
Total	5	155	21	18	1	68	364	9
Total percentage	1%	24%	3%	3%	0%	11%	57%	1%

Summary of responses

57% of all respondents felt that the use of specific return pathways should not be limited and that individuals should be able to utilise them as many times as required. Around a quarter of respondents suggested the pathways should only be used once and 11% did not know their opinion on the matter.

Of the other answers provided 3% felt a driver should be able to utilise the ‘specific return pathways’ 2 times or 3 times, 1% felt that this should not be an option and <1% felt that it should be used four times. A few respondents did not specify a timeframe but gave a longer opinion. These included that it should not be possible to do more than one consecutively, once in every 5 years, and that it should be age and ability based.

Government response

The department will proceed with introducing a specific return pathway for drivers whose DCPC has lapsed and want to return to the sector. This will be a 7 hour return to training module, which will be available from spring 2025 but will be reviewed further to that in conjunction with the consideration of introducing a test (which those returning to the sector would be eligible to take). The remaining 28 hours will need to be completed within 12 months of the 7 hour return to training module.   

We acknowledge the wide support for introduction of a new and specific return pathway for drivers returning to the sector, with the consultation finding this was supported by 74% of respondents. This will help mitigate impacts of any future acute driver shortages, by enabling a quicker pathway to bringing back experienced drivers who recently left the sector. This will allow these experienced drivers to return to driving, without the need to first complete 35 hours of training, whilst retaining the assurance of driver competence.  

Some concerns were raised that introduction of this pathway could result in confusion and create a “2-tiered system”. It is considered that the accelerated pathway of the 7 hour return to driving course is proportionate for experienced drivers wanting to return to the profession, and they will need to complete the remaining 28 hours within 12 months. It is critical to balance the need for drivers to return to the sector as quickly as possible, with the need to ensure professionalism, road safety and consistency between the requirements of renewing and returning drivers.  The testing route for returning drivers to regain DCPC would be the same as the test for existing drivers renewing it. 

On the specific length of the return to driving course, 38% of respondents felt drivers should complete between 1 to 7 hours of training before returning to the sector and 29% felt drivers should complete between 7 to 14 hours, which were the 2 most favoured options. Accounting for this feedback and following assessment of associated considerations, it is judged that 7 hours will provide the appropriate assurance required that experienced drivers who have previously held a DCPC are ready to return. 

This is further balanced by the need for drivers to complete the remaining 28 hours of training within 12 months. This is to ensure that requirements of returning and renewing drivers are consistent and a loophole is not created which unfairly reduces the requirement to complete training. 12 months is consistent with consultation responses, with 36% of respondents saying that training should be made up within the first year, the most favoured option, and in ensuring fairness with the requirements of existing drivers. 

In terms of drivers eligible to utilise the return to driving pathway, a maximum lapse period will be in place to ensure that drivers have not de-skilled. For drivers to be eligible for this pathway, their DCPC qualification must have lapsed for a period of at least 2 months, but less than 2 years. 

The test option for returning drivers was supported by a majority (59%) of respondents, who said that this would be a cost and time effective renewal route. The test would ensure returning drivers have the necessary knowledge to meet DCPC’s objectives of improving road safety and professionalism of drivers.  If a test is introduced to renew DCPC, drivers who have completed their initial DCPC but have let the qualification lapse would also be entitled to take the test to regain their qualification. These drivers will have an established level of knowledge evidenced by their prior holding of DCPC. The test was seen at consultation as a significant examination of a driver’s knowledge, thus providing the necessary assurance of the drivers’ competence.  

We therefore intend that the test, designed for periodic renewal by drivers with valid DCPCs, could also be used by drivers who had a DCPC but whose DCPC has lapsed, regardless of how long the lapse period is.  

We would allow drivers to utilise the return pathway as many times as they would like, with the option to take the test as many times as needed being supported by 57% of respondents to the consultation.

Proposals for short term extensions and exemptions

Short term extensions

Short term extensions would temporarily extend the validity of a drivers existing DCPC qualification in certain circumstances, for example a pandemic. The following questions refer to short term extensions.

Question 94: What circumstances do you think should trigger short term extensions?

	Yes	Percentage of people answering the question*	No	Percentage of people answering the question*	Don’t know	Percentage of people answering the question*
a pandemic for example COVID-19?	745	84%	107	12%	29	3%
a national or international emergency for example the 2021 fuel tanker shortage?	595	67%	235	27%	40	5%
circumstances which would impact on the normal operation of the road transport industry?	530	60%	269	30%	63	7%
availability of training or test provision?	477	54%	316	36%	75	8%

*883 people answered this question, percentages show how many of those 883 supported the particular statement. Respondents could select more than one statement.

Summary of responses

From all responses received to the provided situations an extension should be triggered there was majority support for all by 54% or more. Extensions in light of a pandemic was the most popular selected 84% of the time whilst availability of training or test provision the least popular, but still selected by 54% of respondents answering that question.

105 respondents described other options than those listed. Amongst professional drivers, the most frequently cited reasons for an extension were driver ill health and war. A few also reported national strikes, driver shortages, and that extensions should not be allowed. Trainers and operators mostly gave reasons such as driver personal circumstances, illness, national disasters, civil unrest, and some commented that extensions should not be allowed.

Nottingham City Transport stated that national driver shortage should trigger short term extensions and ALBUM stated that local emergencies should. Unite felt that exemptions and exceptions should apply only on rare occasions and should be “agreed by industry stakeholders including trade unions”.

Question 99: Does the extension period (of 12 months) seem like an appropriate amount of time?

Respondents could select yes, no, or don’t know. Those who selected no could provide an alternative timeframe and responses are reflected in the table below.

Respondent group	Yes	Don’t know	0	1	2	3	4	6	12	18+	Didn’t directly answer the question
Professional driver	285	96	16	3	0	6	0	20	6	14	26
Operator	100	28	3	1	0	2	0	5	0	1	2
Trainer	113	25	9	3	1	5	1	9	3	1	7
Other	55	9	1	0	0	2	0	6	1	5	4
Total	553	158	29	7	1	15	1	40	10	21	39
Total percentage	63%	18%	3%	1%	0%	2%	0%	5%	1%	2%	4%

Summary of responses

The consultation proposed a maximum period of time for extensions of 12 months.

Of the 874 respondents who answered, 63% felt the 12 month extension period did seem like an appropriate amount of time, 14% felt it was not and provided another answer, 18% did not know and 4% didn’t directly answer the question.

Of the respondents that responded in the negative, 124 gave an alternative timeframe. Of these, 8% felt 6 months or less would be an appropriate extension period and 2% felt it should be more than 18 months or more.

A few respondents gave comments instead of a timeframe. One felt that the timeframe should not be fixed, another felt there should be total exemption for “for older, time served drivers”, and another stated it should be dependent on the circumstances. DPD agreed with the latter.

Short term exemptions

Short term exemptions would temporarily remove the requirement to hold a DCPC qualification in certain circumstances, for example in the case of a pandemic. This would allow drivers who’s DCPC has lapsed return to the sector on a short-term temporary basis, with the ability to renew their DCPC qualification and remain in the sector.

Question 95: What circumstances do you think should trigger short term exemptions?

	Yes	Percentage of people answering the question*	No	Percentage of people answering the question*	Don’t know	Percentage of people answering the question*
a pandemic for example COVID-19?	672	78%	148	17%	38	4%
a national or international emergency for example the 2021 fuel tanker shortage?	534	62%	259	30%	47	5%
circumstances which would impact on the normal operation of the road transport industry?	486	56%	298	34%	61	7%
availability of training or test provision?	425	49%	341	39%	71	8%

*866 people answered this question, percentages show how many of those 866 supported the above statements. Respondents could select more than one statement.

Summary of responses

From all responses received to the provided situations an exemption should be triggered there was majority support for all. Exemptions in light of a pandemic was the most popular selected 78% of the time whilst availability of training or test provision the least popular, but still selected by nearly half (49%) of respondents answering that question.

While there was significant support for short term exemptions, support was slightly lower than for short term extensions. 70 respondents gave circumstances other than those listed, with examples including a state of emergency, food industry crises and national driver shortage. Respondents did feel that it would encourage drivers back into the sector.

Question 100: Does the exemption period (of 3 months) seem like an appropriate amount of time?

			No, the extension period should be (in months)
	Yes	Don’t know	0	1	2	3	6	12	18	24+	No time limit	Either didn’t provide a timeframe or didn’t directly answer the question
Professional driver	264	111	19	4	1	1	18	11	2	10	6	26
Operator	93	30	2	1	0	1	3	2	0	1	1	7
Trainer	114	30	7	3	1	0	1	2	0	1	0	17
Other	57	11	4	1	0	0	2	3	0	4	0	3
Total	528	182	32	9	2	2	24	18	2	16	7	53
Total percentage	60%	21%	4%	1%	0%	0%	3%	2%	0%	2%	1%	6%

Summary of responses

The consultation proposed a maximum period of time for exemptions of 3 months.

Of the 875 respondents to the question, the majority (60%) believed the 3 month exemption period seemed like the appropriate length of time, 21% were unsure, 13% felt it was not and provided another time period, 6% either didn’t provide a timeframe or didn’t directly answer the question. Of those who felt it was the wrong length of time, 5% felt it should be less than 3 months, 3% felt it should be six months, 2% 12 months, 2% more than 24 months and 1% felt there should be no time limit.

Government response

While we recognise the benefits short-term extensions and exemptions delivered during the COVID-19 pandemic and ensuing HGV shortages, and could continue to do in the future, it is necessary to further assess the most appropriate legislative means of achieving this. The department is therefore considering a process to allow this. 

The proposal is to take legal powers to allow short-term extensions and exemptions via regulations in the future.

Recognition of non-UK qualifications and electronic DQCs

There is currently no ability to exchange or recognise qualifications or training similar to DCPC that has been obtained outside the EU (except in the rest of the European Economic Area – meaning Norway, Iceland and Liechtenstein – and Switzerland). The department is therefore considering a process to allow this, subject to necessary checks.

The proposal is to take legal powers to allow exchange or recognition to be agreed via regulations in the future.

Question 103 and 104: Would you support the creation of an exchange scheme for non-GB and Non-NI qualifications?

	Total	Total Percentage
Yes	446	51%
No	279	32%
Don’t know	157	18%

Question 105 and 106: Would you support the creation of a recognition scheme for non-GB and Non-NI qualifications?

	Total	Total Percentage
Yes	464	53%
No	232	26%
Don’t know	185	21%

Summary of responses

51% of respondents supported the creation of an exchange scheme, with 32% of respondents not in support and 18% being unsure. 53% supported the creation of a recognition scheme, with 26% of respondents not in support and 21% being unsure.

Those in support of the proposals felt it would improve mobility and flexibility.

Some respondents reported that it would help attract and retain drivers although a few felt that only equivalent or higher exchanges should be included. Among those not in agreement, they felt that other schemes may not be directly comparable which would reduce standards, it may create a complicated process and could undercut the existing workforce.

On the exchange scheme, there were 2 responses from road safety organisations. One felt that it would be a complicated system to manage and stated that the current system works well. PACTS stated that they would support the creation of an exchange scheme as it could make it easier for drivers from mainland Europe to drive in the UK and could also help make up for the HGV driver shortage of in the UK. Wincanton stated that they would be in support if the standards were equivalent to or better. Similarly, Unite would be in support if international standards were equivalent to those of the EU. ALBUM stated that “provided that drivers can demonstrate the necessary competences, the recognition of alternative, relevant qualifications would be a useful option”.

On the recognition scheme, RTITB expressed their support as it could increase the pool of qualified drivers. Equally PACTS and Unite expressed agreement and reiterated their responses to the previous question related to the exchange scheme and provided above.

Government response

The intention is to take legal powers to allow exchange or recognition to be agreed via regulations in the future.

While the government recognises the support for recognition and exchange of third country qualifications, it is necessary to further assess the most appropriate legislative means of achieving this. These proposals will therefore be kept under review.

It is noted that the UK will continue to recognise DCPCs obtained anywhere within the European Economic Area (including Norway, Iceland, Liechtenstein and Switzerland).

Question 107 and 108: Would you like to see the physical DQC replaced by an electronic DQC?

	Driver	Operator	Trainer	Other	Total	Total Percentage
Yes, electronic version of DQC	260	89	106	54	509	57%
No, maintain physical DQC	111	28	39	13	191	22%
Neither for or against the Electronic DQC	90	23	31	17	161	18%
Don’t know	18	4	2	2	26	3%

Summary of responses

There is support across all groups for an electronic DQC, with over 57% of respondents in support of an electronic version, with a further 18% being neither for nor against an electronic DQC. 22% of respondents supported maintaining the physical DQC and 3% did not know.

A total of 620 respondents explained the reason for their response. Of these, 52% were drivers, 16% were operators and 23% were training providers.

Across respondent groups, those who expressed support mostly did so because they felt it would be more practical in that it removes the risk of the DQC being lost or stolen and the inconvenience of carrying it. Some respondents also mentioned that its more cost effective and would provide easier visibility for employers for checks and monitoring.

Respondents that were against an electronic DQC mostly felt the physical version provided reassurance in that it’s easier to produce at roadside or to show to employers. Some also felt it is less open to fraud. A few respondents also stated that an electronic DQC was more difficult to use for drivers that were not computer literate, that they felt pride in carrying the physical card. One respondent also questioned how it would be possible to monitor the expiry date.

There were a few respondents who expressed support for both options to be in-place. As one stated “because there are arguments for and against both the card and the digital option. Why is there not an option to have both?”.

Nottingham City Transport stated that they were not in support because they need a single, uniform form of licence across all PCV drivers as it keeps administration simpler and is fairer. Similarly, RTITB found in their survey among their LGV drivers, 51% want to retain a physical card, and only 25.4% supported an electronic alternative.

ALBUM stated that they were neither for nor against due to differing opinions. They reported that “some employers would welcome the holding of a physical qualification as this would align national and international requirements where employers have both types of operation. Similarly, there is sense that a physical qualification provides an indication of professionalism.” However, they stated that some employers would also welcome using technology.

RoSPA, DPD, and PACTS are in support of the DQC being replaced by an electronic alternative as it would mitigate the risk of DQC cards being lost or stolen.

Government response

While the government recognises the support for replacement of a physical DQC with an electronic alternative, it is necessary to further assess the most appropriate legislative means of achieving this. These proposals will therefore be kept under review.